BLM Mission 

To sustain the health, diversity, and productivity of the public lands for the use and 

enjoyment of present and future generations. 

BLM-UT-PL-08-002-1610 

UT-110-2007-022 

FES 08-24 





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Proposed RMP and Final EIS Abstract 

Kanab RMP i 

Kanab Field Office Planning Area 

Proposed Resource Management Plan and Final Environmental Impact Statement 

Lead Agency: U.S. Department of the Interior, Bureau of Land Management 

Type of Action: Final, Administrative 

Jurisdiction: Portions of Kane and Garfield Counties, Utah 

Abstract: The Kanab Proposed Resource Management Plan (RMP) and Final Environmental Impact 

Statement (EIS) (Proposed RMP/Final EIS) describes and analyzes the Proposed RMP for the planning 

and management of public lands and resources administered by the Bureau of Land Management (BLM), 

Kanab Field Office. The Kanab planning area is located in south-central Utah and includes approximately 

2,847,200 acres of land in Kane and Garfield Counties. Within the Kanab planning area, the BLM 

manages and administers approximately 554,000 acres of public land surface. The Proposed RMP is open 

for a 30-day protest period beginning the date the U.S. Environmental Protection Agency publishes the 

Notice of Availability of the Final EIS in the Federal Register. 

Alternatives A through D were presented in the Draft RMP/EIS released in October 2007. Alternative A

(No Action) is a continuation of the current management direction contained in the five LUPs and offhighway vehicle (OHV) management actions. Alternative B (Preferred Alternative) provides 

opportunities to use and develop resources within the decision area while also ensuring resource 

protection. Alternative B would provide for continued access and development of resources with 

stipulations and mitigation to protect natural and cultural resources. Alternative C emphasizes the 

protection of the decision area’s resource values while allowing commodity uses as consistent with 

current law, regulation, and policy. Management actions would emphasize resource values such as habitat 

for wildlife and plant species (including special status species); protection of riparian areas and water 

quality; preservation of ecologically significant areas; maintenance of wilderness characteristics; and 

protection of scientifically significant cultural and paleontological sites. Access to and development of 

resources within the decision area could occur with intensive management and mitigation of surface 

disturbing and disruptive activities. Alternative D emphasizes opportunities to use and develop resources 

within the decision area. It would provide for motorized access and commodity production with minimal 

restrictions, while providing protection of natural and cultural resources to the extent required by law, 

regulation, and policy. This alternative would largely rely on existing laws, regulations, and policies, 

rather than on management or special designations, to protect sensitive resources. The BLM has the 

discretion to select the Proposed RMP by combining components of the various alternatives presented in 

the Draft RMP/EIS. The Proposed RMP is based on Alternative B of the Draft RMP/EIS, and has been 

modified by public comments, BLM review, and providing the best means to accommodate the widest 

range of public and agency concerns over resources and resource uses. 

Protest Period: Protests must be postmarked or received no later than 30 days after publication of the 

EPA Notice of Availability in the Federal Register. Refer to the instructions in the dear reader letter for 

additional information on how to protest. 

For Further Information Contact: 

Bureau of Land Management, Kanab Field Office 

Attn: Keith Rigtrup, RMP Project Manager 

318 North 100 East 

Kanab, Utah 84741 

Telephone (435) 644-4600
Abstract Proposed RMP and Final EIS 

ii Kanab RMP 

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Proposed RMP and Final EIS Table of Contents 

Kanab RMP iii 

TABLE OF CONTENTS 

VOLUME I 

ABSTRACT 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY 

CHAPTER 1—INTRODUCTION, PURPOSE AND NEED 

CHAPTER 2—PROPOSED KANAB RESOURCE MANAGEMENT PLAN 

CHAPTER 3—AFFECTED ENVIRONMENT 

CHAPTER 4—ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED KANAB RESOURCE

MANAGEMENT PLAN 

CHAPTER 5—CONSULTATION AND COORDINATION 

GLOSSARY 

ABBREVIATIONS AND ACRONYMS 

REFERENCES 

VOLUME II 

APPENDICES 

MAPS 
Table of Contents Proposed RMP and Final EIS 

iv Kanab RMP 

VOLUME I TABLE OF CONTENTS 

ABSTRACT ...................................................................................................................................................................i 

TABLE OF CONTENTS .............................................................................................................................................iii 

READER’S GUIDE TO THIS DOCUMENT..............................................................................................................xi 

EXECUTIVE SUMMARY ....................................................................................................................................ES-1 

CHAPTER 1 —INTRODUCTION, PURPOSE AND NEED .................................................................................. 1-1 

1.1 PURPOSE AND NEED........................................................................................................................... 1-1 

1.1.1 Purpose ............................................................................................................................................. 1-1 

1.1.2 Need.................................................................................................................................................. 1-2 

1.2 DESCRIPTION OF THE DECISION AREA.......................................................................................... 1-2 

1.3 SCOPING AND PUBLIC PARTICIPATION ......................................................................................... 1-5 

1.3.1 Planning Issues Addressed ............................................................................................................... 1-5 

1.3.2 Issues Beyond the Scope of the Plan ...............................................................................................1-13 

1.4 PLANNING CRITERIA.........................................................................................................................1-15 

1.5 PLANNING PROCESS..........................................................................................................................1-16 

1.5.1 Relationship to Other Plans, Policies, and Programs.......................................................................1-19 

1.5.2 Plan Monitoring, Maintenance, Amendment, Revision, and Implementation.................................1-20 

1.6 SUMMARY OF CHANGES MADE BETWEEN THE DRAFT RMP/DRAFT EIS AND THE

PROPOSED RMP/FINAL EIS ...............................................................................................................1-21 

1.6.1 Summary of Changes To Decisions Between the Preferred Alternative (Draft EIS) and the Proposed 

RMP (Final EIS)..............................................................................................................................1-21 

1.6.2 Summary of Changes Made Between the Draft EIS and the Final EIS...........................................1-22 

CHAPTER 2 —PROPOSED KANAB RESOURCE MANAGEMENT PLAN....................................................... 2-1 

2.1 DESCRIPTION OF THE PROPOSED RMP........................................................................................... 2-1 

2.2 MANAGEMENT ACTIONS .................................................................................................................. 2-2 

2.2.1 Resources.......................................................................................................................................... 2-3 

Air Quality ..................................................................................................................................................................... 2-3 

Soil Resources................................................................................................................................................................ 2-4 

Water Resources ............................................................................................................................................................ 2-5 

Vegetation...................................................................................................................................................................... 2-7 

Special Status Species (Threatened, Endangered, and Sensitive)................................................................................. 2-10 

Fish and Wildlife.......................................................................................................................................................... 2-16 

Wildland Fire Ecology................................................................................................................................................. 2-19 

Cultural Resources....................................................................................................................................................... 2-25 

Paleontological Resources ........................................................................................................................................... 2-27 

Visual Resources.......................................................................................................................................................... 2-29 

Non-WSA Lands with Wilderness Characteristics ...................................................................................................... 2-29 

Drought and Natural Disasters..................................................................................................................................... 2-30 

2.2.2 Resource Uses .................................................................................................................................2-31 

Forestry and Woodland Products ................................................................................................................................. 2-31 

Livestock Grazing........................................................................................................................................................ 2-31 

Recreation .................................................................................................................................................................... 2-34 

Transportation.............................................................................................................................................................. 2-42 

Lands and Realty.......................................................................................................................................................... 2-44 

Minerals and Energy .................................................................................................................................................... 2-48 

2.2.3 Special Designations........................................................................................................................2-50 

Areas of Critical Environmental Concern.................................................................................................................... 2-50 

Wild and Scenic Rivers................................................................................................................................................ 2-51 

Wilderness ................................................................................................................................................................... 2-56 

Wilderness Study Areas............................................................................................................................................... 2-57 

Other Designations....................................................................................................................................................... 2-58 

2.2.4 Social and Economic .......................................................................................................................2-59 
Proposed RMP and Final EIS Table of Contents 

Kanab RMP v 

2.2.5 Adaptive Management.....................................................................................................................2-60 

2.3 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL ............................................2-61 

2.3.1 Vermilion Cliffs Heritage Plan........................................................................................................2-61 

2.3.2 Closing the Decision Area to Livestock Grazing ............................................................................2-61 

2.3.3 Livestock Grazing Adjustments Alternative....................................................................................2-62 

2.3.4 No Leasing Alternative....................................................................................................................2-62 

2.4 COMPARATIVE SUMMARY OF IMPACTS ......................................................................................2-64 

CHAPTER 3 —AFFECTED ENVIRONMENT....................................................................................................... 3-1 

3.1 INTRODUCTION ................................................................................................................................... 3-1 

3.2 RESOURCES .......................................................................................................................................... 3-1 

3.2.1 Air Quality........................................................................................................................................ 3-1 

3.2.2 Geology, Topography, and Climate.................................................................................................3-11 

3.2.3 Soil Resources .................................................................................................................................3-17 

3.2.4 Water Resources..............................................................................................................................3-20 

3.2.5 Vegetation........................................................................................................................................3-24 

3.2.6 Special Status Species (Threatened, Endangered, and Sensitive)....................................................3-37 

3.2.7 Fish and Wildlife .............................................................................................................................3-50 

3.2.8 Wildland Fire Ecology.....................................................................................................................3-60 

3.2.9 Cultural Resources...........................................................................................................................3-66 

3.2.10 Paleontological Resources...............................................................................................................3-69 

3.2.11 Visual Resources .............................................................................................................................3-72 

3.2.12 Non-WSA Lands with Wilderness Characteristics..........................................................................3-74 

3.3 RESOURCE USES.................................................................................................................................3-80 

3.3.1 Forestry and Woodland Products.....................................................................................................3-80 

3.3.2 Livestock Grazing............................................................................................................................3-81 

3.3.3 Recreation........................................................................................................................................3-86 

3.3.4 Transportation..................................................................................................................................3-90 

3.3.5 Lands and Realty .............................................................................................................................3-93 

3.3.6 Minerals and Energy........................................................................................................................3-97 

3.4 SPECIAL DESIGNATIONS ................................................................................................................3-101 

3.4.1 Areas of Critical Environmental Concern .....................................................................................3-101 

3.4.2 Wild and Scenic Rivers .................................................................................................................3-102 

3.4.3 Wilderness .....................................................................................................................................3-103 

3.4.4 Wilderness Study Areas.................................................................................................................3-104 

3.4.5 Other Designations ........................................................................................................................3-108 

3.5 SOCIAL AND ECONOMIC FEATURES............................................................................................3-110 

3.5.1 Socioeconomic Conditions ............................................................................................................3-110 

3.5.2 Tribal Interests...............................................................................................................................3-122 

3.5.3 Hazardous Materials and Public Safety.........................................................................................3-123 

CHAPTER 4 —ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED KANAB RESOURCE 

MANAGEMENT PLAN........................................................................................................................................... 4-1 

4.1 INTRODUCTION ................................................................................................................................... 4-1 

4.1.1 Organization of Chapter 4 ................................................................................................................ 4-1 

4.1.2 Types of Impacts .............................................................................................................................. 4-1 

4.1.3 General Analytical Assumptions ...................................................................................................... 4-2 

4.1.4 Determining Significance of Impacts ............................................................................................... 4-3 

4.1.5 Critical Elements .............................................................................................................................. 4-3 

4.1.6 Incomplete or Unavailable Information............................................................................................ 4-4 

4.2 RESOURCES .......................................................................................................................................... 4-6 

4.2.1 Impacts on Air Quality ..................................................................................................................... 4-6 

4.2.2 Impacts on Soil Resources...............................................................................................................4-13 

4.2.3 Impacts on Water Resources ...........................................................................................................4-17 

4.2.4 Impacts on Vegetation.....................................................................................................................4-22 

4.2.5 Impacts on Special Status Species (Threatened, Endangered, and Sensitive) .................................4-29 

4.2.6 Impacts on Fish and Wildlife Habitat..............................................................................................4-40 
Table of Contents Proposed RMP and Final EIS 

vi Kanab RMP 

4.2.7 Impacts on Wildland Fire Ecology ..................................................................................................4-48 

4.2.8 Impacts on Cultural Resources ........................................................................................................4-53 

4.2.9 Impacts on Paleontological Resources ............................................................................................4-64 

4.2.10 Impacts on Visual Resources...........................................................................................................4-70 

4.2.11 Impacts on Non-WSA Lands with Wilderness Characteristics .......................................................4-76 

4.3 RESOURCE USES.................................................................................................................................4-88 

4.3.1 Impacts on Forestry and Woodland Products ..................................................................................4-88 

4.3.2 Impacts on Livestock Grazing.........................................................................................................4-91 

4.3.3 Impacts on Recreation .....................................................................................................................4-97 

4.3.4 Impacts on Transportation .............................................................................................................4-103 

4.3.5 Impacts on Lands and Realty.........................................................................................................4-105 

4.3.6 Impacts on Minerals and Energy ...................................................................................................4-107 

4.4 SPECIAL DESIGNATIONS ................................................................................................................4-112 

4.4.1 Impacts on Areas of Critical Environmental Concern...................................................................4-112 

Water Canyon/South Fork Indian Canyon ACEC...................................................................................................... 4-113 

Cottonwood Canyon ACEC....................................................................................................................................... 4-113 

Welsh’s Milkweed ACEC.......................................................................................................................................... 4-113 

Vermilion Cliffs ACEC ............................................................................................................................................. 4-114 

White Cliffs ACEC.................................................................................................................................................... 4-114 

Parunuweap Canyon ACEC....................................................................................................................................... 4-115 

4.4.2 Impacts on Wild and Scenic Rivers...............................................................................................4-117 

4.4.3 Impacts on Wilderness...................................................................................................................4-122 

4.4.4 Impacts on Wilderness Study Areas ..............................................................................................4-125 

4.4.5 Impacts on Other Designations......................................................................................................4-128 

4.5 SOCIAL AND ECONOMIC ................................................................................................................4-130 

4.5.1 Impacts on Social and Economic Conditions ................................................................................4-130 

4.5.2 Impacts on Tribal Interests ............................................................................................................4-149 

4.5.3 Impacts on Public Safety ...............................................................................................................4-152 

4.6 CUMULATIVE IMPACTS..................................................................................................................4-153 

4.6.1 Cumulative Analysis Methodology ...............................................................................................4-153 

4.6.2 Past, Present, and Reasonably Foreseeable Future Actions...........................................................4-154 

4.6.3 Cumulative Impacts by Resource ..................................................................................................4-158 

CHAPTER 5 —CONSULTATION AND COORDINATION ................................................................................. 5-1 

5.1 COLLABORATIVE MANAGEMENT .................................................................................................. 5-1 

5.2 NATIVE AMERICAN CONSULTATION............................................................................................. 5-2 

5.3 INTERGOVERNMENTAL CONSULTATION AND COORDINATION ............................................ 5-3 

5.4 CONSULTATION AND COORDINATION WITH OTHER FEDERAL AGENCIES.......................... 5-4 

5.4.1 U.S. Fish and Wildlife Service ......................................................................................................... 5-4 

5.4.2 National Park Service ....................................................................................................................... 5-5 

5.4.3 U.S. Forest Service ........................................................................................................................... 5-5 

5.4.4 Environmental Protection Agency.................................................................................................... 5-5 

5.5 CONSISTENCY WITH OTHER PLANS ............................................................................................... 5-5 

5.6 PUBLIC PARTICIPATION ...................................................................................................................5-20 

5.6.1 Notice of Intent and Public Scoping Period.....................................................................................5-21 

5.6.2 Mailing List .....................................................................................................................................5-22 

5.6.3 Planning Bulletins............................................................................................................................5-23 

5.6.4 Website............................................................................................................................................5-23 

5.6.5 Notice of Availability of Draft RMP/EIS ........................................................................................5-24 

5.6.6 Draft RMP/EIS Public Comment Meetings.....................................................................................5-24 

5.6.7 Draft RMP/EIS Public Comment Response Process .......................................................................5-25 

5.6.8 Public Comments.............................................................................................................................5-25 

5.6.9 Summary of Comments and Responses...........................................................................................5-28 

5.7 RECORD OF DECISION.......................................................................................................................5-82 

5.8 LIST OF PREPARERS...........................................................................................................................5-82 

GLOSSARY..............................................................................................................................................................G-1 
Proposed RMP and Final EIS Table of Contents 

Kanab RMP vii 

ABBREVIATIONS AND ACRONYMS..................................................................................................................A-1 

REFERENCES ..........................................................................................................................................................R-1 

TABLES 

Table 1-1. Land and Minerals Ownership Within the Planning Area........................................................1-4 

Table 1-2. Steps in the BLM Land Use Planning Process .......................................................................1-18 

Table 2-1. DWFC by Major Vegetation Group and Actions Needed to Meet DWFC ............................2-19 

Table 2-2. OHV Area Designations in WSAs .........................................................................................2-58 

Table 2-3. Summary Comparison of Impacts ..........................................................................................2-64 

Table 3-1. 2002 Criteria Pollutant Inventory (tons per year).....................................................................3-5 

Table 3-2. Fourth-Order Watersheds .......................................................................................................3-20 

Table 3-3. River and Stream Assessment Units That Require a TMDL..................................................3-22 

Table 3-4. SWReGAP Vegetation Communities.....................................................................................3-25 

Table 3-5. Successional Status.................................................................................................................3-25 

Table 3-6. Upland Functioning Condition ...............................................................................................3-26 

Table 3-7. Plant and Seed Collection – FY04 through FY06 ..................................................................3-32 

Table 3-8. Vegetation Departure from Historic and Estimated Disturbance Acreages ...........................3-33 

Table 3-9. Decision Area Riparian Condition .........................................................................................3-35 

Table 3-10. Acres of Weed Treatments ...................................................................................................3-36 

Table 3-11. Utah Noxious Weed List ......................................................................................................3-36 

Table 3-12. Federally Listed Animal and Plant Species..........................................................................3-38 

Table 3-13. Sensitive Animal and Plant Species .....................................................................................3-42 

Table 3-14. Migratory and Non-Migratory Bird Species.........................................................................3-57 

Table 3-15. Fire Occurrence (Size and Acreage), 1991-2001 .................................................................3-60 

Table 3-16. Fire Regimes Within the Planning Area...............................................................................3-61 

Table 3-17. Condition Class Definitions and Acreages...........................................................................3-61 

Table 3-18. Cultural Time Periods...........................................................................................................3-67 

Table 3-19. Geologic Formations Present in the Decision Area..............................................................3-70 

Table 3-20. VRM Inventory Classes........................................................................................................3-73 

Table 3-21. Visual Resource Inventory Class Definitions.......................................................................3-73 

Table 3-22. Non-WSA Lands Evaluated for Wilderness Characteristics ................................................3-75 

Table 3-23. Woodland Product Harvest...................................................................................................3-81 

Table 3-24. Livestock Grazing Allotments..............................................................................................3-81 

Table 3-25. Domestic Livestock Forage Active Use ...............................................................................3-85 

Table 3-26. Recreation Visitation ............................................................................................................3-87 

Table 3-27. Kanab Field Office RUPs and Individual SRPs: FY01–05 ..................................................3-90 

Table 3-28. OHV Registrations by County, 1998–2005..........................................................................3-92 

Table 3-29. Surface Land Ownership in the Planning Area ....................................................................3-93

Table 3-30. Existing Withdrawals within the Decision Area ..................................................................3-95

Table 3-31. Existing Rights-of-Way within the Decision Area...............................................................3-95 

Table 3-32. Communication Sites within the Decision Area...................................................................3-96

Table 3-33. Oil and Gas Wells Drilled in the Kanab Field Office (1960s–2000s) ..................................3-97 

Table 3-34. Potential Areas of Critical Environmental Concern ...........................................................3-102 

Table 3-35. Rivers Determined Eligible for Designation into the National Wild and Scenic 

Rivers System ..............................................................................................................3-103 

Table 3-36. Wilderness Study Areas......................................................................................................3-104 

Table 3-37. Local Property Taxes Charged Against Natural Resource Properties, 2003......................3-118 

Table 3-38. Payments in Lieu of Taxes, 1999–2004 .............................................................................3-119 
Table of Contents Proposed RMP and Final EIS 

viii Kanab RMP 

Table 4-1. Types of Impacts ......................................................................................................................4-1 

Table 4-2. Critical Elements ......................................................................................................................4-3 

Table 4-3. Base Year (2006) Emissions Inventory for the Decision Area (tons per year) ........................4-9 

Table 4-4. Proposed RMP Long-Term (2026) Emissions Inventory for the Decision Area 

(tons per year) ................................................................................................................4-10 

Table 4-5. Increase in Annual Air Emissions from 2006 Conditions in the Decision Area 

(tons per year) ................................................................................................................4-11 

Table 4-6. Visual Resource Management Class Acreages—Differences from Inventory 

Class Acreages...............................................................................................................4-71 

Table 4-7. Proposed RMP Non-WSA Lands with Wilderness Characteristics Managed for their 

Wilderness Characteristics.............................................................................................4-77 

Table 4-8. Proposed RMP VRM Class of Non-WSA Lands with Wilderness Characteristics ...............4-79 

Table 4-9. Proposed RMP Acres of Oil and Gas Leasing Stipulations Within Non-WSA Lands 

with Wilderness Characteristics.....................................................................................4-82 

Table 4-10. Proposed RMP Oil and Gas Leasing Restrictions and Cumulative Timing Limitations....4-108 

Table 4-11. Proposed RMP EPCA Analysis..........................................................................................4-109 

Table 4-12. Proposed RMP Suitable Segments Coinciding with WSAs or Wilderness Area ...............4-120 

Table 4-13. Proposed RMP Eligible Segments Coinciding with ACECs or WSAs ..............................4-120 

Table 4-14. Data Types and Sources for Sectors for Which Quantification of Employment and 

Income Impacts Is Possible..........................................................................................4-131 

Table 4-15. Annual Coal Mining Value of Production from Federal Mineral Estate............................4-133 

Table 4-16. Assumptions for Fluid Minerals Economic Impact Analysis (in 2005 Dollars) ................4-134 

Table 4-17. Livestock Use per Alternative (AUMs)..............................................................................4-135 

Table 4-18. Estimated Value of Cattle AUMs.......................................................................................4-136 

Table 4-19. Estimated Value of Livestock Production per Year ...........................................................4-136 

Table 4-20. Sectors for Which Quantification of Economic Impacts Is Not Possible...........................4-137 

Table 4-21. Annual Employment and Income (in 2006 Dollars) Generated in the Socioeconomic 

Study Area from Use of BLM Lands Under RMP/EIS Alternatives...........................4-138 

Table 4-22. Costs and Values of Harvests from BLM Public Lands.....................................................4-139 

Table 4-23. 2002 Criteria Pollutant Inventory (tons per year)...............................................................4-158 

Table 4-24. Acres of Areas with Wilderness Characteristics in the Cumulative Impact Analysis 

Boundary......................................................................................................................4-163 

Table 5-1. Garfield County General Plan (January 1998) .........................................................................5-6 

Table 5-2. Garfield County General Management Plan Resource Management Amendment 

(December 2007) .............................................................................................................5-7

Table 5-3. Garfield County Economic Development Plan (2007)...........................................................5-15 

Table 5-4. Kane County General Plan (June 1998) .................................................................................5-15 

Table 5-5. State of Utah Code 63j-4-401.................................................................................................5-17 

Table 5-6. Public Scoping Meeting Location/Attendance .......................................................................5-21 

Table 5-7. Kanab RMP/EIS Written Comments Medium .......................................................................5-22 

Table 5-8. Planning Bulletins/Postcards ..................................................................................................5-23 

Table 5-9. Draft RMP/EIS Public Comment Meeting Locations/Attendance.........................................5-24 

Table 5-10. Organizations that Submitted Substantive Comments .........................................................5-27 

Table 5-11. Individuals that Submitted Substantive Comments..............................................................5-27 

Table 5-12. List of Preparers....................................................................................................................5-83 
Proposed RMP and Final EIS Table of Contents 

Kanab RMP ix 

FIGURES 

Figure 1-1. Kanab RMP Planning Area.....................................................................................................1-3 

Figure 3-1. Ozone Concentrations in Grand Canyon National Park, Arizona...........................................3-2 

Figure 3-2. Mean Annual Ozone Concentrations near the Kanab Planning Area. ....................................3-3 

Figure 3-3. Mean Annual Concentrations of Nitrogen Compounds near the Kanab Planning Area. ........3-4 

Figure 3-4. Mean Annual Concentrations of Sulfur Compounds near the Kanab Planning Area. ............3-5 

Figure 3-5. Visibility Data for Bryce National Park..................................................................................3-7 

Figure 3-6. Visibility Data for Canyonlands National Park.......................................................................3-8 

Figure 3-7. Mean Annual Precipitation pH near the Kanab Planning Area...............................................3-9 

Figure 3-8. Total Nitrogen Deposition for Canyonlands National Park ....................................................3-9 

Figure 3-9. Total Sulfur Deposition for Canyonlands National Park ......................................................3-10 

Figure 3-10. Annual Mean Temperature Change for Northern Latitudes (24 - 90° N) ...........................3-11 

Figure 3-11. Average Monthly Total Precipitation – (1971-2000)..........................................................3-17 

Figure 3-12. Socioeconomic Study Area Population Trends and Projections .......................................3-112 

Figure 3-13. Trends in Wages and Salaries by Industry for Garfield County, 1980–2000....................3-114 

Figure 3-14. Trends in Wages and Salaries by Industry for Kane County, 1980–2000 ........................3-115 

APPENDICES 

Appendix 1. Best Management Practices for Land Uses 

Appendix 2. Best Management Practices for Raptors and Their Associated Habitats 

Appendix 3. Surface Stipulations Applicable to Oil and Gas Leasing and Other Surface Disturbing 

Activities 

Appendix 4. Recreation Management for Special Recreation Management Areas and the Kanab 

Extensive Recreation Management Area 

Appendix 5. Lands Designated for Potential Disposal Via Federal Land Policy and Management Act 

Section 203 Sale 

Appendix 6. Kanab Field Office: Coal Unsuitability Report 

Appendix 7. Travel Management/Route Designation Process 

Appendix 8. Wildland Fire Resource Protection Measures and Reasonable and Prudent Measures, 

Terms and Conditions, and Reporting Requirements Identified Through Section 7 

Consultation 

Appendix 9. Conservation Measures, Oil and Gas Lease Notices, and Recovery Plans for Threatened 

and Endangered Species 

Appendix 10. Utah Public Lands Study: Key Social Survey Findings for Garfield and Kane Counties 

Appendix 11. Changes Between the Draft RMP/EIS and the Proposed RMP/Final EIS 

Appendix 12. State of Utah Letter Addressing Air Quality 

Appendix 13. Wild and Scenic Rivers Study Process 

Appendix 14. Areas of Critical Environmental Concern Evaluation Report 

Appendix 15. Reasonably Foreseeable Development Scenario 

Appendix 16. Summary of County General Plan Public Land Decisions 
Table of Contents Proposed RMP and Final EIS 

x Kanab RMP 

MAPS 

Map 1 Land Ownership 

Map 2 Mule Deer Habitat 

Map 3 Elk Habitat 

Map 4 Pronghorn Habitat 

Map 5 Priority Areas for Vegetation Treatment – Proposed RMP 

Map 6 Visual Resource Management – Proposed RMP 

Map 7 Non-WSA Lands Managed for Wilderness Characteristics – Proposed RMP 

Map 8 Special Recreation Management Areas – Proposed RMP 

Map 9 Off-Highway Vehicle Area Designations – Proposed RMP 

Map 10 Route Designations – Proposed RMP 

Map 11 Right-of-Way Restrictions – Proposed RMP 

Map 12 Locatable Minerals – Recommended Withdrawals – Proposed RMP 

Map 13 Areas Available for FLPMA Section 203 Sales – Proposed RMP 

Map 14 Oil and Gas Leasing – Proposed RMP 

Map 15 Areas Available for Further Coal Leasing Consideration – Proposed RMP 

Map 16 Mineral Material (Salable) Disposal – Proposed RMP 

Map 17 Areas of Critical Environmental Concern – Proposed RMP 

Map 18 Suitable Wild and Scenic Rivers – Proposed RMP 

Map 19 General Surface Disturbance Restrictions – Proposed RMP 

Map 20 EPCA Analysis – Proposed RMP 

Map 21 Surface Geology 

Map 22 Physiographic Sub-Units 

Map 23 Precipitation 

Map 24 Areas with Fragile Soils or Relict Vegetation 

Map 25 Fourth-Order Watersheds (Hydrologic Sub-Basins) 

Map 26 Vegetation Communities and Associations 

Map 27 Inventoried Riparian/Wetland Areas 

Map 28 Mexican Spotted Owl Critical Habitat 

Map 29 Greater Sage-Grouse Brooding and Winter Habitat 

Map 30 Desert Bighorn Sheep Habitat 

Map 31 Paleontological Resource Potential 

Map 32 Non-WSA Lands Inventoried for Wilderness Characteristics 

Map 33 Livestock Grazing Allotments 

Map 34 Inventoried Routes 

Map 35 Oil and Gas Development Potential and Existing Oil and Gas Leases and Fields 

Map 36 Coal Development Potential 

Map 37 Gypsum Development Potential 

Map 38 Sand and Gravel Development Potential 

Map 39 Stone and Clay Development Potential 

Map 40 Wilderness and Wilderness Study Areas 

Map 41 Byways, Backways, and Historic Trails 

Map 42 Socioeconomic Study Area 
Proposed RMP and Final EIS Reader’s Guide 

Kanab RMP xi 

READER’S GUIDE TO THIS DOCUMENT 

The Proposed Resource Management Plan (RMP)/Final Environmental Impact Statement (EIS) is 

published in an abbreviated format and is designed to be used in conjunction with the Draft RMP/EIS 

published in October 2007. Additional copies of the Draft RMP/EIS are available at the Kanab Field 

Office (KFO), Utah State Office public room, and the Kanab RMP planning website. 

This Proposed RMP/Final EIS is organized according to the Bureau of Land Management’s (BLM) land 

use planning guidance (H-1610-1 and 43 Code of Federal Regulations [CFR] 1601 et seq.), BLM NEPA 

Handbook (H-1790-1), Council on Environmental Quality (CEQ) guidelines, and Federal regulations 

implementing the National Environmental Policy Act (NEPA) (40 CFR 1500–1508). This Proposed 

RMP/Final EIS has been developed to address issues, concerns, and conflicts within the planning area and 

to provide guidance for management of BLM-administered lands in the KFO. It contains the following 

major chapter headings and information: 

Chapter 1—Introduction, Purpose, and Need. Contains background and introductory material such as 

the purpose and need for the Proposed RMP/Final EIS and the BLM planning process. 

Chapter 2—Proposed Kanab Resource Management Plan. Contains a description of the Proposed 

RMP based on the range of alternatives considered and analyzed in the Draft RMP/EIS. Decision changes 

from Alternative B of the Draft RMP/EIS are highlighted in gray. Implementation-level decision are 

italicized and identified with an asterisk. 

Chapter 3—Affected Environment. Describes the existing condition of the resources, resource uses, 

and other features of the planning area and the decision area. 

Chapter 4—Environmental Consequences of the Proposed Kanab Resource Management Plan. 

Evaluates potential environmental impacts that could occur from implementing the Proposed RMP 

described in Chapter 2. Potential impacts considered in this chapter include ecological (such as the effects 

on natural resources and on the components, structures, and functioning of affected ecosystems), 

aesthetic, historic, cultural, economic, social, and health impacts (40 CFR 1508.8). 

Chapter 5—Consultation and Coordination. Describes the efforts undertaken by the BLM throughout 

the process of developing the Draft RMP/EIS and the Proposed RMP/Final EIS. These efforts include 

public scoping; designating cooperating agencies; and engaging in consultation with tribal, local, county, 

and state agencies . This chapter also includes responses to public comments on the Draft RMP/EIS. 

Glossary. Provides definitions of terms used in this Proposed RMP/Final EIS. 

Abbreviations and Acronyms. Provides an alphabetized list of abbreviations and acronyms used in this 

Proposed RMP/Final EIS. 

References. Provides information for the references cited. 

Appendices. 

Maps. 
Reader’s Guide Proposed RMP and Final EIS 

xii Kanab RMP 

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Proposed RMP and Final EIS Executive Summary 

Kanab RMP ES-1 

Figure ES-1. Kanab RMP Planning Area

EXECUTIVE SUMMARY 

INTRODUCTION

The Bureau of Land Management (BLM) Kanab Field Office (KFO) is revising its current land use plans 

(LUP). Public lands in the KFO area are currently managed under five LUPs—Escalante Management 

Framework Plan (MFP) (1981), Paria MFP (1981), Vermilion MFP (1981), Zion MFP (1981), and CedarBeaver-Garfield-Antimony Resource Management Plan (RMP) (1986)—and their amendments, as well as 

two temporary administrative actions. The new plan revision, which is to be called the Kanab RMP, and 

its accompanying Environmental Impact Statement (EIS), will provide management direction for public 

lands within the boundaries of the KFO area. The KFO Planning Area comprises approximately 

2,847,200 acres of land, of which approximately 554,000 acres is public land surface estate administered 

by the BLM. 

The planning area is located in south-central Utah and is 

bordered by Piute and Wayne counties on the north, 

Washington County and Zion National Park on the west, 

Arizona on the south (including a boundary with the 

Kaibab-Paiute Tribe Reservation), and Grand StaircaseEscalante National Monument (GSENM), Capitol Reef 

National Park, and Glen Canyon National Recreation 

Area on the east (Figure ES-1). The planning area is 

situated within the Colorado Plateau and Wasatch and 

Uinta Mountains Ecoregions (Omernik 1987). The Utah 

portion of the Paria Canyon–Vermilion Cliffs Wilderness 

is also administered by the KFO. Major drainages in the 

planning area include the North Fork of the Virgin River, 

Orderville Gulch, East Fork of the Virgin River, Kanab 

Creek, Sevier River, Paria River, Birch Creek, and North 

Creek (Escalante River). Elevations range from more than 

10,000 feet northeast of the town of Escalante to about 

4,500 feet at the Barracks along the East Fork of the 

Virgin River. 

PURPOSE AND NEED

Purpose 

The Federal Land Policy and Management Act of 1976 (FLPMA) requires that the BLM “develop, 

maintain, and when appropriate, revise land use plans” (43 United States Code [U.S.C.] 1712 [a]). The 

BLM has determined it is necessary to revise existing LUPs and prepare a new RMP for the KFO based 

on a number of new issues that have arisen since preparation of the existing plans. In general, the purpose 

of this RMP is the following: 

• Ensure that public lands are being managed according to the principles of multiple use and 

sustained yield 

• Provide an overview of goals, objectives, and needs associated with public land management 

• Resolve multiple-use conflicts or issues between resource values and resource uses 
Executive Summary Proposed RMP and Final EIS 

ES-2 Kanab RMP 

• Consolidate the existing five LUPs and their amendments. 

The resulting Kanab RMP will establish consolidated guidance and updated objectives and management 

actions for the public lands in the decision area. The RMP will be comprehensive in nature and will 

address issue categories that have been identified through agency, interagency, and public scoping efforts. 

Need 

Since completion of the existing LUPs, considerable changes have occurred within the planning area, 

resulting in a need for new or additional program direction in existing plans in some areas. These changes 

have resulted in three key topics that necessitate preparation of a new RMP. The three key topics include 

changes in policy, changes in resource conditions or demand for resource use, and changes in 

administrative boundaries. Changes in policy include, but are not limited to, the development of standards 

for rangeland health, new special status species listings, implementation of the Energy Policy and 

Conservation Act of 2000 (EPCA), and policies addressing off-highway vehicle (OHV) use. Examples of 

changes in resource conditions or demand for resource use include a substantial increase in OHV use, the 

federal listing of several species under the Endangered Species Act (ESA), and changes in resource use 

levels and patterns that have created areas of conflict between resource protection and resource uses. 

Changes in administrative boundaries include land transfers, realignment of BLM administrative units, 

and designation of the GSENM. 

PUBLIC INVOLVEMENT

Public participation is integral to ensuring that the wide range of planning issues important to public land 

users is addressed. Public participation in the BLM planning process includes a variety of efforts to 

identify and address public concerns and needs. Public involvement helps the agency in the following 

ways: 

• Broadens the information base for decision-making 

• Informs the public about the RMP/EIS and the potential impacts associated with various 

management decisions 

• Ensures that public needs and viewpoints are understood by BLM. 

Public input is generated through a formal public scoping period, which began with the publication of the 

Notice of Intent (NOI) in the Federal Register on April 2, 2004. The scoping period included four public 

scoping meetings (held in Kanab, Panguitch, Escalante, and Salt Lake City). These meetings were 

announced in the local media; through a planning bulletin and a follow-up postcard; on the RMP and 

Utah BLM websites; and in fliers throughout the counties in locations of heavy traffic such as post 

offices, local convenience stores, supermarkets, municipal buildings, local businesses, and local 

recreation sites. The formal scoping period ended February 15, 2005. During the scoping period, more 

than 1,160 individuals provided comments to the BLM or attended public scoping meetings. The majority 

of comments emphasized recreation and OHV management, special designations, minerals and energy, 

and non–Wilderness Study Area (WSA) lands with wilderness characteristics areas. Other issues of high 

interest included livestock grazing, access to public lands, and social and economic issues. More 

information on the scoping process is presented in Chapter 5 and in the Scoping Report for the Kanab 

RMP and EIS. 

Additional opportunities for public participation were provided in April 2005 during a data call for 

information (e.g., route data and resource inventories and/or condition) and nominations for areas of 

critical environmental concern (ACEC) and wild and scenic rivers (WSR). In January 2006, the public 
Proposed RMP and Final EIS Executive Summary 

Kanab RMP ES-3 

was invited to provide additional input into the planning process by commenting on the preliminary 

ACEC and WSR reports. For each of these requests for comments, the BLM provided at least 30 calendar 

days for public response, as directed by BLM planning regulations (43 CFR 1610.2(e)). 

On October 12, 2007, the BLM and the Environmental Protection Agency (EPA) published a Notice of 

Availability in the Federal Register; the date marked the beginning of the formal 90-day public review 

comment period. During the 90-day public comment period on the Draft RMP/EIS, the BLM held public 

meetings in five locations in an effort to inform the interested and affected public about the Draft 

RMP/EIS. These meetings were attended by 209 people, and were structured in an open house format 

with BLM specialists available to provide information and answer questions. The public was also able to 

request hard copies or CDs of the Draft RMP/EIS and submit written comments at the meetings. During 

the 90-day formal Draft RMP/EIS public comment period, the KFO received 8,571 comments. Of these, 

BLM identified 8,084 to be form letters and 487 to be unique submissions. BLM carefully compiled, 

reviewed, analyzed, and addressed all submissions, where substantive. Chapter 5 contains additional 

information about public participation. 

PLANNING ISSUES 

For each public scoping comment received, a position-neutral issue was identified. Planning issues are 

generally related to concerns or controversies about existing and potential land and resource allocations; 

levels of resource use, production, and protection; and related management practices. This process was 

used for all scoping input. The issues identified from comments at public scoping meetings were added to 

written public scoping comments, internal BLM scoping, and interagency scoping. These issues were 

used throughout creation of the range of alternatives (see Chapter 2 of the Draft RMP/EIS). The primary 

issues identified through this process include non-WSA lands with wilderness characteristics areas, 

recreation, transportation, minerals and energy resources, ACECs, and WSAs. A description of the 

planning issues addressed is included in the Draft RMP/EIS. 

ALTERNATIVES

The Draft RMP/EIS considered four alternatives in detail, three action alternatives (Alternatives B, C, and 

D) and the no action alternative (Alternative A), for management of the decision area. Each alternative 

varies in context and intensity of potential management actions and includes a set of designations, land 

use allocations, and management actions needed to implement the goals and objectives. The BLM has 

selected the Proposed RMP by combining components of the various alternatives presented in the Draft 

RMP/EIS. The selection of the Proposed RMP is based on public comments, BLM review, and providing 

the best means to accommodate the widest range of public and agency concerns over resources and 

resource uses. A discussion of the Proposed RMP is provided in Chapter 2. A brief summary of each 

alternative considered in the Draft RMP/EIS and an overview of the key decisions associated with the 

Proposed RMP is provided below. 

Alternative A (No Action) 

Alternative A is defined as a continuation of the current management direction contained in the five LUPs 

and emergency OHV management actions. This alternative describes the current goals and actions for 

management of resources and land uses in the decision area. The management direction could also be 

modified by current law, regulation, and policy. Alternative A represents the baseline to which the other 

management alternatives are compared. 
Executive Summary Proposed RMP and Final EIS 

ES-4 Kanab RMP 

Alternative B (Preferred) 

Alternative B provides opportunities to use and develop resources within the decision area while ensuring 

resource protection. Alternative B would provide for continued access and development of resources with 

stipulations and mitigation to protect natural and cultural resources. 

Alternative C 

Alternative C emphasizes the protection of the decision area’s resource values while allowing commodity 

uses as consistent with current law, regulation, and policy. Management actions would emphasize 

resource values such as habitat for wildlife and plant species (including special status species); protection 

of riparian areas and water quality; preservation of ecologically significant areas; maintenance of 

wilderness characteristics; and protection of scientifically significant cultural and paleontological sites. 

Access to and development of resources within the decision area could occur with intensive management 

and mitigation of surface disturbing and disruptive activities. 

Alternative D 

Alternative D emphasizes opportunities to use and develop resources within the decision area. It would 

provide for motorized access and commodity production with minimal restrictions, while providing 

protection of natural and cultural resources to the extent required by law, regulation, and policy. 

Alternative D would largely rely on existing laws, regulations, and policies, rather than on special 

management or special designations, to protect sensitive resources. 

Proposed RMP 

The Proposed RMP was based on Alternative B of the Draft RMP/EIS which was modified due to public 

comments, internal review, and further coordination with cooperating agencies. It was selected based on 

the following factors: 

• Balance of use and protection of resources 

• Analysis of environmental impacts 

• Consideration of formal recommendations from cooperating agencies and the public. 

The Proposed RMP was selected because it resolves the major planning issues while providing for 

common ground among conflicting opinions and multiple uses of public lands in a sustainable fashion. It 

provides the best balance of resource protection and use within legal constraints. Key resource decisions 

on public lands within the decision area include the following: 

• Oil and gas leasing: 

– 17 percent (95,400 acres) open to oil and gas leasing subject to the standard terms and 

conditions of the lease form 

– 54 percent (296,200 acres) open to oil and gas leasing subject to moderate constraints (timing 

limitations, controlled surface use [CSU], lease notices) 

– 15 percent (83,400 acres) open to oil and gas leasing subject to major constraints (no surface 

occupancy [NSO]) 

– 14 percent (79,000 acres) closed to leasing. 

• Limit vegetation treatments (e.g., wildlife habitat, watershed, and livestock rangeland treatments; 

wildland fires; fuels treatments; and stewardship contracting) to an annual average of no more 

than 22,300 acres. Manage sagebrush steppe communities to restore natural disturbance processes 
Proposed RMP and Final EIS Executive Summary 

Kanab RMP ES-5 

with an appropriate pinyon-juniper component for a given ecological site. Manage ponderosa 

pine stands to restore natural disturbance processes through treatments, resulting in 

predominantly park-like stands. 

• Close the Water Canyon Allotment to livestock grazing (48 animal unit months [AUM]) for the 

life of the plan. Combine the Lydia’s Canyon Allotment with the Lydia Allotment, and combine 

the Sawmill Allotment with the South Canyon Allotment. 

• Apply protective management to river corridors associated with seven suitable river segments, 

along 4,570 acres (25 miles) tentatively classified as “wild” and 960 acres (5 miles) tentatively 

classified as “scenic.” 

• Designate and manage the potential Cottonwood Canyon ACEC (3,800 acres) as an ACEC; 

designate no additional areas as an ACEC. 

• Identify six Special Recreation Management Areas (SRMA) with nine recreation management 

zones (RMZ) (95,100 acres): 

– Manage two RMZs specifically for motorized uses (19,500 acres) 

– Manage five SRMAs/RMZs specifically for non-motorized uses (38,800 acres) 

– Manage two SRMAs/RMZs for both motorized and non-motorized uses (36,800 acres). 

• Manage OHV use according to open, closed, or limited (seasonally and/or spatially) area and 

“route designations” as follows: 

– Approximately 1,000 acres open to cross-country OHV use 

– 25,000 acres closed to OHV use 

– 528,000 acres of limited OHV use, with 1,401 miles of “designated routes,” 2 miles of routes 

closed seasonally, and 75 miles of closed routes. 

• Manage visual resources to preserve the existing character of the landscape (Visual Resource 

Management [VRM] Class I) in the portions of the Paria Canyon–Vermilion Cliffs Wilderness 

Area in the decision area, all WSAs, and river corridors associated with “wild” suitable segments. 

VRM classes and acreages include the following: 

– VRM Class I: 76,000 acres 

– VRM Class II: 94,400 acres 

– VRM Class III: 210,700 acres 

– VRM Class IV: 172,900 acres. 

• Manage the following non-WSA lands (27,770 acres) specifically to protect, preserve, and 

maintain their wilderness characteristics: East of Bryce, Moquith Mountain, Orderville Canyon, 

Parunuweap Canyon, and Upper Kanab Creek. 

AFFECTED ENVIRONMENT

The Proposed RMP/Final EIS decision area is geographically located in an area that results in a diverse 

array of natural resources and subsequent opportunities for use of those resources. Resources within the 

decision area are important ecologically and scientifically, as evidenced by the continued interest in the 

area by recreationists, biologists, hunters, researchers, and environmentalists. The decision area’s natural 

areas and values, such as the large open landscapes, soil and water resources, and vegetation communities 

provide important habitat for a variety of wildlife and special status species, including high-quality big 

game populations. The remote nature of the area and the dispersed uses have protected cultural and 

paleontological resources. The resources in the decision area have also provided the context for diverse 

land uses. 

Resource uses have historically focused on livestock grazing and recreation and tourism, including 

several destination locations for OHV use. Use of forest and woodland products is minimal, but 

consistent. Mineral uses focus on sand and gravel, although there is a coal lease currently being 

considered, and there is a potential for low levels of oil and gas exploration and development. The 
Executive Summary Proposed RMP and Final EIS 

ES-6 Kanab RMP 

decision area is viewed as some of the remaining lands in the region where traditional commercial uses 

and relatively unrestricted recreational activities can still occur. These lands are considered by many vital 

to meet the developing needs of neighboring communities and to contribute to the economic and social 

well-being of the area. 

Socioeconomic conditions indicate that there are small but increasing populations within the two counties 

that have lower income and higher unemployment rates than the average for the State of Utah. Labor 

income has been decreasing over the past 20 years, while investment and transfer income has increased. 

The services sector and the government sector have provided the greatest amount of wages and salaries, 

and both show substantial upward trends. In Garfield County, both mining and construction earnings 

declined substantially in the early 1980s and have not gone back up. In Kane County, the trade industry 

has provided substantial and increasing amounts of wages and salaries. Agricultural wages and salaries 

have been volatile in both counties, including some periods of negative earnings. Today, although fewer 

families earn their livelihood solely from natural resources such as grazing, timber, and minerals than in 

previous times, the descendants of the area’s settlers still have strong connections to the land. Access to 

public land and resources, whether for earning a living or for recreation, is important to the local people.

ENVIRONMENTAL CONSEQUENCES

The Proposed RMP would allow for many uses to continue, but would constrain certain activities to 

maintain or protect important natural resources. Limiting OHV use to “designated routes” would continue 

to provide for this experience, but it would reduce the impacts on soil, water, vegetation, and cultural 

resources while protecting much of the undeveloped nature of the decision area. Although restrictions in 

some areas could result in a loss of opportunities to resource-extraction businesses, the areas remaining 

open for such uses would provide for the anticipated levels of demand. Local economies would retain 

natural resource development opportunities while allowing for economic development of diverse 

recreational opportunities. Managing non-WSA lands for their wilderness characteristics would maintain 

or improve existing vegetation and wildlife trends and non-motorized wilderness-based recreation 

experiences. 

A summary of potential impacts by alternative is presented in Chapter 2. Detailed descriptions of impacts 

of the Proposed RMP are provided in Chapter 4, along with a discussion of the cumulative impacts, 

irretrievable and irreversible commitments of resources, and unavoidable adverse impacts of the 

alternatives. 

NEXT STEPS

Following publication by the EPA and BLM of a Notice of Availability of the Proposed RMP/Final EIS 

in the Federal Register and distribution of the Proposed RMP/Final EIS, a 30-day protest period runs. In 

addition, a 60-day Governor’s Consistency Review period begins the same day as the protest period. In 

other words, the protest period runs concurrently with the first half of the 60-day Governor’s Consistency 

The State Director will approve the Proposed RMP/Final EIS by issuing a public Record of Decision 

(ROD), which is a concise document summarizing the findings and decisions brought forth from the 

Proposed RMP. However, approval shall be withheld on any portion of a plan being protested until final 

action has been completed on such protest. Before such approval is given, there shall be public notice and 

opportunity for public comment on any significant change made to the proposed plan. Among other 

decisions, the proposed ACEC designations and OHV categories (limitations and closures) will be 

approved when the ROD is signed. 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-1 

CHAPTER 1—INTRODUCTION, PURPOSE AND NEED 

The Kanab Resource Management Plan (RMP) will guide management actions on public lands. The 

Bureau of Land Management (BLM) will document broad-scale land use plan (LUP) decisions in the 

Kanab RMP for each program area that guides subsequent site-specific implementation. As the broadest, 

least specific level in the BLM planning process, the Kanab RMP will prescribe the allocation of and 

general future management direction for the resources and land uses of BLM-administered public lands in 

the planning area. In turn, the RMP also guides more specific tiers of the planning process (i.e., activity 

plans and projects or site-specific plans). Comprehensive in nature, the Kanab RMP will address resource 

management issues identified through public, agency, and interagency scoping efforts as well as resource 

management according to BLM policies. The Kanab RMP will establish goals and objectives for resource 

management, the actions needed to achieve them, and parameters for using BLM lands. Lands that are 

open or available for certain uses, including any applicable restrictions, and lands that are closed to 

certain uses are also identified. The Federal Land Policy and Management Act of 1976 (FLPMA), as 

amended, requires the BLM to manage the public lands and their various resources so that they are used 

in the combination that will best meet the present and future needs of the American people. LUP 

decisions are made according to the procedures in the BLM’s planning regulations (43 Code of Federal 

Regulations [CFR] 1600) and in accordance with FLPMA. 

The development of the Kanab RMP, which requires preparation of an Environmental Impact Statement 

(EIS), constitutes a major federal action and is subject to the National Environmental Policy Act of 1969 

(NEPA). NEPA requires federal agencies to consider environmental consequences in their decisionmaking process. This Proposed RMP/Final EIS analyzes the impacts from the Proposed RMP decisions 

and fulfills the requirements for implementing NEPA found in 40 CFR 1500–1508. The EIS informs 

decision-makers and the public of the Proposed RMP, associated environmental impacts, and any 

mitigation measures required. This Proposed RMP/Final EIS analyzes the Proposed RMP for the decision 

area that resolves the issues identified during the planning effort. All decisions discussed in this document 

apply only to public lands administered by the BLM. 

1.1 PURPOSE AND NEED

1.1.1 Purpose 

FLPMA requires that the BLM “develop, maintain, and when appropriate, revise land use plans” (43 

United States Code [U.S.C.] 1712(a)). The BLM has determined that it is necessary to revise existing 

LUPs and prepare a new RMP for the Kanab Field Office (KFO) based on a number of new issues that 

have arisen since preparation of the existing plans. In general, the purpose of this RMP is to: 

• Ensure that public lands are being managed according to the principles of multiple use and 

sustained yield 

• Provide an overview of goals, objectives, and needs associated with public land management 

• Resolve multiple-use conflicts or issues between resource values and resource uses 

• Consolidate the existing five LUPs and their amendments. 

The resulting Kanab RMP will establish consolidated guidance and updated objectives and management 

actions for the public lands in the decision area. The RMP will be comprehensive in nature and will 

address issue categories that have been identified through agency, interagency, and public scoping efforts. 
Chapter 1 Proposed RMP and Final EIS 

1-2 Kanab RMP 

1.1.2 Need 

Since completion of the existing LUPs, considerable changes have occurred within the planning area that 

have resulted in existing plans needing new or additional program direction in some areas. The three key 

changes necessitating a new RMP are: (1) changes in policy; (2) changes in resource conditions, uses, or 

demands; and (3) changes in administrative boundaries of the planning area. The following paragraphs 

provide a brief summary of these key changes. 

Changes in Policy 

National level BLM policies have been revised since completion of the existing LUPs. Such changes in 

policy include the development of Standards for Rangeland Health; revisions in cultural and 

paleontological resources management; new special status species listings; development of a statewide 

riparian policy; a new Executive Order addressing Migratory Bird Treaty Act compliance; 

implementation of the Energy Policy and Conservation Act of 2000 as amended (EPCA) and the Energy 

Policy Act of 2005; and off-highway vehicle (OHV) use and management, soil, water, and air 

management. This current planning process will allow for these policies to be integrated into the new 

RMP. 

Changes in Resource Condition or Demands 

Since completion of the existing LUPs there have been changes in resource conditions or demand for 

resource use. Many of the changes were identified in a Special Evaluation Report completed in 2002 by 

the KFO (BLM 2002a), which concluded that some of the decisions within the existing LUPs are in need 

of revision. For example, OHV use has substantially increased throughout the planning area, increasing 

the potential for impacts on resources and conflicts with other uses. There are several species that have 

been federally listed under the Endangered Species Act (ESA), critical habitat designated, and other 

special status species identified since the existing plans were developed. In addition, changes in resource 

use levels and patterns have created areas of conflict between resource protection and resource uses. This 

planning effort would provide new management direction to address existing and foreseeable changes to 

resource conflicts, conditions, and demands. 

Changes in Administrative Boundaries 

The need for this planning effort, as noted above, is partly due to changes in administrative boundaries 

since the existing LUPs were completed. Land transfers, realignment of BLM administrative units, and 

the designation of Grand Staircase–Escalante National Monument (GSENM) have changed the land 

ownership and land use patterns throughout the planning area. This planning effort will update resource 

management and use allocations based on these new managerial responsibilities and the associated 

impacts these changes have on land use patterns. 

1.2 DESCRIPTION OF THE DECISION AREA

The BLM Land Use Planning Handbook (H-1601-1) differentiates between geographic areas associated 

with planning. They include the planning area, decision area, and analysis area. 

Planning Area. This is the region within which the BLM will make decisions during a planning effort. A 

planning area boundary includes all lands regardless of jurisdiction; however, the BLM will make 

decisions only on lands that fall under BLM jurisdiction (including subsurface minerals). Figure 1-1 

shows the planning area in relation to the State of Utah. 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-3 

Decision Area. This includes the lands within a planning 

area for which the BLM has authority to make land use 

and management decisions. The BLM directly manages 

all BLM-administered public lands (surface and 

subsurface). The BLM also manages mineral operations 

on those federal lands managed by other federal agencies. 

In addition, it manages mineral operations on split estate 

lands where a private or other non-federal party (state) 

owns the surface while the Federal Government owns the 

subsurface minerals. The Kanab RMP will not include 

any planning and management decisions for areas where 

the land surface and minerals are both privately owned or 

owned by the State of Utah or local governments. For the 

purposes of this document, the decision area refers to all 

BLM-administered surface (Map 1) and subsurface. 

Analysis Area. This includes any lands, regardless of 

jurisdiction, for which the BLM synthesizes, analyzes, 

and interprets data and information that relates to 

planning for BLM-administered lands. Analyses that 

extend beyond the planning area allow management decisions to be made within the context of overall 

resource conditions and trends within the surrounding area. Use of the term “analysis area” in this 

document may vary according to resource or discussion. For example, the social and economic features 

section of this Final EIS refers to an analysis area comprising Garfield and Kane counties.

The planning area is located in south-central Utah and is bordered by Piute and Wayne counties on the 

north, Washington County and Zion National Park on the west, Arizona on the south "(including a 

boundary with the Kaibab-Paiute Tribe Reservation), and Capitol Reef National Park and Glen Canyon 

National Recreation Area (NRA) on the east. The planning area also includes the Utah portion of the 

Paria Canyon–Vermilion Cliffs Wilderness, which is administered by the KFO. Major drainages in the 

planning area include the North Fork of the Virgin River, Orderville Gulch, East Fork of the Virgin River, 

Kanab Creek, Sevier River, Paria River, Birch Creek, and North Creek (Escalante River). Elevations 

range from more than 10,000 feet northeast of the town of Escalante to about 4,500 feet at the Barracks 

along the East Fork of the Virgin River. Intermingled with and adjacent to BLM-administered lands are 

resources of national and international significance, including Bryce Canyon National Park, Zion National 

Park, the North Rim of the Grand Canyon, Glen Canyon NRA, Pipe Spring National Monument, Cedar 

Breaks National Monument, GSENM, Grand Canyon–Parashant and Vermilion Cliffs National 

Monuments, Kodachrome Basin State Park, Escalante Petrified Forest State Park, and Coral Pink Sand 

Dunes State Park. 

The planning area contains historical communities, diverse terrain, scenic landscapes, and recreational 

attractions that figure prominently in the settlement, history, culture, and enjoyment of southern Utah. 

Traditional occupational pursuits historically associated with Utah include farming, ranching, mining, 

tourism, retail trade, transportation, and construction. Major transportation routes include U.S. Highway 

89, State Route 9, State Route 14, State Route 12, Johnson Canyon/Glendale Bench Road, Yellowjacket 

Road, Hancock Road, Posey Lake Road, and Upper Cottonwood Canyon Road. 

Of approximately 2,847,200 acres of land within the planning area, this RMP will make decisions for the 

BLM surface estate and the federal mineral estate managed by the KFO (Table 1-1 and Map 1). 

Figure 1-1. Kanab RMP Planning Area
Chapter 1 Proposed RMP and Final EIS 

1-4 Kanab RMP 

Table 1-1. Land and Minerals Ownership Within the Planning Area 

Jurisdiction Acres1

Total BLM-administered federal land surface to be covered by RMP decisions 554,000 

Total land surface area in the Kanab RMP planning area (all ownerships)1 2,847,200 

Split Estate Federal Minerals (All Minerals) 167,000 

Split Estate Federal Minerals (Coal Only) 75,000 

Split Estate Federal Minerals (Oil and Gas Only) 10,000 

Split Estate Federal Minerals (Geothermal Only) 110 

Split Estate Federal Minerals (Other Minerals) 13,800 

Notes: 1 - Because of land surface and mineral ownership overlaps and administrative responsibility overlaps, acreage figures 

are not additive. For the purpose of the Kanab RMP, where one or more of the mineral resource categories are federally 

owned, the acres are listed as if all minerals in the area were federally owned. Where mixed minerals ownership occurs (for 

example, privately owned oil and gas, overlapping with federally owned coal in the same area), minerals planning and 

management decisions in the RMP will pertain only to the federally owned minerals. 

Sources: Kanab BLM Geographic Information System (GIS) Program, LR2000 

In areas where the land surface is privately owned or owned by the State of Utah or local governments 

and the minerals are federally owned, the RMP will include planning and management decisions for only 

the BLM-administered federal mineral estate. The land and resource uses and values on the non-federal 

surface will be taken into account in the impact analysis and will affect development of the federal 

minerals. However, the RMP decisions will not pertain to non-mineral state and private actions on nonfederal surface. At the same time, surface and minerals management actions and development activities of 

non-federal surfaces and mineral estate will be taken into account for purposes of cumulative impact 

analysis in the Kanab RMP/EIS. 

In areas where the federal land surface is administered by the United States Forest Service (USFS), the 

National Park Service (NPS), or other federal agencies and the federal mineral estate is administered by 

the BLM, the land surface planning and management decisions are the responsibility of these “other” 

federal surface management agencies. BLM administrative responsibilities within these areas (for 

example, actions concerning the federal mineral estate) are handled on a case-by-case basis and are 

guided by the other surface management agencies’ policies, procedures, and plans when applying 

stipulations or restrictions. At the same time, surface and minerals management actions and development 

activities anticipated in these areas will be taken into account for purposes of cumulative impact analysis 

in the Kanab RMP/EIS. 

The planning area is situated within the Colorado Plateau and Wasatch and Uinta Mountains Ecoregions 

(Omernik 1987). The Colorado Plateau Ecoregion, which encompasses the southern and eastern portions 

of the planning area, is characterized by rugged tableland topography with precipitous canyon walls that 

mark abrupt changes in local relief. The region contains a mixture of pinyon-juniper woodlands, grasses, 

and shrubs in the higher elevations and saltbrush-greasewood communities in the lower elevations 

(Environmental Protection Agency [EPA] 2005). The Wasatch and Uinta Mountains Ecoregion, which 

encompasses the northwestern portion of the planning area, is composed of high, precipitous mountains 

with narrow crests and valleys flanked in some areas by dissected plateaus and open high mountains. The 

elevational banding of vegetation is similar to that of most of the mountainous regions in the western 

United States, with coniferous forests (primarily pinyon and juniper) covering much of the region. 

Grasses and shrubs are typical in the lower elevations with Douglas fir, ponderosa pine, aspen, and 

juniper oak woodlands covering the low to middle elevations (EPA 2005). 
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Kanab RMP 1-5 

The planning area is characteristic of these two ecoregions, containing the unique and important 

geological and biological features present in the regions. The Colorado Plateau Ecoregion is particularly 

unique because it is the only area in the United States where large mountain rivers flow through exposed 

sandstone, creating large canyons and world-class recreation opportunities. The most distinguishing 

feature of the Wasatch and Uinta Mountains Ecoregion is its vast expanses of coniferous forests and large 

areas of Gambel oak. The Wasatch and Uinta Rockies differ climatically from other Rocky Mountain 

ecoregions in their relative aridity, a function of the extensive rain shadow cast by the Sierra Nevada 

Mountains 500 miles to the west. These regions are rich in endemic fish and insect species and provide 

habitat for many other forms of wildlife, including pronghorn, elk, mule deer, cougar, black bear, bighorn 

sheep, federally listed species, and BLM sensitive species. 

Much of the Colorado Plateau and Wasatch and Uinta Mountains Ecoregions have been altered by human 

activity, such as livestock grazing, minerals exploration and development, logging, fire suppression, and 

OHV and other recreational use. As demands for these activities increase, the extent of human impacts 

will likely increase. Issues concerning resource conditions within the decision area primarily involve 

balancing the use of resources for commercial and recreational purposes with the need for protection of 

natural resource values. 

1.3 SCOPING AND PUBLIC PARTICIPATION 

Public input is generated through a formal public scoping period, which began with the publication of the 

Notice of Intent (NOI) in the Federal Register on April 2, 2004. The scoping period included four public 

scoping meetings. The formal scoping period ended on February 15, 2005. The majority of comments 

emphasized OHV management, recreation, and areas of special designation. Other issues of high interest 

included livestock grazing, access to public lands, and social and economic issues. 

On October 12, 2007, the BLM and EPA published a Notice of Availability in the Federal Register; the 

date marked the beginning of the formal 90-day public review comment period. During the 90-day public 

comment period on the Draft RMP/EIS, the BLM held public meetings in five locations in an effort to 

inform the interested and affected public about the Draft RMP/EIS. These meetings were attended by 209 

people, and were structured in an open house format with BLM specialists available to provide 

information and answer questions. The public was also able to request hard copies or CDs of the Draft 

RMP/EIS and submit written comments at the meetings. 

During the public comment period, BLM received 8,571 submissions at public meetings, through the 

project website, and by fax, e-mail, and regular mail from the public, cooperating agencies, other federal 

agencies, Indian tribes, organizations, and businesses. BLM responded to substantive comments by 

making revisions to the Proposed RMP/Final EIS. If no change was warranted, BLM responded to the 

substantive comment in writing. The response to substantive comments is included as a CD attached to 

this document. Chapter 5 contains additional information about public participation. 

1.3.1 Planning Issues Addressed 

Planning issues are related to concerns or controversies about existing and potential land and resource 

allocations; levels of resource use, production, and protection; and related management practices. They 

contribute to the need for this proposed plan revision. The RMP process provides an opportunity to 

address these conflicts or questions. Issues are position-neutral statements or questions that set the 

groundwork for development of alternative solutions to be analyzed in the EIS. Issues may be of local, 

state, or national concern, or they may reflect conditions specific to the decision area. Identified issues are 

subject to change throughout the planning process as new conditions or concerns are identified. 
Chapter 1 Proposed RMP and Final EIS 

1-6 Kanab RMP 

Comments were solicited from the public; organizations; tribal governments; and federal, state, and local 

agencies to identify issues. In addition, management concerns were identified through discussions with 

BLM resource specialists. The issues listed below were identified by the KFO during the agency and 

public scoping process. More information on these issues is available in Chapter 3 of the Scoping Report. 

A description of the planning issues addressed is included in the Draft RMP/EIS. 

Resources 

Air Quality 

Current air quality standards postdate earlier planning decisions. The Kanab RMP will incorporate 

objectives for air quality and visibility, describe the current air resource conditions within the decision 

area, provide actions or limitations to manage air resources and visibility, and provide for collaboration 

on regional issues with local, state, and federal agencies. 

Soil Resources 

The Kanab RMP will address protection of soils to reflect the expected future uses and conditions of 

BLM-administered lands, and some standards and objectives may need to be clarified or changed. 

Stipulations currently in place to reduce salinity or erosion impacts during some resource uses could be 

expanded to include all surface disturbing activities. Specific emphasis could be placed on managing 

surface disturbing actions on identified areas of fragile soils and areas susceptible to erosion. Another 

issue raised was minimizing soil loss and salinity contributions to the Colorado River. 

Water and Watershed Resources 

The Kanab RMP will address water quality issues, determine where current resource uses may be 

contributing to water quality problems, include best management practices for riparian/wetland areas, and 

review the State’s 303(d) list for impaired river and streams and determine if BLM-authorized activities 

contribute to the impairment. In addition to the State’s 303(d) list, RMP decisions could consider actions 

that address salinity concerns in the Colorado River. Management decisions could include limiting or 

restricting surface disturbing activities in riparian areas, near impaired rivers and streams, in floodplains, 

and in watersheds used for public drinking water supply. 

Vegetation 

The Kanab RMP will identify desired outcomes for vegetation resources (i.e., Desired Plant Communities 

[DPC]), including the desired mix of vegetation types, structural stages, and landscape and riparian 

functions. The RMP will need to ensure that the Standards for Rangeland Health are applied to all 

resources and uses. The RMP could also designate management for priority plant species. This RMP 

could identify areas available or not available for use of vegetation products, such as pine nuts, grass and 

forb seeds, or live plant collection. The RMP will also address: 

• Vegetation species (native versus non-native) available for rehabilitation/restoration 

• Noxious weeds and non-native invasive species management 

• Preservation of relict plant communities and hanging gardens 

• Encroachment of pinyon-juniper woodlands 

• Application of various vegetation treatment methods to restore degraded habitats 

• Improvement or maintenance of riparian and wetland areas. 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-7 

The RMP will need to ensure that vegetation management activities and treatment of invasive species will 

follow principles of integrated pest management. The following documents are incorporated by reference 

as current national guidance, although they may be updated over the life of this plan: 

• Vegetation Treatments on BLM Lands in 17 Western States Programmatic Environmental 

Report, 2007 

• Vegetation Treatments Using Herbicides in 17 Western States Programmatic Environmental 

Impact Statement, 2007 

• Final Environmental Impact Statement Vegetation Treatment on BLM Lands in 13 Western 

States and Associated Records of Decision, 1991. 

Special Status Species (Threatened, Endangered, and Sensitive) 

Since completion of the existing plans, several plant and animal species have been identified or 

designated as special status. Existing LUP decisions do not adequately address these species. The Kanab 

RMP will address the need to identify specific actions or restrictions to preserve habitat and protect 

threatened, endangered, candidate, and proposed plant and animal species from disruptive activities and 

habitat loss or fragmentation. The plan will implement appropriate conservation agreements and recovery 

plans. In addition, research and monitoring have increased information concerning the distribution and 

habitat requirements of various species. The revised RMP would incorporate this information for listed 

and non-listed special status plant and animal species. The Kanab RMP will address protection of special 

status species (e.g., Greater sage-grouse breeding, nesting, brood-rearing, and wintering habitat and bald 

eagle and other sensitive raptor nest sites) and sensitive areas from disruptive activities. 

Fish and Wildlife 

The Kanab RMP will address the need to improve wildlife habitat and include desired habitat conditions 

for major habitat types that support a wide variety of wildlife species. The plan will address opportunities 

for improving the habitat condition and protecting high-quality habitat areas (e.g., ponderosa pine, aspen, 

and sagebrush) as important wildlife habitat. Priority species, including populations of fish or wildlife 

species, and habitats will be identified. Actions and area-wide use restrictions needed to achieve habitat 

conditions will be identified. 

The existing LUPs do not include management for migratory bird habitat. The RMP revision will 

integrate direction from Executive Order (EO) 13186 by integrating information concerning Utah Partners 

in Flight (PIF) priority species and U.S. Fish and Wildlife Service (USFWS) Birds of Conservation 

Concern. The Kanab RMP will address protection of raptor nest sites and sensitive areas from disruptive 

activities. 

The RMP will also address: 

• Fish and wildlife habitat connectivity 

• The potential for fish and wildlife reintroductions 

• Forage allocation for big game species as established by the Utah Division of Wildlife Resources. 

Wildland Fire Ecology 

While there were scoping issues related to wildland fire and its role in the environment and use as a 

management tool, the Utah Land Use Plan Amendment for Fire and Fuels Management was completed in 

September 2005, amending the existing LUPs with updated wildland fire ecology management decisions. 

Upon review of the issues raised in scoping and the decisions made in the amendment, it was determined 

that the amendment’s decisions adequately address wildland fire management, identifying landscape level 
Chapter 1 Proposed RMP and Final EIS 

1-8 Kanab RMP 

goals and actions needed to achieve them. This RMP effort carries these decisions forward unchanged, 

because they were completed with up-to-date information and were associated with an appropriate-level 

NEPA document. Chapter 3 presents the current environment for wildland fire, and Chapter 4 addresses 

impacts on wildland fire management by management actions related to other resources and resource 

uses.

Cultural Resources 

There are numerous laws, regulations, and policies as well as program guidance for the cultural program 

that postdate the existing LUPs. The existing LUPs address a portion of the required components, but are 

silent on several other key policy requirements such as the Native American Graves Protection and 

Repatriation Act, the 1992 amendments to the National Historic Preservation Act (NHPA), and EO 

13007, and do not have specific resource management goals and actions that address these directives. 

This RMP will provide for the development of a proactive cultural resources management framework that 

incorporates changes in BLM policy and law. This planning effort will provide guidance for the cultural 

resources program and identify priorities for future inventories. The new policy of cultural resource use 

allocations could also provide a framework for priority cultural resource areas or site types. 

Many policies regarding consideration of Native American values, sovereignty, and coordination and 

consultation were not in place during the preparation of existing plans. Thus, the RMP revision will seek 

to actively consult with, address concerns of, and recognize values and resources important to Native 

Americans. 

Paleontological Resources 

Paleontological resources in the decision area and the geologic formations that extend within the adjacent 

GSENM contain extensive fossils, including scientifically significant type specimens. The RMP will 

address the study, use, and protection of these paleontological resources. While there are some decisions 

that address the management of petrified wood, these are directed at consumptive use. This RMP will 

need to address the management of paleontological resources, including their scientific, educational, 

recreational, and consumptive use values. This could be accomplished through programmatic decisions 

providing direction to the paleontology program and through land use stipulations or restrictions to 

protect these values. 

Visual Resources 

The visual resources inventory has been updated based on policy changes. In addition, changes in visitor 

use patterns and frequency and visitor sensitivity to changes in the landscape have occurred. The RMP 

will apply the new visual resources inventory and policy and address areas of high scenic values such as 

viewsheds adjacent to National Parks or existing scenic byways and backways. 

Non-WSA Lands with Wilderness Characteristics 

In September 2005, the U.S. District Court, District of Utah, Central District, approved an agreement to 

settle a lawsuit challenging the BLM’s authority to conduct new wilderness inventories. The policies 

stemming from the settlement stipulated that the BLM’s authority to designate new wilderness study 

areas (WSA) expired no later than October 21, 1993. The BLM retains its Section 201 FLPMA authority 

to inventory resources or other values, including areas with wilderness characteristics such as naturalness 

or solitude and that are conducive to primitive, unconfined recreation. 

The BLM’s policy on considering wilderness characteristics in LUPs is contained in Section 202 of 

FLPMA and clarified in the Land Use Planning Handbook (BLM-H-1601-1). According to the planning 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-9 

handbook, lands with wilderness characteristics may be managed to protect and/or preserve some or all of 

those characteristics. This may include protecting certain lands in their natural condition and/or providing 

opportunities for solitude or primitive and unconfined types of recreation. The BLM can make a variety 

of LUP decisions to protect wilderness characteristics, such as establishing Visual Resource Management 

(VRM) class objectives to guide the placement of roads, trails, and other facilities; establishing conditions 

of use to be attached to permits, leases, and other authorizations to achieve the desired level of resource 

protection; and designating lands as open, closed, or limited to OHV use in order to achieve a desired 

visitor experience. 

There are areas in the decision area outside of existing WSAs that were determined by the BLM in the 

1999 Utah Wilderness Inventory (BLM 1999a) to have wilderness characteristics. In addition, since 1999 

and during scoping for this LUP members of the public submitted information suggesting that additional 

areas outside of existing WSAs have wilderness characteristics and should be managed to preserve those 

values. All the non-WSA lands with wilderness characteristics evaluated in this process are described in 

Chapter 3. Through the RMP planning process, the BLM will consider all available information to 

determine the appropriate mix of resource use and protection that best serves the FLPMA multiple-use 

mandate. 

Resource Uses 

Forestry and Woodland Products 

There is a demand for harvest of forest and woodland species in the decision area. In addition, the Healthy 

Forest Restoration Act passed in 2003 directs additional attention to the management and health of forests 

and woodlands on public lands. This RMP will address whether there are areas that are appropriate for 

commercial timber harvest and for harvest of woodland species for fuelwood, posts, biomass utilization, 

or other woodland products. Management direction for forest and woodland resources could be changed 

to focus on identifying desired forest and woodland stand objectives and using forest and woodland 

product harvest to help achieve desired conditions. 

Livestock Grazing 

Land ownership and designation in the area has changed substantially since the previous LUPs were 

developed. Minor changes have occurred in the grazing program that need to be updated in the context of 

land ownership and the existing condition of the range. This RMP will review and update lands available 

or unavailable for livestock grazing, as referred to in 43 CFR 4130.2. Specifically, this RMP will 

determine management of allotments to improve or maintain rangeland health, including the following: 

• A limited number of necessary changes in the current forage allocation. 

• Allotments that require a change in class of livestock 

• Areas of conflicts between other land uses and livestock grazing 

• Extent and type of livestock movement that is appropriate (historic livestock driveways). 

Forage reallocation has been raised in BLM planning processes throughout the west. Agencies and 

organizations have sought such actions in the past and will likely continue to do so in the future. Existing 

plans hint at allocation of forage to big game, but do not address this issue completely. This planning 

process will address this issue in terms of how future requests for reallocation will be addressed. This 

process could also provide for temporary (outside normal season of use) livestock grazing on these 

allotments to achieve desired vegetation, fuel conditions, or other management objectives. 
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1-10 Kanab RMP 

Recreation 

Since the completion of the existing LUPs, considerable changes to recreation use have occurred within 

the decision area. In certain parts, increased visitor use is affecting soil, water, vegetation, and wildlife 

and the potential for conflicts between recreationists is increasing. In addition to changes in use, BLM 

recreation management policy has changed. This RMP will apply the new policies in providing recreation 

opportunities and benefits while protecting natural and cultural resources. 

Conflict between motorized and non-motorized users was identified as a concern during the public 

scoping process. Specific management initiatives such as travel plans, recreation zoning, developed sites, 

and improved interpretation and education could be considered to improve opportunities and reduce 

conflict. 

The existing extensive recreation management area (ERMA) was identified primarily because there was 

no need for more intensive recreation management; however, recreation use has significantly increased 

since the implementation of current management direction. Portions of the existing ERMA were reviewed 

for potential to be identified as special recreation management areas (SRMA) to effectively manage the 

area’s changing recreation patterns. The planning process will consider a benefits-based recreation 

planning system in order to identify recreation niche opportunities that exist and for determining potential 

SRMAs. The new RMP will assist in protecting resources from the impacts of recreation use and in 

improving recreational opportunities, including the potential for new developed recreation sites. 

Recreation that occurs along travel corridors and at highly developed sites remains popular. As visitation 

to these sites increases, management of the areas may need to focus more heavily on providing defined 

recreation experiences. Users of front country recreation sites typically expect more extensive interpretive 

information and facilities. Areas that were once dispersed recreation sites may have become de facto front 

country recreation sites through increased use. This RMP will address these high-use areas and protect 

recreation opportunities while protecting the resource values. 

Other issues that will be addressed in the RMP include: 

• Management of natural soundscapes, specifically around Bryce Canyon and Zion National Parks 

• Management of dispersed camping 

• Heritage tourism opportunities 

• Areas available for specimen collection (geology, paleontology, etc.). 

Transportation 

Existing transportation management decisions are out of date with existing demand and policy. The 

decisions are limited largely to OHV area designations and do not provide for existing OHV use demands 

while providing for sustained resource protection. OHV use and management will be addressed in 

conformance with the National Management Strategy for Motorized Off-Highway Vehicle Use on Public 

Lands. Existing OHV area and route designations will be reviewed and modified where needed to meet 

changing levels of OHV use, existing resource condition, and changing resource objectives. 

Closures for Parunuweap Canyon, North Fork Virgin River, and Orderville Canyon WSAs will be 

reviewed to determine how OHV use in these areas should occur to protect wilderness values. A travel 

restriction action in the Hog Canyon area will also be reviewed in this RMP. 

In addition, existing plans do not differentiate between the various aspects of the transportation system, 

such as recreational, traditional, casual, agricultural, administrative, commercial, or educational use of the 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-11 

transportation system, and providing access to public land users along routes. Outside of OHV use, 

existing plans do not address any other modes of use or conditions for such use. This planning process 

could establish comprehensive travel system planning, addressing these aspects of use in relation to the 

existing transportation system and resource values, providing for modifications to the transportation 

system to meet the resource and use demands. It could also establish preliminary maintenance standards 

for the transportation network, including the management of undesignated routes. 

Lands and Realty 

Current management has been sufficient in managing lands and realty within the decision area with the 

exception of land disposals for community expansion. Increasing use of the planning area and demands 

on resources will elevate the role of the lands and realty program to manage the increase in requests for 

rights-of-way (ROW), permits, leases, and land tenure adjustments. Therefore, this RMP will include 

management strategies designed to accommodate these increased land requests. Specifically, flexibility 

allowed by land tenure adjustment criteria will be continued, with some possible modifications. 

The demand for utility lines, additional roads, and new communication sites is anticipated to increase 

over the life of the new RMP. Most of the demand for ROWs would be for small encumbrances and 

would not require (or be part of) placement within designated utility corridors. Existing ROW corridors 

will be evaluated and adjusted and new corridors established where necessary in coordination with 

neighboring BLM, other federal, and tribal jurisdictions and major utility companies. To aid in this 

process, ROW avoidance and exclusion areas will be identified, delineated, and mapped with 

consideration for the goals and objectives of other resources. 

Other lands and realty issues that will be addressed in the RMP include: 

• Areas available for new communication sites 

• Areas considered for withdrawal from public land laws for resource protection 

• Lands to be considered for disposal (including sales and providing for needs of local and other 

government entities for public purpose use) 

• Areas available for alternative energy resource development (e.g., wind and solar energy 

development) 

• Management of permits for filming. 

Minerals and Energy Resources 

The Kanab RMP will address the continued sale, leasing, and location of mineral and energy resources 

within the decision area. Oil and gas leasing stipulations will be revised to incorporate new resource data. 

A coal screening process will be applied to identify areas acceptable for leasing consideration. A 

Reasonably Foreseeable Development scenario has been developed for leasable, locatable, and salable 

minerals development, and will help focus the analysis of the development of these resources. The Kanab 

RMP will identify areas recommended for withdrawal from locatable mineral entry and identify areas as 

open or closed to disposal of salable minerals. The Kanab RMP will incorporate best management 

practices and best technology available for minerals and energy development. 

The EPCA directed the Secretary of the Interior, in consultation with the Secretaries of Agriculture and 

Energy, to conduct an inventory of oil and gas resources beneath federal lands. The inventory is contained 

in the January 2003 EPCA Report. The EPCA inventory provided estimates of undiscovered technically 

recoverable resources and proved reserves of oil and gas beneath five major geologic basins in the 

western United States and an inventory of the extent and nature of limitations to their development. The 

Paradox/San Juan Basin, which is partly located within the decision area, is one of the five primary 
Chapter 1 Proposed RMP and Final EIS 

1-12 Kanab RMP 

inventory areas. The Paradox/San Juan Basin and the other four basins were selected because these basins 

contain most of the onshore natural gas and much of the oil under federal ownership. 

Special Designations 

Areas of Critical Environmental Concern 

As part of the RMP process, the Water Canyon/South Fork Indian Canyon Area of Critical Environmental 

Concern (ACEC) will be reevaluated to determine if the relevant and important values are still present. As 

a result, the ACEC designation could be revoked in the new RMP. Management prescriptions for this area 

will also be reviewed to ensure that they can protect the identified relevant and important values. 

In accordance with FLPMA, consideration will be given to the designation of additional ACECs during 

the RMP process. Areas that are determined by the BLM to meet the requisite relevance and importance 

(R&I) criteria for ACEC designation will be identified; will have management developed to protect 

relevant and important values, resources, natural systems or processes, or hazards/safety/public welfare 

(referred to collectively as values); and be brought forward for analysis in one or more of the EIS 

alternatives. 

Wild and Scenic Rivers 

Section 5(d) of the Wild and Scenic Rivers Act directs federal agencies to consider the potential for 

national wild, scenic, and recreational river areas in land use planning documents; therefore, a Wild and 

Scenic Rivers review will be part of the RMP revision process. All potentially eligible rivers will be 

reviewed by the interdisciplinary team to determine if they are free-flowing and contain outstandingly 

remarkable values that make them eligible for congressional designation into the National Wild and 

Scenic Rivers System. All eligible river segments will be assigned a tentative classification of “wild,” 

“scenic,” or “recreational” and will be considered in the RMP/EIS as to their suitability for congressional 

designation into the National Wild and Scenic Rivers System. Management will be designed to protect 

the tentative classification, free-flowing nature, and outstandingly remarkable values of suitable segments. 

Wilderness 

While not specifically addressed in any of the existing LUPs, wilderness areas require more intensive 

management once they are designated. The Wilderness Act directs that wilderness areas be managed to 

provide for their protection and the preservation of their natural conditions and wilderness character. The 

BLM will continue to manage wilderness in this manner in conjunction with applicable law, regulation, 

and policy. An implementation-level Wilderness Management Plan was completed for the Paria CanyonVermilion Cliffs Wilderness in 1986. This RMP process will review the guiding decisions for the Paria 

Canyon-Vermilion Cliffs Wilderness (in coordination with the BLM Arizona Strip Field Office, which 

co-manages the wilderness with KFO) and provide landscape-level direction to ensure protection of 

wilderness characteristics. Such direction would be used in future revisions of or amendments to the 

Wilderness Management Plan. 

Wilderness Study Areas 

For the most part, current management of the five WSAs has been adequate to protect the wilderness 

characteristics of those areas. However, some problem areas have recently developed. Increased OHV use 

has begun to threaten the wilderness characteristics of the Moquith and Parunuweap WSAs. This EIS will 

address increased OHV use through route designations (implementation-level decision) and travel 

management decisions (RMP-level decisions) in order to continue to protect the WSAs’ wilderness 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-13 

characteristics. As directed by BLM policy, the RMP will also set objectives for management of visual 

resources within the WSAs. 

Other Designations 

The RMP will contain management to protect the historic values along the Old Spanish National Historic 

Trail. Potential management will be coordinated with NPS and other BLM offices through which the trail 

segments pass in order to standardize management. The RMP will also consider management of lands 

adjacent to National and State byways and backways. 

Social and Economic Features 

The BLM makes many decisions in an RMP that affect the social and economic environment. As such, 

issues to be addressed in the RMP include social and economic values. The impacts analysis will include 

the impact of alternative RMP decisions on the planning area’s social or economic environment. 

General Issues 

Some issues raised during scoping addressed more general categories related to the RMP. The RMP will 

consider management of different uses and geographic sub-regions through the use of various 

management tools such as livestock grazing, coal unsuitability criteria, oil and gas leasing stipulations, 

SRMAs, and ACECs. This will ultimately resemble a sort of management zoning, using the various 

management tools in concert with each other to achieve multiple-use alternatives across the landscape. 

The RMP will also use the best management practices developed across the BLM. 

Where appropriate, this RMP will address hazardous materials issues. The Kanab RMP will not allow 

unauthorized hazardous material generations, storage, disposal, or transport. RMP prescriptions will be in 

compliance with the Comprehensive Environmental Response, Compensation, and Liability Act and the 

Resource Conservation and Recovery Act. 

1.3.2 Issues Beyond the Scope of the Plan 

Some issues raised by the public are beyond the scope of this RMP and will not be considered in the EIS. 

The issues and concerns beyond the scope of the plan are summarized below and will not be analyzed 

further for the reasons stated. For more information on the issues raised during scoping but not addressed 

in the EIS alternatives, please see Chapter 4 of the Scoping Report. There are three justifications for 

removing these issues from consideration: 

1. The BLM does not have authority to resolve the issue raised. 

2. The issue is addressed through implementation/site-specific planning actions. 

3. The issue raised is resolved through law, regulation, Bureau policy, or administrative action. 

Justification 1 

The BLM cannot make RMP-level decisions to address issues for which the BLM does not have the 

authority to resolve the issue raised, such as wilderness, withdrawals, or wild and scenic river designation. 

The BLM is granted certain authorities through federal law, which are implemented by the CFR. Issues 

that fall under this justification are usually resolved through congressional or judicial action. 

The State of Utah and Kane and Garfield counties may hold valid existing rights-of-way in the planning 

area pursuant to Revised Statute (RS) 2477, Act of July 28 1866, chapter 262, 8, 14 Stat. 252, 253, 
Chapter 1 Proposed RMP and Final EIS 

1-14 Kanab RMP 

codified at 43 USC 932. On October 21, 1976, Congress repealed R.S. 2477 through passage of FLPMA. 

This RMP does not adjudicate, analyze, or otherwise determine the validity of claimed rights-of-way. 

However, nothing in the RMP extinguishes any valid right-of-way, or alters in any way the legal rights 

the state and counties have to assert and protect RS 2477 rights or to challenge in Federal court or other 

appropriate venue any use restrictions imposed by the RMP that they believe are inconsistent with their 

rights. 

Justification 2 

Another variety of issues commonly raised during scoping are those addressed through implementation 

and site-specific planning actions and therefore best resolved at the implementation level of planning. 

RMP decisions provide guidance for “future land management actions and subsequent site-specific 

implementation decisions. These LUP decisions establish goals and objectives for resource management 

(desired outcomes) and the measures needed to achieve these goals and objectives, expressed as actions 

and allowable uses (lands that are open or available for certain uses, including any applicable restrictions, 

and lands that are closed to certain uses)” (BLM-M-1601 Section II A). Some site-specific issues, such as 

the setting of allotment-specific livestock utilization levels, are not appropriate for the RMP level of 

decision-making. For example, adjustments to livestock use on an annual basis are dependent on seasonal 

fluctuations in precipitation, and require more flexibility to manage livestock in a manner that results in 

healthy range conditions. Similar issues concerning site-specific resource concerns and conflicts are best 

answered by site-specific decisions and associated NEPA analysis. A full list of these issues is available 

in Chapter 4 of the Scoping Report; the following are a few examples of issues addressed by this 

justification: 

• What livestock utilization levels should be appropriate? 

• What season of use for livestock grazing should be authorized? 

• How should OHV user education be implemented to reduce impact conflicts (including signage, 

mapping, rules, and trail rating system)? 

• How should recreation waste (trash in general and human waste) be managed? 

• How should vegetative treatments or other range improvements on private land (which affect use 

by wildlife and livestock) be addressed? 

• What management should be necessary to address the visual impacts of pinyon-juniper 

treatments? 

• How should funding be acquired and allocated to implement plan decisions? 

• How could the RMP include volunteer user groups in resource management? 

Justification 3 

The final type of issues is those non-discretionary actions that are required through law, regulation, BLM 

policy, or administrative action. These include actions that are implemented by the BLM as a standard 

operating procedure (SOP), because law or regulation requires it or because they are BLM policy. There 

are several issues raised in scoping that are clearly of concern to the public but which are governed by 

existing laws, regulations, or policy. In addition, NEPA regulations (40 CFR 1500) and the BLM NEPA 

Handbook (BLM-H-1790) contain directions on how to conduct impact analysis. Other issues like this 

include using certain information to make decisions, how to resolve trespasses, and how to involve the 

public more in the planning process. A full list of these issues is available in Chapter 4 of the Scoping 

Report; the following are a few examples of issues addressed by this justification: 

• Management of cultural resources that includes up-to-date inventories, non-disclosure of sensitive 

sites, proposed cultural sites for the National Register of Historic Places, and Native American 

consultation. 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-15 

• How should livestock grazing and range management differ during periods of environmental 

extremes (e.g., drought, floods, or fire)? 

• How long after wildland fire should livestock grazing be prohibited? 

• How would OHV trespasses be addressed? 

• How would the economic impacts of plan decisions be evaluated and displayed? 

• How would the RMP address SOPs, standards, guidelines, etc.? 

• How could the principles of adaptive management be integrated into the RMP? 

• How would private open space be protected (compensation)? 

1.4 PLANNING CRITERIA

BLM planning regulations (43 CFR 1610) require preparation of planning criteria to guide development 

of all plans. Planning criteria are the constraints or ground rules that guide and direct the development of 

the RMP, and they determine how the planning team approaches development of alternatives and 

ultimately selects the Preferred Alternative. Planning criteria ensure that plans are tailored to the 

identified issues and that unnecessary data collection and analyses are avoided. They focus on the 

decisions to be made in the plan and provide an early, tentative basis for inventory and data collection 

needs. Planning criteria used in this RMP process are: 

• This plan will recognize the existence of valid existing rights. 

• Lands addressed in the RMP will be public lands (including split estate lands) managed by the 

BLM. Decisions on lands not managed by the BLM will not be made in the RMP. 

• The BLM will use a collaborative and multi-jurisdictional approach, where possible, to jointly 

determine the desired future condition of public lands. 

• As described by law and policy, the BLM will strive to ensure that its decisions are as consistent 

as possible with other planning jurisdictions within the planning area boundary. 

• Management prescriptions will consider a range of alternatives that focus on the relative values of 

resources and ensure responsiveness to the issues and not the combination of uses that will give 

the greatest economic return or output. 

• Watersheds will be identified and watershed conditions determined for the Utah Interagency 

Colorado River Salinity Ranking Process (BLM, National Resource Conservation Service, U.S. 

Geological Survey, Bureau of Reclamation). 

• The BLM will use current scientific information, research, technologies, and results of inventory, 

monitoring, and coordination with appropriate local and regional agencies to determine 

appropriate local and regional management strategies that will enhance or restore impaired 

systems. 

• Direction provided by the 2001 Federal Wildland Fire Policy will be incorporated into the 

planning process. Planning will be consistent with the National Fire Plan. 

• Management of existing WSAs will be guided by the Interim Management Policy for Lands 

Under Wilderness Review (IMP). Land use allocations made for WSAs must be consistent with 

the IMP and with other laws, regulations, and policies related to WSA management. If areas are 

designated as wilderness by Congress, they will be managed to preserve their wilderness values 

according to applicable laws, regulations, and policy. 

• Rangeland health standards will apply to all activities and uses and will generally be evaluated on 

a watershed basis. Adjustments to current livestock grazing or wildlife forage allocations will be 

considered in accordance with the Standards for Rangeland Health and Guidelines for Grazing 

Management and will be applicable to all alternatives. 

• Baseline Reasonably Foreseeable Development scenarios will be developed and portrayed based 

on historical, existing, and projected future levels for all programs. 
Chapter 1 Proposed RMP and Final EIS 

1-16 Kanab RMP 

• The BLM will consult with Native American Tribes to identify sites, areas, and objects important 

to their cultural and religious heritage. 

• The decisions of this plan will comply with the ESA and follow interagency agreements with the 

USFWS regarding the Section 7 consultation process. 

• The decisions of this plan will comply with the Clean Water Act and follow Utah best 

management practices for ensuring water quality. 

• This planning effort will follow agency manuals, handbooks, and policy for management of 

visual resources in the planning area. 

• Management actions will be responsive to the issues, concerns, and opportunities identified for 

resolution in this plan. 

• Transportation planning will be addressed, including designation of OHV polygons (RMP-level 

decisions) and individual routes (implementation-level decisions). Decisions regarding OHV use 

will be consistent with BLM’s National OHV strategy. 

Public lands within the planning area are being impacted by the growing population in the west. This 

population growth (as well as its impacts on the public lands) will continue in the future. The RMP must 

be flexible enough to address this issue into the future. 

1.5 PLANNING PROCESS

FLPMA is the primary authority for the BLM’s management of public lands. As defined by the Act, 

public lands are those federally owned lands and any interest in lands (e.g., federally owned mineral 

estate) that are administered by the BLM. NEPA provides the basic national charter for environmental 

responsibility and requires the consideration and public availability of information regarding the 

environmental impacts of major federal actions significantly affecting the quality of the human 

environment. RMPs are considered a major federal action and require developing an accompanying EIS. 

In concert, these two laws provide the overarching guidance for administration of all BLM activities. The 

approved RMP will meet the BLM statutory requirement for a comprehensive LUP consistent with 

multiple-use and sustained-yield objectives (FLPMA section 202). 

In addition to the RMP providing management direction, the associated EIS can provide NEPA analysis 

to assist subsequent planning efforts. The “tiering” of NEPA documents is used to prepare new, more 

specific environmental documents without having to duplicate relevant parts of other previously prepared 

more general documents such as RMPs/EISs (BLM-H-1790). When this occurs, environmental 

documents associated with the more specific activity incorporate by reference the general discussions and 

analysis from the broader document (RMP/EIS), enabling the NEPA document for the specific activity to 

concentrate on the issues and impacts of the project that are not specifically covered in the broader 

document (BLM-H-1790). BLM decision-making relevant to land use planning includes the following: 

• Resource Management Plans. The BLM’s broadest, least specific level of decision-making for 

land and resource use is the RMP. The BLM uses RMPs to make land use allocations, provide 

general future management direction for managing specific areas of land, and provide the 

framework for management of all natural resources under BLM authority. Plan decisions are 

based on a public NEPA process, usually including the development of an EIS. 

• Activity Plans. These plans include more detailed management decisions than RMPs. Mid-level 

decisions are provided in activity plans, also known as implementation plans. Activity planning 

addresses management of specific programs and usually selects and applies best management 

practices (BMP) to meet the RMP goals. Decisions covering major (often geographically 

widespread) proposals lead to coordinated activity plans that cover all programs in an integrated 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-17 

manner. A program-oriented activity plan such as a habitat management plan is another example 

of an activity plan. Activity plans also must undergo a NEPA analysis. 

• Project-Level Decisions. At the project level, the BLM analyzes individual actions proposed in a 

specific location within the Field Office for indirect, direct, and cumulative effects, including sitespecific effects. Such an action or project must conform to the existing RMP for the BLM to 

approve it. 

The Kanab RMP will prescribe the allocation of and general future management direction for the 

resources and land uses of BLM-administered public lands in the planning area. The RMP/EIS is the 

foundation for an activity- or implementation-level decision as well as a project-level decision. 

The BLM RMP process consists of nine basic steps and requires the use of an interdisciplinary team for 

the completion of each step. The planning steps described in the regulations (43 CFR 1610.4) and used in 

preparing this plan are shown in Table 1-2. 
Chapter 1 Proposed RMP and Final EIS 

1-18 Kanab RMP 

Table 1-2. Steps in the BLM Land Use Planning Process 

Step 1* Identification of Issues 

This planning step is designed to identify major problems, concerns, or opportunities associated with 

the management of public land in the planning area. Issues are identified by the public, the BLM, and 

other governmental entities. The planning process is then focused on resolving the planning issues. 

Step 2* Development of Planning Criteria 

Planning criteria are identified to guide development of the RMP and prevent the collection of 

unnecessary information and data. 

Step 3 Collect And Compile Inventory Data 

This planning step involves the collation and collection of various kinds of environmental, social, 

economic, resource, and institutional data. In most cases, this process is limited to information needed 

to address the issues. The data required for land use planning decisions is usually at a broader scale 

than data required in implementation level planning and analyses. 

Step 4 Analysis of the Management Situation 

This step calls for the deliberate assessment of the current situation. It identifies the way lands and 

activities are currently managed in the planning area, describes conditions and trends across the 

planning area, identifies problems and concerns resulting from the current management, and identifies 

opportunities to manage these lands differently. It also forms the basis for the “No Action” alternative. 

Step 5 Formulate Alternatives 

During this step, BLM formulates a reasonable range of alternatives for managing resources in the 

planning area. Alternatives include a continuation of current management (no action) alternative and 

other alternatives that strive to resolve the major planning issues while emphasizing different 

management scenarios. Alternatives usually vary by the amounts of resource production or protection 

that would be allowed, or in the emphasis of one program area over another. 

Step 6 Estimation of Effects 

This step involves estimating the physical, biological, economic, and social effects of implementing 

each alternative in order to provide a comparative evaluation of impacts in compliance with CEQ 

regulations for implementing NEPA (40 CFR 1500). 

Step 7 Selection of Preferred Alternative 

Based on the information resulting from the estimation of effects, the BLM identifies a Preferred 

Alternative. The Draft RMP/EIS is then prepared for printing and distributed for a 90 day public review. 

Step 8* Selection of RMP 

Following review and analysis of public comments on the Draft RMP/EIS, BLM makes adjustments as 

warranted and selects a proposed RMP. The Proposed RMP and a Final EIS is then published. A final 

decision is made after a 60-day Governor’s Consistency Review and a 30-day public protest period 

are completed. BLM then publishes the Record of Decision (ROD) and prepares the Approved 

Resource Management Plan. 

Step 9** Monitoring And Evaluation 

This step involves the collection and analysis of resource condition and trend data to determine the 

effectiveness of the plan in resolving the identified issues and achieving desired results. 

Implementation of decisions requiring subsequent action is also monitored. Monitoring continues from 

the time the RMP is adopted until changing conditions require revision of the whole plan or any portion 

of it. 

* Public participation is invited throughout the planning process but is formally requested at these steps. 

** The RMP shall be revised as necessary based on monitoring and evaluation findings, new data, new or revised policy, and 

changes in circumstances affecting the entire plan or major portions of the plan. 

Five documents must be completed during preparation of the RMP to record the planning process: the 

Preplanning Analysis, the Analysis of the Management Situation (AMS), the Draft RMP/EIS, the 

Proposed RMP/Final EIS, and the Record of Decision (ROD) and Final RMP. A given document serves 

as a foundation for the subsequent one. 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-19 

The BLM monitors and evaluates the Final RMP, with formal review taking place every 5 years. Public 

reaction to the BLM’s land management can lead to revision of the RMP through these periodic reviews. 

Public concerns voiced through changes in law or agency policy also serve as a basis for planning 

decisions. 

1.5.1 Relationship to Other Plans, Policies, and Programs 

FLPMA Title II, Section 202, provides guidance for the BLM’s planning process to coordinate planning 

efforts with American Indian tribes, other federal agencies, and state and local governments. To 

accomplish this directive, the BLM has kept abreast of other federal, state, local plans, and tribal 

government plans; considered such plans in the development of the alternatives for the Draft RMP/EIS; 

and worked with these other entities to avoid inconsistencies among their various plans. FLPMA and the 

planning regulations require that BLM plans be consistent with other officially approved or adopted 

resource related plans of other federal, state, and local governments to the extent those plans are 

consistent with federal law and regulations applicable to the public lands. In keeping with the above 

mandates, the Kanab Field Office asked federal, state, and local agencies and tribal councils to review the 

Draft RMP/EIS and inform the BLM of any inconsistencies, and members of the planning team reviewed 

the following federal, state, and local plans: 

• Kane County, Utah, General Plan (1998 and amended 2007) 

• Garfield County, Utah, General Plan (1995 and amended 1998 and 2007) 

• Scenic Byway 12 Corridor Management Plan (2001) 

• State Comprehensive Outdoor Recreation Plan (2003) 

• Utah Comprehensive Wildlife Conservation Strategy (2005) 

• Coral Pink Sand Dunes State Park General Management Plan (2004) 

• Utah’s Water Resources: Planning for the Future, Utah Division of Water Resources (2001) 

• Utah State Law 63j-4-401 

• Zion National Park General Management Plan (2001) 

• Bryce Canyon National Park Fire Management Plan and Environmental Assessment/Assessment 

of Effects (2004) 

• Arizona Strip District Proposed Plan/Final EIS (2007)

• St. George Field Office Resource Management Plan (1999) 

• Grand Staircase–Escalante National Monument Management Plan (1999) 

• Arizona Statewide Wild and Scenic Rivers Legislative EIS (1994) 

• Endangered Species Recovery Plans and Conservation Agreements, including: 

– Mexican Spotted Owl Recovery Plan, 1995 

– Utah Prairie Dog Recovery Plan, 1991 

– Utah Prairie Dog Interim Conservation Strategy, 1997 

– Welsh’s Milkweed Recovery Plan, 1992 

– Siler Pincushion Cactus Recovery Plan, 1986 

– Conservation Agreement and Strategy for the Coral Pink Sand Dunes Tiger Beetle, March 31, 

1997

– Recovery Plan for the California Condor, 1996 

– Final Recovery Plan for the Southwestern Willow Flycatcher, 2002. 
Chapter 1 Proposed RMP and Final EIS 

1-20 Kanab RMP 

Energy Policy and Conservation Act (EPCA) 

In May 2001, the Bush administration's Comprehensive National Energy Policy was issued, which 

directed the Secretary of the Interior to: 

... examine land status and lease stipulation impediments to federal oil and gas leasing, 

and review and modify those where opportunities exist (consistent with the law, good 

environmental practice and balanced use of other resources). 

Under this directive, the Assistant Secretary of the Interior for Land and Minerals Management delivered 

to Congress an inventory of U.S. oil and gas resources in five western basins, as well as the extent and 

nature of any restrictions or impediments to their development. This report was prepared at the request of 

Congress under the provisions of the 2000 Energy Policy and Conservation Act (EPCA). 

In April 2003, the BLM specified four EPCA integration principles, as follows: 

• Environmental protection and energy production are both desirable and necessary objectives of 

sound land management practices and are not to be considered mutually exclusive priorities. 

• The BLM must ensure appropriate accessibility to energy resources necessary for the nation's 

security, while recognizing that special and unique non-energy resources can be preserved. 

• Sound planning will weigh the relative resource values, consistent with the multiple use and 

sustained yield mandates required by FLPMA. 

• All resource impacts, including those associated with energy development and transmission, will 

be mitigated to prevent unnecessary or undue degradation. 

Energy Policy Act of 2005 and the Western Energy Corridor Programmatic EIS 

Section 368 of the Energy Policy Act of 2005 (designation of West-wide energy corridors) is being 

implemented via the current development of an interagency, Programmatic EIS (PEIS). The Final PEIS 

could amend numerous RMPs in the western U.S., providing decisions that will address numerous energy 

corridor-related issues, including the utilization of existing corridors (with enhancements and upgrades), 

identification of new corridors, supply and demand considerations, and compatibility with other corridor 

and project planning efforts. 

Memorandum of Understanding Between U.S. Department Of The Interior, BLM 

and U.S Department of Agriculture, Forest Service 

The purpose of this Memorandum of Understanding (MOU) is to establish joint BLM and Forest Service 

policies and procedures for managing oil and gas leasing and operational activities pursuant to oil and gas 

leases on National Forest System (NFS) lands, consistent with applicable law and policy. The MOU was 

signed in 1991 for the purpose of efficient, effective compliance with statutory and regulatory 

requirements. The MOU establishes the roles of the Forest Service and the BLM in processing 

Applications for Permits to Drill and review of subsequent operations. 

1.5.2 Plan Monitoring, Maintenance, Amendment, Revision, and 

Implementation 

The BLM expects that new information gathered from field inventories, other agency studies, resource 

themes from shared interagency databanks, and other sources will change baseline data used to arrive at 

proposed land use decisions and resource allocations. To the extent such new information and actions 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-21 

bear on issues covered in the plan, the BLM will integrate the data through a process called plan 

maintenance or updating. Decisions would be made with the appropriate level of NEPA analysis along 

with any procedural and regulatory requirements for individual programs (40 CFR 1500–1508, BLM 

NEPA Handbook H-170-1, and 526 DM 1-7). 

When the BLM considers taking or approving actions that would not conform to the goals, objectives, or 

terms and conditions of this plan, the BLM would prepare a proposed plan amendment and environmental 

analysis to determine whether a plan amendment may be warranted. The land use planning process needs 

to be dynamic to respond to the numerous changes that inevitably will affect public lands. Amendments 

can be a necessary part of the planning process. Where changes are of a significant magnitude and affect a 

variety of resource programs, a full or partial plan revision will be considered and will be subject to 

further NEPA analysis. The BLM will review the RMP periodically after the ROD is approved to 

determine whether the plan remains effective in guiding BLM’s management of lands and resources. 

In implementing the plan, the BLM will focus its resources on the highest priority issues determined to 

have the greatest significance to the health of the public lands involved and the socioeconomic well-being 

of local communities. Other issues will be deferred until priority programs and projects are implemented 

and found to be effective in accomplishing their intended purpose. Factors that would be used in setting 

priorities include the following: 

• Legal and administrative mandates 

• The extent to which critical resources or opportunities may be lost if action is not quickly taken 

• Availability of committed partners willing to share in costs and administration 

• Consistency with priority plans and programs of local, state, and other federal agencies 

• Geographic areas that the BLM determines would receive the greatest return for the time and 

resources applied. 

For many actions proposed in this RMP, the BLM will prepare or collaborate in preparation of detailed, 

site-specific activity-level plans that define projects and examine site-specific impacts on affected 

resources. These plans will address specific resource issues in prescribed geographic areas and will be 

completed with appropriate public and agency participation and environmental analysis. Planning at this 

level will allow the BLM to focus on particular land management opportunities or problems needing 

resolution in a manner not possible in the broad overview provided in this RMP. To the extent practical, 

these plans will be integrated with the plans of other interested or affected agencies. 

1.6 SUMMARY OF CHANGES MADE BETWEEN THE DRAFT 

RMP/DRAFT EIS AND THE PROPOSED RMP/FINAL EIS 

As a result of public comments, cooperating agency coordination, and internal review of the Draft 

RMP/Draft EIS, the BLM has made several changes in this Proposed RMP/Final EIS. This section 

describes a summary of the changes and updates from the Draft RMP/Draft EIS. A full description and 

details of all of the changes are presented in Appendix 11. 

1.6.1 Summary of Changes To Decisions Between the Preferred 

Alternative (Draft EIS) and the Proposed RMP (Final EIS) 

The Proposed RMP basically mirrors the Preferred Alternative in the Draft RMP (Alternative B), with 

some slight modifications. The most notable changes to the Proposed RMP are the deletion of a wild and 

scenic river segment; the deletion of a SRMA, the addition of non-WSA lands with wilderness 
Chapter 1 Proposed RMP and Final EIS 

1-22 Kanab RMP 

characteristics; and the enlargement of the crucial mule deer and elk winter range habitat boundaries. 

Numerous other changes include corrections to GIS data errors, editorial and clarification language, 

elimination of duplication of management prescriptions, and resultant acreage changes to certain land use 

allocations due to the modifications described above. 

The Proposed RMP no longer carries forward the suitability recommendation for the East Fork Virgin 

River (segment 36-37) for only that portion tentatively classified as a recreation segment due to 

manageability concerns. The Parunuweap SRMA, which is totally within the Parunuweap WSA, is not 

being brought forward as an SRMA in the Proposed RMP. Five non-WSA areas with wilderness 

characteristics , totaling 27, 700 acres, are carried forward into the Proposed RMP and managed to 

protect, preserve, and maintain their wilderness characteristics. This resulted in acreage changes to 

numerous allocations portrayed in the Preferred Alternative of the Draft RMP because management 

actions attributed to those lands became more restrictive in the Proposed RMP. 

In August of 2005, the Utah Division of Wildlife Resources (UDWR) changed its wildlife habitat 

classification system. Prior to 2005, the UDWR classification system distinguished between “critical” 

habitat (an area that provides for biological and/or behavioral requisites necessary to sustain the existence 

and/or perpetuation of a wildlife population) and “high-value” (an area that provides for intensive use by 

the species). The UDWR has been criticized for using the term “critical”, as the same term refers to 

habitat Federally designated by the U.S. Fish and Wildlife Service as required by the Endangered Species 

Act (ESA). 

In previous BLM planning efforts, mitigation decisions (usually timing stipulations) for impacts to 

UDWR’s “critical” habitats have been integrated into the planning process. BLM rarely incorporated 

management decisions in its RMPs for “high-value” habitats. UDWR changed its classification system to 

include “critical” habitat with “high-value” habitat, in part to accommodate the limitations of having 

classifications that were of no practical value to land managers. The new term “crucial” habitat is defined 

by UDWR as “habitat on which the local population of a wildlife species depends for survival because 

there are no alternative ranges or habitats available. Crucial habitat is essential to the life-history 

requirements of a wildlife species. Degradation or loss of crucial habitat will lead to significant declines 

in the wildlife population in question.” 

Crucial habitat boundaries appear larger on the wildlife maps in this Proposed RMP because they are a 

combination of UDWR’s old “critical” habitat and “high-value” habitat, with some minor modifications. 

Timing stipulations for each of the species now apply to the whole crucial habitat area. It is important to 

note however, that the application of waivers, exceptions and modifications, as outlined in Appendix 3, 

will be taken into consideration and used where/when applicable for all surface disturbing activities in 

these areas. The range of alternatives in the Draft RMP/Draft EIS considered both of UDWR’s old 

classifications of critical and high value habitat. Minor boundary modifications have been made by 

UDWR prior to incorporating them into crucial habitat boundaries. Because this information was taken 

into consideration and analyzed in the Draft, these minor changes are not considered significant in terms 

of resource uses and/or analysis in this Proposed RMP, and therefore a supplement to this EIS is not 

necessary for this purpose. 

1.6.2 Summary of Changes Made Between the Draft EIS and the 

Final EIS 

The major change between the Draft EIS and the Final EIS, as a whole, is the focus of the Final EIS on 

the Proposed RMP and not the range of alternatives that was portrayed in the Draft EIS. The Final EIS 

has been prepared in an abbreviated format, and does not bring forth the alternatives from the Draft RMP 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-23 

in Chapter 2, nor does it re-analyze them in Chapter 4. Chapter 2 only presents the Proposed RMP with 

reference to the associated maps which are provided later in this document. All other components of a 

Final EIS, including the baseline Chapter 3 affected environment section and its associated maps, analysis 

of the Proposed RMP in Chapter 4, consultation and coordination efforts and the responses to public 

comment in Chapter 5, and all of the pertinent appendices and other requirements of an EIS are all 

included herein. 

Chapter 1 

This chapter has been slightly modified to focus on the Proposed RMP. Some new information has been 

added under the vegetation discussion to incorporate by reference to current national guidance. 

Chapter 2 

A summary of changes to Chapter 2 is presented in Section 1.6.1 above. 

Chapter 3 

The Air Quality section of Chapter 3 has been augmented to update baseline information on ambient air 

quality, visibility, atmospheric deposition, and global climate change. Some clarification and new 

information on the salt loading in the Upper Colorado River Basin has been added, along with a revised 

table on Hydrologic Unit Codes, Watersheds, and Drainage Basins. Additional information has been 

added to the Surface Water Quantity and Quality section. 

In the Threatened and Endangered Species section, the bald eagle has been deleted from the list and from 

discussion because it has been delisted by the USFWS. However, the species and discussion has been 

added to the Special Status Species section. In addition, some information has been added concerning 

specific species into the wildlife and fisheries sections for clarification purposes. 

In the Cultural resources section, a statement has been included to inform the reader that no cultural sites 

were found as a result of a Class II inventory of the Coral Pink Sand Dunes. The Visual Resources section 

has added language from the secretarial decision that recognizes the scenic values and protection of Bryce 

Canyon National Park. 

New language has been added to provide baseline information on SITLA lands that are intermixed 

throughout the BLM lands within the Field Office, and the Cotter Decision which mandates appropriate 

access to those lands for economic purposes. In addition, the socio-economic baseline information has 

been revised to clarify the social and economic conditions in the planning area. 

Chapter 4 

Chapter 4 has been rewritten to provide analysis on decisions portrayed for the Proposed RMP in Chapter 

2. Reference to other alternatives for comparative purposes has been removed so that the analysis can 

stand on its own. Additional analysis has been added to the socioeconomic section to analyze impacts to 

the Kaibab-Piute Tribe as it relates to environmental justice. Analysis of the impacts to SITLA lands has 

also been included. 

Chapter 5 

Some of the basic information on public involvement from the Draft RMP/EIS is still included in Chapter 

5, however it has been greatly expanded due to the 90-day public review and comment process that was 
Chapter 1 Proposed RMP and Final EIS 

1-24 Kanab RMP 

afforded beginning in October, 2007. This chapter describes that public process, explains how comments 

on the Draft RMP/Draft EIS were extracted, and responds to those comments. It also refers to a CD that is 

attached to this PRMP/FEIS that has additional public comments that required responses. 

Glossary 

Some additions to the Glossary have been included to define certain terms in the PRMP/FEIS. 

References 

New references have been added for the air quality and vegetation information that has been augmented 

in the PRMP/FEIS. 

Appendices 

The appendices have been “renumbered” – going from letters (A – M) in the Draft to numbers in the 

PRMP/FEIS (1 – 16). New appendices include results from a Socio-Economic Public Land Survey 

(Appendix 10), the detailed changes between the Draft RMP/Draft EIS and the PRMP/FEIS (Appendix 

11), and a copy of a letter from the Utah Division of Air Quality (Appendix 12). Appendix 3, which 

describes Oil and Gas Leasing Stipulations, has had numerous corrections and minor modifications. 

Maps 

Minor mapping errors have been corrected based on updated GIS information. 

As summarized above, BLM has made numerous changes between the Draft RMP/EIS and Proposed 

RMP/Final EIS. They are detailed in Appendix 11. BLM has prepared this Appendix to document if 

changes between the Draft RMP/EIS and the Proposed RMP/Final EIS resulted in a significant change in 

circumstances or conditions, or if the Proposed RMP/Final EIS contains different information from that 

which was presented to the public in the Draft RMP/EIS. Finally, BLM wanted to confirm that all 

changes made to the Proposed RMP/Final EIS fall within the range of alternatives presented and analyzed 

in the Draft RMP/EIS. 

The regulation controlling whether or not a supplement is required is found at 40 CFR 1502.9(c), which 

provides: 

Agencies: 

Shall prepare supplements to either draft or final environmental impact statements if: 

• The agency makes substantial changes in the proposed action that are relevant to 

environmental concerns; or 

• There are significant new circumstances or information relevant to 

environmental concerns and bearing on the proposed action or its impact. 

• May also prepare supplements when the agency determines that the purposes of 

the Act will be furthered by doing so. 

• Shall adopt procedures for introducing a supplement into its formal 

administrative record, if such a record exists. 

• Shall prepare, circulate, and file a supplement to a statement in the same fashion 

(exclusive of scoping) as a draft and final statement unless alternative 

procedures are approved by the Council. 
Proposed RMP and Final EIS Chapter 1 

Kanab RMP 1-25 

All changes to the Kanab Field Office Draft RMP/EIS were made in response to public comment and/or 

internal review. The majority of the changes were editorial changes made to add clarity to the document. 

In some cases, alternatives presented in the Draft RMP/EIS were modified in the Proposed RMP to reflect 

technical corrections and data updates. In other cases, such as in Chapter 3, incorporation of updated 

information was necessary to refine the analysis in Chapter 4 that was incomplete or needed 

augmentation. 

None of the changes described above and further detailed in Appendix 11 meet the regulatory definition 

for significance in 40 CFR 1508.27(a) and (b). These regulations require an agency preparing a NEPA 

document to review the changes for significant new circumstances or information relevant to 

environmental concerns and bearing on the Proposed RMP or its impacts, using context and intensity as 

the trigger for significance. The BLM has reviewed each substantive change through this regulatory 

standard and has determined that none of the changes, individually or collectively, require a supplement 

to this Final EIS.
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1-26 Kanab RMP 

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Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-1 

CHAPTER 2—PROPOSED KANAB RESOURCE 

MANAGEMENT PLAN 

The Bureau of Land Management (BLM) has the discretion to select the Proposed Resource Management 

Plan (RMP) by combining components of the various alternatives presented in the Draft 

RMP/Environmental Impact Statement (EIS). The selection of the Proposed RMP is based on public 

comments, BLM review, and providing the best means to accommodate the widest range of public and 

agency concerns over resources and resource uses. This chapter describes the Proposed RMP. It should be 

noted that while most of these management actions are RMP level, this Proposed RMP also identifies 

designation of individual travel routes, which are an implementation-level decision that can change over 

the life of the plan without amending the RMP (Appendix 7). 

Planning decisions establish desired outcomes and actions needed to achieve them. Decisions are reached 

using the planning process in 43 CFR 1600. When they are presented to the public as proposed decisions, 

they can be protested to the BLM Director. They are not appealable to the Interior Board of Land Appeals 

(from BLM Land Use Planning Handbook, H-1601-1). Implementation decisions are decisions that take 

action to implement land use plan (LUP) decisions and are generally appealable to the Interior Board of 

Land Appeals under 43 CFR 4.410 (from BLM Land Use Planning Handbook, H-1601-1). 

Implementation-level decisions are italicized and marked with an asterisk. 

BLM has prepared this Proposed RMP/Final EIS in order to respond to public comment and cooperative 

agency review of the Draft RMP/EIS. The Proposed RMP is based on Alternative B of the Draft 

RMP/EIS, and has been modified by public comments, BLM review, and providing the best means to 

accommodate the widest range of public and agency concerns over resources and resource uses. The 

changes from the Preferred Alternative (Alternative B in the Draft RMP/EIS) to the Proposed RMP have 

been shaded gray. 

2.1 DESCRIPTION OF THE PROPOSED RMP 

This section provides a brief description of the Proposed RMP. The Proposed RMP provides 

opportunities to use and develop resources within the decision area while ensuring resource protection. 

The Proposed RMP would provide for continued access to and development of resources with stipulations 

and mitigation to protect natural and cultural resources. Key resource decisions on public lands within the 

decision area include the following: 

• Oil and gas leasing: 

– 17 percent (95,400 acres) open to oil and gas leasing subject to the standard terms and 

conditions of the lease form 

– 54 percent (296,200 acres) open to oil and gas leasing subject to moderate constraints (timing 

limitations, controlled surface use [CSU], lease notices) 

– 15 percent (83,400 acres) open to oil and gas leasing subject to major constraints (no surface 

occupancy [NSO]) 

– 14 percent (79,000 acres) closed to leasing. 

• Limit vegetation treatments (e.g., wildlife habitat, watershed, and livestock rangeland treatments; 

wildland fires; fuels treatments; and stewardship contracting) to an annual average of no more 

than 22,300 acres. Manage sagebrush steppe communities to restore natural disturbance processes 

with an appropriate pinyon-juniper component for a given ecological site. Manage ponderosa 
Chapter 2 Proposed RMP and Final EIS 

2-2 Kanab RMP 

pine stands to restore natural disturbance processes through treatments, resulting in 

predominantly park-like stands. 

• Close the Water Canyon Allotment to livestock grazing (48 animal unit months [AUM]) in order 

to protect the Fredonia City Culinary water supply for the life of the plan. In order to have the 

RMP accurately reflect current management, combine the Lydia’s Canyon Allotment with the 

Lydia Allotment, and combine the Sawmill Allotment with the South Canyon Allotment. The 

BLM would not be party to or accept any contingencies or conditions associated with a 

relinquishment that would require future BLM actions. 

• Apply protective management to river corridors associated with seven suitable river segments 

along 4,570 acres (25 miles) tentatively classified as “wild” and 960 acres (5 miles) tentatively 

classified as “scenic.” 

• Designate and manage the potential Cottonwood Canyon Area of Critical Environmental Concern 

(ACEC) (3,800 acres) as an ACEC; designate no additional areas as an ACEC. 

• Identify six Special Resource Management Areas (SRMA) with nine recreation management 

zones (RMZ) (95,100 acres): 

– Manage two RMZs specifically for motorized uses (19,500 acres) 

– Manage five SRMAs/RMZs specifically for non-motorized uses (38,800 acres) 

– Manage two SRMAs/RMZs for both motorized and non-motorized uses (36,800 acres). 

• Manage off-highway vehicle (OHV) use according to open, closed, or limited (seasonally and/or 

spatially) area and “route designations” as follows: 

– Approximately 1,000 acres open to cross-country OHV use 

– 25,000 acres closed to OHV use 

– 528,000 acres of limited OHV use, with 1,403 miles of “designated routes,” 2 miles of routes 

closed seasonally, and 75 miles of closed routes. 

• Manage visual resources to preserve the existing character of the landscape (Visual Resource 

Management [VRM] Class I) in the portions of the Paria Canyon–Vermilion Cliffs Wilderness 

Area in the decision area, all the Wilderness Study Areas (WSA), and river corridors associated 

with “wild” suitable segments. VRM classes and acreages include the following: 

– VRM Class I: 76,000 acres 

– VRM Class II: 94,400 acres 

– VRM Class III: 210,700 acres 

– VRM Class IV: 172,900 acres. 

• Manage the following non-WSA lands with wilderness characteristics specifically to maintain 

their wilderness characteristics (27,770 acres): East of Bryce, Moquith Mountain, Orderville 

Canyon, Parunuweap Canyon, and Upper Kanab Creek. 

2.2 MANAGEMENT ACTIONS

This section lists the RMP goals developed by the BLM with input from cooperating agencies and the 

public. This section also identifies the objectives and describes management decisions applicable to the 

decision area. Decisions are organized by resources, resource uses, and special designations. 

RMP Goals 

• Manage public lands for multiple uses of public resources within the framework of applicable 

laws, regulations, and agency policies. 

• Use adaptive management to meet resource objectives. 

• Apply rangeland standards and guidelines to the decision area. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-3 

• Implement ecosystem management in an open, cooperative, responsive atmosphere to involve 

agencies, groups, and individuals in monitoring and addressing resource issues on public lands—

issues that often span administrative and ownership boundaries. 

• Maintain, improve, and restore (where needed) healthy ecosystems and habitat to support viable 

populations of fish, plants, and wildlife species while reducing habitat loss and fragmentation. 

• Protect and enhance cultural and natural resources and values using the diversity of tools 

available to the BLM. 

• Provide a variety of recreational, educational, and interpretive opportunities for people to 

experience public land resources and values. 

• Reduce conflicts between uses and user groups. 

• Recognize the unique cultural, historical, and social values of the decision area in developing a 

plan that manages the land and protects the heritage it engenders. 

2.2.1 Resources 

Air Quality 

Goals and Objectives 

• Maintain air quality in accordance with standards prescribed by federal and state laws and 

regulations.

Management Actions 

Air Quality 

Manage air quality in accordance with the air quality standards prescribed by federal, state, and local 

laws, regulations, and policies including the following: 

• Applicable National Ambient Air Quality Standards 

• Applicable National Emission Standards for Hazardous Air Pollutants 

• State or tribal implementation plans 

• Prevention of Significant Deterioration (PSD), if applicable 

• Conformity analyses and determinations 

• Regional haze regulations, including visibility impacts on mandatory federal Class I areas 

• Utah Smoke Management Plan. 

Comply with the Clean Air Act through the application of the National Environmental Policy Act 

(NEPA) process on a case-by-case basis. 

Comply with Utah Administrative Code Regulation R307-205, which prohibits the use, maintenance, or 

construction of roadways in disturbed areas without taking appropriate dust abatement measures. 

Compliance would be obtained through site-specific stipulations identified on a case-by-case basis for 

new projects and through the use of dust abatement control techniques in problem areas. 

Mitigate actions that compromise ambient air quality standards or visibility within the Class I air areas. 

BLM will continue to work cooperatively with state, federal, and tribal entities in developing air quality 

assessment protocols to address cumulative impacts and regional air quality issues. 

BLM will continue to work cooperatively with the Utah Airshed Group to manage emissions from 

wildland and prescribed fire activities. 
Chapter 2 Proposed RMP and Final EIS 

2-4 Kanab RMP 

National Ambient Air Quality Standards are enforced by the Utah Department of Environmental Quality, 

Division of Air Quality, with Environmental Protection Agency (EPA) oversight. Special requirements to 

reduce potential air quality impacts will be considered on a case-by-case basis in processing land use 

authorizations. 

BLM will utilize BMPs and site specific mitigation measures, when appropriate, based on site specific 

conditions, to reduce emissions and enhance air quality. Examples of these types of measures can be 

found in the Four Corners Air Quality Task Force Report of Mitigation Options, November 1, 2007. 

Project specific analyses will consider use of quantitative air quality analysis methods (i.e. modeling), 

when appropriate as determined by BLM, in consultation with state, federal, and tribal entities. 

Soil Resources 

Goals and Objectives 

• Maintain and/or restore overall watershed health and reduce erosion, stream sedimentation, and 

salinization of water, with particular emphasis on the Colorado River System. 

• Soils would exhibit infiltration, permeability, and erosion rates appropriate for the soil type, 

climate, and landform. 

• Maintain and restore areas of biological soil crust appropriate for the soil type, climate, and 

landform. 

• Maintain or enhance soil stability, productivity, and infiltration to prevent accelerated erosion and 

to provide for optimal plant growth and the site’s potential. 

Management Actions 

Maintaining Soil Resources 

Implement BMPs designed to minimize impacts on soils from ground disturbing activities, as appropriate 

(Appendix 1). 

Reduce soil loss on watersheds by performing appropriate land treatments (Map 5). 

Land treatments would be prioritized in the following fifth-field watersheds: 

• Upper Sevier River Watershed: 

– Pass Creek/Sevier River 

– City Creek/Sevier River 

– Bear Creek/Sevier River 

• Upper Virgin River/Kanab Creek Watersheds: 

– Muddy Creek 

– Upper Kanab Creek 

– Skutumpah/Mill Creek. 

Initiate reclamation of surface disturbances, where appropriate, during or upon completion of the 

authorized project. 

Close and reclaim temporary roads upon completion of the project that required the roads. 

Remove and reclaim facilities or improvements no longer necessary or desirable, provided no historic 

properties are affected. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-5 

Sensitive/Fragile Soils 

Identify areas of “fragile soils” during preparation of project-level plans, as well as necessary mitigation 

measures to minimize risks and degradation. 

Develop and implement site-specific restrictions and/or mitigations for activities proposed in fragile soil 

areas on a case-by-case basis. Surface disturbing activities must be approved by the BLM before 

construction and maintenance is authorized. 

Allow surface disturbance in fragile soil areas as long as impacts would be mitigated or disturbance 

would be beneficial to rangeland health. 

Preclude cross-country OHV use in areas identified as fragile soils to minimize soil loss and salinity of 

water runoff. 

Allow land treatments (i.e., vegetation treatment and soil stabilization) in fragile soil areas where such 

treatment would reduce erosion and restore watersheds. 

Manage land uses according to the Standards for Rangeland Health to maintain or improve soil 

conditions. 

Incorporate BMPs and soil protection measures into developments on sensitive soils. Measures to 

stabilize soils and minimize surface water runoff would be required for slopes greater than 15 percent, 

both during project activities and following project completion. 

Water Resources 

Goals and Objectives 

• Maintain and/or restore natural hydrologic functions of watersheds, including the capability to 

capture, store, and beneficially release water. 

• Reduce flood-related damage to infrastructure and downstream private lands. 

• Improve watershed conditions on eroding sites and on other sensitive watershed areas, such as 

riparian areas. 

• Maintain and improve water quality to meet state standards for water quality in order to protect 

established beneficial uses. 

Management Actions 

Management of Water Quality and Watershed Health 

Monitor water quality in coordination with the State Division of Water Quality to determine if progress 

toward meeting water quality standards and watershed objectives is being achieved. 

Monitor the management activities to determine if progress toward meeting watershed objectives is being 

achieved. Make appropriate adjustments where and when necessary to ensure progress toward meeting 

watershed objectives. 

Implement BMPs designed to protect water quality for all ground disturbing activities (Appendix 1). 

Provide for the improvement and protection of water quality of the culinary water supply for Fredonia, 

Arizona, by limiting livestock grazing and OHV use above the legally approved water collection points 

for the city in Cottonwood and South Fork Indian Canyons. 
Chapter 2 Proposed RMP and Final EIS 

2-6 Kanab RMP 

Identify public water systems with surface water or groundwater sources (i.e., delineated drinking water 

source protection zones) that may be affected by BLM-authorized activities. Ensure that BLM-authorized 

activities do not pose a threat to public water systems. 

Coordinate with local, state, tribal, and federal authorities on water- and riparian-related issues. 

Implement BMPs designed to improve vegetation cover and reduce soil erosion for surface disturbing 

activities, especially with regard to sources of saline sediments in the Colorado River Basin (Appendix 1). 

Coordinate with the Virgin River Management Plan Watershed Advisory Committee (and other 

applicable committees for other Colorado River tributaries) to reduce salinity. 

Improve watershed health by performing appropriate land treatments (Map 5). 

Land treatments would be prioritized in the following fifth-field watersheds: 

• Upper Sevier River Watershed: 

– Pass Creek/Sevier River 

– City Creek/Sevier River 

– Bear Creek/Sevier River 

• Upper Virgin River/Kanab Creek Watersheds: 

– Muddy Creek 

– Upper Kanab Creek 

– Skutumpah/Mill Creek. 

Continue to cooperatively implement the Upper Sevier River Watershed Management Plan with the 

Upper Sevier Watershed Committee. 

Manage the Sevier River in accordance with the total maximum daily load (TMDL) and Upper Sevier 

River Watershed Management Plan. 

Avoid or minimize impacts on water quality through the application of specific mitigation measures 

identified in activity-level plans. 

Manage oil and gas leasing as open to leasing subject to moderate constraints to protect culinary water 

supply as directed by the Land Use Agreement for Kanab City Existing Wells in the following sections: 

• T 42 S R 6 W Sections 19, 31 

• T 42 S R 7 W Sections 23, 24, 25, 26, 27, 34, 35. 

In these areas (1) oil and gas well placement would be relocated to eliminate potential contamination 

sources or pollution sources, and/or (2) design standards would be implemented to prevent contaminated 

discharges to groundwater. 

Management of Water to Meet Resource Management Objectives 

Cooperate with the State Division of Water Rights and apply for state water rights to meet resource 

objectives, as necessary. 

Water Resources and Discharge of Produced Waters from Energy Development Activities 

Cooperate with the Utah Division of Water Quality; Utah Division of Oil, Gas, and Mining; and affected 

water users to address permitting requirements for any proposed treatment, surface discharge, or 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-7 

underground injection of water produced during mineral exploration and production (Utah Administrative 

Rule R649-5, Underground Injection Control of Recovery Operations and Class II Injection Wells). 

Apply coalbed natural gas BMPs to preserve groundwater quality (Appendix 1). 

Encourage treatment (as needed) and onsite or offsite beneficial use of produced water, so long as that 

water is of adequate quality and the rate of use does not cause adverse impacts on other resources. If 

treatment of produced water is not practical, require reinjection or offsite disposal. 

Do not allow surface discharge of produced water in the Colorado River Basin. 

Vegetation 

Goals and Objectives 

• A mosaic of non-invasive perennial and annual vegetation communities would be present across 

the landscape with diversity of species, canopy, density, and age class in accordance with 

ecological site potential. 

• Protect, enhance, and/or restore ecological processes and functions by allowing tools that are 

necessary and appropriate to mitigate adverse impacts of allowable uses and undesirable 

disturbances and which contribute to meeting the Utah BLM Standards for Rangeland Health. 

• Sustain or reestablish the integrity of the sagebrush communities to provide the quantity, 

continuity, and quality of habitat necessary to maintain sustainable populations of Greater sagegrouse and other sagebrush obligate species. 

• Manage rangelands to prevent net loss of properly functioning sagebrush steppe habitat. 

• Contain or reduce invasive plant species from existing extent; prevent establishment of new 

invasive species through early detection and rapid response actions. 

• Restore native species to meet desired plant community objectives where appropriate. 

• Maintain health of ponderosa pine stands within the decision area. 

• Maintain and/or restore riparian areas to proper functioning condition, or to making significant 

progress toward proper functioning condition, where BLM-managed or -authorized activities 

have been identified as contributing to riparian impairment. 

• Ensure water availability for multiple-use management and functioning, healthy riparian and 

upland systems. 

Management Actions 

General Vegetation 

Apply Standards for Rangeland Health to all rangelands. 

Apply Guidelines for Grazing Management on BLM Lands in Utah (BLM 1997a) and Guidelines for 

Recreation Management for Public Lands in Utah (BLM no date) for maintenance and rehabilitation of 

rangelands. 

Rehabilitation target would be to manage for 51 percent or higher of Potential Natural Community (PNC) 

unless site-specific management objectives for other resources dictate otherwise (e.g., special status 

species adapted to 0 percent to 25 percent of PNC). 

Identify, maintain, and restore forest and woodland old-growth stands to a pre-fire suppression condition. 

Adopt the U.S. Forest Service (USFS) old-growth definitions and identification standards as per the 

USFS document Characteristics of Old-Growth Forests in the Intermountain Region (Hamilton 1993). In 
Chapter 2 Proposed RMP and Final EIS 

2-8 Kanab RMP 

instances where the area of application in the previous document does not apply (for example, Pinus 

edulis), use the document Recommended Old-Growth Definitions and Descriptions, USDA Forest Service 

Southwestern Region (USFS 1992). 

Management of Riparian Areas 

Maintain and/or enhance riparian areas (Utah Riparian Management Policy 2005) through project design 

features and/or stipulations that protect riparian resources. 

Consult with water rights holders when rights-of-way (ROW) are renewed or amended to determine if 

water necessary to prevent riparian and aquatic degradation could be left in-stream through design or 

operation stipulations. 

Analyze proposed new or amended ROWs for water diversions to determine the amount of water that 

must be retained to prevent riparian and aquatic degradation. Incorporate design and operation 

stipulations as necessary to protect riparian and aquatic resources. 

Monitor riparian conditions, as needed, for any surface disturbing activity that could affect riparian areas. 

Retain riparian areas in the public ownership unless it can be clearly demonstrated that specific sites 

cannot be managed in an effective manner by the BLM or through agreements. Exchanges involving 

public land containing riparian areas would generally not be allowed unless it could be shown that parcels 

containing superior public values are being acquired or that existing riparian areas would be enhanced. 

Prioritize monitoring in functioning at-risk and then non-functioning riparian areas. Additional 

monitoring would occur on an as-needed basis (e.g., to assess impacts of specific projects or to establish 

reference conditions). 

Prioritize rehabilitation efforts and management adjustments in functioning at-risk and then nonfunctioning riparian areas where livestock grazing has been determined to be a significant contributing 

factor. As opportunities arise (e.g., cooperative proposals), actions would also be taken to initiate 

recovery and rehabilitation within the site’s potential in non-functioning riparian areas. 

Emphasize management of uses rather than structural efforts when rehabilitating degraded riparian areas. 

As necessary and appropriate (indicated by monitoring results and interdisciplinary analysis), livestock 

numbers, seasons of use, and grazing systems would be modified when necessary to meet riparian 

objectives. 

Existing and new water developments would be maintained and/or managed to reduce detrimental 

impacts on riparian areas (i.e., dewatering) and to change grazing management within riparian areas when 

grazing has been identified as a significant contributing factor. 

Fencing, erosion control structures, and vegetation treatments would each be an option where changes in 

use would not meet management objectives within the desired time frame. 

Do not allow new surface disturbing activities within 330 feet of riparian/wetland areas unless it could be 

shown that (1) there are no practical alternatives, (2) all long-term impacts could be fully mitigated, or (3) 

the activity would benefit and enhance the riparian area. 

Maintain sufficient water, to the extent possible, to sustain native flora and fauna when 

developing/redeveloping springs. Return unused or overflow water to its original drainage. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-9 

Plant and Seed Collection 

Permit commercial seed collection. Areas and species available for commercial collection would be 

determined on a case-by-case basis as climatic conditions allow, in accordance with statewide guidance 

and policy. 

Allow vegetation materials use (excluding seed collection, which is addressed above; pine nut harvest; 

and forest and woodland products) and collection in specified areas identified by permit on a case-by-case 

basis as climatic conditions allow. 

Allow the collection/harvesting of vegetative materials in riparian areas in proper functioning condition 

on a case-by-case basis as climatic conditions allow. 

Allow Native American non-commercial traditional use of vegetation products for the collection of herbs, 

medicines, traditional use items, or items necessary for traditional, religious, or ceremonial purposes, 

through permits. 

Noxious Weeds and Invasive Species 

Implement noxious weed and invasive species control actions as per national guidance and local weed 

management plans in cooperation with state and federal agencies, affected counties, adjoining private 

land owners, and other interests directly affected. 

Apply approved weed control methods to all invasive species in an integrated weed management program 

(including preventive management; education; and mechanical, biological, wildland or prescribed fire, 

and chemical techniques). 

Use minimum tool analysis (in designated wilderness) or the non-impairment standard (in WSAs) to 

identify vegetation treatment methods and approved herbicides to treat invasive plants such as tamarisk 

and Russian olive for the purpose of restoring ecological conditions and functions. 

Require certified weed-free feed for all stock to limit the introduction and spread of noxious weeds and 

other undesirable species. 

Relict Plant Communities and Hanging Gardens 

Manage relict plant communities and hanging gardens to maintain and enhance the biological diversity 

and health of these areas. 

Restrict surface occupancy (NSO) for surface disturbing activities to protect relict vegetation at Diana’s 

Throne and Elephant Butte. 

Recommend Diana’s Throne and Elephant Butte for withdrawal from mineral entry. 

Protect hanging gardens by implementing the no surface disturbance actions identified in the Riparian 

section of this chapter. 

Sagebrush Steppe 

Treat sagebrush steppe communities to restore natural disturbance processes and a healthy, diverse 

mosaic of different height and age structures with components of native grasses and forbs and an 

appropriate pinyon-juniper component for a given ecological site. Mosaics may include stands of young 

and old sagebrush, openings (ranging from bare ground to short or sparse vegetation to high-density 
Chapter 2 Proposed RMP and Final EIS 

2-10 Kanab RMP 

grasslands), wet meadows, seeps, healthy streamside (riparian) vegetation, and other interspersed shrub 

and woodland habitats. 

Follow the Connelly guidelines (Connelly et al. 2000) for vegetation treatment prescriptions for projects 

occurring in occupied and/or historic Greater sage-grouse habitat. Adjust and/or modify these guidelines 

with cooperators (e.g., Utah Division of Wildlife Resources [UDWR], local sage-grouse working group, 

and Utah Partners for Conservation and Development, as necessary, within the range of variability 

described in the appropriate ecological site description. 

Vegetation Restoration Treatments 

Limit acres of vegetation treatments (e.g., wildlife habitat treatments, watershed treatments, livestock 

rangeland treatments, wildland fire use, fuels treatments, and stewardship contracting) to an annual 

average of no more than 22,300 acres (446,000 acres over the life of the plan). 

Use the full range of upland vegetation treatment methods and tools (i.e., prescribed fire, mechanical, 

chemical, biological, woodland product removal, and wildland fire use). 

Vegetation treatments may be authorized where protection of sensitive resources would be ensured. 

Focus restoration or vegetation treatment projects based on the following factors: 

• Restore areas functioning at less than 51 percent of PNC 

• Restore areas with noxious weed and/or non-native invasive plants 

• Maintain previously treated areas 

• Achieve other objectives identified in this RMP 

• Restore special status species habitats to achieve long-term conservation and recovery objectives 

• Achieve rangeland health objectives. 

Manage areas with ponderosa pine to maintain the stand health through use of stand health exams, 

vegetation treatments, wildland fire, and prescriptions on permitted activities on a case-by-case basis. 

Manage stands to be predominantly park like, resilient to low-intensity fire, and have normally expected 

levels of mortality. 

Focus treatment objectives in ponderosa pine vegetation communities on restoring natural disturbance 

processes such as fire; increasing vegetative ground cover of native grasses, forbs, and shrubs; and 

removing invasive, non-native species. 

Special Status Species (Threatened, Endangered, and Sensitive) 

Goals and Objectives 

• Maintain, protect, and recover habitats of federally listed threatened, endangered, or candidate 

plant, animal, or fish species, and actively promote recovery to the point that provisions of the 

Endangered Species Act (ESA) are no longer required. 

• Maintain, protect, and enhance habitats of the latest Utah BLM State Director’s sensitive plant 

and animal species list to ensure that BLM-authorized or approved actions are consistent with the 

conservation needs of the species and do not contribute to the need to list any species under the 

ESA. 

• Cooperate with the U.S. Fish and Wildlife Service (USFWS) and other agencies, such as UDWR, 

in managing special status species and their habitat. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-11 

• Allow, initiate, and/or participate in scientific research of listed and sensitive species and their 

habitats. 

• To the maximum extent possible, maintain habitat connectivity and avoid habitat fragmentation 

for special status plant and animal species. 

• Develop and implement conservation measures to minimize long-term habitat fragmentation 

through avoidance and site-specific reclamation in order to provide the habitat quality and 

quantity to meet ecological requirements and support a natural diversity of species. 

Management Actions 

Special Status Species Conservation and Habitat Enhancement 

Implement Recovery Plan, Conservation Agreement, and Strategy decisions to increase populations and 

improve habitat of special status species, including federally listed species, by enhancing, protecting, and 

restoring occupied and potential habitat. 

Collaborate with the appropriate local, state, and federal agencies to promote public education on species 

at risk, their importance to the human and biological community, and reasons for protective measures that 

would be applied to the lands involved. 

Develop and implement monitoring and conservation measures for listed and non-listed special status 

species and their habitats where land use and human disturbances have been identified as having potential 

for adverse impacts. 

Incorporate USFWS references for listed species, designated critical habitat, down-listed or de-listed 

species, and non-listed special status species into management actions authorized within the decision area. 

Work with the UDWR to implement the Utah Comprehensive Wildlife Conservation Strategy (UDWR 

2005a) to coordinate management actions that would conserve native species and prevent the need for 

additional listings (WO IM 2006-114). 

Apply lease notices and conservation measures (Appendix 9) to leases and other applicable activities 

occurring in special status species habitat. 

Avoid, control, or regulate surface disturbing and disruptive activities on a case-by-case basis to minimize 

impacts on identified crucial habitat for sensitive species for the purpose of protecting these species and 

their associated habitats. 

Should special status species be found, temporarily stop surface disturbing and disruptive activities until 

species-specific protective and/or mitigative measures are developed and implemented, in consultation 

with USFWS and/or UDWR when applicable. 

Apply BMPs to avoid or reduce fragmenting habitat, including: 

• Collocating communication and other facilities 

• Employing directional drilling for oil and gas 

• Using topographic and vegetative screening to reduce the influence of intrusions. 

The BLM will approach compensatory mitigation on an “as appropriate” basis where it can be performed 

on site, and on a voluntary basis where it is performed offsite, or in accordance with current guidance. 
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2-12 Kanab RMP 

Bald Eagles and Other Special Status Raptor Species

Implement conservation measures (Appendix 9) on actions affecting bald eagles or their habitat. 

Do not authorize future ground disturbing activities within 1⁄2 mile of active bald eagle nest sites yearround. Deviations may be made only after appropriate levels of consultation and coordination with 

USFWS. 

Manage stands of ponderosa pine for winter roosting sites for bald eagles and nesting sites for other 

raptors (see Vegetation section for specific management). 

Use BMPs (Appendix 2) to implement raptor guidelines established by USFWS. 

Work with UDWR to identify locations for all known special status raptor species nests, roost sites, and 

winter roost sites on or within 1⁄2 mile of BLM lands. 

Prohibit surface disturbing activities within 1⁄2 mile around special status raptor species nest sites during 

the following time periods: 

• Mar 1–Aug 1: Ferruginous hawk 

• Mar 1–Aug 15: N. Goshawk. 

Prohibit surface disturbing activities within 1⁄4 mile around special status raptor species nest sites during 

the following time periods: 

• Mar 1–Aug 1: Short-eared owl 

• Mar 1–Aug 31: Burrowing owl. 

Comply with Suggested Practices for Raptor Protection on Power Lines: The State of the Art in 2006

(Avian Power Line Interaction Committee 2006) and Avian Protection Plan (APP) Guidelines (Avian 

Power Line Interaction Committee and USFWS 2005) for new powerline construction (including 

upgrades and reconstruction) to prevent electrocution of raptors. 

Protect unoccupied special status species raptor nests in compliance with BLM’s raptor BMPs 

(Appendix 2). 

California Condor

Avoid disruptive activities in California condor communal roosting or nesting areas. Appropriate 

measures would depend on whether the proposed activity is temporary or permanent, and whether it 

occurs within or outside the condor nesting season. (A temporary action is completed outside of the 

breeding season, leaving no permanent structures and resulting in no permanent habitat loss. A permanent 

action continues for more than one breeding season and/or causes a loss of condor habitat or displaces 

condors through disturbances, i.e., creation of a permanent structure.) 

Apply the following avoidance and minimization measures: 

• Surveys could be required prior to implementation of a proposed action to determine 

presence/absence if information suggests birds could be present. Surveys must be conducted by 

qualified individuals, be conducted according to protocol, and be acceptable to the BLM. 

• Preclude disruptive activities within 1 mile of a California condor nest site during the breeding 

season. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-13 

• Monitor recreation uses within 1 mile of condor nest sites and temporarily restrict activities if 

necessary to protect the condor. 

• Preclude special use permit group events within 1 mile of condor nest sites during the breeding 

season. 

• Preclude placement of new permanent structures or roads within 1 mile of condor nest sites. 

Utah Prairie Dog

Implement conservation measures (Appendix 9) on actions affecting Utah prairie dogs or their habitat. 

Permit no surface disturbing activities or surface occupancy within 1⁄2 mile of active, suitable (currently 

inactive), or potential reintroduction (BLM 2002b) Utah prairie dog habitats/sites. Seismic activities 

would avoid these areas, particularly during the active season (April 1 to September 30). 

Allow introduction, augmentation, restocking, translocations, transplantation, and/or reestablishments of 

special status species in cooperation and collaboration with USFWS, UDWR, and other agencies as 

necessary, subject to guidance provided by BLM’s 6840 policy and by existing or future memoranda of 

understanding (MOU). 

Require deterrent devices designed to prevent raptors from perching on powerline structures on all new 

construction (including upgrades and reconstruction) to discourage predation on Utah prairie dogs. 

Reroute renewed or amended ROWs on public land that have the potential to disturb active and inactive 

Utah prairie dog colonies. 

Preclude cross-country OHV use in occupied or inactive Utah prairie dog colonies. 

Allow for the treatment of plague and other diseases that may impact Utah prairie dogs. 

Mexican Spotted Owl

Implement conservation measures (Appendix 9) on actions affecting MSOs or their habitat. 

Restrictions (from the Utah Field Office Guidelines for Raptor Protection From Human and Land Use 

Disturbances [Appendix 2]) include: 

• Permit no surface disturbing activities from March 1 to August 31 in PACs, breeding habitats, or 

designated critical habitat to avoid disturbance to breeding MSOs. 

• If a disruptive or surface disturbing action occurs entirely outside of the MSO breeding season 

(March 1 to August 31) and leaves no permanent structure or permanent habitat disturbance, the 

action may proceed without an occupancy survey. Land disposal actions would require breeding 

season surveys (see Lands and Realty management actions). 

• If disruptive actions would occur during the season restriction (March 1 to August 31), surveys 

according to USFWS protocol for MSOs would be required prior to commencement of activities. 

If MSOs are detected, activities should be delayed until after the seasonal restriction. 

Retain, where appropriate, large down logs, large trees (generally greater than 24 inches in diameter at 

breast height [DBH]), and snags as prey habitats in occupied and suitable MSO habitat. 

Allow fuels treatments and prescribed fire on a case-by-case basis to reduce fire hazard and improve 

habitat condition for MSO prey. 
Chapter 2 Proposed RMP and Final EIS 

2-14 Kanab RMP 

Meet or make significant progress toward meeting BLM Utah’s Standards for Rangeland Health in 

protected and restricted (as defined in recovery plan) MSO habitats. 

Prohibit new recreation facilities or trails within PACs. Continue maintenance restrictions and seasonal 

closure (March 1 to August 31) of existing facilities. Comply with conservation measures in Appendix 9. 

Limit special recreation permit (SRP) group size to 12 or fewer according to the recovery plan in 

protected and restricted (as defined in the recovery plan) MSO habitat. 

Bonneville Cutthroat Trout, Roundtail Chub, Bluehead Sucker, and Flannelmouth Sucker

Monitor stream habitat to detect changes every 5 to 10 years in streams with historic or currently 

occupied habitat, in cooperation with UDWR. 

Maintain or improve stream habitat for those locations with historic or currently occupied habitat 

identified in cooperation with UDWR. Maintain, improve, or provide missing habitat components using 

appropriate habitat improvement techniques. 

Federally Listed and Candidate Plants

Surveys would be required prior to surface disturbance unless species presence and distribution 

information is complete and available. Surveys would be conducted by a BLM-approved botanist. In the 

event species presence is verified, the project proponent may be required to modify operational plans, at 

the discretion of the authorized officer, to include appropriate protection and/or avoidance measures or 

practices for the minimization of impacts on listed and candidate plants and their habitats. 

Initiate Section 7 consultation with USFWS for any planned or authorized activity that is determined to 

have the potential to result in an impact on listed and candidate plants and their habitats. 

Implement the Siler’s pincushion cactus recovery plan. 

Manage oil and gas leasing as open subject to moderate constraints (CSU) in federally listed and 

candidate plant species occupied and suitable habitat. In these areas, well placement would be located to 

not adversely affect the species or their habitats. 

Limit species for rehabilitation and emergency stabilization in federally listed and candidate species 

habitat to species that would not inhibit the listed or candidate species. 

Welsh’s Milkweed 

Implement applicable portions of the Welsh’s Milkweed (Asclepias welshii) Recovery Plan. Consider new 

scientific information obtained since completion of the recovery plan. Include this information and 

management guidance in a joint management plan to be prepared by the BLM and the State of Utah. 

Close approximately 790 acres of designated critical milkweed habitat on the BLM-administered portion 

of the Coral Pink Sand Dunes to OHV use. 

Manage oil and gas leasing as open subject to major constraints (NSO) in Welsh’s milkweed designated 

critical habitat. 

Coral Pink Sand Dunes Tiger Beetle

Implement the conservation actions identified in the Conservation Agreement and Strategy for the Coral 

Pink Sand Dunes Tiger Beetle, as amended. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-15 

Maintain the established 370-acre tiger beetle conservation area on BLM-administered lands in the 

northeast corner of the sand dunes. 

Western Yellow-Billed Cuckoo and Southwestern Willow Flycatcher

Implement conservation measures (Appendix 9) on actions affecting Southwestern willow flycatcher or 

its habitat. 

Manage for regeneration and multiple age classes in cottonwood/willow vegetation in yellow-billed 

cuckoo and Southwestern willow flycatcher habitat. 

Identify sites where Southwestern willow flycatcher habitat restoration (i.e., occupied, suitable, and 

potentially suitable sites) is warranted. Prioritize riparian restoration in Southwestern willow flycatcher 

habitat consistent with riparian rehabilitation decisions in the Water section. 

Prohibit surface disturbing activities within 1⁄4 mile of occupied breeding habitat from May 1 to 

August 15. 

Where possible, collocate roads, new trails, and ROWs and develop stream crossings at right angles to 

yellow-billed cuckoo and Southwestern willow flycatcher habitat to minimize impacts. 

Management of Greater Sage-Grouse Habitat 

Implement the UDWR Sage-Grouse Strategic Management Plan, BLM National Sage-Grouse Habitat 

Conservation Strategy, and recommendations from local sage-grouse working groups to protect, maintain, 

or enhance current Greater sage-grouse populations and habitat. 

Preclude cross-country OHV use in Greater sage-grouse nesting and brood-rearing habitats. 

Avoid new ROWs with high-profile structures (e.g., buildings, storage tanks, overhead powerlines, wind 

turbines, towers, and windmills) within 1 mile of an active Greater sage-grouse lek or in nesting and 

brood-rearing habitat. 

Manage oil and gas leasing as open subject to major constraints (NSO) within 1⁄2 mile of a Greater sagegrouse lek site. 

Allow no surface disturbing or otherwise disruptive activities (e.g., construction and maintenance) within 

2 miles of a Greater sage-grouse lek in nesting and brood-rearing habitat from March 15 to July 15 and in 

winter habitat from December 1 to March 14. 

Avoid insecticide use in Greater sage-grouse nesting and early brood-rearing habitats during the early 

developmental stage (March 15 to July 15) of Greater sage-grouse chicks. 

Prioritize habitat vegetation treatments to maintain and/or improve habitat function in the following areas 

(Map 5): 

• Sage-grouse nesting and brood-rearing habitat 

• Sage-grouse winter range. 

Management of Pygmy Rabbit Habitat 

Apply restrictions (e.g., avoidance or mitigation) to surface disturbing and disruptive activities on a caseby-case basis in occupied and potential pygmy rabbit habitat for the protection of this species and its 
Chapter 2 Proposed RMP and Final EIS 

2-16 Kanab RMP 

associated habitat. Site-specific NEPA documentation would address restrictions around pygmy rabbit 

habitat. 

Recovery Plan Actions for Special Status Species 

Consider and implement the appropriate guidelines and management recommendations presented in 

current and future species recovery or conservation plans (as revised), or alternative management 

strategies developed in consultation with USFWS and/or UDWR. 

Fish and Wildlife 

Goals and Objectives 

• Maintain habitat quantity and quality (forage, water, cover, space, and security) sufficient to 

sustain diverse wildlife populations, meeting objectives identified in cooperation with UDWR 

where applicable. 

• Maintain and/or improve aquatic stream habitat to support productive and diverse fisheries and 

other aquatic populations. 

• Maintain habitat connectivity and unrestricted wildlife movement between ecological zones to the 

maximum extent possible. 

• Maintain and enhance aquatic and wildlife resources and provide for biological diversity of plants 

and wildlife resources while ensuring healthy ecosystems. 

• Manage habitats on an ecosystem basis, ensuring that all parts of the ecosystem on public lands 

are preserved. 

• Conserve habitat for migratory birds as directed by Executive Order 13186 (Responsibilities of 

Federal Agencies to Protect Migratory Birds) and the Migratory Bird Treaty Act and emphasize 

management of migratory birds listed on the USFWS current list of Birds of Conservation 

Concern (BCC) and the Partners-in-Flight (PIF) priority species. 

Management Actions 

Important Wildlife and Fish Habitat 

Consider the USFWS BCC and the Utah PIF Priority Species to identify and conserve priority nesting 

habitats for migratory birds. 

Use Best Management Practices for Raptors and Their Associated Habitats in Utah (Appendix 2) to guide 

raptor management, using seasonal and spatial buffers and mitigation to maintain and enhance raptor 

nesting, foraging, and roosting habitat while allowing other resource uses to occur. 

Work cooperatively with other agencies, such as UDWR or Utah Partners for Conservation and 

Development, to identify and manage habitat for non-listed fish and wildlife species. 

Allow, initiate, and/or participate in scientific research of species and their habitats. 

Complete and assist with inventories and map current occupied and potential habitats for species. 

Conduct habitat improvement treatments for species in accordance with current species-specific 

guidelines and local working group prescriptions. 

Prioritize Bird Habitat Conservation Areas identified in the Coordinated Implementation Plan for Bird 

Conservation in Utah (IWJV 2005, as updated) for conducting bird habitat conservation projects through 

cooperative funding initiatives such as the Intermountain West Joint Venture. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-17 

Coordinate predator management with U.S. Department of Agriculture Animal and Plant Health 

Inspection Service/Wildlife Services and UDWR in accordance with the guidance provided in the existing 

MOU with Animal and Plant Health Inspection Service/Wildlife Services. 

Maintain existing vegetation treatments that benefit wildlife. 

Prioritize habitat vegetation treatments to maintain and/or improve habitat function in areas of crucial 

mule deer winter range (Map 5). 

Road crossings of water bodies that support fish would be designed to provide for fish passage. 

Management of Deer and Elk Habitats 

Preclude surface disturbing activities in crucial mule deer and elk winter range from November 15 to 

April 15 unless the activity would improve mule deer or elk habitat. 

Preclude oil and gas exploration and development and ROW construction/reconstruction in identified big 

game migration and transitional ranges from October 1 to November 15. 

Limit OHV use to designated routes. 

Management of Bighorn Sheep Habitats 

Preclude surface disturbing activities in crucial Desert bighorn sheep habitat during lambing season 

(April 15 to June 15) (Bighorn Institute 2008). 

Do not authorize changes in kind of livestock to sheep or goats within 9 miles of Desert bighorn sheep 

habitat. 

Management of Pronghorn Habitat 

Preclude surface disturbing activities in crucial pronghorn habitat from May 15 through June 15 during 

fawning season. 

Management of Habitat to Provide for Wildlife Management Objectives as Established by UDWR 

Require wildlife-passable fences, consistent with the species found in the area, and essential for effective 

range management or other administrative functions. 

Continue to work with UDWR and conservation organizations to establish additional water 

developments, subject to NEPA consideration, and maintain existing water developments to improve 

wildlife distribution and encourage habitat use by native wildlife species and introduced non-native 

species. 

Authorize construction of wildlife habitat improvement projects (including water developments and 

vegetation treatments) to meet wildlife goals and objectives, provided that the project complies with 

NEPA, ESA, and other applicable laws and policies. 

Retain crucial wildlife habitat in public ownership, unless the land tenure adjustment would meet one or 

more of the land tenure adjustment criteria identified in Lands and Realty management. 

Develop present use area water needs for wildlife as capabilities exist; maintain water throughout the 

spring and fall in existing and new livestock range improvements (e.g., tanks and pipelines). 
Chapter 2 Proposed RMP and Final EIS 

2-18 Kanab RMP 

Manage livestock grazing in riparian areas/fisheries habitat according to the Utah Guidelines for Grazing 

Management. Livestock grazing in riparian areas/fisheries habitat would be evaluated through compliance 

with the Standards for Rangeland Health. 

Minor adjustments to crucial wildlife habitat boundaries periodically made by UDWR would be 

accommodated through plan maintenance. 

Management of Raptor Habitats 

Implement raptor guidelines associated with level of duration of activities established by USFWS. 

Guide raptor habitat management by use of Best Management Practices for Raptors and Their Associated 

Habitats in Utah (Romin and Muck 2002, as amended) and BLM’s raptor BMPs (Appendix 2) using 

seasonal and spatial buffers and mitigation to maintain and enhance raptor nesting, foraging, and roosting 

habitat while allowing other resource uses to occur. 

Prohibit disruptive activities within 1 mile of peregrine falcon nest sites from February 1 to August 31. 

Prohibit disruptive activities to nesting raptors within 1⁄2 mile of raptor nests during the following time 

periods: 

• Jan 1–Aug 31: golden eagle 

• Mar 15–Aug 15: red-tailed hawk 

• Mar 15–Aug 31: Cooper’s hawk, sharp-shinned hawk 

• Mar 1–Aug 31: Swainson’s hawk 

• Apr 1–Aug 15: Northern harrier 

• Apr 1–Aug 31: merlin, osprey 

• May 1–Aug 15: Turkey vulture. 

Prohibit disruptive activities to nesting raptors within 1⁄4 mile of a raptor nest during the following time 

periods: 

• Dec 1–Sep 31: Great-horned owl 

• Feb 1–July 31: boreal owl 

• Feb 1–Aug 15: long-eared owl 

• Mar 1–Aug 15: W. screech owl 

• Mar 1–Aug 31: N. saw-whet owl 

• Apr 1–Aug 1: N. pygmy owl 

• Apr 1–Aug 31: prairie falcon 

• Apr 1–Sep 30: Flammulated owl. 

Protect unoccupied raptor nests in compliance with BLM’s raptor BMPs (Appendix 2) yet allow for 

permanent (long-term) facilities and structures to be constructed within the spatial buffer zone, identified 

above by alternative, outside of the breeding season as long as they would not cause the nest site to 

become unsuitable for future nesting. Non-permanent (short-term) activities would be allowed within the 

spatial buffer of nests during the nesting season as long as those activities are shown to be non-impacting 

to nesting raptors. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-19 

Fish and Wildlife Reintroductions 

Allow introduction, translocation, transplantation, restocking, augmentation, and reestablishment of 

native and naturalized fish and wildlife species in cooperation and collaboration with UDWR, subject to 

guidance provided by BLM’s 1745 policy and by existing or future MOUs with UDWR. 

Management of Forage Allocations for Big Game Species (as established by the Division of Wildlife Resources) 

Allocate 11,045 AUMs to wildlife as shown in Table 3-24. 

Compensatory Mitigation 

The BLM will approach compensatory mitigation on an “as appropriate” basis where it can be performed 

on site, and on a voluntary basis where it is performed offsite, or in accordance with current guidance. 

Wildland Fire Ecology 

Goals and Objectives 

• Firefighter and public safety would be the primary goal in all fire management decisions and 

actions. 

• Wildland fire would be used to protect, maintain, and enhance resources and, when possible, be 

allowed to function in its natural ecological role. 

• Hazardous fuels would be reduced to restore ecosystems; protect human, natural, and cultural 

resources; and reduce the threat of wildfire to communities. 

• Fires would be suppressed at minimum cost, taking into account firefighter and public safety and 

benefits and values to be protected, consistent with resource objectives. 

• The BLM would provide a consistent, safe, and cost-effective fire management program through 

appropriate planning (50 Code of Federal Regulations [CFR] 402, Counterpart Regulations), 

staffing, training, equipment, and management. 

• Every area with burnable vegetation would have a Fire Management Plan (FMP) based on a 

foundation of sound science. 

• Emergency stabilization, rehabilitation, and restoration efforts would be undertaken to protect and 

sustain resources, public health and safety, and community infrastructure. 

• The BLM would work together with its partners and other affected groups and individuals to 

reduce risks to communities and restore ecosystems.

• The general Desired Wildland Fire Condition (DWFC) is to have ecosystems that are at a low risk 

of losing ecosystem components following wildfire and that function within their historical range. 

In terms of Fire Regime Condition Class (FRCC), the DWFC outside Wildland-Urban Interface 

(WUI) is to trend to a lower FRCC using the least intrusive methods possible. In other words, the 

DWFC is to move lands in FRCC 3 to FRCC 2 and lands in FRCC 2 to FRCC 1 through fire and 

non-fire treatments where wildland fire use is the preferred method of treatment, when feasible. 

Inside the WUI, the general DWFC is to have less potential for values to be threatened by 

wildland fire, usually through some modification of fuels. Table 2-1 identifies DWFC by major 

vegetation type and actions needed to meet DWFC. 

Table 2-1. DWFC by Major Vegetation Group and Actions Needed to Meet DWFC 

Major Vegetation 

Group DWFC and Actions Needed to Meet DWFC 

Salt Desert Scrub 

The DWFC, both outside and inside the WUI, is native, open salt desert scrub 

vegetation with little to no invasive species cover. Fire would be mostly excluded 

from these vegetation types. Due to the historical lack of surface fuels, the historical 
Chapter 2 Proposed RMP and Final EIS 

2-20 Kanab RMP 

Major Vegetation 

Group DWFC and Actions Needed to Meet DWFC 

fire-return interval is extremely infrequent. 

• Due to the historical lack of fire and current potential for cheatgrass invasion, do 

not allow wildland fire to burn into salt desert scrub vegetation types. Wildland fire 

is not desired due to the high potential for cheatgrass invasion following wildfire 

and loss of native salt desert scrub communities. 

• Treat salt desert scrub types using a combination of mechanical, chemical, 

seeding, and biological treatments to reduce cheatgrass cover and restore native 

communities. Prescribed fire may be used in conjunction with seeding when part 

of a cheatgrass control objective. 

• Due to the high incidence of cheatgrass in this vegetation type, consider seeding 

following any surface disturbing activity. 

• Following wildland fire, aggressively seed to reduce potential for cheatgrass and 

other noxious weed invasion. 

Pinyon-Juniper Woodland 

Where pinyon and juniper occurred historically, the DWFC outside and inside the 

WUI is open stands of pinyon and juniper with native grass and shrub understory. 

Where pinyon and juniper did not occur historically, the DWFC is the native shrub, 

grass, and forest communities that the pinyon and juniper have invaded. The 

historical role of fire (estimated 15- to 50-year fire-return interval) prevented 

encroachment of pinyon and juniper into other vegetation communities. Most pinyon 

and juniper encroachment has occurred in the past 100 years. Follow treatments 

with seeding in FRCC 2 and FRCC 3 stands that lack native understory vegetation. 

Historical occurrence of pinyon and juniper is difficult to map, but pre-settlement 

trees are generally located in shallow, rocky soils and tend to have unique growth 

form characterized by rounded, spreading canopies; large basal branches; large 

irregular trunks; and furrowed fibrous bark. Historic fire-return intervals in these 

protected sites are more than 100 years. 

• When possible, allow wildland fire to play its natural role, which mimics the 

historical fire-return interval and severity in FRCC 1 and FRCC 2 lands that have 

some cover of native understory vegetation. Due to the high risk of losing key 

ecosystem components in FRCC 2 (lacking native understory vegetation) and 

FRCC 3 lands, avoid wildland fires in these areas. Prescribed fires should be 

applied to pinyon and juniper communities when native surface fuels will carry fire 

and when there is low risk of invasive species. 

• Prescribed fire should be used to approximate historical fire-return intervals and 

promote recovery of the pre-settlement vegetation cover types. Remove most 

young (less than100 years old) pinyon and juniper trees through fire or 

mechanical treatments. In the WUI, construct fuel breaks between BLM and 

private land or other values at risk. 

• Following wildfire in FRCC 3 (and some FRCC 2 areas that are lacking native 

understory vegetation), aggressively seed to reduce invasive species 

establishment and to restore native communities. 

Sagebrush 

The DWFC, outside and inside the WUI, is healthy sagebrush defined as diverse 

age classes with an understory of native grasses and forbs. Research suggests that 

stand-replacement should be burned every 10 to 100 years depending on the 

particular sagebrush species and its associated habitat. Fire management actions in 

sagebrush must be carefully balanced between invasive species concerns, wildlife 

habitat, and the need to restore fire. 

• When possible, allow wildland fire to play its natural role, which mimics the 

historical fire-return interval and severity in FRCC 1 and FRCC 2 lands that have a 

low potential for cheatgrass invasion. Areas with low potential for cheatgrass 

invasion include higher elevation sites and/or sites that have very low incidence of 

cheatgrass pre-fire. 

• Treat dense sagebrush (more than 30 percent) with fire, mechanical, or chemical 

treatments to reduce sagebrush canopy cover and improve native grass and forb 

density and cover; an additional objective in treating sagebrush is to remove 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-21 

Major Vegetation 

Group DWFC and Actions Needed to Meet DWFC 

encroaching pinyon and juniper trees. In the WUI, construct fuel breaks between 

BLM and private land (or other values at risk) in dense stands of sagebrush. 

• Following wildfire in FRCC 2 and FRCC 3 lands, aggressively seed to promote 

native understory grasses and forbs and reduce invasion of cheatgrass and 

noxious weeds. Consider including sagebrush in seeding mixes or planting 

sagebrush seedlings in high-value wildlife areas following large, high-severity 

wildfires when natural seed sources would be lacking.

Grassland 

Where native grasslands occurred historically, the DWFC outside the WUI is native 

grass and forb communities. Native grasslands have been lost to pinyon and juniper 

encroachment, cheatgrass invasion, and non-native plant seedlings (e.g., crested 

wheatgrass, perennial ryegrass, etc.). Where non-native grasslands occur, the 

DWFC is the restoration of the native grassland or shrub community. The historical 

role of fire in Utah’s grasslands is similar to pinyon and juniper and sagebrush 

community types with fires every 15 to 50 years. 

• When possible, allow fire to play its natural role, which mimics the historical firereturn interval and severity. 

• Treat native grasslands with fire, mechanical, or chemical treatments to reduce 

encroaching trees (mainly juniper), shrubs, and invasive plants. Fire treatments 

alone should be avoided where there is potential for cheatgrass invasion (areas 

below 7,000 feet elevation that have adjacent cheatgrass populations). In the 

WUI, consider green stripping between BLM and private lands and other values at 

risk. 

• Following wildfire in FRCC 2 and FRCC 3 lands, aggressively seed to reduce 

potential for cheatgrass and other invasive weeds.

Mountain Shrub 

The DWFC outside of the WUI is stands with patches of differing age classes. In the 

WUI, the DWFC is greatly reduced vegetation density or a conversion to lessflammable vegetation between BLM and private lands or other values at risk. 

• When possible, allow fire to play its natural role, which mimics the historical firereturn interval and severity in all FRCCs. 

• Treat large expanses of even-aged, dense, homogeneous stands to result in 

patches of diverse age classes. To achieve greater habitat diversity and 

decreased potential for large-scale high-severity fire, reduce invasion of pinyon 

and juniper and reduce the average age of stands through fire, mechanical, or 

biological (e.g., grazing goats) treatments. In the WUI, consider aggressive 

vegetation manipulation to create fire breaks in highly flammable shrub types 

(e.g., Gambel oak) when there are values at risk. 

• Because most of these species sprout following wildfire, consider seeding only to 

reduce potential for invasive weeds.

Mixed Conifer 

The DWFC outside the WUI is landscapes with a mosaic of age classes. In the 

WUI, the DWFC is reduced canopy density and reduced ladder fuels between BLM 

and private lands and other values at risk. 

• When possible, allow fire to play its natural role, which mimics the historical firereturn interval and severity in FRCC 1 and FRCC 2 stands. In FRCC 3 stands 

(dense stands with high fuels loadings), consider mechanical treatments prior to 

reintroducing fire. 

• Treat areas to result in a landscape of diverse age classes while retaining patches 

of large old trees. In the WUI, remove ladder fuels and create shaded fuel breaks 

between BLM and private land when values are at risk. 

• Consider tree planting following wildland fire to restore or rehabilitate the forest 

resource to promote forest regeneration. 

Ponderosa Pine The DWFC, outside and inside the WUI, is open stands with a native grass and forb 

understory. 
Chapter 2 Proposed RMP and Final EIS 

2-22 Kanab RMP 

Major Vegetation 

Group DWFC and Actions Needed to Meet DWFC 

• When possible, allow fire to play its natural role, which mimics the historical firereturn interval and severity. Restore fire (natural or prescribed fire) to FRCC 1 and 

FRCC 2 stands. 

• Consider mechanical treatments in dense FRCC 3 stands until they reach a lower 

FRCC before restoring fire. Reduce juniper encroachment through fire (preferred 

when fuels conditions allow) or mechanical treatments. In the WUI, remove ladder 

fuels and create fuel breaks between BLM and private land and other values at 

risk. 

• Following wildfires, consider seeding to reduce invasive weeds and planting 

ponderosa pine seedlings for forest restoration and rehabilitation. 

Riparian Wetland 

The DWFC, outside and inside the WUI, is riparian and wetland areas with the 

appropriate composition of native species (e.g., reduction of tamarisk and other 

invasive species). 

• When possible, allow fire to play its natural role, mimicking the historical fire-return 

interval and intensity. Allow low to moderate severity fire to burn into riparian and 

wetland areas when natural ignitions are managed as wildland fire use. 

• Restore native riparian and wetland species through fire and mechanical 

treatments. Reduce flammable invasive species along riparian corridors (e.g., 

tamarisk) through mechanical, chemical, biological, and fire treatments. For 

prescribed fire, allow low-intensity fire to back into riparian and wetland areas 

through ignition outside of these areas. Mechanical treatment as the initial 

treatment would be emphasized where there is a moderate to high potential for 

riparian and wetland to be burned to a high severity. 

• Consider active restoration options when native riparian and wetland communities 

are unlikely to recover with passive restoration (due to invasive species, stream 

bank erosion, etc.). 

Aspen 

The DWFC, outside and inside the WUI, is healthy clones with diverse age classes 

represented and ample regeneration. 

• When possible, allow fire to play its natural role, mimicking the historical fire-return 

interval and severity in all FRCCs, because aspen readily sprouts following fire. 

• Treat aspen stands with fire or mechanical treatments to reduce encroaching 

junipers and conifers and to stimulate sprouting. If treated aspen stands are small, 

consider excluding big game and livestock until the regeneration can withstand 

grazing. In the WUI, consider increasing aspen cover if possible to create a 

shaded fuel break between private land (and other high-value areas) and the 

more flammable conifer trees on BLM land. 

• Following wildfire, most aspen stands would need little stabilization, except soil 

stabilization on steep slopes. However, burned areas may need to be fenced to 

exclude wildlife and livestock until the regeneration can withstand grazing. 

Source: BLM 2005c 

Management Actions 

The September 2005 completion of the Finding of No Significant Impact and Decision Record (UT-USO04-01) for the Utah Land Use Plan Amendment for Fire and Fuels Management amended the wildland 

fire ecology portions of the existing LUPs. No significant changes in resource condition, data, or policy 

have become available since completion of this amendment. Therefore the decisions from the 2005 

document have been brought forward in their entirety into the Proposed RMP under the Wildland Fire 

Ecology header. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-23 

Fire Management Strategies and Actions 

The appropriate management response would be applied to all wildland fires, emphasizing firefighter and 

public safety and considering suppression costs, benefits, and values to be protected. The appropriate 

management response would be consistent with resource objectives, standards, and guidelines. Response 

to wildland fire would be based on ecological and social costs and benefits of the fire. The circumstances 

under which the fire occurs and the likely consequences to firefighter and public safety and welfare, 

natural and cultural resources, and values to be protected would dictate the appropriate management 

response to the fire. Fire Management Unit objectives (as included in the FMP) would further guide the 

appropriate management response. 

Wildland fire would be used to protect, maintain, and enhance resources and, when possible, would be 

allowed to function in its natural ecological role. Areas where wildland fire use is appropriate and not 

appropriate are identified in Table 2-1. The FMPs would provide further operational guidance for 

wildland fire use. 

To reduce risks and to restore ecosystems, the following fuels management tools would be allowed: 

wildland fire use; prescribed fire; and mechanical, chemical, seeding, and biological actions. As 

conditions allow, the BLM would employ the least intrusive method over more intrusive methods. For 

example, wildland fire use is the preferred method of treatment. Where wildland fire use is not feasible, 

prescribed burning would be the preferred method. Where prescribed burning is not feasible, non-fire 

fuels treatments would become the preferred method of treatment. 

Work with partners in the WUI in wildland firefighting, hazardous fuels reduction, cooperative fire 

prevention education, and technical assistance. Unauthorized wildland fire ignitions would be prevented 

through coordination with partners and affected groups and individuals. The full range of prevention and 

mitigation activities would be used: personal contacts, mass media, education programs, and signage. 

The following Emergency Stabilization and Rehabilitation actions (after wildfire suppression) and 

restoration for planned actions may be used to reduce potential for soil erosion and invasive species 

spread: seeding or planting native and/or non-native species; applying approved herbicides; implementing 

soil stabilization measures (e.g., stabilization structures and mulches); protecting cultural resources; 

repairing or replacing facilities; fencing, herding, or removing livestock; and resting allotments. Specific 

actions could include brush/tree chopping; contour tree felling; silt catchments; waddles, straw, or fabric 

silt traps; mulching; drill seeding; aerial seeding; aerial seeding followed by mechanical seed covering 

(chaining, harrowing, or other mechanical means); planting seedlings; fence construction or rebuilding; 

road/trial maintenance or closures; cattle guards; road culvert installation or cleaning; water bars; sign 

installation and maintenance; herbicidal or mechanical weed treatments; weather station installation and 

maintenance; and repairing or rebuilding of minor facilities (e.g., cross-fencing, wildlife structures, 

recreational facilities). 

Monitoring actions would be undertaken to determine results from fire management decisions and 

actions. Monitoring results would be used in determining the need for further amendment or revisions. 

Wildland Fire Suppression Objectives and Management Actions 

Fires would be suppressed at minimum cost, considering firefighter and public safety, benefits, and values 

to be protected, consistent with resource objectives. 

The BLM would provide a consistent, safe, and cost-effective fire management program through 

appropriate planning, staffing, training, equipment, and management. 
Chapter 2 Proposed RMP and Final EIS 

2-24 Kanab RMP 

Limited Suppression and Wildland Fire Use Objectives and Actions 

Wildland fire would be used to protect, maintain, and enhance resources and, when possible, would be 

allowed to function in its natural ecological role. However, due to resource conditions and proximity to 

values at risk, fire cannot be allowed to resume its natural role on public lands. The DWFC is that as lands 

are transitioned from a higher FRCC to a lower FRCC, the applicability of wildland fire use would 

increase. Therefore, fire managers would periodically assess the FRCC following changes in vegetation 

due to management actions and natural changes. This alternative authorizes wildland fire use as a tool, 

when appropriate, to reach the DWFC. 

Wildland fire use would be an appropriate management response to naturally ignited wildland fires to 

accomplish specific resource management objectives in predefined designated areas. Operational 

management of wildland fire use is described in the Wildland Fire Implementation Plan. This alternative 

attempts to in general clarify the types of areas that are not suitable for wildland fire use while leaving 

other areas open for possible wildland fire use. 

Although specific areas for wildland fires use would be identified in the FMPs, wildland fire use may be 

authorized for all areas, except when the following resources and values may be negatively impacted and 

there are no reasonable Resource Protection Measures to protect such resources and values: 

• WUI areas 

• Areas that are known to be highly susceptible to post-fire cheatgrass or invasive weed invasion 

• Important terrestrial and aquatic habitats 

• Non-fire adapted vegetation communities 

• Sensitive cultural resources 

• Areas of soil with high or very high erosion hazard 

• Class I air-shed areas and particulate matter (less than 10 microns in diameter) (PM10) nonattainment areas 

• Administrative sites 

• Developed recreation sites 

• Communication sites 

• Oil, gas, and mining facilities 

• Above-ground utility corridors 

• High-use travel corridors, such as interstates, railroads, and/or highways. 

The appropriate management response for areas containing these resources or values may be wildland fire 

use, but Resource Protection Measures would be necessary to protect these values if they are threatened. 

Additional protection actions may include employing strategies and tactics to avoid these values (e.g., 

using fire retardant to reduce fire spread in certain areas). In fire situations where these resources or 

values would not be impacted, wildland fire use may still not be employed due to other parameters 

(weather, personnel availability, etc.). In these situations, the appropriate management response—from 

aggressive initial action to monitoring—would be used. The DWFC would be to restore fire to 

ecosystems when feasible; therefore, fuel treatments should focus on protecting the resources and values 

listed above so future wildland fire use actions could be more easily implemented. 

Current BLM regulations do not allow for funding of emergency stabilization or rehabilitation actions 

following wildland fire use. Utah BLM land managers often prefer to evaluate a fire after it occurs to 

determine if there is a need for any post-fire rehabilitation or stabilization. The inability to rehabilitate or 

stabilize burned areas following wildland fire use restricts some acres from being considered by BLM 

managers for wildland fire use. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-25 

Prescribed Fire Objectives and Actions 

All prescribed fire acres would be for a primary purpose of hazardous fuels reduction or community 

protection from fires. While these acres would likely also accomplish other resource objectives, this plan 

aims to directly analyze effects from fire management decisions. 

Non-Fire Fuels Objectives and Actions 

All non-fire treatment acres would be for a primary purpose of hazardous fuels reduction or community 

protection from fires. While these acres would likely also accomplish other resource objectives, this plan 

aims to directly analyze effects from fire management decisions. 

Criteria for Establishing Fire Management Priorities 

Protection of human life is the primary priority. Setting priorities among protecting human communities 

and community infrastructure, other property and improvements, and natural and cultural resources would 

be based on human health and safety, the values to be protected, and the costs of protection. Priorities for 

all aspects of fire management decisions and actions would be based on the following: 

• WUI 

• Maintain existing healthy ecosystems 

• High priority sub-basin (Hydrologic Unit Code [HUC] 4) or watershed (HUC 5) 

• Special status species 

• Cultural resources and cultural landscapes. 

Resource Protection Measures for Fire Management Practices 

Resource Protection Measures for fire management practices to protect natural or cultural resource values 

are described in Appendix 8 (obtained from the Utah Land Use Plan Amendment for Fire and Fuels 

Management Finding of No Significant Impact and Decision Record, Table 2.3). 

Cultural Resources 

Goals and Objectives 

• Identify, preserve, and protect significant cultural resources and ensure that they are available for 

appropriate uses by present and future generations (Federal Land Policy and Management Act 

[FLPMA] Sections 103(c) and 201(a) and (c); National Historic Preservation Act [NHPA] 

Section 110(a); and Archaeological Resources Protection Act, Section 14(a)). 

• Seek to reduce imminent threats and resolve potential conflicts from natural or human-caused 

deterioration, or potential conflict with other resource uses (FLPMA Section 103(c); NHPA 

Sections 106 and 110(a)(2)) by ensuring that all authorizations for land use and resource use 

would comply with NHPA Section 106. 

• Provide opportunities for scientific and educational uses of cultural resource sites. Interpretation 

of and education about previous human occupation and use of the area would be accomplished 

using appropriate sites and methods. 

• Provide opportunities for traditional (Native American) uses of cultural resources and sites. 

• Ensure compliance with Native American Grave Protection and Repatriation Act (NAGPRA). 

Management Actions 

Protection of Cultural Resources 

Mitigate adverse impacts on cultural resources resulting from authorized surface disturbing activities. 
Chapter 2 Proposed RMP and Final EIS 

2-26 Kanab RMP 

Mitigate and/or preserve cultural and historic values on cultural properties eligible for National Register 

of Historic Places (NRHP) listing. 

Meet responsibilities under the NHPA as addressed in the State Protocol Agreement Between the Utah 

State Director of BLM and the Utah State Historic Preservation Officer (SHPO), and the National 

Cultural Programmatic Agreement. 

Complete cultural resources inventories prior to allowing permitted surface disturbing activities, 

excluding those areas and circumstances identified in BLM-M-8110.23, UT-BLM-H-8110 Section II.C, 

and UT-BLM-H-8110 Appendix 1. 

Continue geographic and archaeological scientific inventories based on imminent threats from natural or 

human-caused deterioration, on potential conflict with other resource uses, and for compliance with 

NHPA Section 110. 

Update the Class I cultural resources inventory every 10 years. 

Provide opportunities for local interpretation (for local population) of cultural resources and public 

education (for general resource users). 

Use proactive research, protection, and inventories involving universities, avocational and service groups, 

site stewards, tribes, and community outreach to gain a better understanding of cultural resources and 

preserve them for present and future study and use. 

Consider land acquisitions from willing parties to preserve cultural resources, as appropriate (as identified 

in criteria #2 for land tenure adjustments in the lands and realty alternatives). 

Preclude surface disturbing activities within 1⁄4 mile or within the visual horizon, whichever is closer, of 

cultural sites where landscape association contributes to eligibility for the NRHP. Unevaluated portions of 

the setting would be managed as contributing until a cultural inventory and evaluation is completed and 

the setting is determined to be contributing or non-contributing. 

Establish a comprehensive monitoring program emphasizing: 

• Cultural sites that have been previously identified as being impacted (e.g., from vandalism, 

erosion, grazing, or other) 

• Cultural sites identified on maps, brochures, or other media that bring the site into public 

awareness 

• Sites that are known to be popular for public visitation (e.g., public use site) 

• A representative sample of sites known to be prone to impacts from predictable sources (e.g., 

vandalism, recreation, grazing, or development). 

Management of Scientific, Traditional, Educational, Public, and Research Cultural Resource Values 

Allocate and manage cultural resource sites for scientific, public, conservation, traditional, and 

experimental uses and discharged from management categories described in BLM-M-8110.4 as follows: 

• South Fork Indian Cave (42Ka1576), Helldive Canyon (42Ka1695), and Mansard (42Ka4427) 

would be placed in the Public Use category. 

• Sites identified as Native American Traditional Cultural Properties would be placed in the 

Traditional Use category. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-27 

• All other sites considered eligible to the NRHP would be placed in the Most Appropriate Use 

category. 

Sites would be included in the Discharged from Management category if both of the following conditions 

are met and documented: 

• The BLM and the SHPO have formally agreed that the site is not eligible for listing on the 

NRHP. 

• The site has no value for other cultural uses (as described in BLM-M-8110.4). 

Allocations should be reevaluated and revised by site or area when circumstances change or when new 

data becomes available. Consult with the SHPO and Native American tribes as appropriate. 

Proactive Cultural Resource Inventories 

Prioritize new field inventories (Class II or III) directed by NHPA Section 110 as follows: 

• Recreation areas identified for public use (i.e., OHV open areas) 

• 100 feet (30 meters) (depending on topography) on either side from the centerline of designated 

OHV routes 

• Areas of special cultural designation (ACECs, National Register sites, etc.) that have not been 

fully inventoried 

• Resources eligible for the NRHP at a national level of significance that have not been fully 

inventoried 

• Road systems—100 feet (30 meters) (depending on topography) on either side from the centerline 

of road 

• Areas lacking existing inventories (large areas with no inventory data) 

• 5-mile vulnerability zones surrounding cities and towns 

• Hiking/equestrian trails. 

Areas and Values of Importance to Native American Tribes 

Identify and manage traditional cultural properties in coordination with Native American tribes. 

Work with Native American tribes to ensure compliance with NAGPRA, when needed. 

Work with Native American tribes to protect their rights including access to sacred sites and traditional 

cultural areas. Accommodate tribal access to sacred sites and traditional cultural properties when planning 

and implementing land uses. Prevent or mitigate physical damage or intrusions that might impede use of 

sacred sites and traditional cultural properties. 

Establish and maintain agreements with all Native American tribes interested in specific projects or areas 

on which they wish to consult. 

Allow Native American non-commercial traditional use of vegetation and forest and woodland products 

for the collection of herbs, medicines, traditional use items, or items necessary for traditional, religious, or 

ceremonial purposes, through permits. 

Paleontological Resources 

Goals and Objectives 

• Protect scientifically significant paleontological resources. 
Chapter 2 Proposed RMP and Final EIS 

2-28 Kanab RMP 

• Protect paleontological resources with exceptional historic, cultural, or interpretive significance. 

• Provide opportunities for scientific, educational, and recreational uses of paleontological 

resources. 

• Cooperate with other federal, state, and local agencies in paleontological resources management 

activities. 

Management Actions 

Protection of Paleontological Resources 

Monitor the highest priority scientifically significant paleontological sites for trend and condition. 

Require on-the-ground paleontological inventories (field surveys) prior to permitting surface disturbing 

activities in paleontological Class I areas. Require paleontological assessments (formal analysis of 

existing data) prior to permitting surface disturbing activities in paleontological Class II areas. 

Allow surface collection (as defined in BLM Manual 8270) of common invertebrate and botanical 

paleontological resources for personal (non-commercial) use without permits unless such resources are of 

critical scientific or recreational value and need to be protected, or where collection is incompatible with 

other resource protection. 

Consult/coordinate with other local, state, and federal land agency paleontological resource specialists (if 

available) before undertaking significant ground disturbing activities in Class I areas to ensure protection 

of adjacent resources. 

Proactive Paleontological Inventories 

Conduct non-Section 106 proactive inventories intermittently as resources allow. 

Prioritize paleontological resource inventories in the following areas (Map 3-14 of the Draft RMP/EIS): 

• High resource potential 

• Medium resource potential 

• Low resource potential. 

Management of Scientific, Traditional, Educational, Public, and Research Paleontological Resource Values 

Provide opportunities for local interpretation of paleontological resources. 

When appropriate, target fossil sites with high scientific value for excavation and curation either by the 

BLM or by an outside academic or curatorial/research facility to protect them from theft, erosion, and/or 

vandalism. If excavation is not carried out within one field season, periodic monitoring should be 

conducted to document the integrity of the site until complete collection is accomplished. 

Monitor high-significance (scientific or interpretive) sites with fossil resources that are not feasible or 

desirable to excavate or collect when possible to document their condition. Frequency of monitoring 

action for identified sites would be determined by the physical nature of the resource and potential threats. 

Develop onsite or community-based interpretation for significant sites/specimens to foster an appreciation 

for the unique nature of the resource and to create opportunities for public access to such resources. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-29 

Visual Resources 

Goals and Objectives 

• Plan, modify, and implement resource management activities in a manner that would minimize 

impacts on visual resources. 

• Manage the diversity of landscapes in the decision area for a desired level of change consistent 

with and giving consideration to other resource values and uses.

Management Actions 

Visual Resource Management Classes 

Designate the following acreages for the objectives defined for each VRM class (Map 6): 

• Class I: 76,000 acres 

• Class II: 94,400 acres 

• Class III: 210,700 acres 

• Class IV: 172,900 acres. 

WUI areas would be in VRM Class III or IV. 

Visual Intrusions 

To the extent practicable, bring existing visual contrasts into VRM class conformance as the opportunity 

arises. 

Non-WSA Lands with Wilderness Characteristics 

Goals and Objectives 

• Protect, preserve, and maintain wilderness characteristics (appearance of naturalness, outstanding 

opportunities for solitude, or primitive and unconfined recreation) of non-WSA lands with 

wilderness characteristics, as appropriate. Manage these primitive and backcountry landscapes for 

their undeveloped character and to provide opportunities for primitive recreational activities and 

experiences of solitude, as appropriate. 

Management Actions 

Maintenance of Non-WSA Lands with Wilderness Characteristics 

Manage the following non-WSA lands with wilderness characteristics (27,770 acres) specifically to 

protect, preserve, and maintain their wilderness characteristics: East of Bryce (850 acres), Moquith 

Mountain (9,600 acres), Orderville Canyon (2,700 acres), Parunuweap Canyon (120 acres), and Upper 

Kanab Creek (14,500 acres) (Map 7). 

Protect, preserve, and maintain wilderness characteristics through the following prescriptions: 

• Designate as VRM Class II (Map 6). 

• Close to commercial and personal-use forest and woodland product harvest (e.g., pole, post, 

firewood cutting, Christmas trees, seed collection, and wildings) except for incidental collection 

for onsite campfire use and administrative purposes. 

• Limited to designated routes (Map 10). 
Chapter 2 Proposed RMP and Final EIS 

2-30 Kanab RMP 

• Avoid new ROWs (linear, communication sites, and wind and solar projects) (Map 11). 

• Retain public lands in federal ownership 

• Close to mineral material disposals. 

• Open to fluid mineral leasing with major constraints (NSO) (Map 14). 

Drought and Natural Disasters 

Management Actions 

Coordinate appropriate management responses with affected parties when natural resources may be 

affected by drought, insects, diseases, or natural disasters. A variety of emergency or interim actions may 

be necessary to minimize land health degradations such as reduced forage allocations, reductions in the 

number of livestock and/or wildlife, increased mitigation measures to ensure reclamation, and limitations 

on energy field activities and recreational uses. 

Incorporate current Utah BLM Standards for Rangeland Health, as appropriate, across all resource 

programs. Management prescriptions in the form of constraints to use, terms and conditions, and 

stipulations may be needed to sustain rangeland health and viability. Management prescriptions will 

consider the following: 

• Surface disturbing activities—These will be closely monitored to ensure compliance with 

authorizations and permit’s conditions of approval or terms and conditions. Action minimizing 

new surface disturbance, allowed by regulations, and actions ensuring successful reclamation, 

will be emphasized. During periods of drought, the BLM could require additional actions such as 

changes to standard seed mix compositions, amount, and/or method of application. Additionally, 

methods to ensure successful revegetation following disturbance could include hydromulching, 

installation of drip irrigators, and fencing to exclude ungulate grazing/browsing. 

• Livestock grazing—During periods of prolonged drought use will be allowed in both quantity and 

timing that will not result in a downward shift in rangeland health and/or production. The BLM 

will work cooperatively to effect a grazing strategy specific to a grazing permittee’s individual 

grazing allotment(s) and make changes to the grazing authorizations, as appropriate, in 

accordance with the grazing regulations. In the case of drought, the BLM could temporarily close 

the range, or portions of it, to livestock grazing. 

• Wildlife management—During periods of prolonged drought to the extent that vegetation 

monitoring indicate that habitat for wildlife ungulate populations cannot be sustained and overall 

animal health is compromised, the BLM will enter into discussions with the UDWR regarding 

herd numbers and overall management options to combat the effects of drought. 

• Recreation—During periods of prolonged drought, the BLM, in cooperation with local and state 

fire management agencies, will limit campfires to established fire rings or fully contained fires. 

The last resort will be to close the public lands to campfires of any kind. 

• OHVs—Off-highway/road vehicle use during periods of prolonged drought could be further 

restricted, or if site-specific conditions warrant, closure to OHVs could be implemented to 

minimize vehicle-induced injury or damage to rangeland and/or woodland resources and to 

minimize the potential of spark-caused fires. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-31 

2.2.2 Resource Uses 

Forestry and Woodland Products 

Goals and Objectives 

• Provide a sustainable supply of a variety of commercial and non-commercial forest and woodland 

products. 

Management Actions 

Commercial Timber Harvest 

Permit commercial timber harvest on a case-by-case basis for the purposes of promoting or sustaining 

forest health. 

Woodland Product Harvest 

Permit commercial and non-commercial harvest of green or dead pinyon and juniper woodland products 

(e.g., cedar posts, Christmas trees, fuel wood, and biomass utilization) areawide unless otherwise 

designated or stipulated. Permit harvest of other woodland species on a case-by-case basis. 

Close WSAs and non-WSA lands with wilderness characteristics to woodland product harvest, except for 

incidental collection for onsite campfire use and administrative purposes. 

Permit harvesting of woodland products in riparian areas in proper functioning condition on a case-bycase basis for the maintenance and/or improvement of riparian ecosystems. 

Prohibit the removal of ponderosa pine for Christmas trees. 

Develop a Forest Woodland Management Plan as required in the Utah Forest and Woodland 

Management Action Plan. 

Native American Use of Forestry and Woodland Products 

Allow Native American non-commercial traditional use of forest and woodland products for the 

collection of herbs, medicines, traditional use items, or items necessary for traditional, religious, or 

ceremonial purposes, through permits. 

Livestock Grazing 

Allotments in the decision area that are managed under the Escalante and Paria Management Framework 

Plans (MFP) will be addressed by the Rangeland Health EIS being prepared by Grand Staircase–

Escalante National Monument (GSENM). 

Goals and Objectives 

• Maintain or restore healthy, sustainable rangeland ecosystems to meet BLM Utah’s Standards for 

Rangeland Health and to produce a wide range of public values such as wildlife habitat, livestock 

forage, recreation opportunities, clean water, and functional watersheds. 

• Integrate livestock use and associated management practices with other multiple-use needs and 

objectives to maintain, protect, and improve rangeland health. 
Chapter 2 Proposed RMP and Final EIS 

2-32 Kanab RMP 

• Reduce or eliminate livestock-related rangeland resource problems on all allotments not meeting 

rangeland health standards while maintaining a production goal of livestock forage in the long 

term. 

Management Actions 

Manage livestock grazing allotments within the decision area as available for livestock grazing. 

Forage Allocation 

Use an interdisciplinary allotment evaluation process to provide specific guidance and actions for 

managing livestock grazing. 

Allocate long-term increases and decreases in forage on a case-by-case basis based on an allotmentspecific analysis through the NEPA process. 

Allocate forage for livestock as noted in Table 3-24, except as noted below: 

• Close the Water Canyon Allotment to livestock grazing for the life of the plan in order to protect 

the Fredonia City Culinary water supply. 

• In order to have the RMP accurately reflect current management, combine the Lydia’s Canyon 

Allotment with the adjacent Lydia Allotment. The resulting Lydia Allotment would be available 

for livestock grazing with no additional livestock AUMs. 

• Maintain existing forage allocations on the Lower North Fork Allotment. 

• Maintain existing forage allocations on the Zion Park Allotment. 

• In order to have the RMP accurately reflect current management, combine the Sawmill Allotment 

with the adjacent South Canyon Allotment. The resulting South Canyon Allotment would be 

available for livestock grazing with no additional livestock AUMs. 

Grazing Management Practices 

Manage livestock grazing according to the Guidelines for Grazing Management on BLM Lands in Utah

(BLM 1997a), implementing these guidelines when authorizing livestock grazing use and related 

activities. 

Use livestock grazing to enhance ecosystem health and/or help accomplish resource objectives (e.g., 

noxious/invasive weed control and hazardous fuel reduction) on allotments where authorized by the 

authorized officer on a case-by-case basis. 

Consider requests for changes in kind of livestock on a case-by-case basis (except as outlined below), and 

after review evaluate potential impacts on riparian and upland vegetation and other resource uses. 

Allow motorized access to range improvements within WSAs according to the Interim Management 

Policy for Lands Under Wilderness Review (IMP). 

Design grazing systems and range improvements to achieve and maintain healthy rangelands. 

Analyze conversions in kind of livestock (such as from sheep to cattle) in light of the Standards for 

Rangeland Health. Allow conversion where they would not be adverse to achieving a standard, or they 

would not be in conflict with other decisions in this plan. 

Limit allocation of AUMs to the following kinds of livestock: 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-33 

• Domestic cattle 

• Horses 

• Sheep 

• Goats. 

Do not authorize changes in kind of livestock to sheep or goats within 9 miles of Desert bighorn sheep 

habitat (same as decision in the Fish and Wildlife section). 

Allocation of Relinquished Preference for Livestock Forage 

A grazing permittee may voluntarily relinquish in writing all or a percentage of the grazing preference 

that is attached to the base property they own for any reason they may choose. This action would not 

require consent or approval by the BLM or any other entity. The BLM would not be a party to or accept 

any contingencies or conditions associated with a relinquishment that would require future BLM action(s) 

such as discontinuing livestock grazing. Once the preference and associated permitted use has been 

relinquished in whole or in part, it would remain available for application for preference and a grazing 

permit. However, upon relinquishment, the BLM may determine through a site-specific evaluation and 

associated NEPA analysis that the public lands within a grazing allotment are better used for other 

purposes, such as recreation, wildlife, watershed for a culinary water source, disposal, etc. or a 

combination of these and/or other uses. Grazing may then be discontinued on the allotment through an 

amendment to the existing RMP or a new RMP effort. Any decision issued concerning discontinuance of 

livestock grazing on federal lands would not be permanent and would be subject to reconsideration during 

subsequent revision or amendment of the RMP. The evaluation and associated NEPA analysis may also 

determine that resource conditions are such that livestock grazing should be temporarily discontinued 

until site-specific resource objectives have been achieved. This evaluation and NEPA analysis would 

include a narrative with an evaluation time frame and process identified, indicating that once the 

objectives have been achieved the BLM would reconsider application(s) for grazing use. 

Mitigating Conflicts Between Livestock Grazing and Other Uses 

Give emphasis to changes in grazing management practices (e.g., changing season of use and fencing) 

before reducing AUMs on allotments to resolve conflicts with other uses. 

Suspend authorization of AUMs in areas of intensive surface disturbance (such as surface coal mining) 

until rehabilitation is complete. 

Range Treatments for Livestock Grazing 

Complete land treatments to maintain or provide additional AUMs needed to meet the demand for 

livestock forage and divide the AUMs proportionally among all operators within the affected allotments. 

Prioritize treatments on the following allotments (Map 5): 

• South Canyon 

• Sethy’s Canyon 

• Sandy Creek 

• Sanford Bench 

• Sugar Knoll 

• Spring Hollow 

• Circleville Cove 

• Kane Spring (non-WSA portion) 

• Buck Knoll 

• Spencer Bench 
Chapter 2 Proposed RMP and Final EIS 

2-34 Kanab RMP 

• Clay Flat 

• Harris Flat 

• Three Mile 

• Limestone Canyon 

• Spry 

• Chris Spring 

• Big Flat 

• Limekiln Creek 

• Poverty Flat (non-WSA portion) 

• Roller Mill 

• Oak Spring 

• Yellowjacket (non-WSA portion) 

• Dog Valley 

• Bald Knoll 

• Alton Cove 

• Coop Creek 

• Areas that are not achieving Standards for Rangeland Health. 

Recreation 

OHV and other transportation decisions are primarily included in the transportation management 

decisions. 

Goals and Objectives 

• Provide recreational activities in a variety of physical, social, and administrative settings, from 

primitive to near-urban, that allow visitors to have desired recreational experiences and enjoy the 

resulting benefits. 

• Provide for public health and safety through interpretation, facility development, and visitor 

management. 

• Manage and protect recreational areas and resources containing significant scenic, natural, and 

cultural values as well as areas with scientific importance. 

• Provide opportunities for visitor use and enjoyment of the area, consistent with resource 

capabilities and mandated resource requirements; provide for visitor education and interpretation 

of the recreational opportunities within the decision area. 

• Maintain important recreational values and sites in federal ownership to ensure a continued 

diversity of recreation activities, experiences, and benefits. 

Management Actions 

Special and Extensive Recreation Management Areas 

Identify the following Recreation Management Areas (RMA) (Map 8): 

• Kanab Community SRMA (community) (33,100 acres) 

• Paria SRMA (destination) (21,200 acres) 

• Moquith Mountain SRMA (community) (15,000 acres) 

• Orderville Canyon SRMA (undeveloped) (1,950 acres) 

• North Fork Virgin River SRMA (undeveloped) (1,050 acres) 

• Escalante SRMA (community) (22,800 acres) 

• Kanab Field Office Extensive Recreation Management Area (ERMA) (458,900 acres). 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-35 

Recreation management direction for each SRMA is outlined in Appendix 4. This includes direction for 

the following recreation management components: 

• Recreation Niche 

• Recreation Management Objectives 

• Primary Activities 

• Experiences 

• Benefits 

• Setting Character Conditions. 

Develop SRMA management plans that identify site-specific development needs to achieve recreation 

benefits, experiences, and objectives. 

Portions of the decision area not identified as an SRMA would be identified as an ERMA. ERMAs would 

receive only custodial management (which addresses only activity opportunities) of visitor health and 

safety, user conflict, and resource protection issues with no activity-level planning. Therefore, actions 

within ERMAs would generally be implemented directly from LUP decisions. 

Kanab Community SRMA

Market Strategy: Community 

OHV RMZ (18,500 acres) 

Recreation Niche: Close-to-town OHV travel in an exceptionally scenic setting with a variety of trails 

for different skill levels. 

Primary Activities: Driving OHVs, viewing scenery and wildlife, photography, spending time with 

friends and family, and participating in and/or viewing competitive/organized events. 

Required Management: 

• OHV: Minimal designated routes to access RMZ and provide a variety of OHV opportunities 

• VRM: Class III 

• Minerals: Open to oil and gas leasing subject to major constraints (NSO) 

• Facilities: Provide support facilities for recreation experience. 

Non-Motorized RMZ (14,600 acres) 

Recreation Niche: Town-accessible hiking and equestrian trail network offering outstanding views and 

varied terrain. 

Primary Activities: Hiking, rock-scrambling, viewing scenery and wildlife, photography, equestrian, 

spending time with friends and family, and participating in and/or viewing competitive/organized events. 

Required Management (outside the Moquith Mountain non-WSA lands with wilderness characteristics 

area) (10,700 acres): 

• OHV: Limit to designated routes to access trail heads 

• VRM: Class II 

• Minerals: Open to oil and gas leasing subject to major constraints (NSO) 

• Facilities: Provide support facilities for recreation experience. 
Chapter 2 Proposed RMP and Final EIS 

2-36 Kanab RMP 

Required Management (inside the Moquith Mountain non-WSA lands with wilderness characteristics 

area) (3,900 acres): 

• Designate as VRM Class II. 

• Close to commercial and personal-use forest and woodland product harvest (e.g., pole, post, 

firewood cutting, Christmas trees, seed collection, and wildings) except for incidental collection 

for onsite campfire use and administrative purposes. 

• Limited to designated routes. 

• Avoid new ROWs (linear, communication sites, and wind and solar projects). 

• Retain public lands in federal ownership 

• Close to mineral material disposals. 

• Open to fluid mineral leasing with major constraints (NSO). 

Paria SRMA

Market Strategy: Destination 

Canyon RMZ (1,100 acres) 

Recreation Niche: World-class wilderness trekking adventure viewing deeply entrenched slickrock 

canyon and associated slot canyon features. 

Primary Activities: Hiking and scrambling, backpacking, canyoneering, outdoor photography, camping, 

viewing scenic vistas, viewing cultural sites, and wilderness exploration. 

Required Management: 

• Manage according to the management actions for the Paria Canyon-Vermilion Cliffs Wilderness 

Uplands RMZ (20,100 acres) 

Recreation Niche: Unique, world-class primitive and backcountry adventure recreation viewing unique 

upland geologic features. 

Primary Activities: Hiking and scrambling, outdoor photography, viewing wildlife and scenic vistas, 

wilderness exploration, equestrian, and camping. 

Required Management: 

• Manage according to the management actions for the Paria Canyon-Vermilion Cliffs Wilderness 

Moquith Mountain SRMA

Market Strategy: Community 

Dunes RMZ (1,000 acres) 

Recreation Niche: Unique, scenic, and expansive sand dunes OHV opportunities. 

Primary Activities: Driving among sand dunes, camping along dune fringes, photography, and spending 

time with friends and family. 

Required Management (the Dunes RMZ is entirely within the Moquith Mountain WSA): 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-37 

• According to IMP 

• OHV: Open beyond vegetated and conservation areas. All vehicles on the dunes are required to 

stay at least 10 feet from vegetation. 

• VRM: Class I. 

• Facilities: Provide support facilities for recreation experience. 

Non-Dunes Wooded RMZ (14,000 acres) 

Recreation Niche: Scenic and extensive OHV trail network accessing vistas, overlooks, flora and fauna, 

and cultural sites. 

Primary Activities: Driving OHVs; viewing flora/fauna, geology, and cultural sites; hiking; equestrian; 

camping; hunting; photography; and spending time with friends and family. 

Required Management (the Non-Dunes Wooded RMZ is partially inside the Moquith Mountain WSA) 

(10,600 acres): 

• According to IMP 

• OHV: Limit to designated routes to access trail heads 

• VRM: Class I. 

• Facilities: Provide support facilities for recreation experience. 

Required Management (the Non-Dunes Wooded RMZ is partially inside the Cottonwood Canyon ACEC) 

(3,700 acres): 

• OHV: Limit to designated routes to access trail heads 

• VRM: Class II. 

• Minerals: Open to oil and gas leasing subject to major constraints (NSO), recommend 

withdrawing from mineral entry, close to mineral material disposals 

• Facilities: Provide support facilities for recreation experience. 

Required Management (for the remainder of the Non-Dunes Wooded RMZ): 

• OHV: Limit to designated routes to access trail heads 

• VRM: Class III 

• Minerals: Open to oil and gas leasing subject to major constraints (NSO) 

• Facilities: Provide support facilities for recreation experience. 

Dry Lakebed (Implementation-Level Decision)∗

• No dumping of grey water or black water from RV units. 

• Firepans required for all open fires, and firewood must be packed in from outside the SRMA. 

• No digging of holes or pits. 

• No construction of fire-rings. 

• All trash and fire residue must be packed out and not left in the SRMA. 

 

∗ This is an implementation-level decision that cannot be protested under the planning regulations. Please see the cover letter for 

further information. 
Chapter 2 Proposed RMP and Final EIS 

2-38 Kanab RMP 

Ponderosa Grove Campground (Implementation-Level Decision)∗

• No dumping of grey water or black water from RV units. 

• No fires outside of established campsite fire grates. 

• No digging of holes or pits. 

Orderville Canyon SRMA

Market Strategy: Undeveloped 

(1,950 acres) 

Recreation Niche: Spectacular, primitive riparian canyon travel with abundant geologic formations and 

diverse flora and fauna. 

Primary Activities: Canyoneering, hiking, backpacking, hunting, camping, outdoor photography, 

viewing nature and wildlife, equestrian, and studying geology. 

Required Management (the Orderville Canyon SRMA is entirely within the Orderville Canyon WSA and 

500 acres of the SRMA are within the Orderville Canyon suitable “wild” segment): 

• According to IMP 

• OHV: Limit to designated routes except closed to OHV use within the 500 acres of the Orderville 

Canyon suitable “wild” segment 

• VRM: Class I 

• Facilities: Provide support facilities for recreation experience. 

North Fork Virgin River SRMA

Market Strategy: Undeveloped 

(1,050 acres) 

Recreation Niche: Spectacular, primitive riparian canyon travel with abundant geologic formations and 

diverse flora and fauna. 

Primary Activities: Canyoneering, hiking, backpacking, hunting, camping, outdoor photography, 

viewing nature and wildlife, equestrian, and studying geology. 

Required Management (the North Fork Virgin River SRMA is entirely within the North Fork Virgin 

River WSA and 200 acres of the SRMA are within the North Fork Virgin River suitable “wild” segment): 

• According to IMP 

• OHV: Limit to designated routes except closed to OHV use within the 200 acres of the North 

Fork Virgin River suitable “wild” segment 

• VRM: Class I 

• Facilities: Provide support facilities for recreation experience. 

 

∗ This is an implementation-level decision that cannot be protested under the planning regulations. Please see the cover letter for 

further information. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-39 

Escalante SRMA

Market Strategy: Community 

(22,800 acres) 

Recreation Niche: Town-accessible OHV touring, mountain biking, and hiking/equestrian trail networks 

offering outstanding views and varied terrain. 

Primary Activities: OHV touring, mountain biking, hiking, rock-scrambling, viewing scenery and 

wildlife, photography, equestrian, spending time with friends and family, and participating in and/or 

viewing competitive/organized events. 

Required Management: 

• OHV: Limit to designated routes 

• VRM: Class III 

• Minerals: Open to leasing subject to standard terms and conditions

• Facilities: Provide support facilities for recreation experience. 

Kanab Field Office ERMA

(458,900 acres) 

Primary Activities: OHV touring; hiking; picnicking; backpacking; hunting; fishing; camping; 

equestrian; outdoor photography; viewing geologic features, nature, and wildlife; and participating in 

and/or viewing competitive/organized events. 

Required Management: 

• Facilities: Provide support facilities for recreation experience. 

General Recreation Management 

Develop recreation sites and facilities needed to accommodate users, facilitate recreational uses of public 

lands, and protect resources. 

Implement the necessary safety measures to protect visitors in the Coral Pink Sand Dunes/Moquith 

Mountain area through coordination between the BLM and the State of Utah. Emphasis would be placed 

on minimizing interaction between motorized and non-motorized uses on the sand dunes, as well as 

enforcement of existing state and federal laws and policies. The existing OHV trails adjacent to Hancock 

Road would be closed. BLM and State Park personnel would continue to cooperate with local authorities 

on law enforcement matters. 

Regulate rock climbing within 300 feet of cultural sites. Climbing routes that impact cultural resource 

sites would generally not be allowed, and climbing routes designed to access cultural resource sites would 

not be allowed unless under permit for scientific investigation. 

No person or persons should occupy one area on BLM lands within the decision area for longer than 

14 consecutive days in any 28-day period; however, extensions beyond the 14-day length of stay could be 

authorized for permitted uses on a case-by-case basis. Any site on public land within 30 air miles 

constitutes the same area for the purpose of this management decision. 
Chapter 2 Proposed RMP and Final EIS 

2-40 Kanab RMP 

Close areas to rock climbing within the distance and time restrictions identified in the management of 

raptor habitat decisions. 

Use the minimum necessary signage to provide for public safety and information or to control 

unauthorized use. 

Design facilities to be compatible with the local landscapes and recreation experience. 

Management responses to unacceptable resource and/or social conditions would range from least 

restrictive methods (e.g., information and education) to most restrictive (e.g., visitor limits, supplemental 

rules, or restrictions). Where feasible, the least restrictive methods would be the first priority. (Recognize 

that various levels of regulations and limits are necessary. Restrictions and limitations on public uses 

should be as small as possible without compromising the primary goal.) Use on-the-ground presence as a 

tool to protect public lands. 

Developed recreation sites would be recommended for withdrawal from mineral entry, closed to mineral 

material disposal, and open to oil and gas leasing subject to major constraints (NSO). 

Developed recreation sites would be fenced to exclude grazing use. 

Identify areas for rock crawling where impacts could be minimized or eliminated and where such use 

would be compatible with other resource goals and objectives. 

Dispersed Camping

Allow dispersed camping throughout the decision area without permit, unless specified in the plan. 

Limit vehicle parking for dispersed camping within 150 feet of designated routes. 

Interpretation and Environmental Education

Provide information regarding recreation opportunities, interpretation of natural and human history, and 

specific rules and regulations pertaining to use of public lands to visitors. 

Provide education and outreach programs such as Tread Lightly or Leave No Trace. 

Provide information on the area’s cultural and natural resources through outreach programs (e.g., 

organizations, schools, and partnerships) to build emotional, intellectual, and recreational ties with the 

area. 

Public information would be provided only for those cultural sites designated for public use. 

Heritage Tourism

Coordinate with local communities and other groups to foster heritage tourism throughout the decision 

area. 

Big Game Retrieval

Allow use of non-motorized wheel carriers to retrieve game kills outside of WSAs. 

Acquisition of Easements

Acquire legal access to areas of high recreation interest from willing parties. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-41 

Night Skies and Soundscapes

Impacts on night sky would be considered and mitigated through the application of specific mitigation 

measures (e.g., down lighting and low-level lighting) identified in activity-level planning and NEPA 

review. See also Lands and Realty restrictions on the use of strobe lights. 

Impacts to soundscapes around national parks would be considered and mitigated through the application 

of specific mitigation measures identified in activity-level planning and NEPA-level review. 

Special Recreation Permits 

Issue SRPs after evaluation of the various factors including the following: 

• Use conforms to the recreation goals and objectives outlined in the Resource Management Plan 

• Nature of proposed event or activity (i.e., commercial versus competitive) 

• Size (acreage) and sensitivity of land and resources affected (ACEC, WSA, VRM) 

• Compatibility with other uses, activities, and visitors in that area 

• Proposed number of participants and group size 

• Associated vehicle and equipment 

• Time (daily, seasonally) and duration of proposed use 

• Potential social impacts (crowding, group encounters, conflicting activities, and/or experiences) 

• Specific resources impacted (e.g., wildlife, cultural, paleontology, visual, riparian, soil, air, and 

water) 

• Rehabilitation and monitoring needs and feasibility 

• Support needs (people, equipment, supplies, vehicles) 

• Safety issues. 

Vending would be authorized in conjunction with organized events when it directly supports the 

recreation experience and is appropriate to support the experience and setting as outlined in the Resource 

Management Plan and when the vending is necessary to support resource protection or appropriate 

recreation use. 

Vending along scenic byways and backways would be coordinated with the Scenic Byway coordination 

committees and local government and highway authorities. 

In protected and restricted MSO habitat, limit SRP group size to no more than 12 according to recovery 

plan. 

Prohibit OHV or mountain bike tours in the following areas: 

• Where compliance with the Utah Riparian Policy would not be achieved 

• The loop within Moquith Mountain WSA 

• The Elephant Cove Way within Parunuweap WSA. 

Limit camping associated with SRPs to areas beyond 200 feet of riparian areas unless specific campsites 

are required during permitting. Approval of these specific campsites would be considered on a case-bycase basis. 

Group size would be limited to 12 people total (including tour guides) in the following areas: 

• Wetlands/riparian zones 

• WSAs 

• Designated critical habitat for special status species. 
Chapter 2 Proposed RMP and Final EIS 

2-42 Kanab RMP 

Group size would be limited to 25 people total in the remainder of the decision area, with permits for 

groups of more than 25 people being considered on a case-by-case basis in areas where resources would 

not be damaged. 

SRPs would be subject to the following restrictions unless specifically authorized: 

• No collection of natural resources (not including firewood for personal onsite use). 

• No SRP activities would be authorized in bald eagle winter roost areas from November 15 

through March 15 during critical roosting hours (from 1 hour after sunset to 9 a.m.). 

• If surveys reveal the presence of nesting Southwestern willow flycatchers, authorize no SRP 

activities in these locations between May 15 and June 30. 

• No Greater sage-grouse lek areas would be advertised by SRP holders or the BLM. 

• Implement seasonal/area closures during Greater sage-grouse breeding (March 1 to April 30) 

and/or wintering (November 1 to February 28) seasons if BLM biologists determine that breeding 

or wintering is being impacted by SRP activities. 

Transportation 

Goals and Objectives 

• Maintain access, where needed, to meet public and administrative needs including acquiring or 

maintaining necessary access across non-federal land. 

• Compatible traditional, current, and future use of the land would be sustained by establishing a 

route system that contributes to protection of sensitive resources, accommodates a variety of uses, 

and minimizes user conflicts. 

• Public access, resource management, and regulatory needs would be considered through 

transportation planning, incorporating consideration of access needs and the effects of and 

interaction among all forms of travel, including motorized, mechanized, and nonmotorized/mechanized travel. 

• Coordinate OHV management with adjacent BLM field offices and other agencies where 

possible. 

• Provide opportunities for OHV use on public lands. 

Management Actions 

OHV Area Designations 

Management of motorized access would balance protection of resources while providing for resource use 

needs. Area designations would be as follows (Map 9): 

• Open to cross-country OHV use: 1,000 acres 

• Limited to designated routes: 528,000 acres 

• Closed to OHV use: 25,000 acres. 

See Recreation section for specific management of OHV use in SRMAs. 

Areas Open for Cross-Country OHV Use 

Designate the following managed open areas: 

• Moquith Mountain SRMA: Dunes RMZ beyond vegetated and conservation areas 

• DD Hollow topsoil pit. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-43 

Areas Where OHV Use Would Be Limited Spatially or Seasonally 

Spatial Limitations

Management of OHV use in areas not designated as open or closed would be limited to designated routes 

(528,000 acres) (Map 9). 

Seasonal Limitations

Designated routes on the north side of Pugh Canyon are closed annually to motorized use between 

February 1 and August 31 if a breeding pair of raptors is using the area (to protect the reproductive 

success of a breeding pair of raptors). If no nesting behavior is initiated prior to June 1, a BLM authorized 

officer could open the route to motorized use. During the remainder of the year OHV use would be 

limited to designated routes. 

Designated Routes (Implementation-Level Decision)∗

Manage inventoried routes as follows (Map 10): 

• Open to motorized vehicle use: 1,403 miles 

• Limited (closed seasonally) to motorized vehicle use: 2 miles 

• Closed to motorized vehicle use: 75 miles. 

Consideration of route and trail modifications (new or existing) would be conducted on a case-by-case 

basis in accordance with resource/use objectives and after appropriate NEPA review and analysis 

(Appendix 7). 

Areas Closed to OHV Use 

Designate the following areas as closed to OHV use: 

• Paria SRMA—both RMZs 

• Designated wilderness (by Congressional designation) 

• In and through islands of vegetation in Welsh’s milkweed designated critical habitat (790 acres) 

• Suitable “wild” river corridors. 

Transportation System Management 

Coordinate transportation planning with Kane and Garfield counties. 

The BLM would continue to repair, maintain, and rehabilitate routes to maintain existing route 

conditions. Route modifications (new facilities or expansion of existing facilities) would be determined 

on a case-by-case basis in accordance with resource/use objectives and after appropriate NEPA review 

and analysis. 

Pursue maintenance agreements with highway authorities in the decision area. 

BLM, in preparing its RMP designations and its implementation-level travel management plans, is 

following policy and regulation authority found at 43 CFR 8340, 43 CFR 8364, and 43 CFR 9268. 

 

∗ This is an implementation-level decision that cannot be protested under the planning regulations. Please see the cover letter for 

further information. 
Chapter 2 Proposed RMP and Final EIS 

2-44 Kanab RMP 

Where the authorized officer determines that OHVs are causing or would cause considerable adverse 

impacts, the authorized officer shall close or restrict such areas. Local highway authorities would be 

consulted as appropriate. The public would be notified. 

BLM could impose limitations on the types of vehicles allowed on specific designated routes if 

monitoring indicates that a particular type of vehicle is causing disturbance to the soil, wildlife habitat, 

cultural or vegetative resources, especially by off-road travel in an area that is limited to designated 

routes. 

As per the State of Utah v. Andrus, October 1, 1979 (Cotter Decision), BLM would grant the State of 

Utah reasonable access to state lands for economic purposes on a case-by-case basis. 

Where routes would remain available for motorized use within WSAs, such use could continue on a 

conditional basis. Use of the existing routes in the WSAs (“ways” when located within WSAs) could 

continue as long as the use of these routes does not impair wilderness suitability, as provided by the IMP 

(BLM 1995). If Congress designates the area as wilderness, the routes will be closed. In the interim, if use 

and/or non-compliance are found through monitoring efforts to impair the area’s suitability for wilderness 

designation, BLM would take further action to limit use of the routes or close them. The continued use of 

these routes, therefore, is based on user compliance and non-impairment of wilderness values. 

Lands and Realty 

Goals and Objectives 

• Make public lands available for community growth and expansion needs, recreation, and public 

purposes as well as other infrastructure needs. 

• Strive to increase and diversify our Nation’s sources of traditional and alternative energy resources, 

improve our energy transportation network, and ensure sound environmental management in 

support of minerals and energy development, as required by the President’s National Energy Policy 

and the Energy Policy Act of 2005. 

• Retain in public ownership public lands that enhance multiple-use management, allow access to 

public lands, or contain sensitive or rare resources. 

• Acquire lands or interests in lands to complement existing resource values and uses. 

• Consider for disposal lands or interests in lands that are difficult and uneconomic to manage as part 

of the public lands, are no longer needed for a federal purpose, or where disposal would serve 

important public objectives. 

• Resolve any outstanding State Grant entitlements (quantity grants, in-lieu selections). 

• Make public lands available for ROWs, permits, and leases. The suitability for these land actions 

would be judged on a case-by-case basis. 

• Consider energy and utility corridors to focus placement of new major ROWs for energy and 

transportation systems. 

Management Actions 

Management of ROWs and ROW Corridors 

Prepare communication site plans for all existing communication sites before any new types of uses or 

new facilities would be authorized on the site. Site plans would be prepared for all new communication 

sites before any development of the site(s) would be authorized. 

Evaluations for the siting and construction of communications towers will take into account potential 

impacts on migratory birds. Measures to avoid and minimize impacts would be considered during design, 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-45 

including avoiding known bird migration corridors, eliminating guy wires, restricting height of towers to 

less than 200 feet, and installing minimum lighting with use of white strobe lights rather than red (strobe 

or non-strobe) lights. The addition of new communications devices on existing towers will be considered 

where it is practical and does not present a safety or operational risk. 

Require a feasibility study and site plan for new communications locations. 

Exclude new ROWs (including communication sites) (75,700 acres) in the following areas (Map 11): 

• WSAs 

• Wilderness areas 

• Suitable WSR corridors with a tentative classification of “wild” or “scenic.” 

Avoid new ROWs (106,670 acres) in the following areas (Map 11): 

• The five non-WSA lands with wilderness characteristics managed to protect, preserve, and 

maintain those characteristics (27,700 acres) 

• Within 1 mile of an active Greater sage-grouse lek (avoid ROWs with high-profile structures 

[e.g., buildings, storage tanks, overhead powerlines, wind turbines, towers, and windmills]) 

• Within Greater sage-grouse nesting and brood-rearing habitat (avoid ROWs with high-profile 

structures [e.g., buildings, storage tanks, overhead powerlines, wind turbines, towers, and 

windmills]. 

Preference would be to locate ROW developments in common (within existing ROWs/disturbance areas). 

Consider burying new and reconstructed utility lines (including powerlines up to 24 kilovolts [kV]) 

unless: 

• Visual quality objectives can be met without burying 

• Geologic conditions make burying infeasible 

• Burying would produce greater long-term site disturbance. 

New and reconstructed powerlines must meet non-electrocution standards for raptors. If electrocution or 

line strike issues develop with existing powerlines, corrective actions to meet these non-electrocution 

standards would be taken. 

Construct powerlines greater than 230 kV using non-reflective wire. Towers would be constructed using 

non-reflective material. Powerlines would not be high-lined unless no other location exists. 

Linear crossings, such as pipelines, utilities, or roads, across riparian areas and/or ephemeral channels 

would be considered on a case-by-case basis to protect the above areas. Surface disturbing activities 

would be avoided on unstable areas, such as landslides, and slumps. 

Areas Recommended for Withdrawal 

Request the cancellation of the Classification and Multiple Use Act of 1964 classifications segregating the 

following lands from all forms of appropriation including mineral location: 

• Township 42 S, Range 7 W, Sec. 4, Lots 5, 6, 11, and 12 (140.05 acres) 

• Township 43 S, Range 7 W, Sec. 7, NE1

/4 (160 acres) 

• Township 43 S, Range 7 W, Sec. 14, SE1

/4 (160 acres) 

• Township 43 S, Range 7 W, Sec. 17, NW1

/4, SE1/4SE1/4 (200 acres) 
Chapter 2 Proposed RMP and Final EIS 

2-46 Kanab RMP 

• Township 43 S, Range 8 W, Sec. 13, NW1/4NW1/4 (40 acres) 

• Township 43 S, Range 8 W, Sec. 14, NE1

/4NE1/4 (40 acres). 

The values for which these lands were classified would be reviewed and if they still warrant protection, 

specific protective withdrawals under FLPMA Section 204 would be obtained prior to the cancellation of 

the existing classifications. 

Existing Withdrawals

Review existing withdrawals on a case-by-case basis. Determine whether the use is consistent with the 

intent of the withdrawal and whether the withdrawal should be continued, modified, revoked, or 

terminated. 

Manage land becoming unencumbered by withdrawals in a manner consistent with adjacent or 

comparable public land within the planning area. 

New Withdrawals

Limit the size of proposed withdrawals to the minimum acreage consistent with the demonstrated need. 

In addition to the 24,591 acres withdrawn, recommend the following areas (9,500 acres) for withdrawal 

from mineral entry (Map 12): 

• Cottonwood Canyon ACEC 

• Developed recreation sites 

• Suitable “wild” river corridors 

• Suitable “scenic” river corridors 

• Relict vegetation areas (Diana’s Throne and Elephant Butte). 

Review existing withdrawals to determine whether they are serving the purposes for which they were 

withdrawn. 

Existing Classifications and Segregations

Review existing classifications and segregations on a case-by-case basis to determine whether the 

classification or segregation is appropriate and should be continued, modified, or terminated. A notice of 

termination and opening order would be published to notify the public when and to what extent the land 

will be opened, consistent with planning decisions. Land on which a classification or segregation has been 

terminated would be managed in a manner consistent with adjacent or comparable public land within the 

planning area. 

Areas and Lands Available for Land Tenure Adjustment 

Public lands, in order to be considered for any form of land tenure adjustment (including exchanges, inlieu selections, desert land entries, R&PP, easement acquisitions, etc.), except for FLPMA Section 203 

sales, must meet one or more of the following criteria: 

• Is in the public interest; accommodates the needs of state, local, or private entities, including for 

the economy and community growth and expansion; and is in accordance with other land use 

goals, objectives, and planning decisions 

• Results in net gain of important and manageable resource values on public lands such as crucial 

wildlife habitat, significant cultural sites, high-value recreation areas, high-quality riparian areas, 

live water, special status species habitat, or areas key to maintenance of productive ecosystems 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-47 

• Ensures the accessibility of public lands in areas where access is needed and cannot otherwise be 

obtained 

• Is essential to allow effective management of public lands in areas where consolidation of 

ownership is necessary to meet resource management objectives 

• Results in the acquisition of lands that serve a national priority as identified in national policy 

directives. 

Habitat for listed threatened, endangered, and candidate species would be retained in federal ownership 

unless land tenure adjustments would result in a net increase of habitat. All actions involving listed 

species or their habitat would result in the proper consultation with USFWS. Land tenure adjustments 

may be considered with the State of Utah and others after consultation with and concurrence by USFWS. 

Retain non-WSA lands with wilderness characteristics in federal ownership where identified to protect, 

preserve and maintain their wilderness characteristics. 

Lands with mining claims could be considered for disposal if the following apply: (1) the new surface 

owner is the mining claimant, or (2) the new surface owner agrees to accept the surface with the claim 

encumbrance. 

Approximately 6,400 acres of public land would be available for FLPMA Section 203 sales with NEPA 

compliance and consistent with other decisions in this RMP (Map 13; Appendix 5). 

Manage oil and gas with NSO stipulations on R&PP leases. If these sites are no longer required, they 

would be managed as are adjacent lands. 

Give land exchanges with the State of Utah priority consideration to resolve inholdings issues. 

As per the Cotter Decision, reasonable access to state lands would be authorized for economic purposes. 

Alternative Energy Resource Development (Wind Energy and Solar Energy Development) 

Adopt programmatic policies and BMPs in the Wind Energy Development Program identified in Record 

of Decision for Implementation of a Wind Energy Development Program and Associated Land Use Plan 

Amendments (BLM 2005e). 

Consider proposals for ROWs for wind and solar energy development throughout the decision area with 

the following exceptions: 

• Designated wilderness 

• WSAs 

• ACECs 

• Suitable WSR corridors. 

Management of Filming Permits 

Filming may be authorized throughout the decision area after site-specific NEPA analysis is completed. 
Chapter 2 Proposed RMP and Final EIS 

2-48 Kanab RMP 

Minerals and Energy 

Goals and Objectives 

• Provide opportunities for mineral exploration, development, and reclamation under the mining 

and mineral leasing laws (e.g., coal mining, alabaster gypsum), subject to legal requirements to 

protect other resource values. 

• Provide salable and free-use mineral materials to meet local demand through the case-by-case 

issuance of permits and sale contracts. 

• Identify lands available for mineral leasing and development. 

Management Actions 

Oil and Gas Leasing 

Close public lands or federal mineral estate within incorporated municipalities to mineral leasing in 

accordance with the Mineral Leasing Act (30 United States Code [U.S.C.] 181 and 43 CFR 3100.0-

3(a)(2)(iii) and 3100.0-3(b)(2)(ii)). 

Exceptions, waivers, or modifications to stipulations on oil and gas leases and other surface disturbing 

activities may be considered on a case-by-case basis in accordance with Appendix 3 guidelines. 

Manage the following sites as open to leasing subject to major constraints (NSO): 

• Cemeteries 

• Landfills, existing and closed 

• Lands managed under R&PP Act leases 

• Developed recreation sites 

• Airports 

• Federal facilities. 

Manage fluid mineral leases as shown on Map 14: 

• Open to leasing subject to standard terms and conditions: 95,400 acres 

• Open to leasing subject to moderate constraints (seasonal and CSU): 296,200 acres 

• Open to leasing subject to major constraints (NSO): 83,400 acres 

• Closed to leasing: 79,000 acres. 

In accordance with an UDEQ-DAQ letter dated June 6, 2008, (see Appendix 12) requesting 

implementation of interim nitrogen oxide control measures for compressor engines; BLM will require the 

following as a Lease Stipulation and a Condition of Approval for Applications for Permit to Drill: 

• All new and replacement internal combustion gas field engines of less than or equal to 300 

design-rated horsepower must not emit more than 2 gms of NOx per horsepower-hour. This 

requirement does not apply to gas field engines of less than or equal to 40 design-rated 

horsepower. 

• All new and replacement internal combustion gas field engines of greater than 300 design rated 

horsepower must not emit more than 1.0 gms of NOx per horsepower-hour. 

Geophysical Exploration 

Limit vehicular use for necessary tasks, such as geophysical exploration including project survey and 

layout, to OHV designations. Exceptions may be granted by permit on a case-by-case basis. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-49 

Allow geophysical operations consistent with existing regulations and policies and subject to constraints 

in areas with special designations (WSA, ACEC, WSR segments tentatively classified as “wild” or 

“scenic”) as determined through site-specific NEPA analysis. 

Other Leasable Minerals 

Lease geothermal resources consistent with oil and gas leasing stipulations and consistent with other 

resource objectives. 

Areas Available for Further Coal Leasing Consideration 

Make available for further coal leasing consideration approximately 113,629 acres (Map 15) 

(Appendix 6). Approximately 37,580 acres (Map 15) are determined to be unsuitable based on the 20 

criteria identified in Appendix 6. 

Additional areas could be found unsuitable based on site-specific analysis (Appendix 6). 

Incorporate erosion control stipulations in mining plans for surface mining disturbance as per Surface 

Mining Control Reclamation Act regulations. 

Locatable Minerals 

Allow location, exploration, and development of locatable minerals on public lands except where 

withdrawn. Evaluate operations for exploration and development in the context of its requirement to 

prevent unnecessary and undue degradation of other resources. 

In addition to the 24,591 acres withdrawn, recommend withdrawing the following areas (9,500 acres) 

from mineral entry (Map 12): 

• Cottonwood Canyon ACEC 

• Developed recreation sites 

• Suitable “wild” river corridors 

• Suitable “scenic” river corridors 

• Relict vegetation areas (Diana’s Throne and Elephant Butte). 

Mineral Materials 

Allow mineral material disposals on a case-by-case basis subject to site-specific environmental analysis 

excluding the following areas (105,000 acres) (Map 16): 

• Cottonwood ACEC 

• Relict Vegetation (Diana’s Throne and Elephant Butte) 

• WSAs 

• Non-WSA lands with wilderness characteristics 

• Paria Canyon–Vermilion Cliffs Wilderness area (closed to mineral material disposals by 

congressional designation) 

• Suitable “wild” river corridors 

• Suitable “scenic” river corridors 

• Developed recreation sites. 

Incorporate erosion control and rehabilitation stipulations into mining plans. 
Chapter 2 Proposed RMP and Final EIS 

2-50 Kanab RMP 

2.2.3 Special Designations 

Areas of Critical Environmental Concern 

Goals and Objectives 

• Designate and manage as ACECs areas where special management attention is required to 

protect and prevent irreparable damage to important historic, cultural, or scenic values; 

protect fish and wildlife resources or other natural system or processes; or protect life and 

safety from natural hazards. 

Management Actions 

Include stipulations for permitted actions within the designated ACEC to ensure relevant and important 

values, resources, processes, systems, and hazards are protected or managed for. 

Designate and manage the 3,800 acres as the Cottonwood Canyon ACEC (Map 17). Manage the relevant 

and important values as follows: 

Scenic: 

• Designate as VRM Class II 

• Limit OHV use to designated routes 

• Open to oil and gas leasing subject to major constraints (NSO) 

• Recommend withdrawing from mineral entry 

• Close to mineral material disposals. 

Cultural: 

• Monitor specific sites on a regular basis 

• Retain all lands and interests in land in federal ownership 

• Work with the School and Institutional Trust Lands Administration (SITLA) to acquire state 

inholdings. 

Hazard/Safety/Public Welfare: 

• Close the Water Canyon Allotment (48 AUMs) to livestock grazing in order to protect the 

Fredonia City Culinary water supply for the life of the plan. 

Approximately 2,400 acres (63 percent) of the Cottonwood Canyon ACEC are inside the Moquith 

Mountain WSA. The relevant and important values in this portion of the ACEC would be managed 

according to the IMP and the following management prescriptions: 

Scenic: 

• Designate as VRM Class I 

• Limit OHV use to designated routes 

• Recommend withdrawing from mineral entry 

Cultural: 

• Monitor specific sites on a regular basis 

• Retain all lands and interests in land in federal ownership 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-51 

• Work with the School and Institutional Trust Lands Administration (SITLA) to acquire state 

inholdings. 

Hazard/Safety/Public Welfare: 

• Close the Water Canyon Allotment (48 AUMs) to livestock grazing in order to protect the 

Fredonia City Culinary water supply for the life of the plan. 

Wild and Scenic Rivers 

Goals and Objectives 

• Preserve suitable rivers, or segments of rivers, and their immediate environments in their freeflowing condition for the protection of their outstandingly remarkable values (ORV) and for the 

benefit and enjoyment of present and future generations, giving consideration to other resource 

values and uses. 

Management Actions 

Wild and Scenic Rivers Act Recommendations 

Management to protect the river segments would be provided in the following ways: 

• Free-flowing values: The free-flowing characteristics of river segments would not be modified to 

allow stream impoundments, diversions, channelization, and/or rip-rapping to the extent the BLM 

is authorized under law. 

• Outstandingly Remarkable Values: Each river segment would be managed to protect identified 

ORVs and, to the extent practicable, such values would be enhanced. 

• Tentative Classification: Management and development of the river and its corridor would not be 

modified to the degree that its tentative classification would be affected. A river segment’s 

tentative classification would not be changed due to modification from “wild” to “scenic” or from 

“scenic” to “recreational.” 

Protective management would apply to BLM lands within the river corridor, which does not exceed 

“more than 320 acres of land per mile measured from the ordinary high water mark on both sides of the 

river” (16 U.S.C. 1274(b)). The corridors may vary on either side of the river and be narrower or wider to 

protect ORVs, but the total corridor widths may not exceed 320 acres (half of a mile or 2,640 feet wide) 

per river mile. 

Protective interim management of eligible or suitable rivers would not involve assertion of federal 

reserved water rights. 

Manage rivers determined suitable for congressional designation into the National Wild and Scenic 

Rivers System (NWSRS) in a manner that would protect their ORVs, free-flowing nature, and tentative 

classification, in accordance with protective management for the river corridors. 

Six eligible river segment corridors (Map 18) would be determined suitable for WSR designation 

(5,530 acres/30 miles), with the tentative classifications of “wild” (4,570 acres/25 miles) or “scenic” (960 

acres/5 miles). 
Chapter 2 Proposed RMP and Final EIS 

2-52 Kanab RMP 

North Fork Virgin River—Segment 48-49

Suitable—Wild 

Manage the portion of the North Fork Virgin River (segment 48-49) suitable “wild” river segment inside 

the North Fork WSA to protect the tentative classification and ORVs through the following specific 

management prescriptions (within 1⁄4 mile of each side of the river or the viewshed from the river, 

whichever is less): 

• According to the IMP 

• VRM: Class I 

• Recommend for withdrawal from locatable mineral entry 

• Motorized Travel: Close to OHV use 

• ROW exclusion area. 

Manage the portion of the North Fork Virgin River (segment 48-49) suitable “wild” river segment outside 

the WSA to protect the tentative classification and ORVs through the following specific management 

prescriptions (within 1⁄4 mile of each side of the river or the viewshed from the river, whichever is less): 

• VRM: Class I 

• Minerals: Close to oil and gas leasing, recommend for withdrawal from locatable mineral entry, 

and close to mineral material disposal 

• Motorized Travel: Close to OHV use 

• ROW exclusion area. 

East Fork Virgin River—Segment 37-40a

Suitable—Scenic 

Manage the East Fork Virgin River (segment 37-40a) suitable “scenic” river segment inside the 

Parunuweap WSA to protect the tentative classification and ORVs through the following specific 

management prescriptions (within 1⁄4 mile of each side of the river or the viewshed from the river, 

whichever is less): 

• According to the IMP 

• VRM: Class I 

• Recommend for withdrawal from locatable mineral entry 

• Motorized Travel: Limit to designated routes 

• ROW exclusion area. 

East Fork Virgin River—Segment 40a-41

Suitable—Wild 

Manage the East Fork Virgin River (segment 40a-41) suitable “wild” river segment inside the 

Parunuweap WSA to protect the tentative classification and ORVs through the following specific 

management prescriptions (within 1⁄4 mile of each side of the river or the viewshed from the river, 

whichever is less): 

• According to the IMP 

• VRM: Class I 

• Recommend for withdrawal from locatable mineral entry 

• Motorized Travel: Close to OHV use 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-53 

• ROW exclusion area. 

East Fork Virgin River—Segment 36-37

Not Suitable 

Orderville Gulch (Esplin Gulch)—Segment 44-45

Suitable—Wild 

Manage the portion of the Orderville Gulch (Esplin Gulch) (segment 44-45) suitable “wild” river segment 

inside the Orderville Canyon WSA to protect the tentative classification and ORVs through the following 

specific management prescriptions (within 1⁄4 mile of each side of the river or the viewshed from the river, 

whichever is less): 

• According to the IMP 

• VRM: Class I 

• Recommend for withdrawal from locatable mineral entry 

• Motorized Travel: Close to OHV use 

• ROW exclusion area. 

Manage the portion of the Orderville Gulch (Esplin Gulch) (segment 44-45) suitable “wild” river segment 

outside the Orderville Canyon WSA to protect the tentative classification and ORVs through the 

following specific management prescriptions (within 1⁄4 mile of each side of the river or the viewshed 

from the river, whichever is less): 

• VRM: Class I 

• Minerals: Close to oil and gas leasing, recommend for withdrawal from locatable mineral entry, 

and close to mineral material disposal 

• Motorized Travel: Close to OHV use 

• ROW exclusion area. 

Meadow Creek/Mineral Gulch—Segment 33-35, 35-38

Suitable—Wild 

Manage the portion of the Meadow Creek/Mineral Gulch (segment 33-35, 35-38) suitable “wild” river 

segment inside the Parunuweap WSA to protect the tentative classification and ORVs through the 

following specific management prescriptions (within 1⁄4 mile of each side of the river or the viewshed 

from the river, whichever is less): 

• According to the IMP 

• VRM: Class I 

• Recommend for withdrawal from locatable mineral entry 

• Motorized Travel: Close to OHV use 

• ROW exclusion area. 

Manage the portion of the Meadow Creek/Mineral Gulch (segment 33-35, 35-38) suitable “wild” river 

segment outside the Parunuweap WSA to protect the tentative classification and ORVs through the 

following specific management prescriptions (within 1⁄4 mile of each side of the river or the viewshed 

from the river, whichever is less): 

• VRM: Class I 
Chapter 2 Proposed RMP and Final EIS 

2-54 Kanab RMP 

• Minerals: Close to oil and gas leasing, recommend for withdrawal from locatable mineral entry, 

and close to mineral material disposal 

• Motorized Travel: Close to OHV use 

• ROW exclusion area. 

Deep Creek—Segment 50-51

Not Suitable 

Cottonwood Creek—Segment 28-29

Not Suitable 

Indian Canyon—Segment 26-27

Not Suitable 

South Fork Indian Canyon—Segment 22-23

Not Suitable 

North Branch of South Fork Indian Canyon—Segment 24-25

Not Suitable 

Water Canyon—Segment 20-21

Not Suitable 

Hell Dive Canyon—Segment 30-31

Not Suitable 

Paria River—Segment 68-69

Suitable—Wild 

ORVs in the Paria River would be preserved through the following management approach (from the Final 

Arizona Statewide Wild and Scenic Rivers Study Report/Record of Decision [BLM 1997b], which 

determined eligibility for the Paria River and is carried forward in this document): 

• Developed campgrounds, interpretive centers, or administrative headquarters within the river 

corridor would be prohibited. Simple comfort and convenience facilities would be permitted. 

• New electric transmission lines, natural gas lines, water lines, and other ROWs would be 

prohibited. 

• Woodcutting would not be permitted except where needed to clear trails, for visitor safety, or to 

control fire. 

• Livestock grazing would be managed to protect ORVs within the area. 

• No new flood control dams, levees, or other water works would be permitted. 

• Hydroelectric power facilities would be prohibited. 

• All water supply dams and major diversions would be prohibited. 

• Construction of new routes for motorized travel would be prohibited. 

Three Mile Creek—Segment 56-57

Not Suitable 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-55 

Management of Suitable Rivers 

Allow other activities within the suitable river segment corridors on a case-by-case basis as long as their 

ORVs, free-flowing nature, and tentative classification would be protected. See BLM Manual-8351, 

Section 5, for implementation guidance. 

Coordination with State Agencies, Federal Agencies, and Tribal Governments 

BLM would work with the State of Utah, local and tribal governments, and other federal agencies, in a 

state-wide study, to reach consensus regarding recommendations to Congress for the inclusion of rivers in 

the NWSRS. Besides applying consistent criteria across agency jurisdictions, the joint study would avoid 

piecemealing of river segments in logical watershed units in the state. The study would evaluate, in detail, 

the possible benefits and effects of designation on the local and state economies, agricultural and 

industrial operations and interests, outdoor recreation, natural resources (including the outstandingly 

remarkable values for which the river was deemed suitable), water rights, water quality, water resource 

planning, and access to and across river corridors within, and upstream and downstream from the 

proposed segments(s). Actual designation of river segments would only occur through congressional 

action or as a result of Secretarial decision at the request of the Governor in accordance with provisions of 

the Wild and Scenic Rivers Act (the Act). BLM will work with the state, local and tribal governments, 

and the agencies involved to coordinate its decision-making on wild and scenic river issues and to achieve 

consistency wherever possible. 

BLM recognizes that water resources on most river and stream segments within the State of Utah are 

already fully allocated. Before stream segments that have been recommended as suitable under this 

Proposed RMP are recommended to Congress for designation, BLM will continue to work with affected 

local, state, federal, and tribal partners to identify in-stream flows necessary to meet critical resource 

needs, including values related to the subject segments. Such quantifications would be included in any 

recommendation for designation. BLM would then seek to jointly promote innovative strategies, 

community-based planning, and voluntary agreements with water users, under State law, to address those 

needs. 

Should designations occur on any river segment as a result of Secretarial or congressional action, existing 

rights, privileges, and contracts would be protected. Under Section 12 of the Act, termination of such 

rights, privileges, and contracts may happen only with the consent of the affected non-federal party. A 

determination by the BLM of eligibility and suitability for the inclusion of rivers on public lands to the 

NWSRS does not create new water rights for the BLM. Federal reserved water rights for new components 

of the NWSRS are established at the discretion of Congress. If water is reserved by Congress when a river 

component is added to the NWSRS, it would come from water that is not appropriated at the time of 

designation, in the amount necessary to protect features which led to the river’s inclusion into the system. 

BLM's intent would be to leave existing water rights undisturbed and to recognize the lawful rights of 

private, municipal, and state entities to manage water resources under state law to meet the needs of the 

community. Federal law, including Section 13 of the Act and the McCarren Amendment (43 U.S.C. 666), 

recognizes state jurisdiction over water allocation in designated streams. Thus, it is BLM's position that 

existing water rights, including flows apportioned to the State of Utah interstate agreements and 

compacts, including the Upper Colorado River Compact, and developments of such rights would not be 

affected by designation or the creation of the possible federal reserved water right. BLM would seek to 

work with upstream and downstream water users and applicable agencies to ensure that water flows are 

maintained at a level sufficient to sustain the values for which affected river segments were designated. 
Chapter 2 Proposed RMP and Final EIS 

2-56 Kanab RMP 

Wilderness 

Goals and Objectives 

• Manage for the long-term protection and preservation of the area’s wilderness character under a 

principle of non-degradation. The area’s natural condition; opportunities for solitude; 

opportunities for primitive and unconfined types of recreation; and any ecological, geological, or 

other features of scientific, educational, scenic, or historical value present would be managed so 

that they remain unimpaired. 

• Manage designated wilderness for the use and enjoyment of visitors in a manner that leaves the 

area unimpaired for future use and enjoyment as wilderness. The wilderness resource would be a 

dominant factor in all management decisions where a choice must be made between preservation 

of wilderness character and visitor use. 

• Manage designated wilderness using the minimum tools, equipment, and/or structures necessary 

to accomplish the objective successfully, safely, and economically. The chosen tools, equipment, 

or structures would be the ones that least degrade wilderness values temporarily or permanently. 

Management would seek to preserve spontaneity of use and as much freedom from regulation as 

possible. 

• Manage non-conforming but accepted uses permitted by the Wilderness Act and subsequent laws 

in a manner that would prevent unnecessary or undue degradation of the area’s wilderness 

character. Non-conforming uses are the exception rather than the rule; therefore, emphasis would 

be placed on maintaining wilderness character. 

Management Actions 

Management of the Paria Canyon–Vermilion Cliffs Wilderness 

Manage the Paria Canyon–Vermilion Cliffs Wilderness cooperatively with Arizona BLM. 

Implement the Paria Canyon–Vermilion Cliffs Wilderness Management Plan. 

The wilderness character of the Paria Canyon–Vermilion Cliffs Wilderness would be protected and 

enhanced. 

Maintain the current group size and visitor use limits required for use in Paria Canyon, subject to adaptive 

management decisions deemed necessary through monitoring and evaluation of resources and social 

conditions. 

Restore lands within the wilderness area where ecological integrity is outside the range of natural 

variability and where compatible with wilderness objectives. 

Restore ecological functions and structure in wilderness using the minimum requirement standard for 

BLM wilderness areas and the best mix of chemical, biological, or mechanical means with fire and 

natural processes. 

For fire and fuels management, the use of earth-moving equipment must be authorized by the Field Office 

Manager. 

Fire management actions would rely on the most effective methods of suppression that are least damaging 

to wilderness values, other resources, and the environment while requiring the least expenditure of public 

funds. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-57 

A resource advisor would be consulted when fire occurs in the Wilderness. 

Use natural processes to restore areas of preexisting human imprints. Where proactive restoration of 

wilderness conditions is desirable, require the minimum requirement standards; plans to address 

restoration of preexisting human impacts may be required. 

Ensure that any change in the landscape is very low. 

Manage to protect or restore the natural quiet and natural soundscapes of the area. 

Prohibit all motorized vehicles, motorized equipment, aircraft landing, and other forms of mechanical 

transport (including mountain bikes and wheeled game carriers). Exceptions may be authorized per the 

Wilderness Act Section 4(d) when it is: 

• Necessary to meet minimum requirements for the administration of the area 

• Required in emergencies involving the health and safety of persons within the areas 

• For the exercise of a private existing right or other special provision. 

Wilderness Study Areas 

Goals and Objectives 

• Manage WSAs in a manner that does not impair their suitability for designation as wilderness. 

Temporary uses that create no new surface disturbance nor involve permanent placement of 

structures may be allowed in WSAs on a case-by-case basis. 

Management Actions 

WSA Management 

Planning decisions in this RMP will not affect the existence of or recommendations on WSAs identified 

as a result of inventory conducted under Section 603 of FLPMA and awaiting action by Congress. 

Further, although the formal Section 603 wilderness review process was determined to have expired on 

October 21, 1993, BLM may and will continue to inventory public lands for resource values including 

wilderness characteristics on lands that have not been reviewed, or where new information is provided 

that shows additional inventory is necessary. However, additional Wilderness Study Areas will not be 

designated through this planning process. 

Manage all WSAs according to the IMP (BLM Manual Handbook H-8550-1) until legislation is enacted 

to either designate the areas as wilderness or release them for uses other than wilderness. 

Only Congress can release a WSA from wilderness consideration. Should any WSA, in whole or in part, 

be released from wilderness consideration, such released lands will be managed in accordance with the 

goals, objectives, and management prescriptions established in this RMP, unless otherwise specified by 

Congress in its releasing legislation. BLM will examine proposals in the released areas on a case-by-case 

basis but will defer all actions that are inconsistent with RMP goals, objectives, and prescriptions until it 

completes a land use plan amendment. Because any released lands will continue to be managed consistent 

with the prescriptions identified in this plan unless and until the plan is amended, no separate analysis is 

required to address impacts to released lands. 

Where routes would remain available for motorized use within WSAs, such use could continue on a 

conditional basis. Use of the existing routes in the WSAs (“ways” when located within WSAs) could 
Chapter 2 Proposed RMP and Final EIS 

2-58 Kanab RMP 

continue as long as the use of these routes does not impair wilderness suitability, as provided by the IMP 

(BLM 1995). If Congress designates the area as wilderness, the routes will be closed. In the interim, if use 

and/or non-compliance are found through monitoring efforts to impair the area’s suitability for wilderness 

designation, BLM would take further action to limit use of the routes or close them. The continued use of 

these routes, therefore, is based on user compliance and non-impairment of wilderness values. 

Designate WSAs as VRM Class I. 

OHV Use in WSAs 

Manage OHV use in WSAs as shown in Table 2-2 and on Map 9. 

Table 2-2. OHV Area Designations in WSAs 

WSA OHV Designation Acres 

Canaan Mountain Limited 4,300 

Acquired Land Managed as Part of the 

Canaan Mountain WSA Limited 600 

Closed 400 

Moquith Mountain Limited 13,800 

Open 1,000 

Closed 200 

North Fork Virgin River 

Limited 850 

Closed 500 

Orderville Canyon 

Limited 1,450 

Closed 6,200 Parunuweap Canyon 

Limited 24,600 

Designate 25.0 miles of inventoried ways in WSAs (Moquith Mountain–8.5 miles; Parunuweap Canyon–

15.9 miles; Orderville Canyon–0.6 miles) as open for OHV use (Map 10) (implementation-level 

decision).∗

Other Designations 

Goals and Objectives 

• Coordinate management of National Scenic Byways, Utah Scenic Byways, and Utah Scenic 

Backways with other agencies and BLM offices, as appropriate. 

• Consider impacts on other designations when evaluating all proposed projects. 

• Promote the preservation and appreciation of the Old Spanish National Historical Trail for the 

enjoyment of the American people. 

 

∗ This is an implementation-level decision that cannot be protested under the planning regulations. Please see the cover letter for 

further information. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-59 

Management Actions 

National and State Scenic Byways and State Scenic Backways 

Cooperate with state and local authorities to implement the purposes of designation. 

Old Spanish National Historic Trail 

Work with the BLM and National Park Service (NPS) planning team in the development of a 

comprehensive management plan for the National Historic Trail. 

Prepare an Activity (Trail) Plan for the Old Spanish National Historic Trail to identify specific on-theground actions that would be taken to implement the goals and objectives of the Trail. 

Highway 89/20 Segment, Garfield County

Work in cooperation with Utah State Parks and Recreation, Garfield County, Old Spanish Trail 

Association, and the NPS on interpretive and recreation opportunities for this segment: 

• Provide interpretive information at appropriate locations (e.g., kiosks, road junctions, Garfield 

County line) 

• Retain public lands in federal ownership 

• Limit OHV use to designated routes 

• Manage for VRM objectives (VRM Class II in Circleville Canyon and VRM Class III and Class 

IV elsewhere). 

Highway 89 Segment, Kane County

Work in cooperation with Utah State Parks and Recreation, Kane County, Old Spanish Trail Association, 

and the NPS on interpretive and recreation opportunities for this segment: 

• Provide interpretive information at appropriate locations (e.g., kiosks, road pullouts, Kane County 

line). 

2.2.4 Social and Economic 

Public Safety 

Goals and Objectives 

• The BLM would strive to ensure that human health and safety concerns on public lands remain a 

major priority. 

• Hazardous or potentially hazardous sites and situations, including hazardous materials, hazardous 

or solid wastes, abandoned mine sites, abandoned well sites, and other potential hazards on public 

lands would be mitigated or eliminated. 

• The potential for intentional or accidental releases of hazardous materials or wastes and solid 

wastes onto public lands would be minimized or eliminated. 

Management Actions 

Management of Abandoned Mine Lands 

In conformance with the BLM’s long-term strategies and national policies regarding Abandoned Mine 

Lands (AML), this RMP recognizes the need to work with our partners toward identifying and addressing 
Chapter 2 Proposed RMP and Final EIS 

2-60 Kanab RMP 

physical safety and environmental hazards at all AML sites on public lands. To accomplish this long-term 

goal, the criteria discussed in the following paragraphs would be established to assist in determining 

priorities for site and area mitigation and reclamation. 

The criteria that would be used to establish physical safety hazard program priorities are: 

• The AML physical safety program’s highest priority would be cleaning up those AML sites 

where (a) a death or injury has occurred; (b) the site is situated on or in immediate proximity to 

developed recreation sites and areas with high visitor use; and (c) upon formal risk assessment, a 

high or extremely high risk level is indicated. 

• AML would be factored into future recreation management area designations, land use planning 

assessments, and all applicable use authorizations. 

• The site is listed or is eligible for listing in the Abandoned Mine Site Cleanup Module of the 

Protection and Response Information System. 

• AML hazards should be, to the extent practicable, mitigated or remediated on the ground during 

site development. 

The criteria that would be used to establish water quality-based AML program priorities are: 

• The site has identified the watershed as a priority based on (a) one or more water laws or 

regulations, (b) threat to public health or safety, and (c) threat to the environment. 

• The project reflects a collaborative effort with other land management agencies. 

• The site is listed or is eligible for listing in the Abandoned Mine Site Cleanup Module of the 

Protection and Response Information System. 

• The project would be funded by contributions from collaborating agencies. 

Maintain the State Multi-Year Work Plan and update as needed to reflect current policies for identifying 

program physical safety and water quality AML site priorities for reclamation and remediation. 

2.2.5 Adaptive Management 

Adaptive management is a formal, systematic, and flexible approach to learning from the results of 

management actions, accommodating change, and improving management. It involves synthesizing 

existing knowledge, exploring alternative actions, and making explicit forecasts about their results. 

Management actions and monitoring programs are carefully designed to generate reliable feedback and 

clarify the reasons underlying results. Actions and objectives are then adjusted based on this feedback and 

improved understanding in order to continue to try to achieve the desired outcomes. In addition, 

decisions, actions, and results are carefully documented and communicated to others so that knowledge 

gained through experience is passed on rather than lost when individuals move or leave the organization. 

Land use plan level decisions would not be immediately adaptable. These include the goals and 

objectives, allowable uses, management actions, and special designations. Plan amendments would be 

required to change these decisions. Implementation or activity-level decisions could be adapted. Future 

activity-level plans would follow NEPA procedures and involve the public. 

This Proposed RMP/Final EIS recommends an adaptive management strategy. This adaptive management 

process is flexible and generally involves four phases: planning, implementation, monitoring, and 

evaluation. As the BLM obtains new information, it is able to evaluate monitoring data and other resource 

information to periodically refine and update desired outcomes (goals and objectives), management 

actions, and allowable uses. This allows for the continual refinement and improvement of management 

prescriptions and practices. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-61 

2.3 ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL

Several organizations and individuals provided components of alternatives and management actions as 

possible ways of resolving individual resource management issues and conflicts. However, none of the 

submissions address the purpose and need of this RMP revision, including the multiple-use requirements 

identified in FLPMA. While BLM considered components of some of the submissions in developing 

alternatives, none provided the full range of decisions required by the purpose and need. 

2.3.1 Vermilion Cliffs Heritage Plan 

The Vermilion Cliffs Heritage Plan was developed and/or endorsed by a number of state and national 

organizations and was provided to the BLM during the public scoping period. The Vermilion Cliffs 

Heritage Plan, as presented, incorporated many timely issues and concerns that would be required of any 

balanced approach to managing public lands. Specifically, the plan identifies several points to be 

considered during the route designation process and identifying stipulations to be attached to oil and gas 

leases. The BLM gave careful consideration to the Vermilion Cliffs Heritage Plan and incorporated parts 

of the plan into the range of RMP alternatives. While the Vermilion Cliffs Heritage Plan appears to be 

multiple use in nature, it does not meet the purpose and need for the RMP revision because it does not 

address all resource values and uses that the BLM is required to manage on public lands. 

2.3.2 Closing the Decision Area to Livestock Grazing 

An alternative that proposes to close the entire decision area to livestock grazing would not meet the 

purposes and need of this Draft RMP/EIS. NEPA requires that agencies study, develop, and describe 

appropriate alternatives to recommended courses of action in any proposal that involves unresolved 

conflicts concerning alternative uses of available resources. No issue or conflict has been identified 

during this land use planning effort that requires the complete elimination of grazing within the decision 

area for its resolution. Where appropriate, closures and adjustments to livestock use have been 

incorporated into the alternatives on an allotment or area basis to address issues identified in the RMP. 

Because the BLM has considerable discretion through its grazing regulations to determine and adjust 

stocking levels, seasons of use, and grazing management activities and to allocate forage to uses of the 

public lands in RMPs, the analysis of an alternative to entirely eliminate grazing is not needed. 

An alternative that proposes to close the entire decision area to grazing would also be inconsistent with 

the intent of the Taylor Grazing Act, which directs the BLM to provide for livestock use of BLM lands; 

adequately safeguard grazing privileges; provide for the orderly use, improvement, and development of 

the range; and stabilize the livestock industry dependent upon the public range. 

FLPMA requires that public lands be managed on a “multiple use and sustained yield basis” (FLPMA 

Sections 302(a) and 102(7)) and includes livestock grazing as a principal or major use of public lands. 

While multiple use does not require that all lands be used for livestock grazing, complete removal of 

livestock grazing on the entire decision area would be arbitrary and would not meet the principle of 

multiple use and sustained yield. 

Livestock grazing is and has been an important use of the public lands in the decision area for many years 

and is a continuing government program. Although the Council on Environmental Quality (CEQ) 

guidelines for compliance with NEPA require that agencies analyze the “No Action Alternative” in all 

EISs, for purposes of this NEPA analysis the “No Action Alternative” is to continue the status quo, which 

includes livestock grazing (CEQ Forty Most Asked Questions, Question 3). For this reason and those 
Chapter 2 Proposed RMP and Final EIS 

2-62 Kanab RMP 

stated above, a no grazing alternative for the entire decision area has been dismissed from further 

consideration in this RMP. 

2.3.3 Livestock Grazing Adjustments Alternative 

During scoping and comment on the Draft EIS it was suggested that the BLM consider adjustments to 

livestock numbers, livestock management practices, and the kind of livestock grazed on allotments within 

the Kanab Field Office in order to benefit wildlife and protect and promote land health including soils, 

hydrologic cycles, and biotic integrity. 

BLM policy regarding adjustments to the levels of livestock use authorized is to monitor and inventory 

range conditions under existing stocking levels and make adjustments to livestock use as indicated by this 

data to help ensure that Standards for Rangeland Health and resource objectives are met. Regulations at 

43 CFR 4130.3 require that the terms and conditions under which livestock are authorized “ensure 

conformance with the provisions of subpart 4180” (Standards for Rangeland Health) and further that 

“livestock grazing use shall not exceed the livestock carrying capacity of the allotment.” It would be 

inappropriate and unfeasible to estimate and allocate the available forage, design specific management 

practices, and determine if changes to the kind of livestock are necessary for each allotment in the Kanab 

Field Office or in the area as a whole in the RMP/EIS. Such changes would not be supportable 

considering the type and amount of data required and the analysis necessary to make such changes. 

According to BLM policy decisions regarding authorized livestock use, levels and the terms and 

conditions under which they are managed is an implementation decision (H-1610-1, Appendix C, page 

15). BLM assesses the condition of rangeland health, conducts monitoring and inventories, and evaluates 

this data on a periodic basis, normally on an allotment and/or watershed basis. After NEPA analysis, 

necessary changes to livestock management and implementation of Utah’s Guidelines for Rangeland 

Management are implemented through a proposed decision in accordance with 43 CFR 4160. These 

decisions determine the exact levels of use by livestock in conformance with the LUP and to meet 

resource objectives and maintain or enhance land health. For these reasons this alternative has been 

dismissed from further consideration in this LUP revision. 

2.3.4 No Leasing Alternative 

During scoping for the Draft RMP/EIS it was suggested that BLM should address a "No Leasing 

Alternative" and that No Leasing must be addressed because it is the "No Action Alternative" that must 

be analyzed in all EISs. 

The “No-Leasing Alternative” in an RMP revision is actually an action alternative because where lands 

have already been leased, the no-action for NEPA purposes continues to allow for (honor) valid existing 

rights. Proposing a “No-Leasing Alternative” would require revisiting existing leases and either buying 

them back from the leasee, or allowing them to expire on their own terms. The first option (buying back), 

is outside the scope of any RMP. This is a political decision that BLM has no authority to undertake in 

planning. As a result, BLM does not regularly include a “No-Leasing Alternative”. 

The purpose and need for the land use plan is to identify and resolve potential conflicts between 

competing resource uses rather than to eliminate a principle use of the public lands in the Kanab Field 

Office Area. Leasing of the public lands for oil and gas exploration and production is required by the 

Mineral Leasing Act of 1920 as amended and BLM's current policy is to apply the least restrictive 

management constraints to the principal uses of the public lands necessary to achieve resource goals and 

objectives. A field office-wide No Leasing Alternative would be an unnecessarily restrictive alternative 

for mineral exploration and production on the public lands. 
Proposed RMP and Final EIS Chapter 2 

Kanab RMP 2-63 

The National Environmental Policy Act (NEPA Section 102 (E)) requires that agencies "study, develop, 

and describe appropriate alternatives to recommended courses of action in any proposal which involves 

unresolved conflicts concerning alternative uses of available resources". No issues or conflicts have been 

identified during this land use planning effort which requires the complete elimination of oil and gas 

leasing within the planning area for their resolution. BLM's Land Use Planning Handbook (BLM Manual 

Ref. 1-1693), Appendix C, item H, requires that land use plans identify areas as open or unavailable for 

leasing. 

Given these potential categories of decisions, the alternatives analyzed in the Draft RMP/EIS included no 

leasing for certain areas, but a field office-wide no leasing alternative was not necessary in order to 

resolve issues and protect other resource values and uses. 

As mentioned above, a "No Leasing Alternative" should not be confused with the "No Action 

Alternative" for purposes of NEPA compliance. Leasing and No Leasing on the public lands has 

previously been analyzed in several NEPA documents. In 1973 the Department of Interior published the 

Final Environmental Impact Statement on the Federal Upland Oil and Gas Leasing Program. The 

proposed action was to lease Federal lands for production of oil and natural gas resources. Alternatives 

included the No Action Alternative, which at initiation of the program was "No Leasing". To supplement 

that EIS, BLM prepared a series of high intensity Environmental Assessments (then titled "Environmental 

Analysis Records or EARs") including the Oil and Gas Leasing Program Kanab District Environmental 

Analysis Record (EAR), 1976 which addressed oil and gas leasing for the public lands in the Kanab Field 

Office area. Alternatives again included the No Action or "No Leasing" alternative. The outcome was a 

category system for leasing which categorized all public and Forest Service lands into four groups: 1) 

open to leasing with standard lease stipulations, 2) Special Stipulations to address special concerns, 3) No 

surface occupancy and 4) No Leasing. Since completion of the EAR in 1976, oil and gas leasing in the 

Kanab Field Office Area has been an ongoing federal program under the established categories. 

The Council on Environmental Quality notes that Section 1502.14(d) of NEPA requires the alternatives 

analysis in an EIS to “include the alternative of no action”, but explains that there are two distinct 

interpretations of “no action” that must be considered, depending on the nature of the proposal being 

evaluated. “The first situation might involve an action such as updating a land management plan where 

ongoing programs initiated under existing legislation and regulations will continue, even as new plans are 

developed. In these cases "no action" is "no change" from current management direction or level of 

management intensity. To construct an alternative that is based on no management at all would be a 

useless academic exercise. Therefore, the "no action" alternative may be thought of in terms of continuing 

with the present course of action until that action is changed." (CEQ Forty Most Asked Questions, 

Question 3). Therefore, for the Kanab Draft RMP/EIS, the No Action Alternative would continue the 

status quo which is to lease under the oil and gas categories established in the current land use plans. 
Chapter 2 Proposed RMP and Final EIS 

2-64 Kanab RMP 2.4 COMPARATIVE SUMMARY OF IMPACTSTable 2-3 presents a comparison summary of impacts from management actions proposed for the four management alternatives. Chapter 4 provides a more detailed impact analysis. 

Table 2-3. Summary Comparison of Impacts 

Alternative A Proposed RMP Alternative C Alternative D 

Impacts on Air Quality 

The highest amount of emissions expected. However, the emission increase would not cause ambient air quality standards to be exceeded. Under Alternative A, emissions have been calculated for the base year (2006) and 20-year (2026) time horizons, which serves as the basis for comparing alternatives. The total emissions of criteria pollutants increased from 2,694 tons per year in the base year (2006) to 3,670 tons per year by 2026 for Alternative A. Most of the increase is a result of non-oil and gas activities, primarily OHV activities.

The second lowest amount of emissions expected. However, the emission increase would not cause ambient air quality standards to be exceeded. The Proposed RMP produces lower emissions than Alternative A with 3,554 tons per year in 2026. 

The lowest amount of emissions expected. However, the emission increase would not cause ambient air quality standards to be exceeded. Alternative C produces lower emissions than Alternative A with 2,841 tons per year in 2026. 

The second highest amount of emissions expected. However, the emission increase would not cause ambient air quality standards to be exceeded. Alternative D (3,629 tons per year) also produces emissions levels lower than Alternative A, but higher than for the Proposed RMP and Alternative C. 

Impacts on Soil Resources 

Surface disturbing activities could remove vegetation and topsoil and result in compaction or loss of some of the exposed soil surface, resulting in the majority of impacts on soil resources. Management actions that limit surface disturbing activities or implement BMPs (Appendix 1) and mitigation measures would protect and maintain current soil resources and minimize erosion. Compared to the other alternatives, management actions to limit surface 

The Proposed RMP would place more restrictions on surface disturbing activities, including crosscountry OHV use (1,000 acres) and mineral development, and help reduce impacts on soil resources described in Alternative A. Management actions to restrict surface disturbance and implement performance measures in areas with fragile soils would reduce impacts on these soil resources. 

Alternative C management actions would place the greatest restrictions on surface disturbing activities and thus provide the greatest amount of protection to soil resources (particularly fragile soil areas). Increasing restrictions on surface disturbing activities could reduce impacts on soil resources. The additional restrictions on surface disturbance could decrease localized erosion and maintain soil productivity. 

The surface disturbance restrictions would be slightly more restrictive than Alternative A. Compared to the Proposed RMP and Alternative C, fewer surface disturbance restrictions could increase localized erosion and decrease soil productivity. Alternative D could allow some activities in fragile soil areas, which could increase the potential for soil loss and erosion. 
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disturbing activities are the least restrictive, which would provide the least amount of protection to soil resources. Fewer surface disturbance restrictions could increase localized erosion and decrease soil productivity. Cross-country OHV use (466,600 acres) could increase soil compaction, reduce water infiltration, and increase the potential for soil loss and erosion. 

Impacts on Water Resources 

Surface disturbing activities could remove vegetation and topsoil and result in increased erosion and sedimentation, reducing watershed health and water quality. Management actions that limit surface disturbing activities or implement BMPs and mitigation measures could protect and maintain current water quality and minimize erosion and sedimentation. Compared to the other alternatives, management actions to limit surface disturbing activities are the least restrictive, which would provide the least amount of protection to water resources. Fewer surface disturbance restrictions could increase localized erosion and sediment loading and decrease water quality. 

The Proposed RMP would place more restrictions on surface disturbing activities and help reduce impacts on water resources described in Alternative A. Management actions that restrict surface disturbance and implement performance measures in areas with fragile soils reduce impacts on water resources. 

Alternative C management actions would place the greatest restrictions on surface disturbing activities and thus provide the greatest amount of protection to water resources. Increasing restrictions on surface disturbing activities could reduce impacts on water quality. More surface disturbance restrictions could decrease localized erosion and sediment loading and maintain water quality and watershed health. 

The surface disturbance restrictions would be slightly less restrictive than Alternative A. Fewer surface disturbance restrictions could increase localized erosion and sediment loading and decrease water quality. 

Impacts on Vegetation 

Surface use and disturbances could remove components of vegetation communities. Disturbances could alter the composition and structure of vegetation communities, increase the 

Compared to Alternative A, more restrictions on surface disturbing activities would reduce the extent of associated impacts on vegetation communities. Not allowing surface 

This alternative would have the most restrictions on surface disturbing activities, reducing the extent of associated impacts on vegetation communities compared to Alternative 

The restrictions on surface disturbing activities would be slightly more than Alternative A, but less than the Proposed RMP and Alternative C. This would slightly reduce the extent 
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potential for the introduction and establishment of noxious weeds, and reduce species diversity, primary production, and recruitment of new plants. This in turn could make upland, riparian, and forest and woodland communities less resilient to disease, drought, fire, invasive species, and other natural disturbances/stressors. Protecting riparian areas from all surface uses and disturbances through protective stipulations and not allowing occupancy or other surface disturbance within 400 feet of rivers and creeks would minimize the potential for these impacts on riparian and wetland communities. Implementing vegetation treatments and managing vegetation resources to meet desired vegetation conditions would generally maintain or improve vegetation communities. Vegetation treatments under this alternative would not be conducted in areas containing ponderosa pine trees, which would continue to lead to increased understory and fuel loads and possibly lead to larger crown fires and associated loss of ponderosa pine stands. 

disturbance within 330 feet of riparian and wetland areas and implementing in-kind offsite compensatory mitigation would minimize and mitigate impacts on riparian and wetland communities. Implementing additional measures to manage and improve vegetation, including an annual average of no more than 22,300 acres, could improve vegetation health compared to Alternative A. This would result in a more systematic approach to treating vegetation communities, which would likely further improve vegetation conditions. Treatments would be conducted in areas containing ponderosa pine trees, which would reduce fuel loads and reduce the potential for larger crown fires and associated loss of ponderosa pine stands. Restoring forest and woodland old-growth stands to a pre-fire suppression condition would increase tree spacing and encourage understory vegetation production. 

A. Not allowing surface disturbance within 660 feet of riparian and wetland areas and implementing inkind offsite compensatory mitigation near the project site would provide more protection than under Alternative A and the Proposed RMP and ensure continuity of and restoration within the same watershed. Implementing vegetation treatments on an annual average of at least 4,650 acres, not to exceed an annual average of 22,300 acres, and preferring the use of vegetation treatment methods that mimic natural processes would result in a slower process of vegetation enhancement. Prioritizing treatments in areas not functioning properly would help maintain or improve the health of vegetation communities. 

of associated impacts on vegetation communities. Not allowing surface disturbance within 330 feet of riparian and wetland areas and implementing in-kind or out-of-kind offsite compensatory mitigation would minimize and mitigate these impacts on riparian and wetland communities. Impacts from vegetation and forest and woodland treatments would be the same as described in the Proposed RMP. 

Impacts on Special Status Species 

Special status species habitat within the Alton coal field could be lost in the short and long term due to surface coal mining activities on and adjacent to these areas. Specifically, this would affect the southern-most population of the Greater sage-grouse. Development of the coal mine, removal of the overburden, and surface mining operations would result in the long-term (life of the RMP) loss of habitat resources and displacement of individual birds and could result in the loss of the local population. Surface disturbing activities affect habitat components, resulting in habitat alteration, fragmentation, and/or loss of habitat components needed for species survival (e.g., 

The Proposed RMP would place more restrictions on surface disturbing activities (e.g., mineral exploration and development ROW construction) and help reduce 

Alternative C management actions would place the greatest restrictions on surface disturbing activities (e.g., mineral exploration and development ROW construction) and further 

Compared to Alternative A, Alternative D would place more restrictions on surface disturbing activities (e.g., mineral exploration and development ROW construction), 
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forage and cover). This results in a reduction in usable ranges and disruption of movements among habitats, transitional areas, and breeding areas. OHV use has the potential to cause direct mortality of special status species through accidental kills by vehicles; stress-related mortality caused by human and OHV presence or incidental harassment; and modification of habitat as a result of loss of vegetation, soil compaction, and introduction of weed species. Cross-country OHV use (466,600 acres) could result in the incidental loss of special status species, of which plants would be most susceptible because they are stationary and have specialized habitat needs, including unique soil substrates. 

impacts described in Alternative A. Managing OHV use throughout the majority of the decision area (528,000 acres, 95 percent) as limited to 1,403 miles of designated routes and restricting cross-country OHV use would minimize surface disturbances to special status species and their habitats, greatly reducing surface disturbance of special status species habitat as compared to Alternative A. 

reduce impacts described in Alternative A. Managing OHV use throughout the majority of the decision area (388,300 acres, 70 percent) as limited to 1,190 miles of designated routes and precluding cross-country OHV use would minimize surface disturbances to special status species and their habitats, greatly reducing surface disturbance of special status species habitat as compared to Alternative A. 

but fewer restrictions than the Proposed RMP and Alternative C. Managing OHV use throughout the majority of the decision area (525,300 acres, 95 percent) as limited to 1,464 miles of designated routes and restricting cross-country OHV use would minimize surface disturbances to special status species and their habitats, greatly reducing surface disturbance of special status species habitat as compared to Alternative A. 

Displacement from activities such as cross-country OHV use, motorized recreation, dispersed recreation, and/or surface disturbing activities may move animals into less desirable habitat and increase competition for available resources with other species and uses. 

Limiting OHV use to designated routes on 95 percent of the decision area would limit the potential for displacement of special status species. In addition, restricting surface disturbing activities (e.g., mineral exploration and development ROW construction) and placing restrictions on recreation use in special status species habitats would reduce the potential for displacement compared to Alternative A. Displacement of special status wildlife species during vegetation treatments would be the same as described in Alternative A, except more acres could be treated. 

Not allowing cross-country OHV use would eliminate potential impact from displacement. In general, OHV use on 884 miles of designated routes that result in increased human presence could temporarily displace special status species. Seasonal restrictions on 306 miles of OHV routes for raptor species and deer and elk crucial winter range would provide protection from disturbance and habitat degradation during the closure periods. In addition, access to several open routes would be limited due to the seasonal closures, which would increase protection from disruptive activities compared to Alternative A and the Proposed RMP. Displacement of special status wildlife species during vegetation 

Limiting OHV use to designated routes on 95 percent of the decision area would limit the potential for displacement of special status species. In addition, restricting surface disturbing activities (e.g., mineral exploration and development ROW construction) and placing restrictions on recreation use in special status species habitats would reduce the potential for displacement compared to Alternative A. However, there would be fewer restrictions in comparison to the Proposed RMP and Alternative C, increasing the potential for displacement. Displacement of special status wildlife species during vegetation treatments would be the same as described in Alternative A, except 
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treatments would be the same as described in Alternative A, except more acres could be treated. 

more acres could be treated. 

Vegetation treatments would result in temporary displacement of special status species wildlife during treatment. However, over the long term the treated areas would provide improved forage conditions and reduced erosion, which would enhance special status species wildlife habitat and fisheries. 

Focusing vegetation treatments on identified high-priority areas and increasing the potential treatment acres would target areas where habitat function could be most improved. These treatments would improve overall habitat conditions in targeted habitats. This would result in an increase in habitat components, including increased forage and shelter. 

Requiring at least an annual average of 4,650 acres to be treated would help reintroduce natural disturbance rates over the long term. Special status plant species in vegetation communities that are adapted to regular disturbances could benefit from this reintroduction of natural disturbance rates. This would improve habitat values in decadent vegetation communities. Preferring treatment methods that use or mimic natural processes could reduce impacts associated with human presence and more disruptive treatment methods. 

Management of vegetation treatments to emphasize commodity production to increase forage and woodland products would likely convert habitats to early seral stages, resulting in habitat that is less desirable to special status species. 

Impacts on Fish and Wildlife Habitat 

Surface disturbing activities affect habitat components resulting in habitat alteration, fragmentation, and/or loss of habitat components needed for species survival (e.g., forage and cover). This results in a reduction in usable ranges and disruption of movements among habitats, transitional areas, and breeding areas. OHV use has the potential to cause direct mortality of special status species through accidental kills by vehicles; stress-related mortality caused by human and OHV presence or incidental harassment; and modification of habitat as a result of loss of vegetation, soil compaction, and introduction of weed species. Cross-country OHV use (466,600 acres) could result in the incidental 

The Proposed RMP would place more restrictions on surface disturbing activities (e.g., mineral exploration and development ROW construction) and help reduce impacts described in Alternative A. Managing OHV use throughout the majority of the decision area (528,000 acres, 95 percent) as limited to 1,403 miles of designated routes and restricting cross-country OHV use would minimize surface disturbances to wildlife species and their habitats, reducing surface disturbance of habitat as compared to Alternative A. 

Alternative C management actions would place the greatest restrictions on surface disturbing activities (e.g., mineral exploration and development ROW construction) and further reduce impacts described in Alternative A. Managing OHV use throughout the majority of the decision area (388,300 acres, 70 percent) as limited to 1,190 miles of designated routes and precluding cross-country OHV use would minimize surface disturbances to wildlife species and their habitats, greatly reducing surface disturbance of wildlife species habitat as compared to Alternative A. 

Compared to Alternative A, Alternative D would place more restrictions on surface disturbing activities (e.g., mineral exploration and development ROW construction), but fewer restrictions than the Proposed RMP and Alternative C. The potential for habitat changes from surface disturbing activities would remain. Managing OHV use throughout the majority of the decision area (525,300 acres, 95 percent) as limited to 1,464 miles of designated routes and restricting cross-country OHV use would minimize surface disturbances to wildlife species and their habitats, reducing surface disturbance of habitat as compared to Alternative A. 
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loss of wildlife species, although the loss of habitat components in areas that receive frequent and/or intense cross-country OHV use would be a greater impact. Displacement from activities such as cross-country OHV use, motorized recreation, dispersed recreation, vegetation treatments, and/or surface disturbing activities may move animals into less desirable habitat and increase competition for available resources with other species and uses. 

Limiting OHV use to designated routes on 95 percent of the decision area would limit the potential for displacement of wildlife species. In addition, restricting surface disturbing activities (e.g., mineral exploration and development ROW construction) and placing restrictions on recreation use in wildlife species habitats would reduce the potential for displacement compared to Alternative A. Displacement of wildlife species during vegetation treatments would be the same as described in Alternative A, except more acres could be treated. 

Not allowing cross-country OHV use would eliminate potential impact from displacement. In general, OHV use on 884 miles of designated routes that result in increased human presence could temporarily displace special status species. Seasonal restrictions on 306 miles of OHV routes for raptor species and deer and elk crucial winter range would provide protection from disturbance and habitat degradation during the closure periods. In addition, access to several open routes would be limited due to the seasonal closures, which would increase protection from disruptive activities compared to Alternative A and the Proposed RMP. Displacement of wildlife species during vegetation treatments would be similar to those described in Alternative A, except focusing on treatments that use or mimic natural processes would decrease displacement due to a decreased presence of humans. 

Limiting OHV use to designated routes on 95 percent of the decision area would limit the potential for displacement of special status species. In addition, restricting surface disturbing activities (e.g., mineral exploration and development ROW construction) and placing restrictions on recreation use in special status species habitats would reduce the potential for displacement compared to Alternative A. However, there would be fewer restrictions in comparison to the Proposed RMP and Alternative C, increasing the potential for displacement, moving wildlife to less desirable habitat and increasing competition. Displacement of special status wildlife species during vegetation treatments would be the same as described in Alternative A, except more acres could be treated. 

Vegetation treatments would result in temporary displacement of wildlife species during treatment. However, over the long term the treated areas would provide improved forage conditions and reduced erosion, which would enhance wildlife habitat and fisheries. 

Focusing vegetation treatments on identified high-priority areas and increasing the potential treatment acres would target areas where habitat function could be most improved. These treatments would improve overall habitat conditions in targeted habitats. This would result in an increase in habitat components, including increased forage and 

Requiring at least an annual average of 4,650 acres to be treated would help reintroduce natural disturbance rates over the long term. This would improve habitat values in decadent vegetation communities. Preferring treatment methods that use or mimic natural processes could reduce impacts associated with human presence and more disruptive 

Management of vegetation treatments to emphasize commodity production to increase forage and woodland products would likely convert habitats to early seral stages, resulting in habitat that is less desirable to diverse wildlife populations. It could also favor grazing ungulates and other wildlife species that prefer grasses and 
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shelter. treatment methods. forbs. 

Impacts on Wildland Fire Ecology 

Implementing vegetation treatments and permitting commercial and noncommercial harvest of forest and woodland products would continue to reduce fuel and subsequently reduce wildland fire intensity. Vegetation treatments and harvests under this alternative would not be conducted in areas containing ponderosa pine trees, which would continue to lead to increased understory and fuel loads and could lead to larger crown fires and associated loss of ponderosa pine stands. Restricting surface disturbing activities could preclude certain types of fire suppression activities, which would limit the ability to control fires. Wildfire suppression costs would be maintained under this alternative. 

Impacts from implementing vegetation treatments and permitting commercial and non-commercial harvest of forest and woodland products would be the same as described in Alternative A, except additional measures to manage and improve vegetation would further reduce fuel loading and the intensity of wildfire. Treatments would be conducted in areas containing ponderosa pine trees, which would reduce fuel loads and reduce the potential for larger crown fires. Managing for old-growth forests and woodlands stands would reduce the amount of dead and downed fuels. Increasing the restrictions on surface disturbing activities would limit mechanical land treatments, which could result in fuels build-up and increased risk of catastrophic wildfires. Wildfire suppression costs would likely be reduced under this alternative as compared to Alternative A. 

Impacts from implementing vegetation treatments would be the same as described in the Proposed RMP, except using treatment methods that mimic natural processes would result in a shortterm increase in the potential for larger, more intense wildland fires. Precluding commercial forest and woodland product harvest could lead to higher fuel loads and pinyonjuniper encroachment. This alternative would have the most restrictions on surface disturbing activities. This could result in fuels build-up and increased risk of catastrophic wildfires. Wildfire suppression costs could increase under this alternative as compared to Alternative A. 

Impacts from vegetation treatments and permitting commercial and noncommercial harvest of forest and woodland products would be the same as the Proposed RMP. Under this alternative, harvest could occur over a larger area than the other alternatives, although the level of harvest would likely remain the same. Increasing the restrictions on surface disturbing activities would limit mechanical land treatments, which could result in fuels build-up and increased risk of catastrophic wildfires. Wildfire suppression costs would likely be reduced under this alternative as compared to Alternative A. 

Impacts on Cultural Resources 

The BLM would continue to mitigate impacts on cultural resources from authorized uses through project abandonment, redesign, and if necessary data recovery investigations. However, cultural resources would continue to deteriorate through natural agents and inadvertent damage. Due to inventories associated with mineral development (mineral materials, locatable minerals, oil and gas, and coal), between 28 (low site density) and 658 (high site density) cultural sites would be identified over the life of the plan. Most identified sites would be avoided, although sites identified during development 

of the surface coal mine (between 9 and 219) would likely be eliminated following data recovery. 

Cross-country OHV use would generally impact surface features and break artifacts, otherwise disturb cultural resources at the surface, and 

Not managing the decision area as open to cross country OHV use except for small areas of previous disturbance that have been 

No areas would be managed as open for OHV use, so there would be no impacts from cross-country OHV travel. 

Managing small areas of previous disturbance as open to cross-country OHV use could result in inadvertent unmitigated damage of sites and 
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increase the potential for inadvertent damage. OHV use on 1,495 miles of designated or existing routes would result in minimal additional impacts on cultural resources due to existing use on these routes. Because the designated routes currently exist, the damage adjacent to them would also be minimal. 

inventoried for cultural resources would reduce the potential for inadvertent unmitigated damage from such use compared to Alternative A. Impacts from OHVs would be limited to use on 1,403 miles of designated routes which would result in minimal additional impacts on cultural resources due to existing use on these routes. Because the designated routes currently exist, the damage to cultural sites adjacent to them would also be minimal. Designated routes would be one of the highest inventory priorities to reduce the potential for impacts. 

OHV use on 1,190 miles of designated routes would result in minimal additional impacts on cultural resources due to existing use on these routes. Because the designated routes currently exist, the damage adjacent to them would also be minimal. 

associated inadvertent damage. These areas have either had Section 106 compliance (mineral developments) completed or are the highest priority for cultural resource inventories in compliance with Section 106. OHV use on 1,464 miles of designated routes would result in minimal additional impacts on cultural resources due to existing use on these routes. Because the designated routes currently exist, the damage adjacent to them would also be minimal. 

Impacts on Paleontological Resources 

Paleontological resource assessments would be performed on a case-by-case basis prior to proposed land uses. While assessments would minimize the potential for unmitigated impacts on known paleontological resources, they would not require an onsite inventory prior to all disturbances. This could result in the inadvertent damage of paleontological resources that were not identified prior to surface disturbance. Inadvertent damage to vertebrate fossils or other scientifically significant paleontological resources would generally be a significant impact, although mitigation could reduce the magnitude of damage through data recovery. Managing 84 percent of the decision area as open to OHV use could result in direct damage to paleontological resources, but it also allows for motorized access to paleontological 

Requiring on-the-ground paleontological inventories prior to permitting surface disturbing activities in paleontological Class I areas would result in the identification, evaluation, and protection, where appropriate, of scientifically significant fossil resources. By focusing on paleontological Class I areas, the formation and facies most likely to contain scientifically significant fossils would be scrutinized. Requiring assessments in paleontological Class II areas would allow for mitigation needs to be identified and implemented in areas less likely to contain significant fossils. There is a potential for some localities in Class II areas to be damaged after surface disturbance begins if a field inventory were not performed. Restricting motorized use to 

Requiring paleontological inventories throughout the decision area prior to permitting surface disturbing activities, regardless of paleontological Class, would result in the inventory, identification, and collection of paleontological resources throughout the decision area. This would result in the lowest potential for incidental damage to paleontological resources because no surface disturbance would occur until an on-the-ground inventory cleared the area to proceed and any paleontological resources were identified and avoided or recovered. In addition, increases in the acres inventoried would result in more paleontological localities identified than the other alternatives. While precluding cross-country OHV use would eliminate the potential for direct damage from OHVs, it would also limit access for paleontological study and excavations compared to 

Requiring paleontological assessments prior to permitting surface disturbing activities in paleontological Class I areas would identify new paleontological localities. While assessments would minimize the potential for unmitigated impacts on known paleontological resources, they would not require an on-theground inventory prior to all disturbances. This could result in the inadvertent damage of paleontological resources that were not identified prior to surface disturbance. Inadvertent damage to vertebrate fossils or other scientifically significant paleontological resources would generally be a significant impact, although mitigation could reduce the magnitude of damage through data recovery. Not requiring assessments or inventories for Class II areas could result in damage to paleontological resources after surface disturbance 
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localities. Motorized access is important for the study and excavation of paleontological resources because such activities often require the use of heavy equipment and the extraction of large specimens. 

designated routes would protect paleontological resources from damage associated with cross country OHV use, but it could also limit access for paleontological study and excavations. 

Alternative A. In addition, reducing the number of routes open for motorized use could further reduce the accessibility of remote paleontological localities. 

commences, resulting in the loss of scientifically significant paleontological resources. Impacts from OHV decisions would be same as the Proposed RMP. 

Impacts on Visual Resources 

Development affecting scenic quality would be designed to conform to an area’s designated VRM class objectives. Although areas available for mineral development vary by alternative, development of all minerals is anticipated to disturb 8,426 acres (Appendix 15, Reasonably Foreseeable Development [RFD]) in every alternative. Any areas within the viewshed of the disturbances would be affected, reducing visual quality over larger areas. These disturbances would alter the landform, remove vegetation, and introduce human-made structures to the landscape. Contrast would occur in the color, line, and texture of the vegetation community. The complete magnitude of this impact would vary depending on the topography, vegetation, 

size of disturbances, viewer sensitivity, and any mitigation actions that could be applied to reduce visual impacts. 

Acres managed as Class I (21,200 acres) would be approximately the same as inventoried acres, preserving the landscape in the Paria Canyon–Vermilion Cliffs Wilderness Area. Approximately 166,600 acres inventoried as VRM Class II and Class III would be managed as VRM Class IV, allowing major modifications to the landscape in areas of high visual quality. Impacts from oil and gas exploration and development could occur within 473,400 acres (86 percent) open to oil and gas leasing subject to the standard terms on the lease form or subject to moderate constraints. The density of development (well spacing)—small and localized or evident at a broader landscape level—would affect the overall degree of impact. Managing 466,600 acres (84 percent) for cross-country OHV use could decrease vegetation and expose soil, increasing visual contrast from line, 

Compared to Alternative A, there would be a 255 percent increase in acres managed as VRM Class I (76,000 acres) than were inventoried as Class I. The acres that would be managed by Class I objectives mostly inventoried as Class II and were adjusted due to the presence of a WSA. There would also be a shift of Class IV inventoried areas to Class III management objectives on approximately 24,600 acres. This change in management would require visually obtrusive activities to decrease their visual impact through mitigation measures. In addition, the portion of the decision area southwest of Highway 89 between Kanab and Mt. Carmel Junction would be managed as VRM Class III while much of it was inventoried as VRM Class II to allow for vegetation treatments to be implemented to a greater extent in areas of pinyonjuniper encroachment. Impacts from oil and gas exploration and development would be the same 

Acres managed as Class I would increase to 168,300 acres compared with inventoried acres (a 694 percent increase), protecting not only highquality and sensitive landscapes, but also limiting visible landscape changes to support other management actions in this alternative. VRM Class II, Class III, and Class IV would decrease compared to their inventoried acres. The decision area’s landscape would experience the least amount of change in this alternative. Impacts from oil and gas exploration and development would be the same as Alternative A, but could occur within 298,300 acres (54 percent) open to oil and gas leasing subject to the standard terms on the lease form or subject to moderate constraints. Impacts from OHV use would be similar to the Proposed RMP, except there would be no impacts from cross-country OHV use and impacts from OHV use on designated routes 

Impacts from VRM management would be similar to the Proposed RMP, except many areas managed as Class II in Alternative A and the Proposed RMP would be managed as Class III, specifically around the White Cliffs area north of Highway 89 and south of Alton. This shift in management direction would result from prescriptions aimed at allowing vegetation treatments in areas heavily encroached by pinyon-juniper woodlands and providing for increased OHV recreation opportunities. Impacts from oil and gas exploration and development would be the same as Alternative A, but could occur within 455,900 acres (82 percent) open to oil and gas leasing subject to the standard terms on the lease form or subject to moderate constraints. Allowing cross-country OHV use on only approximately 1,100 acres would decrease visual impacts compared to Alternative A. Nearly all 
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color, and texture. Limiting OHV use to 57 miles of designated routes on 66,200 acres (12 percent) would maintain the visible lines on the landscape from the routes. Where OHV use is limited to designated routes impacts on the landscape would be limited to the existing transportation system, eliminating the creation of new routes that would result in further changes to the landscape and visual quality. Vegetation management actions could alter vegetation composition, which could improve visual variety, by introducing a mosaic of vegetation patterns in the landscape. Maintenance of existing pinyonjuniper treatments would retain the existing vegetative character of the landscape. 

as Alternative A, but could occur within 95,400 acres (17 percent) open to oil and gas leasing subject to the standard terms on the lease form or subject to moderate constraints. Allowing cross-country OHV use on only approximately 1,000 acres would decrease visual impacts compared to Alternative A. Nearly all visual impacts from OHV use would be associated with maintaining the visible lines of disturbance associated with 1,403 miles of designated routes. Impacts from vegetation would be the same as Alternative A, except more acres could be affected by treatments. 

would occur on only 1,190 miles of routes. Focusing on using vegetation treatment methods that use or mimic natural processes would reduce the short-term impacts in visual quality associated with the treatments. More acres would be impacted by firerelated treatments. Impacts associated with vegetation treatments would be the same as Alternative A, except treatment types used would reduce the long-term impacts on visual quality. 

visual impacts from OHV use would be associated with maintaining the visible lines of disturbance associated with 1,465 miles of designated routes. Impacts from vegetation would be the same as the Proposed RMP. 

Impacts on Non-WSA Lands with Wilderness Characteristics 

Cross-country OHV use would be allowed on 98 percent of these areas. While OHV registration and use continues to climb, this would result in a long-term loss of naturalness due to loss of vegetation during the creation of new routes. VRM classes in non-WSA lands with wilderness characteristics would be managed as follows: • Class I 0 acres • Class II 29,330 acres • Class III 4,970 acres • Class IV 46,600 acres 

• Unknown 8,880 acres 

The potential for some impacts from mineral exploration and development would remain. However, were all 

All or portions of five non-WSA lands with wilderness characteristics would receive direct management to protect, preserve and maintain their wilderness characteristics. Wilderness characteristics in the remaining areas could receive indirect protection from other management or could be impacted by other resources or uses. OHV use would be limited to 118 miles of designated routes (27.75 miles in areas managed for protection of wilderness characteristics and 90.25 in the remaining non-WSA lands with wilderness characteristics), decreasing impacts compared to Alternative A. OHV use along these 

Non-WSA lands with wilderness characteristics would be closed to OHV use, eliminating impacts described in Alternative A and the Proposed RMP. VRM classes in these areas would be managed as follows: 

• Class I 89,780 acres • Class II 0 acres • Class III 0 acres 

• Class IV 0 acres 

Impacts from mineral exploration and development would be eliminated. Oil and gas leasing in non-WSA lands with wilderness characteristics would be managed as follows: 

• Standard Stipulations 0 acres 

OHV use would be limited to 105 miles of designated routes, decreasing impacts compared to Alternative A. There would be shortterm perceived loss of opportunities for solitude and primitive recreation. VRM classes in non-WSA lands with wilderness characteristics would be managed as follows: 

• Class I 0 acres • Class II 20,620acres • Class III 62,840 acres 

• Class IV 6,320 acres 

Impacts from mineral exploration and development would be the same as Alternative A, except oil and gas leasing in non-WSA lands with wilderness characteristics would be 
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acres of disturbance anticipated in the RFD to occur on non-WSA lands with wilderness characteristics, less than 1 percent of all these areas would be directly impacted: • Standard Stipulations 83,050 acres • Moderate Constraints 5,600 acres • Major Constraints 1,130 acres 

• Closed 0 acres 

routes in inventoried non-WSA lands with wilderness characteristics would resulting a short-term perceived loss of opportunities for solitude and primitive recreation. VRM classes in non-WSA lands with wilderness characteristics would be managed as follows: 

• Class I 320 acres • Class II 50,050 acres • Class III 29,390 acres 

• Class IV 10,020 acres 

Impacts from mineral exploration and development would be the same as Alternative A, except oil and gas leasing in non-WSA lands with wilderness characteristics would be managed as follows: 

• Standard Stipulations 8,470 acres • Moderate Constraints 40,810 acres • Major Constraints 38,700 acres 

• Closed 1,800 acres 

• Moderate Constraints 0 acres • Major Constraints 0 acres 

• Closed 89,780 acres 

managed as follows: 

• Standard Stipulations 80,060 acres • Moderate Constraints 7,340 acres • Major Constraints 2,380 acres 

• Closed 0 acres 

Impacts on Forest and Woodland Products 

Designated harvest areas would continue to facilitate product harvest. Commercial harvest of forest and woodland products would continue to be excluded in all designated recreation sites, outstanding natural areas, areas of recent surface reclamation work, areas recommended for protective watershed management, VRM Class I and II areas, ACECs, WSRs, and areas that are heavily used for vegetation. Implementing vegetation treatments and managing vegetation resources 

Permitting commercial timber harvest on a case-by-case basis to promote or sustain forest health, unless otherwise designated or stipulated, would limit the potential for harvest. Permitting commercial and noncommercial harvest of pinyon-juniper areawide and other woodland species on a case-by-case basis, unless otherwise designated or stipulated, would facilitate woodland products harvest. Impacts from implementing vegetation treatments would be the same as described in Alternative A, 

Precluding commercial timber harvest would eliminate the potential for commercial harvest in the decision area. Impacts from commercial and noncommercial harvest of woodland products would be the same as described in the Proposed RMP. Impacts from implementing vegetation treatments would be the same as described in the Proposed RMP, except using treatment methods that mimic natural processes would reduce the quantity and quality of forest and woodland 

Permitting commercial timber harvest and commercial and non-commercial harvest of woodland products areawide, unless otherwise designated or stipulated, would facilitate product harvest. Under this alternative, harvest could occur over a larger area. Impacts from implementing vegetation treatments would be the same as described in the Proposed RMP. 
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Alternative A Proposed RMP Alternative C Alternative D 

to meet desired vegetation conditions would maintain or improve the quality of products available for harvest. 

except additional measures to manage and improve vegetation would be implemented. 

products available for harvest in the short term. 

Impacts on Livestock Grazing 

Surface disturbing activities, crosscountry OHV use, and general human disturbance could lead to sitespecific loss of forage, spread of noxious weeds, and displacement of livestock. These impacts would be minor due to the low levels of disturbance and use throughout the decision area. Vegetation treatments would generally help to offset forage losses by increasing forage production in treatment areas. 

Limiting OHV use to designated routes would limit loss of forage due to surface disturbance to 4,056 acres over the long term. The potential for harassment would also decrease. In addition, the management of SRMAs (95,100 acres) could focus recreation use and lead to site-specific loss of forage and displacement of livestock. Vegetation treatments would be prioritized to restore areas functioning at less than 51 percent of PNC, restore areas with noxious weed and/or non-native invasive plants, maintain previously treated areas, and achieve other objectives identified in the RMP. This would likely further improve vegetation conditions and increase forage production. 

Same as the Proposed RMP, except the management of SRMAs (129,050 acres) would focus on non-motorized recreation uses. This could decrease displacement of livestock and interference with grazing management due to OHV use. Surface use restrictions would be applied to SRMAs, which could also decrease the degree of forage removal and disturbance to livestock. Vegetation treatments would occur. However, treatment methods that use or mimic natural processes would be preferred. Using these preferred methods would result in a slower process of vegetation enhancement and related forage increases. 

Same as the Proposed RMP, except the management of SRMAs (122,800 acres) would focus on motorized recreation uses. This could increase the degree of disturbance to livestock and interference with grazing management due to OHV use. However, these impacts would be less than Alternative A due to limiting OHVs to designated routes. Impacts from vegetation treatments would the same as the Proposed RMP. 

Impacts on Recreation 

Development activities would create surface disturbances that would displace recreationists, reduce opportunities for primitive/unconfined recreation, and diminish the recreation setting and experience for those wanting a natural or undeveloped setting. Impacts would also occur in the form of conflicts among recreation users. Motorized recreation use would conflict with primitive/unconfined recreation when they occur in close proximity and would result in degradation of the setting and 

Although the types of impacts would be the same as described in Alternative A, the degree of impact would change. Increased land use restrictions to mitigate impacts from mineral development and to protect vegetation and biological resources would be implemented. This would help to maintain recreation opportunities and enhance the recreation setting and experience. Recreational user conflicts would be reduced through management of SRMAs (95,100 acres). Management of these areas would focus on 

Although the types of impacts would be the same as described in Alternative A, the degree of impact would change. Areas managed as SRMAs would be increased to 129,050 acres, the majority of the decision area would be subject to moderate and major constraints on leasable mineral development, nearly half of the decision area would be managed according to VRM Class I and II objectives, and 60,600 acres would be designated as ACECs. These intensive land use management actions and restrictions would provide the greatest level of 

Although the types of impacts would be the same as described in Alternative A, the degree of impact would change and fall somewhere between that of Alternative A and the Proposed RMP. Surface disturbing activities would displace recreationists, reduce opportunities for primitive/unconfined recreation, and degrade the recreation setting and experience, but to a lesser extent than under Alternative A because increased land use restrictions would reduce surface disturbances and, subsequently, impacts on recreation. 
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Alternative A Proposed RMP Alternative C Alternative D 

experience associated with primitive/unconfined recreation activities. Land use restrictions would help to reduce these impacts by enhancing the setting in which recreation activities take place and precluding certain activities in areas of user conflict. However, some restrictions could limit opportunities for motorized and hunting activities. 

preservation of scenic, cultural, and biological resources and allocating lands to different types of recreation uses. In addition to reducing user conflicts, this would enhance the recreation setting and experience. Opportunities for cross-country OHV use would be considerably reduced, because open OHV areas would be reduced by 99 percent. However, trail-based OHV opportunities would remain over most of the decision area. 

protection to recreation opportunities, settings, and experience. However, cross-country OHV use would be prohibited across the entire decision area. Although this would eliminate opportunities for this type of OHV use, it would protect opportunities for solitude and primitive/unconfined recreation and reduce the potential for user conflicts. Trail-based OHV use would still be allowed across most of the decision area. 

Management of SRMAs would serve to reduce recreation user conflicts to the same degree identified for the Proposed RMP. Opportunities for cross-country OHV use would be reduced to the same degree identified for the Proposed RMP. 

Impacts on Transportation 

Cross-country access would be provided for most of the decision area. While most motorized use within these acres would use the 1,499 miles of routes, the availability of cross-country use would allow motorized access regardless of the presence of a route. Designating 57 miles of routes on 66,200 acres would provide for motorized access to most of these areas, where nonmotorized access would be retained in the areas beyond the designated routes. Impacts on transportation and access via state-maintained highways and BLM-maintained system roads would occur as a result of land tenure adjustments. Acquiring legal access within the North Fork Virgin River, Orderville Gulch, Cogswell Point Road, and Branch of Cogswell Point Road would increase access to these areas and facilitate travel across the decision area and to adjacent public lands through the creation of a more contiguous decision area. 

Motorized access would be allowed on 1,403 miles of routes. The designated routes in these areas would provide for motorized access to most of the decision area, where non-motorized access could be obtained in the areas beyond the designated routes. The 75 miles of routes closed to use would not eliminate access to any portion of the decision area, although in some areas motorized access would require travel on more miles of routes to access the same area. Impacts on transportation and access via state-maintained highways and BLM-maintained system roads would occur as a result of land tenure adjustments. The disposal (via Section 203 sales) of 6,400 acres of public land could improve access to private and public land parcels and facilitate travel across the decision area through consolidating public lands and creating a more cohesive transportation system. However, 

Motorized access would be allowed on 1,190 miles of routes. The designated routes in these areas would provide for motorized access to most of the decision area, where non-motorized access could be obtained in the areas beyond the designated routes. However, closing 306 miles seasonally and 315 miles yearlong would reduce access to various areas of the decision area. Specifically, motorized access to the Orderville SRMA would be eliminated, as would motorized access within the WSAs. On a seasonal basis, motorized access would be eliminated between the Canaan Mountain and Parunuweap WSAs, in an area between Mt. Carmel Junction and Kanab, and south of highway 143 southwest of Panguitch. Impacts from lands and realty would be similar to those identified for the Proposed RMP, except the extent of disposals (via Section 203 sales) would decrease to 2,500 acres. 

Motorized access would be allowed on 1,464 miles of routes. The designated routes in these areas would provide for motorized access to most of the decision area, where non-motorized access could be obtained in the areas beyond the designated routes. The 41 miles of routes closed to use would not eliminate access to any portion of the decision area, although in some areas motorized access would require travel on more miles of routes to access the same area. Impacts from lands and realty would be similar to those identified for the Proposed RMP, except the extent of disposals (via Section 203 sales) would increase to 20,500 acres. While this could increase opportunities to consolidate public lands, allowing the sale of lands along the Arizona border would result 

in at least eight routes no longer being in public ownership, eliminating motorized and non-motorized access in these areas. 
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Kanab RMP 2-77 

Alternative A Proposed RMP Alternative C Alternative D 

these disposals could also reduce access due to the loss of public access to those areas. 

Impacts on Lands and Realty 

ROW restrictions include protection of riparian areas from lands and realty actions and VRM management actions to rehabilitate visual intrusions that could possibly restrict placement of facilities. The ROW seasonal limitation would be the 1⁄4-mile restriction around bald eagle roost and perch sites from November 1 to April 30, which could limit access and delay project construction of new ROWs and maintenance activity on existing ROWs. Allowing land tenure adjustments would facilitate access, improve management ability, accommodate resource management needs, and reduce conflicts between private landowners and uses. Diana’s Throne and the Water Canyon/South Fork Indian Canyon ACEC would be retained in public ownership. 

ROW avoidance (106,670 acres) and exclusion areas (75,700 acres) could lead to the placement of ROWs in less desirable locations or areas with restrictions on accessibility or construction. These restrictions could affect associated costs on new or amended ROWs. Public lands that contain riparian areas, crucial wildlife habitat, Cottonwood Canyon ACEC, sensitive cultural sites, and the Old Spanish National Historic Trail (Highway 89/20 segment in Garfield County) would be retained in public ownership. Land tenure adjustments, including FLPMA Section 203 disposals, would be allowed on 6,400 acres. 

The intensity and magnitude of impacts associated with ROW exclusion and avoidance areas would increase compared to Alternative A and the Proposed RMP. ROW avoidance (3,400 acres) and exclusion areas (255,200 acres) could lead to the placement of ROWs in less desirable locations or areas with restrictions on accessibility or construction. These restrictions could affect associated costs on new or amended ROWs. The majority of the ROW exclusion areas occur along U.S. Highway 89, which could hinder the ability to approve future ROW requests. Public lands that contain riparian areas, crucial wildlife habitat, nonWSA lands with wilderness characteristics, Cottonwood Canyon ACEC, Welsh’s Milkweed ACEC, Vermilion Cliffs ACEC, White Cliffs ACEC, sensitive cultural sites, and the Old Spanish National Historic Trail (Highway 89/20 segment in Garfield County) would be retained in public ownership. Land tenure adjustments, including FLPMA Section 203 disposals, would be allowed on 2,500 acres. 

Alternative D would have the fewest restrictions on ROWs. ROWs avoidance (15,200 acres) and exclusion areas (75,200 acres) could require design and siting requirements and affect associated costs on new ROWs or amended ROWs. Public lands that contain riparian areas, crucial wildlife habitat, sensitive cultural sites, and the Old Spanish National Historic Trail (Highway 89/20 segment in Garfield County) would be retained in public ownership. Land tenure adjustments, including FLPMA Section 203 disposals, would be allowed on 20,500 acres. 

Impacts on Minerals and Energy 

This alternative would have the least restriction on oil and gas leasing compared to the other alternatives. Approximately 76 percent of the 

While management actions under this alternative would not reduce the projected number of wells, the management actions could increase 

This alternative would have the greatest restriction on oil and gas leasing compared to the other alternatives. While management 

The impacts from this alternative are similar to Alternative A, but slightly more restrictive. Approximately 71 percent of the decision area would be 
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Alternative A Proposed RMP Alternative C Alternative D 

decision area would be open to oil and gas leasing subject to standard terms and conditions and 15 percent would have an NSO stipulation or be closed to leasing. 

costs associated with exploration and development and could require the installation of facilities in less desirable locations. Approximately 17 percent of the decision area would be open to oil and gas leasing subject to standard terms and conditions and 29 percent would have an NSO stipulation or be closed to leasing. 

actions under this alternative would not reduce the projected number of wells, they could increase costs associated with exploration and development and could require the installation of facilities in less desirable locations. Approximately 5 percent of the decision area would be open to oil and gas leasing subject to standard terms and conditions and 46 percent would have an NSO stipulation or be closed to leasing. 

open to oil and gas leasing subject to standard terms and conditions and 18 percent would have an NSO stipulation or be closed to leasing. 

Approximately 24,591 acres (4 percent) is currently withdrawn from locatable mineral entry. Areas withdrawn from locatable mineral entry would prohibit locatable mineral development, but due to low development potential this would minimally affect the ability to meet the demand for locatable minerals. 

In addition to the existing withdrawals (24,591 acres), an additional 9,500 acres would be recommended for withdrawal from locatable mineral entry, but this would not further affect exploration and development activities. 

Same as Alternative A, but this alternative would recommend the most acres for withdrawal from locatable mineral entry. However, due to low development potential, the 158,800 acres of areas recommended for withdrawal from locatable mineral entry would not affect exploration and development activities. 

Same as Alternative A, but this alternative would recommend the least acres for withdrawal from locatable mineral entry. The 7 acres of areas recommended for withdrawal from locatable mineral entry would not affect exploration and development activities. 

This alternative would close the fewest acres to mineral material disposals. The Crescent Butte, Shinarump Cliffs, and Vermilion Cliffs recreation sites and the 40-acre ponderosa pine area would be closed to mineral material disposals. Closing these areas to mineral material sales would not decrease the ability to meet the overall demand for mineral materials throughout the decision area. 

The majority of the 105,000 acres of areas closed to mineral material disposals do not coincide with sand and gravel high development potential areas, and the closed areas do not overlap areas with potential for stone deposit disposals. 

This alternative would close the most acres to mineral material disposals. The majority of the 175,000 acres of areas closed to mineral material disposals do not coincide with sand and gravel high development potential areas, and the closed areas do not overlap areas with potential for stone deposit disposals. 

The 21,200 acres closed to mineral material sales do not include areas of high development potential for sand, gravel, and stone. 

Coal management actions would allow for the leasing and development of coal resources on lands identified as suitable. Based on the coal unsuitability criteria under Alternative A, the Alton, Kolob, Kaiparowits, and Johns Valley coal 

Coal management actions would allow for the leasing and development of coal resources on lands identified as suitable (Appendix 6). Based on the coal unsuitability criteria, approximately 113,629 acres would be suitable for 

Same as the Proposed RMP. Same as the Proposed RMP. 
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Kanab RMP 2-79 

Alternative A Proposed RMP Alternative C Alternative D 

fields would be suitable for further leasing consideration. 

further leasing consideration. 

Impacts on Areas of Critical Environmental Concern 

Management associated with the existing ACEC would protect the associated relevant and important values. At least one relevant and important value in all five of the potential ACECs would be at threat of irreparable damage due to the potential for unmitigated threats. 

Management associated with the potential Cottonwood Canyon ACEC (and therefore the Water Canyon/South Fork Indian Canyon ACEC) would protect the associated relevant and important values. Management from other decisions in this alternative would provide protection to the relevant and important values associated with the other four potential ACECs. 

All relevant and important values would be protected through special management associated with the designation of the ACECs. 

Although no ACECs would be designated, management from other decisions in this alternative would provide protection to the relevant and important values associated with the Parunuweap Canyon ACEC. At least one relevant and important value in the four other potential ACECs would be at threat of irreparable damage due to the potential for unmitigated threats. 

Impacts on Wild and Scenic Rivers 

Impacts on WSR tentative classification would primarily result from increased OHV use access to “wild” river segments and from land treatments that could potentially impact “wild” river segments’ natural character. Impacts on outstandingly remarkable values (ORV) would primarily occur from land treatments and habitat management. However, impacts associated with such actions would likely be short term in duration and over the long term would likely result in protections to the ORVs. 

Impacts on WSRs would be similar to those described in Alternative A; however, impacts on the tentative classification and ORVs of suitable river segments would decrease because of management associated primarily with WSA, recreation, VRM, and WSR. Under this alternative, greater restrictions would be placed on surface disturbance, OHV use, and on maintaining the natural character of the areas in which the suitable river segments are located. By not finding some river segments suitable, there is a potential that impacts could occur on the ORVs and tentative classification that could be severe enough to preclude them from any future opportunities for WSR consideration. 

Impacts on WSRs would be similar to those described in the Proposed RMP; however, there would be greater indirect protections to the tentative classifications and ORVs from increased restrictions on actions that could impact these values. 

No eligible river segments would be considered as suitable for inclusion in the NWSRS, and as such no direct protections would be afforded any eligible rivers. Any protections to the ORVs or tentative classification identified in Alternative A would be indirect, resulting from management associated with other resource programs. Because no direct protections would be afforded to eligible river segments, there is a potential that impacts could occur on the ORVs and tentative classification that could be severe enough to preclude them from any future opportunities for WSR consideration. 

Impacts on Wilderness 

Implementation of the Wilderness Management Plan allows for periodic adjustments to site-specific management to ensure wilderness 

Implementation of the Wilderness Management Plan allows for periodic adjustments to site-specific management to ensure wilderness 

Same as the Proposed RMP, except using only natural and prescribed fire to restore ecological functions would reduce short-term impacts from 

Same as the Proposed RMP. 
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2-80 Kanab RMP 

Alternative A Proposed RMP Alternative C Alternative D 

characteristics are preserved. Solitude could be eliminated in the short term by vegetation manipulation projects. Over the long term, naturalness would be restored. 

characteristics are preserved. Impacts from vegetation manipulation would be the same as described in Alternative A, except having a full suite of restoration tools would allow the broadest approach to controlling invasive species and restoring ecological function. 

vegetation treatments, but also could increase impacts on natural character and functions of the wilderness area over the long term. 

Impacts on Wilderness Study Areas 

Wilderness characteristics within WSAs would be protected under this alternative. Motorized use along 32.6 miles of designated routes in the Parunuweap Canyon, Moquith Mountain and Orderville Canyon WSAs would result in short-term loss of solitude and perceived naturalness. In the long term, motorized use along designated routes (inventoried ways) would not result in the areas being disqualified from wilderness consideration by Congress. High concentrations of recreation users (large group sizes and/or frequent group encounters) would decrease outstanding opportunities for solitude in WSAs. This would be most evident in the areas currently receiving high levels of use, such as the North Fork Virgin River, Orderville Canyon, and Parunuweap Canyon WSAs. 

Same as Alternative A, except impacts from OHV use would decrease because 7.6 miles of routes/inventoried ways would be closed to OHV use. In addition, limiting group size associated with SRPs within WSAs to 12 would protect opportunities for solitude and primitive unconfined recreation. In addition to the reduction in the number of users as compared to Alternative A, supporting education and outreach programs such as “Tread Lightly” and “Leave No Trace” would reduce impacts from increasing numbers of overnight users as campers recreate in a manner that leaves fewer impacts. 

Wilderness characteristics within WSAs would be protected under this alternative. Designating no routes for motorized use within WSAs would eliminate any impact from that use. Limiting group size associated with SRPs within WSAs to 12 would protect opportunities for solitude and primitive unconfined recreation. In addition, limitations on group size within sensitive Mexican spotted owl habitat would increase protections on opportunities for solitude and primitive unconfined recreation within the Orderville Canyon, North Fork Virgin River, and western portions of the Parunuweap Canyon WSAs. However, further reductions in group sizes due to MSO habitat could also result in fewer opportunities for recreationists to access these areas. 

Same as Alternative A, except increasing group sizes associated with SRPs within WSAs to 20 could result in the temporary loss of opportunities for solitude or unconfined recreation for users from other groups. 

Impacts on Other Designations 

Under this alternative, the lack of any specific management for either segment of the Old Spanish National Historic Trail could result in alteration of the trail corridor or associated resources, which could impact the 

Management of the Old Spanish Trail would provide for consideration of the historic values present along the corridor and the subsequent developments that have occurred. In addition, coordination and 

Same as the Proposed RMP. Same as the Proposed RMP. 
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Alternative A Proposed RMP Alternative C Alternative D 

character and historic setting of the Old Spanish National Historic Trail. 

interpretative efforts would increase public appreciation for the trail’s values and significance in the region and nation’s history. Management of the trail components in the Kanab Field Office would be consistent with a Comprehensive Management Plan’s intent and would help lead to a consistent approach along the entire trail. This could lead to an enhanced experience for a trail visitor. 

Impacts on Social and Economic Conditions 

The total economic impacts from coal mining, oil and gas drilling and production, and livestock grazing from activities directly attributable to decision area lands were estimated using IMPLAN and data and assumptions based on professional judgment. Employment and income generated by activities associated with the 

BLM lands in this RMP/EIS are a small percentage of total employment and personal income in the two-county socioeconomic study area. For coal mining, oil and gas drilling, and oil and gas production, the IMPLAN analysis was based on Alternative A because insufficient information is available to 

allow quantification of economic differences between the alternatives. Coal mining would provide between 167 and 237 direct and indirect jobs and $10,827,000 and $15,446,000 in direct and indirect income. Oil and gas drilling would provide approximately 12 direct and indirect jobs and approximately $859,000 in direct 

and indirect income. Oil and gas production would provide between 1 and 7 direct and indirect jobs and $11,000 and $211,000 in direct and indirect income. In the case of livestock grazing, the alternatives include differences in the number of AUMs allocated to livestock. However, the resulting differences in the 

value of production, when run through the IMPLAN model, produced differences for employment of less than one job and differences in labor income of only a few hundred dollars for both current active AUMs and total permitted AUMs—in both cases well within the margin of error of any economic model and within the rounding margin for reporting of results. Livestock production from the decision area would provide between 11 and 26 direct and indirect jobs and $56,000 and $132,000 in direct and indirect income. For some resources, quantification of economic impacts was not possible. The lack of quantifiable differences in economic impacts does not mean that 

differences would not occur. Some differences are simply not quantifiable given the available data. The following sectors are likely to have economic impacts, 

but quantification of impacts was not possible: locatable minerals (specifically, septarian concretions and gypsum); salable minerals (specifically, sand and 

gravel, stone, and clay); lands and realty (e.g., ROWs, disposals); recreation; and transportation (OHV use). In particular, recreational activities (including OHVbased recreation) no doubt generate substantial employment and income. For these sectors, qualitative description of economic impacts is provided in Chapter 

4 if there are any economically discernable differences in the alternatives. 

This alternative would allow coal, oil, and gas development to occur as expected under the RFD. Coal mining would generate some additional population growth that could result in increased demands on community services. Alternative A continues most current land management policies and 

The Proposed RMP would provide improved management approaches to use of resources that would address many potential resource use conflicts. The Proposed RMP’s closure of almost all land to crosscountry OHV use would produce some impacts on local custom and culture, such as some motorized 

Alternative C would allow for resource uses for economic benefits while maximizing protection of natural values. As such, it would have more pronounced adverse impacts on individuals and groups that favor resource development over preservation. Alternative C would somewhat favor 

Alternative D would maximize resource uses for economic benefits while providing some protection of natural values. As such, it would have more pronounced adverse impacts on individuals and groups that favor preservation over resource development. Alternative D would be most 
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2-82 Kanab RMP 

Alternative A Proposed RMP Alternative C Alternative D 

practices, which would be welcomed by some users in and beyond the socioeconomic study area but found less desirable by many others who see a variety of adverse impacts and foregone opportunities under current management. Specifically, the crosscountry OHV use throughout 466,000 acres (82 percent) would continue to provide ample opportunities for motorized recreation while resulting in increased user conflicts between those interested in motorized recreation and those interested in preservation and non-motorized recreation. It is likely that given current trends, conflicts between these and other resource users would increase. 

recreation users of BLM lands could be restricted. At the same time, managing 95 percent of existing OHV routes and provision of increased facilities and other improvements would improve the recreational experience for many motorized recreation users and would reduce some conflicts with non-motorized users. The Proposed RMP would include land treatments to increase livestock forage availability that would be welcomed by livestock grazing interests. Preservation interests would welcome the Proposed RMP’s increased constraints on natural resource development compared to Alternative A. At the same time, natural resource development interests would still find substantial development opportunities available under the Proposed RMP. 

persons and groups interested in non-motorized recreation and preservation of habitat, ecosystem, visual, and similar values of natural landscapes. However, opportunities for oil and gas development, motorized recreation, and other more traditional uses of BLM lands would still exist, but would likely require extensive mitigation. 

preferred by individuals and groups interested in natural resource development and motorized recreation and less favored by those with preferences for less development and use of public lands, although it would still provide important protections for the local environment. 

Impacts on Tribal Interests 

The BLM will protect and preserve access to religiously/spiritually significant Native American sites for the exercise of traditional religions and worship through 

ceremonials and traditional rites. Sacred sites would be identified on a case-by-case basis through consultation efforts with Native American tribes. As these sacred sites are identified, the BLM would protect them and allow access to them through site-specific means identified on a case-by-case basis. 

Existing LUPs do not specifically address tribal issues or Native American religious concerns. Identification and protection of sites and traditional use areas would take place on a case-by-case basis. Managing wildland fire to restore preEuropean settlement conditions could result in a short-term loss of traditional use opportunities, but in the long term vegetation conditions would move toward a pre-European settlement state, improving the condition of traditionally used species. However, if during 

Proactive coordination with interested tribes could result in the identification and management of traditional use areas and Native American religious sites prior to disruptive projects being proposed. Impacts from restoring vegetation to pre-European settlement conditions would increase compared to Alternative A due to implementing up to 22,300 acres of vegetation treatments annually. These treatments could result in a shortterm loss of traditional use opportunities, but in the long term 

Proactive coordination with interested tribes could result in the identification and management of traditional use areas and Native American religious sites prior to disruptive projects being proposed. Impacts from restoring vegetation to pre-European settlement conditions would increase compared to Alternative A due to implementing 4,650 acres of vegetation treatments annually. Limiting treatments methods to emphasize restoration of natural processes could reduce the rate at which vegetation communities 

Proactive coordination with interested tribes could result in the identification and management of traditional use areas and Native American religious sites prior to disruptive projects being proposed. Impacts from restoring vegetation to pre-European settlement conditions would be the same as the Proposed RMP. Making 20,500 acres available for potential FLPMA Section 203 sale would include all the areas the Kaibab-Paiute Tribe requested be made available for disposal except 
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Alternative A Proposed RMP Alternative C Alternative D 

rehabilitation non-native plant species replaced native plant species culturally important to Native American tribes, there would be a decrease in future opportunities for traditional use of native species. None of the 80 acres available for FLPMA Section 203 sale include the areas that the Kaibab-Paiute Tribe requested be made available for disposal. 

vegetation conditions would move toward a pre-European settlement state, improving the condition of traditionally used species. None of the 6,400 acres available for FLPMA Section 203 sale include the areas that the Kaibab-Paiute Tribe requested be made available for disposal. 

are restored compared to the Proposed RMP and Alternative D. None of the 2,700 acres available for FLPMA Section 203 sale include the areas that the Kaibab-Paiute Tribe requested be made available for disposal. 

acres within WSAs. This would help the Tribe’s interest in obtaining lands within the State of Utah, although they would still have to purchase the land. 

Impacts on Public Safety 

The potential for impacts from hazardous material and waste would be low, because hazardous waste sites do not currently exist within the decision area. Impacts would be further limited through federal regulation of hazardous materials, substances, and waste; national contingency plans; BLM policy on 

hazardous waste disposal; and continued coordination with federal and state partners regarding hazardous materials and waste issues (e.g., abandoned mine 

lands). BLM-administered public land sites contaminated with hazardous wastes would be reported, secured, and remediated according to applicable federal 

and state regulations and contingency plans. 
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Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-1 

CHAPTER 3—AFFECTED ENVIRONMENT 

3.1 INTRODUCTION

Chapter 3 describes the existing condition of the resources, resource uses, and other features of the 

planning area and the decision area. The affected environment serves as the baseline of existing 

conditions from which the impacts of the alternatives are analyzed. 

The first part of this chapter describes the existing natural and cultural resources, discussing resource 

indicators, current conditions, trends, forecasts, and key features. The second part describes resource uses, 

discussing existing and potential uses, forecasts, and trends. The third section describes special 

designations, and the last section describes social and economic features. 

3.2 RESOURCES

The public lands administered by the Kanab Field Office (KFO) are managed for multiple uses. Multiple 

use management includes the management of resource uses as well as resource values. The decision area 

is important for its natural areas and values, such as the large number of wilderness study areas (WSAs) 

and special status species/habitat. These values are important ecologically and scientifically, as evidenced 

by the continued interest in the area by universities and colleges. The resources in the decision area have 

also provided the context for diverse land uses. The existing condition of the decision area’s resources 

will provide the context in which management can continue to ensure the sustained yield of multiple uses. 

The following sections discuss each resource present in the decision area and include, where applicable, a 

discussion of the following five factors: 

• Indicators: Factors that are used to describe the condition of the resources 

• Current Condition: Location, extent, and current condition of the resources 

• Trends: Degree and direction of change between the present and some point in the past 

• Forecast: Predicted changes in the condition of resources given current management 

• Key Features: Geographic location, distribution, areas, or types of resource features that should 

guide management decisions. 

3.2.1 Air Quality 

In accordance with the 1970 Clean Air Act (CAA) and the 1977 and 1990 Clean Air Act Amendments, 

the Environmental Protection Agency (EPA) promulgated ambient air quality standards and regulations. 

The National Ambient Air Quality Standards (NAAQS) were enacted for the protection of the public 

health and welfare. The Utah Division of Air Quality (UDAQ) is responsible for regulating and 

monitoring air quality in Utah. Measurements are typically taken in urban areas where ambient pollution 

levels are expected to be the highest. Concentrations of inhalable particulate matter (PM) less than 10 

microns in diameter (PM10) and less than 2.5 microns in diameter (PM2.5) are expected to be higher near 

towns and unpaved roads. Regional PM10 and PM2.5 levels are likely a result of fugitive dust sources. 

Ambient Air Quality

The existing air quality in the planning area is expected to be typical of undeveloped regions in the 

western United States. For ozone (O3) data have been collected at Grand Canyon National Park from 

1999-2007 and Canyonlands National Park from 1996-2007. Figure 3-1 shows the 8 hour average 
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3-2 Kanab RMP 

concentrations for Grand Canyon. Annual average ozone concentrations are shown in Figure 3-2 for 

Canyonlands. The data indicate compliance with the ozone standard. Also, no data trends are noted. 

Figure 3-1. Ozone Concentrations in Grand Canyon National Park, Arizona. 

0.06

0.065

0.07

0.075

0.08

0.085

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Data taken from EPA Air Data

Grand Canyon National Park station

3 year rolling average of 8 hour 4th maxima

8 hour O3 concentration (ppm)

former NAAQS

NAAQS
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-3 

Figure 3-2. Mean Annual Ozone Concentrations near the Kanab Planning Area. 

0

10

20

30

40

50

60

70

80

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Data taken from Clean Air Status & Trends

CASTNet Canyonlands National Park station: CAN407

O3 concentration (ppb)

Additionally, nitrogen and sulfur compounds have been measured at Canyonlands National Park from 

1995-2006. Figure 3-3 and Figure 3-4 show that the data are typical for rural western US locations. A 

slight downward trend in the data is noted for sulfur compound. 
Chapter 3 Proposed RMP and Final EIS 

3-4 Kanab RMP 

Figure 3-3. Mean Annual Concentrations of Nitrogen Compounds 

near the Kanab Planning Area. 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

Data taken from Clean Air Status & Trends Network

CASTNet Canyonlands National Park station: CAN407

Typical concentrations for remote areas:

HNO3 (nitric acid): .05 - 8 ug/m3

NH4 (ammonium): .2 ug/m3

NO3 (nitrate): .5 ug/m3

Concentration (ug/m3)

HNO3

NH4

NO3
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-5 

Figure 3-4. Mean Annual Concentrations of Sulfur Compounds 

near the Kanab Planning Area. 

0

0.5

1

1.5

2

2.5

1995 1996 1997 1998 1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Data taken from Clean Air Status & Trend Network

CASTNet Canyonlands National Park station CAN407

Typical concentrations for remote areas

SO2: 2.6 - 26 ug/m3

SO4: 2.5 ug/m3

Concentration (ug/m3)

SO2

SO4

Other ambient air data are not available for the immediate area. Limited data collected in typical areas 

indicate that ambient pollutant levels are usually near or below measurable limits. Locations vulnerable to 

decreasing air quality include the areas immediately around surface-disturbing activities, such as energy 

and mineral development projects and farm tilling, and local population centers affected by residential 

emissions. 

The most recent UDAQ Statewide Emissions Inventory Report shows that the primary air pollutant in 

Garfield and Kane counties is volatile organic compounds (VOC), followed by carbon monoxide (CO), 

PM10, nitrogen oxides (NOx), sulfur oxides (SOx), and PM2.5. Table 3-1 shows the criteria pollutant levels 

in tons per year from the Statewide Emissions Inventory. 

Table 3-1. 2002 Criteria Pollutant Inventory (tons per year). 

Area PM10 PM2.5 SOx NOx VOC CO 

Garfield 5,155 4,024 95 1,638 51,387 57,471 

Kane 750 205 89 564 48,948 16,544 

Utah Total 82,439 23,288 49,090 205,313 911,310 1,314,041 

Utah Average 3,053 1,208 1,818 7,604 33,752 48,668 

Source: (UDAQ 2002) 
Chapter 3 Proposed RMP and Final EIS 

3-6 Kanab RMP 

The greatest sources of air pollution emissions in Garfield and Kane counties are area sources and on-road 

mobile sources. Area sources include small mobile and stationary sources such as gas stations or wood 

burning. Vehicles are the major source of on-road mobile emissions. 

Native American tribal governments have the responsibility to develop, implement, and manage programs 

within tribal lands. The 1977 CAA authorizes eligible tribes to implement their own tribal air programs. 

Because tribes in Utah do not have approved tribal implementation plans, the air resources comprising the 

surrounding Native American Reservations should be viewed as potentially sensitive areas. 

Although the Prevention of Significant Deterioration (PSD) program applies only to stationary source 

permitting activities and does not apply to land use planning decisions, it does help describe the goals and 

objectives set forth in the Resource Management Plan (RMP) and the actions that can be taken to 

accomplish those goals and objectives. The purpose of the PSD program is to maintain and protect areas 

of pristine air quality and prevent significant deterioration, while still allowing some development in other 

areas. Federal, state, and tribal air quality laws and regulations designed to comply with the PSD program 

are used to help set goals and objectives for the planning area. The concept behind PSD is to keep clean 

areas clean. Under PSD each area in the country is classified under federal and state law according to the 

following system: 

• PSD Class I Areas. Areas with pristine air quality, such as wilderness areas, national parks, and 

some Indian reservations, are accorded the strictest protection. Only very small incremental 

increases in concentration are allowed to maintain very clean air quality in these areas. 

• PSD Class II Areas. Moderate incremental increases in concentration are allowed, although the 

concentrations are not allowed to reach the concentrations set by NAAQS. 

• PSD Class III Areas. No areas have yet been designated Class III. Concentrations would be 

allowed to increase to established NAAQS concentrations. 

The 1977 CAA automatically designated certain large areas (e.g., national parks, national monuments, 

and wilderness areas established before this date) as Class I areas, the most highly protected category. The 

following lists the areas within Utah that are designated as mandatory Class I areas (EPA 2000) and their 

location relative to the planning area: 

• Arches National Park—120 miles northeast 

• Bryce Canyon National Park—Within the planning area 

• Canyonlands National Park—60 miles east 

• Capitol Reef National Park—Adjacent to the planning area 

• Zion National Park—Adjacent to the planning area. 

All other areas where the secondary NAAQS are met, or that cannot be classified, were initially 

designated as Class II areas. The decision area is designated as either attainment or unclassified with 

respect to NAAQS for all criteria pollutants and, therefore, is classified as PSD Class II. The decision area 

is designated as either attainment or unclassified with respect to NAAQS for all criteria pollutants and, 

therefore, is classified as PSD Class II. There are no nearby nonattainment areas for the Class I areas 

listed above. 

Other areas with air quality designations administered by federal agencies include Paria Canyon–

Vermilion Cliffs Wilderness (managed by the BLM) and Box-Death Hollow Wilderness (managed by the 

U.S. Forest Service). These were established after August 1977, and are, therefore, Class II areas. In 

addition, Glen Canyon National Recreation Area (National Park Service [NPS]), and Grand Staircase–

Escalante National Monument (GSENM) (Bureau of Land Management [BLM]) are Class II areas. An 

additional Class I area in the vicinity is Grand Canyon National Park. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-7 

Any smoke emissions resulting from annual prescribed burning projects or treatments within the planning 

area are conducted and managed in compliance with guidelines in the Utah Smoke Management Plan and 

interagency group program. Active group participants include various federal and state agency land 

managers, as well as the UDAQ. The purpose of this program and the Utah Smoke Management Plan is to 

ensure that mitigation measures are taken to reduce the impacts on public health, safety, and visibility 

from prescribed fire and wildland fire used for resource benefits (UDAQ 2004). Compliance with the 

Utah Smoke Management Plan is the primary mechanism for land managers to implement prescribed 

burns while ensuring compliance with the CAA. Burn plans written under this program include actions to 

minimize fire emissions, exposure reduction procedures, a smoke dispersion evaluation, and an air quality 

monitoring plan. Proposed burns are reviewed daily by the program coordinator and burns are approved 

or denied based on current climatic and air quality conditions.

Visibility 

Regional haze is an issue of increasing concern throughout the western United States. Regional haze 

causes visual impairment by obscuring the clarity, color, texture, and form of what can be seen. As part of 

the Interagency Monitoring of Protected Visual Environments (IMPROVE) network, visual air quality in 

Bryce Canyon National Park and Canyonlands National Park has been monitored from 1992–2004. 

Figure 3-5 and Figure 3-6 indicate that the visibility trend both in Bryce Canyon National Park and 

Canyonlands is improving on the clearest days. 

Figure 3-5. Visibility Data for Bryce National Park 
Chapter 3 Proposed RMP and Final EIS 

3-8 Kanab RMP 

Figure 3-6. Visibility Data for Canyonlands National Park 

Atmospheric Deposition

Atmospheric deposition of air pollutants can increase the acidity of soils and water resources. 

Measurements of atmospheric deposition are currently being taken in Class I areas of Bryce Canyon 

National Park, and Canyonlands National Park by the National Acid Deposition Program. Figure 3-7 

shows precipitation pH data at Bryce national Park from 19985-2006. Recent measurements show less 

acidity for the period 1994-2001. Available data indicate that wet deposition of ammonium as measured 

by the NADP station in Bryce Canyon National Park has indeed increased from .2 to .8 kg/ha-year during 

the period from 1984 through 2006. 

Total nitrogen and sulfur deposition are shown for Canyonlands National Park from 1995-2004 in Figure 

3-8 and Figure 3-9. The data indicate the rates of atmospheric deposition of nitrogen and sulfur in rain are 

relatively low in Canyonlands National Park. Trend analysis shows that nitrogen deposition has remained 

relatively constant and that sulfur deposition has slightly decreased. Total nitrogen deposition from 

nitrogen compounds, including ammonium, remains below the nitrogen deposition level-of-concern of 3 - 

5 kg/ha-year (Fox, 1989), with deposition ranging from 1.7 to 2.2 kg/ha-year during the period from 1995 

through 2004. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-9 

Figure 3-7. Mean Annual Precipitation pH near the Kanab Planning Area. 

4

4.2

4.4

4.6

4.8

5

5.2

5.4

5.6

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

2005

2007

Data taken from National Atmospheric Deposition Program

NADP Bryce Canyon National Park - Repeater Hill station: UT99

precipitation pH

Figure 3-8. Total Nitrogen Deposition for Canyonlands National Park 
Chapter 3 Proposed RMP and Final EIS 

3-10 Kanab RMP 

Figure 3-9. Total Sulfur Deposition for Canyonlands National Park 

The lack of available data limits the forecasting trends of air quality; however, ambient air quality is not 

exceeding standards, visibility is typical of clear skies associated with remote areas in the western United 

States, and atmospheric deposition levels are below federal levels of concern. Future changes to air 

quality conditions would occur according to the intensity and expansion or reduction of activities that 

produce air pollutants. However, the use of air pollution mitigation techniques can reduce emissions from 

sources, and in some cases, also minimize air quality impacts. At this time, future impacts to air quality 

within the planning area from non-BLM sources (e.g., power plants and fireplaces) are uncertain; 

however, emissions from these existing sources are not anticipated to increase. 

Global Climate Change

On-going scientific research has identified the potential impacts of climate changing pollutants on global 

climate. These pollutants are commonly called “greenhouse gases” and include carbon dioxide, CO2; 

methane; nitrous oxide; water vapor; and several trace gas emissions. Through complex interactions on a 

regional and global scale, these emissions cause a net warming effect of the atmosphere, primarily by 

decreasing the amount of heat energy radiated by the Earth back into space. Although climate changing 

pollutant levels have varied for millennia (along with corresponding variations in climatic conditions), 

recent industrialization and burning of fossil carbon sources have caused CO2 concentrations to increase 

dramatically, and are likely to contribute to overall climatic changes, typically referred to as global 

warming. Increasing CO2 concentrations also lead to preferential fertilization and growth of specific plant 

species. 

Global mean surface temperatures have increased nearly 1.0°C (1.8°F) from 1890 to 2006 (Goddard 

Institute for Space Studies, 2007). However, observations and predictive models indicate that average 

temperature changes are likely to be greater in the Northern Hemisphere. Figure 3-10 demonstrates that 

northern latitudes (above 24° N ) have exhibited temperature increases of nearly 1.2°C (2.1°F) since 

1900, with nearly a 1.0°C (1.8°F) increase since 1970. Without additional meteorological monitoring 

systems, it is difficult to determine the spatial and temporal variability and change of climatic conditions, 

but increasing concentrations of these “greenhouse gases” are likely to accelerate the rate of climate 

change. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-11 

The Intergovernmental Panel on Climate Change (IPCC) has recently completed a comprehensive report 

assessing the current state of knowledge on climate change, its potential impacts, and options for 

adaptation and mitigation. At printing of this PRMP/FEIS, this assessment is available on the IPCC web 

site at http://www.ipcc.ch/. According to this report, global climate change may ultimately contribute to a 

rise in sea level, destruction of estuaries and coastal wetlands, and changes in regional temperature and 

rainfall patterns, with major implications to agricultural and coastal communities. The IPCC has 

suggested that the average global surface temperature could rise 1 to 4.5 degrees Fahrenheit (°F) in the 

next 50 years, with significant regional variation. The National Academy of Sciences (2006) has 

confirmed these findings, but also indicated that there are uncertainties regarding how climate change 

may affect different regions. Computer models indicate that such increases in temperature will not be 

equally distributed globally, but are likely to be accentuated at higher latitudes, such as in the Arctic, 

where the temperature increase may be more than double the global average (BLM 2007b). Also, 

warming during the winter months is expected to be greater than during the summer, and increases in 

daily minimum temperatures is more likely than increases in daily maximum temperatures. 

Vulnerabilities to climate change depend considerably on specific geographic and social contexts.

BLM recognizes the importance of climate change and the potential effects it may have on the natural 

environment. Several activities occur within the planning area that may generate emissions of climate 

changing pollutants. For example, oil and gas development, large fires, and recreation using combustion 

engines, can potentially generate CO2 and methane. Wind erosion from disturbed areas and fugitive dust 

from roads along with entrained atmospheric dust has the potential to darken glacial surfaces and snow 

packs resulting in faster snowmelt. Other activities may help sequester carbon, such as managing 

vegetation to favor perennial grasses and increase vegetative cover, which may help build organic carbon 

in soils and function as “carbon sinks”. 

Figure 3-10. Annual Mean Temperature Change for Northern Latitudes (24 - 90° N) 

Source: Goddard Institute for Space Studies (2007) 

3.2.2 Geology, Topography, and Climate 

Most of the planning area is located on the western edge of the Colorado Plateau physiographic province, 

with the northwestern reaches located in the Basin and Range/Colorado Plateau Transitional 

physiographic region (Stokes 1986). These two physiographic provinces are further broken into three 
Chapter 3 Proposed RMP and Final EIS 

3-12 Kanab RMP 

physiographic subunits—Southern High Plateaus, Grand Staircase, and Kaiparowits Plateau–Escalante 

Benches. The planning area’s general surface geology is shown on Map 21. 

Topography 

The Colorado Plateau is a massive block of stratified rock that began to rise during a tectonic mountainbuilding episode between 80 million and 40 million years ago. The layers of rock in the Colorado Plateau 

are “virtually as level and undeformed as when they were deposited” (Stokes 1986). The Grand Staircase 

subunit of the Colorado Plateau (Map 22) is a series of cliffs and terraces that rise stratigraphically from 

the Grand Canyon in the south to high plateaus in Utah. A succession of cliffs form a massive staircase 

displaying more than 200 million years of the earth’s history. The series of cliffs, starting at the southern 

edge of the planning area, are Shinarump or Chocolate (Triassic), Vermilion (Triassic/Jurassic), White 

(Jurassic), Grey (Jurassic/Cretaceous), and Pink (Paleogene). Each step in the staircase is present in the 

planning area. Topographically, the stairstep relief results in a large increase in elevation from the 

planning area’s southern edge (approximately 5,000 feet above sea level) to its northern edge (more than 

10,000 feet above sea level). The Kaiparowits Plateau–Escalante Benches subunit of the Colorado Plateau 

(Map 22), like the Grand Staircase to the west, rises in elevation to the north, with a trellis system of 

incised canyons cutting along and perpendicular to the northward-aligned geologic structures. The 

Kaiparowits Plateau consists primarily of Cretaceous age marine and non-marine sedimentary rocks. 

Older rock units within the subdivision define benches or terraces that border Glen Canyon and Paria 

Canyon on the south. Younger rocks are exposed in the pink cliffs that define the northern boundary of 

the subdivision. The decision area in the north is composed of scattered tracts of land between the Dixie 

National Forest and GSENM. On the south, the Paria Canyon–Vermilion Cliffs Wilderness occupies the 

southwestern corner of this subunit. 

The Basin and Range/Colorado Plateau Transition province is a broad belt between two major western 

physiographic provinces in which features of both provinces are evident (Stokes 1986). The Southern 

High Plateaus subunit of the province is “the most extensive, relatively unbroken expanse of extrusive 

igneous rocks...capping much of the High Plateaus” (Stokes 1986 p. 249). The southern and eastern 

portions of the subunit are characteristic of the Colorado Plateau; the western and northern landform in 

the Southern High Plateaus is more characteristic of the Basin and Range (Map 22). The southernmost 

reaches of the subunit are characterized by outcrops of the Claron Formation and sharing of the pink cliffs 

of the Colorado Plateau’s Grand Staircase subunit. The Southern High Plateaus within the planning area 

include most or all of the Markagunt Plateau, the Paunsaugunt Plateau, and the Aquarius Plateau. These 

plateaus are separated by the Sevier Fault (Sevier Valley) and the Paunsaugunt Fault (Johns Valley), 

respectively. Portions of the Tushar Mountains, the Sevier Plateau, and the Awapa Plateau are also found 

in the northern part of the planning area. The planning area ranges in elevation from 6,100 feet at the 

mouth of Circleville Canyon to 11,200 feet on the top of Boulder Mountain. 

Mineral and Energy Resource Occurrence 

The presence and distribution of minerals in the planning area is controlled by the associated geology. 

This section addresses the major mineral occurrences within the planning area. More information about 

the planning area’s geology and associated minerals is provided in the Mineral Potential Report (BLM 

2005d) for the Kanab Planning Area. That report contains extensive information on the lithology, 

depositional settings, and stratigraphic relations of the rock units present within the planning area. The 

report discusses geologic formations ranging in age from the Precambrian through the Tertiary, although 

only Permian-age and younger rocks are exposed at the surface (BLM 2005d). In addition, the report 

describes the area’s energy and mineral resources and their potential for development. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-13 

Oil and Gas. An area that has the geologic components required for oil and gas to be present and 

recoverable is called a “play.” The U.S. Geological Survey (USGS) defines an oil and gas play as a set of 

known or postulated oil and (or) gas accumulations sharing similar geologic, geographic, and temporal 

properties, such as source rock, migration pathway, timing, trapping mechanism, and hydrocarbon type. 

The USGS has identified four oil and gas plays within portions of the planning area. Many of these plays 

are hypothetical because they have no proven reserves or production history. The four oil and gas plays 

are the following: 

• Late Proterozoic/Cambrian Play 

• Paleozoic Devonian-Pennsylvanian Play 

• Permo-Triassic Unconformity Play 

• Cretaceous Sandstone Play. 

Although it is possible that one deep well could test all five stratigraphic intervals of the plays, each play 

is considered an individual target that will have separate, spatially isolated hydrocarbon accumulations 

that must be discovered on a play-by-play basis. The Late Proterozoic/Cambrian Play and Cretaceous 

Sandstone Play are rated moderate (M) for occurrence potential with a moderate (C) level of certainty. 

The Devonian-Pennsylvanian Play and the Permo-Triassic Play are rated high (H) for occurrence 

potential with a high (D) level of certainty. 

Only limited exploration and development for oil and gas has occurred within the planning area. As of 

2005, there is only one producing oil field, the Upper Valley field, which was discovered in 1964 (BLM 

2005d). During development of this field, oil and gas resources were identified in several geologic 

formations, although production is predominantly from formations within the Permo-Triassic 

Unconformity Play. The Upper Permian Kaibab Formation is one of the primary oil-producing units in 

the Upper Valley field. Early development of the field also produced minor amounts of oil from the 

deeper Mississippian Redwall Limestone in the Paleozoic Devonian-Pennsylvanian Play (BLM 2005d). 

Wells into this formation are currently capped, but there is potential for further development and 

production. 

In addition to the occurrence of conventional oil and gas, the potential for coalbed natural gas (CBNG) 

has been identified in the planning area. The presence of methane gas in coal seams has long been 

recognized; however, only recently have some coals been recognized as both a reservoir and source rock 

for this unconventional energy resource. Under some geologic conditions, the methane produced in 

coalbeds can be extracted. New plays have been identified for areas that are prospective for CBNG. This 

group, known as the Cretaceous Coal Bed Gas Plays, was defined by the Utah Geological Survey (UGS) 

to cover potential reservoir areas of the coal-bearing Upper Cretaceous units of south-central Utah 

(Dakota and Straight Cliffs Formations). Depths of the coalbed reservoirs in this group of plays range 

from 0 to about 6,000 feet. The Cretaceous Coal Bed Gas Play is rated moderate (M) for occurrence 

potential with a moderate (C) level of certainty. 

Another related petroleum resource, known as tar sands, is present on the eastern edge of the planning 

area. This deposit is a play along the Permo-Triassic Unconformity that over time has been exposed to 

erosion, allowing the volatiles from the oil and gas reservoir to escape and leaving a viscous tar-like 

substance. 

Coal. Beds of coal thick enough to be mined commercially occur in the Dakota Formation and Straight 

Cliffs Formation in the planning area (Doelling and Graham 1972, Doelling et al. 1989). Areas within 

each field that have thick, shallow coal are rated high (H) for occurrence potential with a high (D) level of 

certainty. The deeper and thinner parts of each coal field are rated as high (H) for occurrence potential 

with a moderate (C) level of certainty. 
Chapter 3 Proposed RMP and Final EIS 

3-14 Kanab RMP 

The coals of the Dakota Formation (Alton and Kolob coal fields) and the Straight Cliffs Formation 

(Kaiparowits Plateau Coal Field) were deposited by a series of coalescing delta complexes derived from a 

westerly source. Local lenses and stringers of coal can be found in the Triassic Chinle Formation in the 

planning area, but none are thick enough for commercial development. 

There are two commercial coal zones in the Dakota Formation (Smirl and Bald Knoll). These coalbeds 

are as thick, but lower in heat content and higher in ash and sulfur content than the coalbeds mined in the 

Blackhawk Formation in the coal fields of central Utah. More information on the quality of the coal in 

these fields is contained in the Mineral Potential Report (BLM 2005d). The part of the Alton coal field 

within the planning area contains a total of 1,278 million tons, of which 203 million tons (about 16 

percent) is at surface minable depths (Doelling and Graham 1972). The topography of the Kolob coal 

field in the decision area is steeper than in the Alton area, resulting in little coal that is surface minable. 

Therefore, no surface minable resource was calculated, and all 1,360 million tons of coal in the part of the 

Kolob field within the planning area would probably have to be accessed by underground methods. 

The Straight Cliffs coals are exposed on the eastern and western margins of the Kaiparowits Basin in the 

Escalante and Tropic areas, respectively. The majority of these coals are not within the decision area, 

although they are within the planning area. They are thicker and more numerous on the eastern side of the 

Kaiparowits coal field near Escalante and thinner to the west (BLM 2005d). The coal down to a depth of 

3,000 feet is potentially minable; the coal between 1,000 and 6,000 feet deep could be prospective for 

CBNG. The maximum measured total net coal thickness in the Straight Cliffs coals in the planning area is 

100 feet in a drill hole north of the town of Escalante. Although the ash and sulfur levels of the analyzed 

portions of the Straight Cliffs Formation are similar to those of the coal currently being mined from the 

Blackhawk Formation in central Utah, their moisture content is considerably higher and the heat content 

correspondingly lower. More information on the quality of the coal in these fields is contained in the 

Mineral Potential Report (BLM 2005d). 

The Johns Valley area is an informally named coal-bearing area in Township 33 and 34 S, Range 2 W 

(Doelling and Davis 1978). Several drill holes in the southeast corner of Section 33, Township 33 S, and 

Range 2 W penetrated an 18-foot-thick coalbed in the upper part of the Dakota Formation at depths from 

400 to 700 feet. More wide-spaced drilling would be needed to define minable resources in the Johns 

Valley area. 

Geothermal. Geothermal energy is heat that originates within the earth. With few exceptions, the higher 

temperature geothermal areas in Utah occur either in the Basin and Range province or in the Transition 

Zone. The Transition Zone coincides mainly with the Garfield County portion of the planning area, but 

extends slightly into the northern part of Kane County. Identified geothermal areas are located primarily 

in western Garfield County within the Basin and Range province and the Transition Zone. Few lowtemperature thermal springs occur within the planning area. Although some springs are present in areas 

with geothermal indicators (e.g., young volcanic rocks and recent faulting), there are no identified 

geothermal temperature systems in the planning area. 

Locatable Minerals. Several locatable mineral commodities occur throughout the planning area in small, 

sub-economic deposits, or as minor minerals associated with other mineral deposits. Minerals such as 

copper, chromium, lead, fluorine, manganese, mercury, silver, titanium, and zirconium could occur, but 

are minor occurrences that have no potential for future development in the next 15 years (BLM 2005d). 

Minerals with deposits of significance are uranium and vanadium, antimony, limestone, gypsum, and 

septarian concretions. 

The principal uranium-vanadium hosts in the planning area are the Dakota Formation (and uppermost 

Carmel Formation) and the Shinarump Member of the Chinle Formation. However, within the planning 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-15 

area, neither formation contains large or high-grade deposits. Two areas of the Chinle Formation that 

have the potential for a uranium-vanadium deposit occur within the planning area; one is in the 

southwestern part of the area, straddling US Highway 89, and the other is in the northeast part of the area, 

on the west flank of the Teasdale anticline. Doelling et al. (1989) report that only two small prospect pits 

were found in the southwestern area, and it is unlikely that new large, ore-grade deposits will be found in 

this area. At least five prospects have been opened on the Teasdale anticline Chinle deposits, but these 

deposits are generally lower grade than similar deposits found elsewhere in Utah. An area of very lowgrade uranium deposits, known as the Bulloch group of claims, is located on both sides of Orderville 

Gulch in the western portion of the planning area (Doelling et al. 1989). 

An area of interest for antimony is situated in the northern section of the planning area in Antimony Creek 

Canyon. Antimony ore occurrences are found on both sides of the canyon for a distance of a little more 

than 2 miles and in Russell Hollow and Dry Wash about 5 miles north of Antimony Canyon. 

Several geologic formations in the planning area contain limestone and dolomite, but there is limited 

information about their purity or utility. The two most important limestone-bearing units are the Carmel 

and Claron Formations. Because limestone materials are common and widespread, a local market is 

necessary if a source is to be economic. It is unlikely that a high-purity resource can be found (BLM 

2005d). 

Gypsum is abundant and widespread in the planning area; however, no deposits have been developed 

other than small mining operations for sculpting alabaster. The most important gypsum deposits are found 

in the Paria River Member of the Carmel Formation, which contains massive, white gypsum in beds from 

3 to 30 feet thick that remain fairly consistent in thickness across much of the area (Doelling et al. 1989). 

In places the gypsum beds in the Paria River Member have little cover, making them suitable for surface 

mining and the most likely locations for potential commercial development. Smaller beds of gypsum 

suitable for sculpting alabaster can be found in the Wiggler Wash Member of the Carmel Formation. 

Septarians are concretions or nodules of limestone or dolomite with calcite infilling that have formed in 

the Tropic Shale. Active mining is occurring northwest of Mt. Carmel. The septarians are cut and 

polished to make a variety of gem figurines or larger objects such as bookends. 

Salable Minerals. Several salable mineral commodities occur in the planning area. The occurrence of 

diatomaceous earth and glass sand is noted here, but these commodities will not be discussed further 

because they are minor occurrences that have no potential for future development in the next 15 years 

(BLM 2005d). The salable mineral deposits of significance are sand and gravel, stone, and clay. Certain 

collectable commodities such as petrified wood, septarian concretions, agate, jasper, and common nonvertebrate fossils also occur, but their removal would occur primarily as incidental activities that would 

not involve significant disturbance of the land surface. 

Sand and gravel resources that meet construction specifications are not abundant in the planning area; 

however, there is a distribution of excellent deposits that do (BLM 2005d). There are seven main areas in 

the planning area that have been exploited for sand and gravel and that have the best potential for future 

development: the Sevier River drainage, the East Fork of the Sevier River drainage, the upper Paria River 

drainage near Cannonville, the East Fork of the Virgin River drainage, the Johnson Wash drainage north 

of US Highway 89, the upper Escalante River drainage, and the Wahweap Creek drainage near Big Water 

(BLM 2005d). There also are several other areas that might contain exploitable sand and gravel. 

Unconsolidated Quaternary deposits are the chief sources of sand and gravel and there are many varieties 

of such deposits. Alluvium is found in stream channels or in the floodplains of streams; the Utah 

Department of Transportation (UDOT) considers this material as sources of borrow only. Pediment 

gravels form caps on knolls, ridges, and benches and are the principal sources of gravel. Landslides 
Chapter 3 Proposed RMP and Final EIS 

3-16 Kanab RMP 

scattered throughout the area contain too much clay and not enough gravel to be economically 

exploitable. Glacial deposits, such as moraines, till, and outwash, usually consist of boulders and clay, 

although they may contain local beds of gravel. Aeolian deposits are principally dune sands, which form 

potential borrow sources. Tertiary gravels and conglomerates are excellent sources of sand and gravel. 

The Mineral Potential Report (BLM 2005d) considers four categories of stone: (1) crushed and broken 

stone, (2) building/dimension stone, (3) field stone, and (4) ornamental stone. Various rock units in the 

planning area are potential hosts for different types of stone deposits. The following describes 

characteristics of these rock units: 

• Not all the rock in the geologic formations produce good crushed stone. The Paleozoic limestones 

would make the best material, but there are very limited exposures of these units. Intrusive 

igneous rocks would be adequate for many of the uses, but would be difficult to quarry. The 

primary crushed stone in the decision area comes from tertiary quartzite terrace gravels. 

• Dimension stone is rock that is easily broken along planes of weakness, such as bedding planes 

and inherent fractures or joints, to produce blocks, sheets, or slabs, which satisfy dimensional 

requirements. Several formations exposed in the planning area can provide suitable dimension 

stone, but there has been little to no production from most. There are areas of igneous intrusives 

that could be an excellent source of granitic dimension stone. However, the use of stone from the 

planning area is not likely to occur unless there is a specific local need because there are similar 

resources available in the metropolitan areas of northern Utah. 

• Field stones are defined as cobbles, boulders, and rocks that can be used as is, or split and 

trimmed with little effort. Field stone has been used in Utah from the time the pioneers first began 

to build. Many formations have rock of suitable strength that could be used as field stone. This 

market is expanding with the growth in the area, but will remain minor unless a specialty material 

is found. 

• Ornamental stone may be in crushed form, in dimension stone, or even in field stone condition, 

but must have the added feature of attractiveness. Most sandstone in the planning area is tinted 

with varying amounts of tan to brown staining. Some sandstones are interestingly mottled, 

banded, and even have artistic patterns. This is observable in several formations, but probably 

best developed in the Navajo Sandstone and the Shinarump Member of the Chinle Formation near 

Kanab. Burnt shale (clinker) is quarried from areas in the Dakota Formation where coalbeds have 

burned and baked the surrounding shale into a red gravelly material. The material is used as a 

decorative landscaping cover. 

Clay, claystone, mudstone, and shale deposits have seen limited development and testing for quality in 

the planning area (Doelling, 1975, Doelling et al. 1989). Clay is present in several formations, especially 

the Chinle (Monitor Butte and Petrified Forest Members), Dakota, Tropic, Straight Cliffs, and Claron, and 

in some volcanic units, but only a few localities have been examined specifically for clay. The claybearing units contain fairly thick and extensive deposits of clay that can be used for general purposes. 

Humate is derived from plant debris associated with carbonaceous shales or coals that were deposited in a 

swampy, continental environment. The most desirable feature of humate is its humic acid content, which 

is used to enhance soil productivity (BLM 2005d). In the planning area, humate deposits are found along 

the outcrops of the Cretaceous Dakota and Straight Cliffs Formations, which contain several thick 

intervals of carbonaceous shale and shaley coal. This humate interval occurs along the exposures of the 

Dakota Formation in the Alton and Kolob coal fields, primarily in Kane County, and the Straight Cliffs 

Formation, primarily in Garfield County. The topography of the Alton coal field is not as steep as that in 

the other two coal fields and would likely have more extensive areas of humate development along the 

outcrop where the coalbeds have not burned. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-17 

Climate 

Climate is a characterization of the atmosphere over a long period of time, which takes into account 

temperature, precipitation, and wind. Annual precipitation varies with elevation. In the higher northern 

portions of the planning area, precipitation varies from 9 inches annually in the canyons and valleys to 

more than 30 inches in the high mountains (Map 23). As the elevation decreases to the south, annual 

precipitation decreases to a more uniform 11 to 17 inches between Kanab and Zion National Park, and to 

only 5 to 8 inches in the Paria Canyon–Vermilion Cliffs Wilderness. Similarly, the timing of precipitation 

varies throughout the planning area (Figure 3-11). In the southwest and southern portions of the planning 

area (Kanab, Orderville, Alton, and Big Water), precipitation occurs in a pronounced bi-modal 

distribution, with peaks in the winter and summer months. Precipitation in the remainder of the planning 

area is dominated by rains associated with the summer monsoons from July through October. Springtime 

months (April, May, and June) are generally the driest in the planning area, although the winter months 

(December and January) are the driest in the Panguitch area. 

Figure 3-11. Average Monthly Total Precipitation – (1971-2000) 

0.0

0.2

0.4

0.6

0.8

1.0

1.2

1.4

1.6

1.8

2.0

Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec

Precipitation (in inches)

Kanab/Orderville/Alton Panguitch Tropic/Escalante Church Wells (West of Big Water)

Source: Western Regional Climate Center 2006 

Cycles of drought are a normal occurrence in the planning area. The variations in elevation and 

precipitation combine to produce varying climate zones. The average annual high temperature in Kanab is 

approximately 70°F, and varies from 47°F in the winter to about 93°F in the summer. The average annual 

low temperature is about 39°F, and ranges from 22°F in the winter to approximately 58°F in the summer. 

3.2.3 Soil Resources 

Soils in the planning area vary based on landform, geology, vegetation, and microclimate. They range 

from shallow, weakly developed and rocky soils on plateaus, cliffs, and ridges to deeper, more productive 
Chapter 3 Proposed RMP and Final EIS 

3-18 Kanab RMP 

soils on alluvial fans and in valley bottoms. The dry climate and parent materials have also affected 

development and concentrations of carbonates, salts, and gypsum within the soils and rooting zones, 

which affects plant growth and water movement. The sandy parent materials throughout much of the 

decision area are characterized by well-drained, sandy soils forming in stabilized and active dunes. Some 

of these soils are dunes stabilized by a vegetative cover of shrubs and grasses (Sutcliffe 2004). Loss of 

vegetation in these soils may result in the short-term reactivation of the dunes and increases in wind 

erosion. 

Many resources and resource uses depend on the presence soils of suitable quality for their sustainability 

and continued health; therefore, soil attributes and conditions are important to BLM management 

decisions. Soil data are available for only a limited portion of the decision area. In 1990, the Soil 

Conservation Service, in cooperation with the Forest Service, BLM, and Utah Agricultural Experiment 

Station, conducted a soil survey of the Panguitch area, including parts of Garfield, Iron, Kane, and Piute 

counties. The most recent soil survey in the region was conducted in 2003 in GSENM. The BLM 

coordinates soil management efforts with other management agencies or committees, such as the Upper 

Sevier Watershed Committee and the Virgin River Management Plan Watershed Advisory Committee. 

Rangeland health evaluations have been conducted throughout the decision area, which contain 

assessments of soil condition indicators. The indicators are qualitative evaluations of an area’s departure 

from anticipated ecological conditions, usually obtained from a representative site description. Indicators 

include rills, gullies, soil surface resistance to erosion, compaction layers, evidence of wind erosion, and 

loss or degradation of soil surface. More than 97 percent of the sites were classified as none to slight or 

slight to moderate departure from the site description. These evaluations indicate that the landscape-level 

soil condition within the decision area is largely considered to be functioning, although there may be sitespecific issues of soil impacts or degradation. 

Salinity 

Salt and sediment yield are major concerns in the Colorado River Basin, and erosion on public lands is 

one source of sediment and associated salts in the decision area. Some of this erosion is natural or results 

from relatively stable conditions in a semiarid climate regime with periodic, high-intensity storms. Salt 

enters the Colorado River and its tributaries from groundwater flows, surface runoff, and from point 

sources such as saline springs and flowing wells. Dissolution of minerals from saline soils results in 

highly saline groundwater that ultimately contributes the largest amount of salt to the Colorado River 

system. Surface runoff from BLM-administered lands on the entire Colorado Plateau is estimated to 

contribute less than 15 percent of the total salt load, and the decision area would contribute only a small 

portion of that total contribution (USDOI 2003). Salinity in rangeland surface runoff can be closely 

related to vegetation and soil erosion, especially in areas with saline soils; thus, effective vegetation 

management and minimizing soil erosion can help to reduce and control salinity in rangeland surface 

runoff. Saline geologic formations and slightly to highly saline soils are present in the decision area. 

Major salt-bearing formations that act as parent material for saline soils include the Tropic Shale, 

Moenkopi, and Carmel. It is now generally accepted by the Colorado River Basin Salinity Control Forum 

that saline ground-water flowing through the soils to the rivers may be contributing as much as 85% of 

the salt loading from public lands in the Upper Colorado River Basin (Warner et. al. 1985 and 

Westenburg 1995). 

Sensitive and Fragile Soils 

Some of the soils within the decision area are prone to erosion or difficult to restore because of intrinsic 

properties such as steep slopes, high salt or gypsum content, low available water-holding capacity, clayey 

textures, or high water tables. These soils are generally defined in this RMP as “sensitive soils” and 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-19 

sometimes require protection or restoration measures beyond standard operating procedures and best 

management practices to minimize impacts of surface-disturbing activities. Design of such protection 

measures is best done during site-specific project planning. Currently, there is insufficient soils data to 

Map these areas accurately, and they are usually determined at the project level through field verification 

of available data. 

For the purposes of this analysis, a subset of these sensitive soils are “fragile soils” (i.e., highly erosive 

soils), which were identified and Mapped using the available soil, geology, topographic information, and 

best professional judgment and experience. The criteria used to define and Map fragile soils include high 

soil salinity, very fine textures, shallow depths, and steep slopes (greater than 30%). Soils derived from 

Tropic shale or from other saline sedimentary formations tend to be high in salts, and high salt 

accumulations affect the availability of plant nutrients and water for plant growth. Because of the 

resultant sparse vegetative cover on these soils, soil particles may not be “anchored” in place and may 

easily be eroded by wind or water. Slope steepness also increases the erosion potential of soils because it 

increases the rate at which water will flow overland and transport soil particles. Many scientists (Swenson 

and Bayer 1990) identify slopes of 20–35 percent as potentially contributing to a severe erosion hazard. 

Soil texture also contributes to the integrity of soil. Fine-textured soils such as clays or silty clays have 

slow infiltration rates and high runoff rates. As a result, rills and gullies form easily during storm events. 

In the decision area, there are approximately 6,300 acres of soils identified as fragile soils based on these 

criteria (Map 24). 

Biological Soil Crusts 

Biological soil crusts are recognized as having an influence on terrestrial ecosystems where they occur. 

These communities, referred to as cryptogamic, cryptobiotic, microbiotic, or microphytic soil crusts, 

serve as a living mulch by retaining soil moisture and discouraging the growth of some types of annual 

weeds. They can reduce wind and water erosion, fix atmospheric nitrogen into a form usable by plants, 

and contribute to the soil organic matter (USDOI 2001). These crusts can be used as indicators of physical 

disturbance. Biological soil crusts are found on various soil surfaces throughout the decision area (USDOI 

2001). 

Total crust cover is usually inversely related to vascular plant cover, as less plant cover results in more 

surface available for colonization and growth of crustal organisms (USDOI 2001). When all crust types 

are combined (e.g., cyanobacterial, moss, lichen), cover is greatest at lower elevation inland sites because 

there is less vascular plant cover. In the decision area, most of the biological soil crusts are mostly 

cyanobacteria (Microcoleus) and nitrogen-fixing lichens (Collema). These cyanobacteria and nitrogenfixing lichens are generally limited and sparse in the decision area because of the relatively high 

elevations (4,500–9,000 feet) and the relatively dense vascular plant cover. However, there are small 

areas of more concentrated soil crusts within the decision area, especially at lower elevation dry sites with 

less dense vegetative cover. There has not been a systematic inventory of soil crusts within the planning 

area, although there is a growing body of literature and research on soil crusts of the Colorado Plateau, 

especially related to land use and management. This research indicates that biological crusts are sensitive 

to physical disturbance, increased frequency and intensity of fire, and global climate changes (USDOI 

2001). Sandy, course-textured soils with low stability, fertility, and water-holding capacity recover more 

slowly than fine-textured soils with high silt or clay content. Stable areas with low slopes, little sand 

movement, and embedded rocks are quicker to recover than less stable sites with steeper slopes and more 

soil surface movement or sand deposition (USDOI 2001). 

The importance of biological soil crusts is recognized by the scientific community and by the BLM. 

Biological crusts can stabilize the surface by protecting it from wind and water erosion. Generally 

biological crusts are considered to aid in infiltration of water and, because they increase surface 
Chapter 3 Proposed RMP and Final EIS 

3-20 Kanab RMP 

roughness, they reduce runoff and increase the amount of water storage for plants. In semi-arid systems 

biological crusts can provide a significant amount of nitrogen for plant growth. However, research has not 

determined how much soil crust is needed in a certain soil type or ecological range site or woodland 

community for ecological processes to operate in a healthy state (Curtis 2005). That is, there is no clear 

“biological crust yardstick” that can be applied on a site-specific basis to allow for sound and reasoned 

decisions on this subject to quantify the appropriate amounts and distribution of biological soil crusts. 

The BLM’s standard for assessing the conditions of public lands involves the use of ecological sites and 

woodland community descriptions developed for specific soil survey areas in accordance with standards 

established and developed by the Natural Resource Conservation Service (NRCS), U.S. Department of 

Agriculture (USDA). These ecological site descriptions generally do not contain specific information 

about the quantities of cryptobiotic crusts that are expected to be on the site. 

Prime and Unique Farmland 

By definition, no prime farmland occurs within the decision area. However, some areas could qualify as 

prime farmland if an adequate and dependable water supply were available. Precipitation is inadequate 

and dependable irrigation water is lacking on BLM lands. Unique farmlands or additional farmlands of 

statewide or local importance within the decision area have not been identified. 

3.2.4 Water Resources 

Water resources are important in dry environments. The BLM manages water resources for resource 

values (e.g., watershed health, wildlife, riparian) and resource uses (e.g., recreation and water supply) 

within the framework of applicable laws, regulations, and agency policies. The water resources traverse 

BLM-administered land and could be affected by BLM management activities. 

Hydrology and Watershed 

This section addresses both surface water and groundwater quality and quantity. Watershed management 

is the protection, conservation, and use of the natural resources of a specific watershed in a manner that 

keeps the soil mantle in place and productive. The BLM manages watersheds to ensure that water yield 

and quality meet the desired uses. Watersheds can exhibit undesirable responses (e.g., severe flooding or 

erosion) following natural or human-caused vegetation or soil disturbance. Surface-disturbing activities 

could affect watershed health, which could increase erosion rates and sedimentation and affect water 

quality. 

Portions of the Lower Colorado, Virgin River, and Sevier River Basins are located within the planning 

area. Within these three basins there are 11 subbasins, or fourth-order watersheds, and 31 fifth-order 

watersheds. The fourth-order watersheds are listed in Table 3-2 and shown on Map 25. 

Table 3-2. Fourth-Order Watersheds 

Hydrologic Unit Code (HUC) Watershed Drainage Basin 

14070001 Upper Lake Powell Colorado River Basin 

14070003 Fremont Colorado River Basin 

14070005 Escalante Colorado River Basin 

14070006 Lower Lake Powell Colorado River Basin 

14070007 Paria Colorado River Basin 

15010003 Kanab Colorado River Basin 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-21 

Hydrologic Unit Code (HUC) Watershed Drainage Basin 

15010008 Upper Virgin Colorado River Basin 

15010009 Fort Pierce Wash Colorado River Basin 

16030001 Upper Sevier Great Basin 

16030002 East Fork Sevier Great Basin 

16030006 Escalante Desert Colorado River Basin 

Source: U.S. Geological Survey (USGS) 2005 

Groundwater Quantity and Quality 

Three Colorado Plateau aquifers underlie the planning area; the Mesaverde aquifer (composed of 

Cretaceous sandstones), the Dakota–Glen Canyon aquifer (composed of lower Cretaceous, Jurassic, and 

Triassic sandstones, including Navajo Sandstone), and the Coconino–De Chelly aquifer (composed of 

Permian sandstones) (Freethey and Cordy 1991, Robson and Banta 1995). Although the quantity and 

quality of the water in these aquifers are extremely variable, the aquifers are capable of yielding usable 

quantities of water with a quality suitable for most agricultural or domestic uses. In addition, there are 

many shallow perched aquifers of water-bearing Quaternary river gravels associated with floodplains. 

These smaller aquifers are important for irrigation and domestic water supply. 

Groundwater is important for many resources and uses. Ecologically, groundwater supports important 

hydrologic features such as seeps, springs, hanging gardens and riparian areas. In these areas groundwater 

provides regular supplies of water that support biologically diverse vegetation and wildlife species. Range 

management may utilize groundwater for water developments at springs and wells, providing consistent 

water sources for livestock and wildlife. Groundwater is a vital resource for the communities in the 

planning area. The development and use of groundwater resources has influenced the economic 

development and growth of the area. “Groundwater is used for public water supply, irrigation, domestic 

supply and for stock watering” (Utah Board of Water Resources 1993). 

Groundwater quality is classified by the Utah Water Quality Board based primarily on the amount of total 

dissolved solids (TDS). Lower amounts of TDSs indicate higher water quality. The quality of the water in 

the Mesaverde aquifer is extremely variable. However, in the planning area, limited data indicate that 

TDS concentration ranges from about 1,000 to 4,000 milligrams per liter. In general, areas of the 

Mesaverde aquifer that are recharged by infiltration from precipitation or surface water sources contain 

relatively fresh water. The Dakota–Glen Canyon aquifer system underlies the majority of the planning 

area. The depth to the top of the Dakota–Glen Canyon aquifer system is approximately 2,000 feet. In 

general, where the aquifer system is less than 2,000 feet below land surface, TDS concentrations are less 

than 1,000 milligrams per liter. In the planning area, the TDS concentration in water from the Coconino–

De Chelly aquifer is approximately 1,000 milligrams per liter (USGS 2005). 

Groundwater recharge areas are vulnerable to surface sources of pollution because groundwater 

movement is generally downward due to gravity and because primary recharge areas do not have 

protective layers to filter pollutants. Potential sources of groundwater pollution include agricultural 

operations, various types and methods of waste disposal, mining operations, and natural geologic 

conditions. Pollution related to natural geologic conditions is nearly impossible to control. To date there 

has been little or no pollution to groundwater from produced water associated with mineral operations. 

TDS of surface water can be increased from saline ground-water inflow to the streams. In areas such as 

the Paria River and Kanab Creek watersheds, shallow ground-water flow through eroded sediments from 
Chapter 3 Proposed RMP and Final EIS 

3-22 Kanab RMP 

saline rock formations (Tropic Shale for the Paria River and Chinle and Moenkopi formations for Kanab 

Cr) contributes salt (mainly gypsum) to the surface water naturally. 

Surface Water Quantity and Quality 

A stream is a general term for a body of flowing water. In hydrology the term is generally applied to 

water flowing in a natural channel as distinct from a canal. Streams in natural channels are classified as 

being perennial, intermittent or seasonal, or ephemeral. 

Major rivers and streams located within the planning area are the Escalante River, Kanab Creek, Sevier 

River, East Fork Sevier River, Paria River, and East Fork Virgin River. There are also numerous springs 

and small streams that are often diverted for livestock watering and irrigation. Most human use of the 

water from these rivers and streams is for agricultural purposes. Other beneficial uses include instream 

(recreation and fish habitat), culinary, irrigation, and industrial uses, which vary over time, with more 

water being diverted during the vegetative growing season. 

The State of Utah has designated the North Fork Virgin River and tributaries and East Fork Virgin River 

and tributaries as High Quality Waters—Category 1. As defined by Rule R317-2-3 of the Utah 

Administrative Code, “waters of high quality which have been determined by the Utah Water Quality 

Board to be of exceptional recreational or ecological significance or have been determined to be a state or 

national resource requiring protection shall be maintained at existing high quality through designation as 

High Quality Waters—Category 1.” In these waters, rule R317-2-3.2 directs that “new point source 

discharges of wastewater, treated or otherwise, are prohibited” and that diffuse sources (non-point 

sources) of wastes not covered by other exiting state regulations “shall be controlled to the extent feasible 

through implementation of best management practices or regulatory programs.” State regulations do 

provide that “projects such as, but not limited to, construction of dams or roads will be considered where 

pollution will result only during the actual construction activity, and where best management practices 

will be employed to minimize pollution effects.” 

Generally, as water moves downstream and is diverted and used, water quality deteriorates. The major 

sources of pollution to surface water are natural sedimentation from highly erosive substrates and mancaused non-point sources, and increased salinity levels. Water quality standards are set by the State of 

Utah according to EPA guidelines. These standards identify the uses for each water body and aquatic life 

support, and the scientific criteria supporting those uses. Pursuant to Section 303(d) of the Clean Water 

Act each state is required to identify water bodies that do not meet state water quality standards. A total 

maximum daily load (TMDL) is calculated for water bodies that do not meet water quality standards. The 

TMDL is the maximum amount of a pollutant that a water body can receive and still meet water quality 

standards. A complete list of the rivers, streams, lakes, and reservoirs within the decision area for which 

TMDLs have been completed or that require TMDLs is found in Table 3-3. 

Table 3-3. River and Stream Assessment Units That Require a TMDL 

Water Body Name Water Body 

Description HUC Unit Causes 

Upper Escalante 

Escalante River and some 

tributaries from Boulder 

Creek confluence to Birch 

Creek confluence 

14070005 Temperature 

Paria River-1 

Paria River from start of 

Paria River Gorge to 

headwaters 

14070007 Salinity/TDS/chlorides 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-23 

Water Body Name Water Body 

Description HUC Unit Causes 

Paria River-3 

Paria River and tributaries 

from Arizona-Utah state 

line to Cottonwood Creek 

confluence 

14070007 Salinity/TDS/chlorides 

Upper Sevier 

Sevier River and 

tributaries from Horse 

Valley Diversion upstream 

to Long Canal Diversion, 

excluding Panguitch 

Creek, Bear Creek, and 

their tributaries; Sevier 

River and tributaries from 

Long Canal to Mammoth 

Creek confluence 

16030001 Total phosphorus, habitat 

alteration, and sediment 

Source: Utah DEQ Division of Water Quality 2004 

Interagency working groups have been developed management for the Upper Sevier watershed. The 

Upper Sevier Watershed Management Plan addresses cooperative watershed management and water 

quality on private, state, and federal lands within the watershed. Management issues include watershed 

quantity and quality as well as riparian health. The BLM helped develop the multi-agency plan. Similar 

cooperative efforts are underway for the Virgin River Watershed. 

The Virgin River Management Plan Coordinating Committee, consisting of local and federal agencies and 

interested parties, completed the Virgin River Watershed Management Plan in 2006. The plan comprises 

a suite of activities and management practices to target specific problems in the watershed. The plan 

addresses issues such as stream flow, dissolved solids, nutrients, stream bank stabilization, native fishes, 

and recreation. In addition, the U.S. Army Corps of Engineers is conducting the federally funded Virgin 

River Comprehensive Watershed Analysis. The Corps is working in partnership with local and county 

governments; tribal, state, and federal agencies; municipalities; landowners; citizen groups; and the 

public. A goal of the analysis is to produce a watershed plan that assists stakeholders in successful 

management of the Virgin River and tributaries and related resources. 

Water Rights 

A water right is composed of a quantity, source, priority date, type of use, season of use, and point of 

diversion. In Utah and most of the western states, the priority to receive water is based on the date on 

which water use first began; this is known as the prior appropriation system. The State of Utah, through 

the state engineer, administers the water rights for the State of Utah. Individual and institutional owners 

control the rights of the waters that flow through and under the decision area. The BLM protects its water 

needs by participating in water rights adjudication and permitting processes, forming cooperative 

relationship with the Utah Division of Water Rights, and filing protests as necessary to protect BLM 

water uses. 

Water Supplies 

Water resources in the decision area have been developed for use as long as humans have been 

establishing permanent settlements in the area. These developments have varied from stream diversions 

for irrigation to spring development by early European settlers. After 1900, groundwater wells were 

developed (Utah Board of Water Resources 1993). According to BLM geographic information system 

(GIS) data, there are 16 developed wells/springs in the decision area and 55 developed wells/springs on 
Chapter 3 Proposed RMP and Final EIS 

3-24 Kanab RMP 

lands adjacent to the decision area. Of these developed wells/springs, 43 are active, 21 are inactive, and 6 

are currently in the planning stages. Most community water supplies rely on groundwater wells; only the 

town of Fredonia relies on a surface water diversion, and that is fed by groundwater springs. The BLM 

KFO has entered into agreements with communities in the planning area to protect the watersheds 

associated with these water supplies. 

3.2.5 Vegetation 

Vegetation provides aesthetic appeal, as well as food and habitat for wildlife and livestock. Vegetation 

also provides root systems that help maintain soil integrity and reduce erosion (particularly on steep 

slopes and in areas adjacent to waterways) and provides forest and woodland products. Many BLM land 

management policies are directed toward maintenance of healthy vegetation communities. Vegetation can 

generally be characterized by ecological provinces, and more specifically by communities and 

associations. The vegetation communities and associations discussed in this section comprise the major 

vegetation communities and associations in the decision area. Upland vegetation, riparian/wetland 

vegetation, and invasive species are discussed in this section. Special status plant species (threatened and 

endangered [T&E] species and sensitive species) are discussed in the Special Status Species section. 

Ecological Provinces 

The planning area is situated in the canyon, plateau, and desert areas of the Colorado Plateau 

physiographic province and corresponds with Bailey’s description of the Colorado Plateau Semi-Desert 

province (Bailey 1995). The Colorado Plateau Semi-Desert province portion of the planning area has 

noticeable vegetation zones, but they lack uniformity. 

Plant Communities and Associations 

Plant communities and associations are groups of plant populations that coexist in space and time and 

directly or indirectly affect each other’s population dynamics. Distinct plant communities are influenced 

by characteristics such as soil depth, texture, and salinity; climate variables, particularly temperature, total 

and seasonal distribution of precipitation, and wind; and topographic features, the most important of 

which are elevation, aspect, and slope. The following discussions of plant communities that occur within 

the decision area show the diverse and complex nature of the vegetation resources in the area. 

Plant communities can be represented by plant cover types that reflect the dominant species present in an 

area, such as the plant cover types documented by the Southwest Regional Gap Analysis Project 

(SWReGAP) data. The SWReGAP is an update of the Gap Analysis Program’s Mapping and assessment 

of biodiversity for the five-state region encompassing Arizona, Colorado, Nevada, New Mexico, and 

Utah. The 43 SWReGAP land cover types were combined to form 9 vegetation cover types (Table 3-4 

and Map 26) to better reflect the BLM’s management of vegetation communities and associations. Table 

3-4 lists acres and percent of vegetation communities and associations in the decision area. Because of the 

dispersed nature, relatively small size, and limited amount of riparian/wetland vegetation communities in 

the decision area, SWReGAP landscape-level remote sensing is not an accurate method for their 

inventory or condition assessment. SWReGAP readings related to riparian/wetland communities are 

included in the various adjacent vegetation categories, which are described in the categories’ narratives. 

Site-specific riparian/wetland inventories and assessments have been conducted throughout the decision 

area. Results of these inventories and assessments are discussed in the Riparian/Wetland section. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-25 

Table 3-4. SWReGAP Vegetation Communities 

Vegetation Communities or Associations Acres % of Decision Area1

Aspen 350 <1 

Other 700 <1 

Mixed Conifer 550 <1 

Ponderosa Pine 4,200 <1 

Oak/Mountain Shrub 15,100 3 

Desert Scrub 22,200 4 

Non-Vegetated 40,200 7 

Sagebrush Steppe 145,900 26 

Pinyon-Juniper Woodland 324,800 59 

Total 554,000 100 1

 Rounded to nearest %. 

Source: USGS 2004a (SWReGAP data) 

Upland Vegetation 

The BLM divides the landscape into ecological sites for the purposes of inventory, evaluation, and 

management. “An ecological site is a distinctive kind of land with specific physical characteristics that 

differs from other kinds of land in its ability to produce a distinctive kind and amount of vegetation” 

(BLM 2001a). Each ecological site has characteristic soils, hydrology, and a kind and amount of 

vegetation adapted to specific fire regimes and herbivory (BLM 2001a). Within each site, the soils, 

hydrology, and vegetation communities are interrelated, each affecting the development of the other. 

Vegetation communities on an ecological site are in a dynamic state of succession and retrogression. 

“Succession is the process of soil and plant community development on an ecological site. Retrogression 

is the change in species composition away from the historic climax plant community due to management 

or severe natural climatic events” (BLM 2001a). Vegetation communities are in a continual flux based on 

relationships with and responses to climate (e.g., drought and wet periods), disturbance (e.g., fire, lack of 

fire, human-caused disturbances), insects and disease, and management intervention. The BLM uses a 

state and transition model to explain vegetation dynamics and associated management interactions on 

each ecological site (BLM 2001a). This model enables extensive, complex information to be described in 

terms of relatively stable vegetation conditions (state) and transitions from one ecologically adapted 

vegetation community to another, leading to the potential natural community (PNC). A PNC “is defined 

as the biotic community that would become established on an ecological site if all successional sequences 

were completed without interference by people under the present environmental conditions” (BLM 

2001a). The existing vegetation community in a given area can be compared to the PNC for that area’s 

ecological site in terms of the kind, proportion, and amount of vegetation the site is capable of producing 

(BLM 2001a). This comparison provides the means for identifying the existing successional status of 

vegetation. Table 3-5 identifies the successional status based on Rangeland health evaluations conducted 

throughout the decision area. 

Table 3-5. Successional Status 

Status % PNC # of Sites % with 

Value % Total 

Early Seral Class 0-25 9 2 2 

Mid Seral Class 26-50 116 32 30 

Late Seral Class 51-76 182 50 47 
Chapter 3 Proposed RMP and Final EIS 

3-26 Kanab RMP 

Status % PNC # of Sites % with 

Value % Total 

PNC 76-100 60 16 15 

None - 22 - 6 

Total - 389 100 100 

Source: Kanab Field Office Grazing Files 

Rangeland health evaluations also contain an assessment of rangeland biotic integrity. Assessments are 

based on qualitative evaluations of indicators of an area’s departure from anticipated ecological 

conditions, which are usually obtained from a representative site or ecological site description. Some 

indicators include functional/structural vegetation groups, plant mortality and decadence, annual 

production, presence of invasive plants, and reproductive capability. The ecologic condition and 

associated trends have been assessed on nearly 400 upland sites in the decision area (Table 3-6). On 

upland sites where functional status has been determined (99 percent of assessed sites), approximately 93 

percent of sites are functioning properly. Of the 21 sites (5.4 percent of assessed sites) that are functioning 

at risk, 62 percent are not improving (static) or are decreasing in condition (static to downward and 

downward), comprising approximately 3 percent of all assessed sites. The dominant reason that sites are 

functioning at risk or trending downward is the encroachment of pinyon-juniper woodlands. Other 

reasons identified include the presence of cheatgrass and other invasive species, lack of species diversity, 

shrub die-off, and heavy wildlife use. 

Table 3-6. Upland Functioning Condition 

Functional Status Trend # of 

Sites % Functioning at Risk % Assessed Sites 

Downward 5 24 1.3 

Static to 

Downward 5 24 1.3 

Static 3 14 0.8 

Static to Upward 2 9 0.5 

Upward 0 0 0.0 

Functioning at Risk 

Unknown 6 29 1.5 

Total Functioning at Risk 21 100.0 5.4 

Functioning Properly 363 N/A 93.3 

Unknown 5 N/A 1.3 

Total 389 N/A 100 

Source: Kanab Field Office Grazing Files 

The following sections address each vegetation community listed in Table 3-4. Species compositions are 

noted, as well as general characteristics and current management issues for each community. 

Aspen 

Quaking aspen (Populus tremuloides) is the most widely distributed tree in North America. Although it 

has limited distribution in the decision area, it is an important vegetation community because of its value 

for wildlife habitat and high species diversity. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-27 

Aspen provide habitat for a wide variety of wildlife that needs young forests, including black bear, deer, 

elk, ruffed grouse, and a number of smaller birds and animals. Compared with conifer forests, aspen 

forests allow more surface water and/or groundwater recharge and streamflow because aspen forests have 

lower seasonal water losses to interception and transpiration. Aspen stands produce abundant forage that 

amounts to as much as 1,000–2,500 pounds per acre (1,100–2,800 kilograms per hectare) in the Rocky 

Mountains annually, or three to six times more than typical conifer stands. These amounts are comparable 

to forage production on some grasslands. Because of low fuel accumulations, aspen stands have low 

flammability and make excellent firebreaks (Little 1971). 

Aspen may have a canopy cover of 30 to 60 percent. Canopy openings and mesic conditions allow lush 

understory vegetation to exist. Mountain snowberry (Symphoricarpos oreophilus) canopy cover ranges 

from 10 to 40 percent and is usually the dominant shrub in this association. Other understory vegetation 

includes Gambel oak (Quercus gambelii) and Wood’s rose (Rosa woodsii). Aspen seedlings may also be 

present, but usually contribute less than 5 percent of woody species cover. Herbaceous cover is variable, 

but generally is dominated by bluegrass (Poa pratensis) and aspen bluebells (Mertensia arizonica). Blue 

wildrye (Elymus glaucus) and other wheatgrasses may also be present, as well as exotics (USGS 2004b). 

Aspen forest types, which reproduce through suckering rootstock, need disturbance or dieback to 

stimulate regeneration (O’Brien and Waters 1998). In the absence of disturbance, areas once dominated 

by aspen have been converted to conifer or sagebrush vegetation types (Bartos and Campbell 1998). 

Although conifer invasion is a natural pattern, long-term fire suppression throughout Utah has resulted in 

an increased representation and dominance by conifer in aspen stands, thus reducing the extent of aspendominated stands (Mueggler 1989). Areas with small amounts of aspen in a stand may indicate that the 

area was once dominated by aspen (Bartos and Campbell 1998). “An approximately 60% decline in aspen 

dominated landscapes has occurred on National Forest System lands across Utah” (Bartos and Campbell 

1998, p. 23). Aspen conditions throughout Utah are not expected to be different from those in the decision 

area.

Other 

This category describes an aggregation of areas with small unconsolidated vegetation types that do not fit 

under other vegetation classifications. These areas may include sites planted for ungulate grazing or 

watershed protection, as well as small disturbed areas such as community pits. 

Mixed Conifer 

Mixed conifer vegetation communities within the planning area are dominated by two associations—

white fir (Abies concolor) and Douglas fir (Pseudotsuga menziesii). Mixed conifer vegetation 

communities and associations are found within the planning area at elevations ranging from 5,000 to 

8,500 feet. This mesic vegetation community generally occurs on steep, lower slopes and benches with 

northern aspects, and in narrow canyons and ravines. Its soils are generally deep, coarse-textured 

alluvium. Mixed conifer vegetation communities include upper montane/subalpine riparian forests, 

shrublands, and herbaceous riparian areas. These riparian areas are linear or patches confined to specific 

environments occurring on floodplains or terraces of rivers and streams. Shrubs found in these areas 

include thinleaf alder (Alnus incana), water birch (Betula occidentalis), red osier dogwood (Cornus 

sericea), coyote willow (Salix exigua), yellow willow (S. lutea), and mountain willow (S. moniticola) 

(Rondeau 2001, Welsh et al. 1993). Understory conditions vary widely from dry, open-canopy forests 

with grassy undergrowth on open slopes and ridges to moist, closed-canopied stands dominated by 

numerous herbaceous plants in the canyons and ravines. 
Chapter 3 Proposed RMP and Final EIS 

3-28 Kanab RMP 

The white fir association is well represented in the planning area, but is only slightly represented within 

the decision area. In the white fir association, white fir is well represented in the tree canopy, with height 

averaging 60 to 80 feet. The subcanopy is dominated by bigtooth Maple (Acer grandidentatum) and other 

species contributing 30 to 70 percent of the total subcanopy and canopy cover, which may include 

Douglas fir, black Maple (Acer negundo), and Gambel oak (Quercus gambelii). Subshrubs include 

creeping mahonia (Mahonia repens), mountain lover (Paxistima myrsinites), and mountain snowberry 

(Symphoricarpos oreophilus). The herbaceous layer may be diverse, but does not contribute significant 

groundcover. 

In the mixed conifer Douglas fir association, Douglas fir is the dominant species in the canopy layer, 

represented by few to several mature trees. Mature western juniper (Juniperus scopulorum) is likely to be 

represented in the subcanopy by young trees and seedlings. At some sites, the subcanopy is dominated by 

Gambel oak (Quercus gambelii). The canopy and subcanopy species combined provide high foliar cover. 

Herbaceous cover is sparse and commonly represented by mesic forest species, starry false Solomon’s 

seal (Maianthemum stellatum), Fendler’s meadow rue (Thalictrum fendleri), and bracken fern (Pteridium 

aquilinum) (USGS 2004b). 

Ponderosa Pine 

Ponderosa pine (Pinus ponderosa) is the most widely distributed pine species in North America, ranging 

north to south from southern British Columbia to central Mexico and east to west from central Nebraska 

to the West Coast (Little 1971). In climax forests, ponderosa pine stands often contain many small, evenaged groups rather than a continuous uneven-aged structure. Ponderosa pine communities in central and 

southern Utah are usually the lowest in elevation of the coniferous forest types, and often border 

shrublands or pinyon-juniper (Pinus edulis–Juniperus osteosperma) woodlands. Dominant understory 

species include curlleaf mountain-mahogany (Cercocarpus ledifolius), greenleaf manzanita 

(Arctostaphylos patula), black sagebrush (Artemisia nova), Gambel oak (Quercus gambelii), and 

mountain snowberry (Symphoricarpos oreophilus). Ponderosa pine and mountain muhly (Muhlenbergia 

microsperma) occur mainly in central and southern Utah (Youngblood and Mauk 1985). 

In ponderosa pine forests, typical land uses are timber production, livestock grazing, and recreation, 

although no timber production occurs in the decision area. Ponderosa pine forests are found at low 

elevations, offering year-round recreation and providing habitats for various wildlife species. Snags in the 

mature pine forest provide a large number of species with nesting and roosting sites. Big game, such as 

deer and elk, also use the pine forests for food and shelter (Howard 2003). 

Exclusion of frequent, low-intensity fires in ponderosa pine stands has resulted in a buildup of understory 

fuels in these stands. This change from natural disturbance regimes threatens ponderosa pine stands, 

which are resistant to low-intensity fire but susceptible to large crown fires. Understory fuels act as 

ladders, allowing fire to jump to the trees’ crowns, resulting in the loss of ponderosa pine stands. 

Oak/Mountain Shrub 

There are two types of mountain shrub communities within the planning area—mountain big sagebrush 

(Artemisia tridentata ssp. vaseyana) and mixed mountain shrub. Their distribution depends on soil type, 

aspect, and elevation. Mountain big sagebrush communities extend from the upper edge of the pinyonjuniper woodlands to 10,000 feet. The soil is usually well drained, shallow, course-textured, and rocky. 

Mountain big sagebrush seldom exceeds 4 feet in height. On protected, north-facing slopes with sufficient 

soil moisture, aspen will invade, which in turn may be succeeded by shade-tolerant conifers. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-29 

Associated with mountain big sagebrush are rabbitbrush (Chrysothamnus ssp.), bitterbrush (Purshia 

tridentata), and snowberry (Symphoricarpos longiflorus). Grasses are usually abundant. Grasses, shrubs, 

and forbs associated with mountain big sagebrush include bluebunch wheatgrass (Elymus spicatus), 

thickspike wheatgrass (Elymus lanceolatus), needle and thread grass (Stipa comata), muttongrass (Poa 

fendleriana), sandberg bluegrass (Poa secunda), sheep fescue (Festuca ovina), mountain low rabbitbrush 

(Chrysothamunus viscidiflours lanceolatus), arrowleaf balsamroot (Balsamorhiza sagittata), and lupine 

(Lupinus spp.) 

The mixed mountain shrub community is found at elevations ranging from 7,000 to 8,500 feet. It is 

typically found on soils with dark-colored surface horizons where roots can grow deep. This community 

is more diverse on protected slopes where the force of the wind is moderated. Common shrubs include 

true mountain mahogany (Cercocarpus montanus), Utah serviceberry (Amalanchier utahensis), 

chokecherry (Prunus virginiana), snowberry (Symphocarpus longiflorus), mountain big sage (Artemisia 

tridentata ssp. vaseyana), squawbush (Rhus trilobata), squaw current (Ribes cereum), and Mormon tea 

(Ephedra spp.). Common grasses and forbs include needle and thread grass (Stipa comata), mutton grass 

(Poa fendleriana), junegrass (Koeleria macrantha), mountain brome (Bromus carinatus), fescue grasses 

(Festuca ssp.), arrowleaf balsam root (Balsomorhiza sagittata), scarlet gilia (Gilia aggregate), and lupine 

(Lupinus spp.). 

Desert Scrub 

Desert scrub vegetation communities range from southeastern Oregon into Utah and Nevada where 

annual precipitation is usually less than 10 inches (25 cm). Typically, this vegetation community and 

associations occupy the driest regions of the planning area. Structural and compositional variations in this 

habitat are related to changes in salinity and fluctuations in the water table and can be described as 

occurring in two vegetation associations—saltbush and salt desert scrub. 

The saltbush vegetation association may be the most arid vegetation type in the intermountain west 

(Knight 1994). These areas are characterized by accumulations of salt in poorly developed deep soils. 

Soils in these areas usually have a pH of 7.8 to 9, which restricts the uptake of water by all but the most 

salt-tolerant plants (halophytes). Halophytes function essentially to redistribute salts from the soil depths 

to the surface, thereby concentrating salts around the perimeter of the plant. This enables the plant to 

eliminate competition for scarce water and nutrients from other less salt-tolerant plants (Goodin and 

Mozafar 1972). 

The salt desert scrub association is characterized by drought-tolerant shrubs, with few grasses and forbs in 

the understory. The soils in these areas are shallow saline clays and loams. Typical shrubs in these 

vegetation types are shadescale (Atriplex confertifolia), fourwing saltbush (Atriplex canescens), spiny 

hopsage (Grayia spinosa), greasewood (Sarcobatus vermiculatus), winterfat (Ceratoides lanata), broom 

snakeweed (Gutierrezia sarothrae), and bud sagebrush (Picrothamnus desertorum) (USGS 2004b). 

Desert scrub areas also include greasewood flats–ephemeral wet meadows. These areas can be large 

patches defined by hydrologic regime, soil salinity, and texture. Shrubs and grasses associated with these 

areas include salt grass (Distichlis spicata), common spikerush (Eleocharis palustris), alkali sacaton 

(Sporobolus airoides), and greasewood species (Sarcobatus spp.). 

Non-Vegetated 

Non-vegetated lands consist of areas with less than 30 percent vegetation cover. These areas include lava 

outcrops, canyon cliffs, and sparsely vegetated sand dunes. Volcanic areas are mostly exposed rock 
Chapter 3 Proposed RMP and Final EIS 

3-30 Kanab RMP 

(usually greater than 90 percent of the surface, with sparse alpine vegetation). These areas are typically 

less than 1 acre in size and are located at upper elevations in the northwest portion of the decision area. 

Lava outcrops occur throughout the intermountain west and are limited to non-vegetated and sparsely 

vegetated volcanic substrates (generally less than 10 percent plant cover) such as basalt lava, basalt dikes, 

and basalt cliff faces with associated loose deposits of rock debris (USGS 2004a). 

Colorado Plateau cliffs, talus slopes, and canyons are present in the foothills and up to subalpine 

elevations, and include non-vegetated and sparsely vegetated landscapes (generally less than 10 percent 

plant cover) of steep cliff faces, narrow canyons, and smaller rock outcrops of various igneous or 

sedimentary rocks. The Colorado Plateau cliffs and canyons are composed largely of exposed bedrock 

(usually sedimentary) and scree; whereas the Rocky Mountain cliffs and canyons are composed of various 

igneous, sedimentary, and metamorphic rocks (USGS 2004a). 

Active and stabilized sand dune areas are located primarily in the southwestern portion of the decision 

area. These sand areas have sparse to moderate vegetation adapted to unstable coarse sands (USGS 

2004a). The soil supporting the vegetation is unconsolidated windblown sand on active dunes. The 

surrounding habitat is either vegetated, stabilized sand, sandstone slickrock, or various exposed shales and 

other fine-grained exposed geologic rock types or finer-grained developed soils. Plants associated with 

these sand dunes include sand mulesears (Wvethia scabrida var. attenuata), blowout grass (Redfieldia 

flexuosa), sand dropseed (Sporobolus cryptandrus), giant dropseed (Sporobolus gigantus), Indian 

ricegrass (Achnatherum hymenoides), sandhill muhly (Muhlenbergia pungens), silky sophora (Sophora 

nuttalliana), Kanab yucca (Yucca kanabensis), rubber rabbitbrush (Chrysothamnus nauseosus), winged 

wild-buckwheat (Eriogionum alatum), ponderosa pine (Pinus ponderosa), pinyon pine (Pinus edulis), 

Utah juniper (Juniperus osteosperma), and Welsh’s milkweed (Asclepias welshii) (USFWS 1992). 

Sagebrush Steppe 

Sagebrush steppe vegetation communities and associations are common in Utah, Washington, Oregon, 

Idaho, and adjacent Wyoming, and Nevada. Sagebrush steppes, found mostly at elevations between 2,000 

and 6,000 feet, are a major vegetation community in the decision area and are usually interspersed with 

pinyon-juniper woodlands and desert scrub vegetation communities. A functioning sagebrush steppe is a 

mosaic patchwork of vegetation states (seral diversity) that can range from recovering perennial grassshrublands following natural fire, to multi-aged sagebrush with a small pinyon-juniper component, to oldgrowth, decadent sagebrush steppe with high canopy cover and reduced herbaceous understory 

(Wyoming Interagency Vegetation Committee 2002).

Sagebrush steppe communities include a diversity of vegetation states (seral diversity); that is, sagebrush 

steppe communities are not limited to those dominated only by sagebrush. Areas dominated by perennial 

grasslands (native) and areas with recent sagebrush seedings may be considered the early vegetation state 

in the sagebrush steppe. In addition, many areas now dominated by Utah juniper (Juniperus osteosperma) 

and pinyon pine (Pinus edulis) are sagebrush steppe with a prolonged absence of disturbance. 

Shrubs typically provide 10 to 60 percent of the vegetation cover in undisturbed conditions. Vegetation 

structure in this community is characterized by an open shrub layer over a moderately open to closed 

bunchgrass layer. The more productive sites generally have a denser grass layer and sparser shrub layer 

than more xeric sites. The bunchgrass layer may contain a variety of forbs. Sagebrush steppe vegetation 

communities generally have relatively little exposed bare ground, and mosses and lichens may carpet the 

area between taller plants. Moist sites may support tall bunchgrasses greater than 3.3 feet in height or 

rhizomatous grasses (IBIS 2004). 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-31 

Characteristic and dominant mid-tall shrubs in the shrub-steppe habitat include basin sagebrush 

(Artemisia tridentata ssp. tridentata), Wyoming sagebrush (A.t. ssp. wyomingensis), mountain sagebrush 

(A.t. ssp. vaseyana), antelope bitterbrush (Purshia tridentata), and silver sagebrush (A. cana). Each of 

these species can be the only shrub or appear in complex seral conditions with other shrubs. Rabbitbrush 

(Chrysothamnus viscidiflorus) and short-spine horsebrush (Tetradymia spinosa) are common associates 

and often dominate sites after disturbance. Big sagebrush occurs with the shorter stiff sagebrush (A. 

rigida) or low sagebrush (A. arbuscula) on shallow soils or high-elevation sites (IBIS 2004). Moisture 

and temperature control movement of sagebrush species within their range. 

The sagebrush steppe community comprises approximately 26 percent of the decision area. It is estimated 

that during pre-settlement times sagebrush comprised as much as 72 percent of the decision area (Table 

3-8). In the past 150 years the extent of sagebrush steppe has been greatly reduced because the natural 

disturbance regimes have been altered. This is largely attributed to the lack of regular disturbance because 

of organized fire suppression, removal of fine fuels that results from livestock grazing, and subsequent 

encroachment by pinyon-juniper woodlands. 

Pinyon-Juniper Woodland 

Pinyon-juniper woodlands are the most widely distributed and largest vegetation community in the 

decision area, comprising approximately 59 percent of vegetation cover. This community generally 

occurs on a variety of slopes and aspects and its soils are usually coarse-texture, calcareous alluvium 

derived from sandstone and shale. They comprise both closed and open woodlands. Increases in canopy 

cover result in significant amounts of bare ground, litter, and desert pavement at the soil surface (USGS 

2004b). On lower edges of the woodland zone, Utah juniper is frequently the only tree species. Utah 

juniper is more xeric than pinyon pine, and often serves as nurse tree for pinyons in well-developed 

forests. The undergrowth is variable and dependent on canopy closure, soil texture, elevation, and aspect 

(Welsh et al. 1993). In healthy pinyon-and juniper woodland communities, the average canopy height 

ranges from 15 to 30 feet. 

The health and relative density of pinyon and juniper vary widely within the decision area; however, 

canopy densities greater than 50 percent occur over large areas. Pinyon pine and Utah juniper vigorously 

compete with other plants for available soil water, crowding out grasses and shrubs that usually are 

present as understory vegetation. The lack of protective vegetative cover in pinyon-juniper stands leaves 

the soil surface particularly susceptible to erosion. 

The vegetation is dominated by Utah juniper (Juniperus osteosperma) and pinyon pine (Pinus edulis), 

with sagebrush (Artemisia spp.) dominating the sparse to moderately dense short-shrub layer. Other 

shrubs, such as fourwing saltbush (Atriplex canescens), shadscale (Atriplex confertifolia), yellow 

rabbitbrush (Chrysothamnus viscidiflorus), Mormon tea (Ephedra spp.), rubber rabbitbrush (Ericameria 

nauseosa), broom snakeweed (Gutierrezia sarothrae), prickly pear (Opuntia spp.), or cliffrose (Purshia 

spp.) may be present with low percent cover. The sparse to moderately dense herbaceous layer is 

dominated by graminoids, such as indian ricegrass (Achnatherum hymenoides), three-awn (Aristida spp.), 

grama (Bouteloua spp.), threadleaf sedge (Carex filifolia), bottlebrush squirreltail (Elymus elymoides), 

needle-and-thread grass (Hesperostipa comata), galleta (Pleuraphis jamesii (Hilaria jamesii)), western 

wheatgrass (Pascopyrum smithii), Sandberg’s bluegrass (Poa secunda), bluebunch wheatgrass (Elymus 

spicatus), dropseed (Sporobolus spp.), and introduced annuals including cheatgrass (Bromus tectorum). 

Associated forbs may include fringed sagebrush (Artemisia frigida), buckwheat (Eriogonum spp.), carpet 

phlox (Phlox hoodii), and Purshes’ plantain (Plantago patagonica) (USGS 2004b). 

Pinyon-juniper woodlands areas also include lower montane riparian woodlands. These are linear areas or 

patches that occur primarily at the lowest elevations. The areas are dependent on the natural hydrologic 
Chapter 3 Proposed RMP and Final EIS 

3-32 Kanab RMP 

regime and flooding, and are often found near wet meadows. Shrubs associated with these riparian areas 

include skunkbrush (Rhus aromatica var. trilobata) and narrowleaf willow (Salix exigua) (Rondeau 2001, 

Welsh et al. 1993). 

Pinyon-juniper woodland species are long-lived; pinyon pine can exceed 600 years in age and juniper can 

exceed 1,000 years in age (Monson and Stevens 1999). Based on tree-age data collected through the U.S. 

Forest Service Forest Inventory and Analysis, approximately 90 percent of pinyon-juniper woodlands in 

the decision area are less than 150 years old. It is estimated that pinyon-juniper woodlands throughout the 

intermountain west have increased 10-fold over the past 150 years (Miller and Tausch 2001). Monitoring 

data indicate that approximately 80 percent of the areas classified as pinyon-juniper woodlands in the 

decision area are functioning outside of their pre-European–settlement ranges (Table 3-8). This increase 

in pinyon-juniper woodlands is attributed to historic land use practices, such as fire suppression, reduction 

of fine fuels, and climatic variations (Miller and Tausch 2001, Yorks et al. 1994, Brockway et al. 2002, 

Belsky 1996). 

The reduction of fine fuels and increases in fire return intervals have resulted in pinyon encroachment, 

leading to large acreages of closed-canopy pinyon-juniper in formerly treeless areas (Brockway et al. 

2002). As a result, structural vegetation stages are weighted to more acres and denser pinyon-juniper 

stands than conditions before European settlement. The reversibility of this expansion depends on sitespecific factors such as the extent and duration of alteration from the previous vegetation state. Vegetation 

treatments have been conducted with success within the decision area to restore sagebrush steppe 

ecosystems on which pinyon-juniper woodlands have encroached. 

Old-growth pinyon and juniper can be characterized by rounded, spreading canopies; large basal 

branches; large, irregular trunks; and furrowed, fibrous bark (Miller and Rose 1999). These old-growth 

stands are often restricted to steep, dissected, and rocky terrain and thin substrates along ridges. 

Throughout the west old-growth pinyon-juniper woodlands are estimated to comprise less than 10 percent 

of the current area classified as pinyon-juniper woodlands (Miller and Tausch 2001). Based on inventory 

data, it is estimated that these old-growth stands exist on approximately 63,000 acres (11 percent) within 

the decision area. 

Plant and Seed Collection 

There has been limited demand for the collection and sale of live plants and live plant seed over the past 

decade. Generally, this limited demand has focused on collection of live Utah juniper (Juniperus 

osteosperma), pinyon pine (Pinus edulis), and sagebrush (Artemisia spp.). Seed collection has mainly 

included sagebrush (Artemisia spp.), fourwing saltbush (Atriplex canescens), and winterfat (Ceratoides 

lanata). The seed collection policy for public lands in Utah requires verification of good vegetative 

condition (e.g., species vigor, root reserves, viable seed, seed abundance) before a seed collection permit 

is issued. Availability of live plants and seed for collection varies based on climatic fluctuation and could 

be precluded during drought years to maintain vegetation community health. Based on historic demand 

for plants and seed, vegetation communities provide ample opportunities to meet continued demand for 

plant and seed collection. However, there has been increased interest in native plant and seed collection to 

support landscaping. Table 3-7 shows the amount of plant and seed collection over the past 3 years. 

Table 3-7. Plant and Seed Collection – FY04 through FY06 

2004 2005 2006 

Vegetation Type Units Total 

Cost Units Total Cost Units Total Cost 

Live Plants (# of plants) 4 $20.00 11 $34.00 20 $60.00 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-33 

2004 2005 2006 

Vegetation Type Units Total 

Cost Units Total Cost Units Total Cost 

Seeds: (Total pounds) 0 $0 0 $0 510 $51.00 

Sagebrush (pounds of seed) 0 $0 0 $0 200 $20.00 

Fourwing Saltbush (pounds of seed) 0 $0 0 $0 300 $30.00 

Winterfat (pounds of seed) 0 $0 0 $0 10 $1.00 

Source: Kanab Field Office Files 

Disturbance Regimes 

Many areas in the decision area have not been functioning within their historic fire/disturbance regimes. 

As noted above, changes to the fire/disturbance regimes have altered the distribution and health of aspen, 

ponderosa pine, sagebrush steppe, and pinyon-juniper woodlands across the landscape. In the absence of 

disturbance, areas once dominated by aspen have been converted to conifers or sagebrush (Bartos and 

Campbell 1998). Exclusion of frequent, low-intensity fires in ponderosa pine stands threatens these stands 

with stand-replacing crown fires due to the presence of abundant ladder fuels. Removing regular 

disturbances from the sagebrush steppe has resulted in the encroachment of pinyon-juniper woodlands 

and the increasing decadence of existing sagebrush. As a result, many of these vegetation communities 

are not ecologically stable. Communities are considered stable when they can withstand and/or recover 

from disturbance. 

Existing vegetation distribution across the landscape was analyzed based on changes over the past 150 

years. Table 3-8 identifies the existing vegetation acres, the estimated historic (pre-European settlement) 

acres based on the historic fire/disturbance regimes, and the estimated acres disturbed every 20 years 

(current planning window) based on those regimes (at both the upper and lower extents of the ranges). 

Table 3-8. Vegetation Departure from Historic and Estimated Disturbance Acreages 

Vegetation Estimated Departure from Historic Estimated Disturbance Acres 

Class Name Existing 

Acreages 

% of 

Total 

Estimated 

Historic 

Acreages 

% of 

Total 

Historic Fire 

Regime 

(years)

Acres 

Disturbed 

(20 years) 

Frequent 

Return 

Acres 

Disturbed 

(20 years) 

Infrequent 

Return 

Non-Vegetated 40,200 7 40,200 7 N/A 0 0 

Other 700 <1 700 <1 N/A 0 0 

Desert Scrub 22,200 4 22,200 4 N/A 0 0 

Mixed Conifer 550 <1 400 <1 100-300 70 10 

Aspen 350 <1 1,200 <1 25-100 930 290 

Ponderosa Pine 4,200 <1 5,400 1 5-25 21,400 4,300 

Oak/Mountain 

Shrub 15,100 3 20,300 4 25-100 16,000 4,000 

Pinyon-Juniper 

Woodland 324,800 59 62,000 11 200-300 6,000 4,100 

Sagebrush 

Steppe 145,900 26 401,600 72 20-100 401,600 80,300 

Total 554,000 554,000 446,000 93,000 

Note: All acres apply to the decision area only. 

Sources: USGS 2004a; BLM 2005c; Fule et al. 1997; Harrington 1985 
Chapter 3 Proposed RMP and Final EIS 

3-34 Kanab RMP 

Riparian/Wetland 

Wetland areas (Map 27) are defined by federal policy as areas that are inundated or saturated by surface 

water or groundwater at a frequency and duration sufficient to support, and which, under normal 

circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. 

BLM Technical Reference 1737 (Riparian-Wetland Area Management) includes marshes, shallow 

swamps, lakeshores, bogs, wet meadows, and riparian areas as wetlands. Riparian areas are further 

defined by BLM Technical Reference 1737 as a form of wetland transition between permanently 

saturated wetlands and uplands areas. These areas exhibit vegetation or physical characteristics reflective 

of permanent surface or subsurface water influence. Lands along, adjacent to, or contiguous with 

perennially and intermittently flowing rivers and streams, and shores of lakes and reservoirs with stable 

water levels are typical riparian areas. Excluded are such sites as ephemeral streams or washes that do not 

exhibit the presence of vegetation dependent on free water in the soil. 

Although riparian and wetland areas occupy only a small percentage of land, they provide a wide range of 

functions critical to different wildlife species, water quality, scenery, soil conservation, and recreation 

(Brimson 2001). The distribution of riparian and wetlands areas is documented on SWReGAP vegetation 

Maps, on National Wetland Inventory Maps, and on decision area specific Maps of wetland (lentic) and 

stream (lotic) resources. The SWReGAP vegetation cover types associated with riparian and wetlands 

areas are grass- or forb-dominated wetlands, forested wetlands, and shrub-dominated wetlands. The 70.64 

miles and 385.54 acres of riparian and wetland areas within the decision area occur primarily in the Sevier 

River, East Fork Virgin River, and Kanab Creek drainages. Wetlands are afforded protection under 

Executive Order (EO) 11990 (wetland protection), EO 11988 (floodplain management), and Section 404 

of the Clean Water Act. 

Riparian areas in the decision area are dominated by wetland species such as Fremont cottonwood 

(Populus fremontii), velvet ash (Fraxinus velutina), box elder (Acer negundo), and the introduced 

tamarisk (Tamarix chinensis) and Russian olive (Elaeagnus angustifolia). Riparian and wetland areas 

may be dominated by herbaceous or shrub species such as Baltic rush (Juncus balticus), Nebraska sedge 

(Carex nebraskenis), seepwillow (Baccharis emoryi), and sandbar willow (Salix exigua). Some of these 

riparian forests and woodlands lack understories or are dominated by nonnative species (USGS 2004b). 

The Riparian-Wetland Initiative for the 1990s (BLM 1991a) establishes goals and objectives for 

managing riparian-wetland resources on public lands and includes a strategy to focus management on 

entire watersheds. The Utah BLM Riparian Management Policy (IM-UT-2005-091) is tiered to this 

overall national strategy with objectives to “identify, maintain, restore, and/or improve riparian values to 

achieve a healthy and productive ecological condition...in order to provide watershed protection while 

still preserving quality riparian dependent aquatic and terrestrial species habitats and, as appropriate, 

allow for reasonable resource uses.” The Utah Standards for Rangeland Health (BLM 1997a) also 

contain ecologically based riparian standards that must be met, or toward which riparian conditions must 

be progressing. The ecological condition of riparian-wetland areas is measured using proper functioning 

condition (PFC) assessments. PFC assessments provide a consistent approach for considering hydrology, 

vegetation, and erosion/deposition (soils) attributes and processes to assess the condition of riparianwetland areas (USDOI 1998, USDOI 1999). A PFC assessment is a qualitative assessment based on 

quantitative science to determine how well a riparian-wetland area’s physical processes are functioning. 

PFC is a state of resiliency that allows an area to produce desired values, such as fish habitat, neotropical 

bird habitat, or forage, over time. Riparian-wetland areas that are not functioning properly cannot sustain 

these values. Table 3-9 shows the existing condition and trend of the decision area’s riparian-wetland 

areas. Although more than 28 miles (more than 39 percent of assessed mileage) of riparian-wetland miles 

are functioning at risk, only 1.2 miles are in a downward trend, and most are improving in condition. 

More than 233 acres (60 percent of assessed acres) of riparian-wetland acres are in proper functioning 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-35 

condition. Of all assessed riparian-wetland acreage, approximately 16 acres (4.2 percent of assessed 

acres) are non-functioning or functioning at risk in a downward trend. Of all assessed riparian-wetland 

mileage, approximately 7 miles (10.2 percent of assessed mileage) are non-functioning or functioning at 

risk in a downward trend. 

Table 3-9. Decision Area Riparian Condition 

Functional 

Status Trend Miles Evaluated 

% of Miles 

Evaluated 

Acres 

Evaluated 

% of Acres 

Evaluated 

Non Functioning N/A 6 8.5 5.83 1.5 

Downward 1.2 1.7 10.3 2.7 

Static 1.99 2.8 9.05 2.3 

Static to Upward 1.75 2.5 23.25 6.0 

Upward 21.15 29.9 90.75 23.5 

Functioning at Risk 

Unknown 2 2.8 10.2 2.6 

Proper Functioning 

Condition N/A 36.22 51.3 233.16 60.5 

Unknown N/A 0.33 0.5 3 0.8 

Total 70.64 100 385.54 100 

Source: Kanab Field Office Riparian-Wetland Files 

Relict Vegetation 

There are two known areas of relict plant communities in the decision area, Elephant Butte and Diana’s 

Throne (Map 24). Relict plant communities contain unique vegetation assemblages representative of 

vegetation communities that have not been historically affected by historic human actions such as 

livestock grazing, fire suppression, or surface-disturbing actions. The unique quality of these areas is 

directly related to their isolation over time or their lack of disturbance. This isolation also provides an 

opportunity to gauge impacts occurring elsewhere in the decision area and on the Colorado Plateau. These 

areas have potential value for scientific study and for comparison with similar communities that have 

been affected by historic human activities. 

Invasive Species/Noxious Weeds 

Invasive species are nonnative plants that have adaptive characteristics such as high seed production; are 

aggressive and difficult to manage; are capable of invading native habitats; and can often significantly 

change vegetation communities and affect ecological relationships. Noxious weeds are a subset of 

invasive plant species. They are legally designated by state or federal law to have these characteristics and 

require prevention and control measures to help contain or eradicate them. Seventeen species of state or 

county listed noxious weeds are currently known to occur within the boundary of the planning area (in 

Kane and Garfield counties). Weed infestations usually occur on disturbed areas where native vegetation 

has been significantly or totally removed (e.g., roadsides, livestock trails, reservoir sites, and flood 

damaged areas). Noxious weeds and invasive species often exclude other vegetation, reducing species 

diversity. If unrestricted, noxious weeds and invasive species may threaten to occupy additional acreage 

of public and private lands. The BLM is required by law to control noxious weeds (Federal Noxious 

Weed Act of 1974 [PL 93-629] as amended). 

The Kanab field office works closely with the Color Country Cooperative Weed Management Area and 

Kane and Garfield County weed coordinators to identify and monitor infested areas and determine the 

needed treatment and control methods. Active control measures are taken on the following species on 
Chapter 3 Proposed RMP and Final EIS 

3-36 Kanab RMP 

public lands: Scotch thistle (approximately 1,000 acres in Kane County), musk thistle (approximately 500 

acres in Panguitch Valley), spotted knapweed (approximately 20 acres in Kane County) and hoary cress 

(less than 100 acres in Panguitch Valley). These acreages generally have small, dispersed populations of 

noxious weeds that are not normally contiguous. Because most of the infestations are small, the primary 

method of control has been spraying with herbicides and hand grubbing. Table 3-10 shows acres of weed 

treatments throughout the decision area for the past 5 years. The increase in acres in FY 2002 was due to 

the identification of new populations, not to the expansion of existing infestations. Due to treatments, 

noxious weed populations are stable. 

Table 3-10. Acres of Weed Treatments 

Fiscal Year (FY) Acres Treated 

FY00 1,000 

FY01 1,000 

FY02 1,552 

FY03 1,500 

FY04 1,500 

Source: Kanab Field Office Files 

Table 3-11 lists the common and scientific names of noxious weeds listed by the Utah State Department 

of Agriculture and Food for Garfield and Kane counties. The distribution and extent of areas with noxious 

weed populations are well documented. 

Table 3-11. Utah Noxious Weed List 

Common Name Scientific Name 

Bermuda grass Cynodon dactylon 

Canada thistle Cirsium arvense 

Diffuse knapweed Centaurea diffusa 

Dyers woad Isatis tinctoria L. 

Field bindweed Convolvulus arvensis 

Hoary cress Cardaria drabe 

Johnsongrass Sorghum halepense 

Leafy spurge Euphorbia esula 

Medusahead Taeniatherum caput-medusae 

Musk thistle Carduus mutans 

Perennial pepperweed Lepidium latifolium 

Perennial sorghum Sorghum halepense L. and S. almum 

Purple loosestrife Lythrum salicaria L.

Quackgrass Agropyron repens 

Russian knapweed Centaurea repens 

Scotch thistle Onopordum acanthium 

Spotted knapweed Centaurea maculosa 

Squarrose knapweed Centaurea squarrosa 

Yellow starthistle Centaurea solstitialis 

Source: Utah Department of Agriculture and Food 2005 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-37 

In addition to the listed noxious weeds, there are several plant species that occur in the planning area that 

are considered undesirable. A plant is usually labeled undesirable when it presents a poisoning threat to 

livestock. Some undesirable plants occur as part of the natural vegetative community. Others invade or 

increase as a result of poor rangeland conditions. It is not feasible to attempt control of most undesirable 

species because they are common and widespread; however, livestock management techniques can be 

used to prevent or minimize livestock losses. Regionally, locoweed (Astragalus spp.) has accounted for 

most of the reported livestock poisonings. Locoweed is an episodic problem. In years when it is abundant 

before other range forage species greenup, it can become a problem to livestock. For example, in 1993 

and 1994, there was considerable loss of calves to locoweed poisoning in Utah. Other livestock losses 

have been attributed to death camas (Zigadenus spp.), rubberweed (Hymenoxys spp.), cocklebur 

(Xanthium strumarium), whorled milkweed (Asclepias subverticillata), and Gambel oak (Quercus 

gambelii). 

Changes to the noxious weed list occur as new plant species become problems. It should be noted that a 

species’ absence from the list does not mean that the species is not considered in management decisions. 

For example, although cheatgrass is not on the list, it has become a management concern throughout the 

region because, once cheatgrass is established on a site over just a few cycles of seed production and 

dispersal, the seed bank can contain two or three times as many viable cheatgrass seeds as there are 

established plants in the community (Zouhar 2003). Cheatgrass invasion may be accelerated by 

disturbance, but disturbance is not required for cheatgrass to become established. Cheatgrass can also 

thrive in areas that have little or no history of cultivation or grazing by domestic livestock. It can become 

established in these relatively undisturbed areas when seed disperses from nearby patches and establishes 

on sites of small natural disturbances, such as where rodents or predators dig in the soil (Zouhar 2003). 

Cheatgrass is more of a concern in the southern half of the decision area. In Garfield County, cheatgrass 

invasion and spread is limited by long cool spring months and higher elevations. 

3.2.6 Special Status Species (Threatened, Endangered, and 

Sensitive) 

Special status species include both animals and plants that require specific management attention as a 

result of population or habitat concerns. The five categories of these species are the following: 

• Federally Listed Threatened and Endangered Species and Designated Critical Habitats 

• Federally Proposed Species and Proposed Critical Habitats 

• Federal Candidate Species 

• BLM Sensitive Species 

• State of Utah listed or sensitive species. 

Federally listed species may have critical habitat identified as crucial to species viability. For those 

species that are listed and have not had critical habitat designations identified for them, the BLM 

cooperates with the United States Fish and Wildlife Service (USFWS) to determine, identify, and manage 

habitats of importance. The mission of the USFWS is to work with other federal, state, and local agencies 

to conserve, protect, and enhance fish, wildlife, and plant species and their habitats. Protective measures 

for migratory birds are provided in accordance with the Migratory Bird Treaty Act of 1918 and the Bald 

Eagle Protection Act of 1940. Other fish and wildlife resources are considered under the Fish and 

Wildlife Coordination Act (1934). 

The BLM has entered into a memorandum of agreement (MOA) with the USFWS to improve the 

efficiency and effectiveness of RMP-level Section 7 consultation processes under the Endangered Species 

Act (ESA). Through this MOA, the BLM agrees to promote the conservation of candidate, proposed, and 
Chapter 3 Proposed RMP and Final EIS 

3-38 Kanab RMP 

listed species and to informally and formally consult on listed and proposed species and designated and 

proposed critical habitat during planning to protect and improve the condition of species and their habitats 

to a point where their special status is no longer necessary. 

Threatened and Endangered Species 

The BLM will continue to implement actions that will further the management, protection, and recovery 

of listed and non-listed special status plant and animal species. The BLM accomplishes this management 

through coordination with the USFWS, the Utah Division of Wildlife Resources (UDWR), and others. 

The BLM will initiate Section 7 consultation with USFWS before approving or implementing any action 

that may affect listed species or designated critical habitat. Habitat for these species will be managed in 

such a manner that actions authorized, funded, or carried out by the BLM do not contribute to the need for 

the species to become listed under the ESA. Table 3-12 identifies the federally listed animal and plant 

species in the decision area. It should be noted that although suitable habitat may be present, some of 

these species may not be known to actually occur within the decision area. 

Table 3-12. Federally Listed Animal and Plant Species

Common Name Scientific Name Status 

Birds 

California Condor Gymnogyps californianus Experimental 

Mexican Spotted Owl Strix occidentalis Threatened 

Southwestern Willow Flycatcher Empidonax traillii extimus Endangered 

Western Yellow-Billed Cuckoo Coccyzus americanus occidentalis Candidate 

Mammals 

Utah Prairie Dog Cynomys parvidens Threatened 

Invertebrates 

Kanab Ambersnail Oxyloma kanabense Endangered 

Coral Pink Sand Dunes Tiger Beetle Cicindela limbata albissima Candidate 

Plants 

Autumn Buttercup Ranunculus aestivalis Endangered 

Siler Pincushion Cactus Pediocactus sileri Threatened 

Welsh’s Milkweed Asclepias welshii Threatened 

Source: USFWS 2005 

California Condor (Gymnogyps californianus) was listed as endangered on March 11, 1967, and noted 

to occur only in California. On October 16, 1996, the USFWS announced plans to reintroduce California 

condors into northern Arizona and southern Utah and to designate these birds as nonessential 

experimental populations as provided by Section 10j of the ESA. Federal Register Notice vol. 61, no. 

201, pages 54044–54060 further directs the establishment of a nonessential experimental population of 

California condors in northern Arizona. The purpose of the reintroduction was to achieve the primary 

recovery goal of establishing a second noncaptive population that is spatially separated from the noncaptive population in southern California. 

California condors are among the largest flying birds in the world. Adults weigh as much as 22 pounds. 

They are black except for prominent white underwing linings and white edges on the upper secondary 

coverts. Condors are opportunistic scavengers, feeding only on carcasses. Since European settlement of 

California, condor populations have steadily declined. Poisoning, shooting, egg and specimen collecting, 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-39 

collisions with man-made structures, and loss of habitat contributed to the decline of the species. By 

1987, the last wild condor was captured and taken to San Diego Wild Animal Park. Beginning with the 

first successful breeding of California condors in 1988, the population (in 1996) was 121, including 104 

in the captive flock and 17 in the wild. The nonessential experimental status of this condor population 

places the following requirements on federal agencies: (1) that agencies use their authorities to conserve 

the condors and (2) for the purposes of Section 7 consultation, they are treated as if they are proposed for 

listing; therefore, the BLM will informally confer with the USFWS on actions likely to jeopardize the 

continued existence of the condor (50 CFR Part 17, FR vol. 61, No. 201, pages 54044–54060). 

Birds from northern Arizona frequently forage and roost in Utah and are likely to nest in southern Utah 

(UDWR 2005a). To date there are no known California condor nesting or roosting sites within the 

decision area. However, recent surveys have identified roosting sites next to Zion National Park on the 

Kolob Terrace adjacent to the decision area (Parish 2005). Access to these roosting sites would likely 

require the California condor to fly over the decision area. Threats to the condors include inadequate 

protection of suitable nesting sites as well as foraging areas near nesting sites (UDWR 2005a). 

Mexican Spotted Owl (Strix occidentalis lucida) was listed as a threatened species on April 15, 1993 

(USFWS 1993). The range of the Mexican spotted owl extends from the southern Rocky Mountains in 

Colorado and the Colorado Plateau in central and southern Utah, southward through Arizona and New 

Mexico and into northern Mexico. Mexican spotted owls forage primarily at night, their diet consisting of 

a variety of mammals, birds, reptiles, and insects, with mammals making up the bulk of the diet 

throughout the owls’ range. Wood rats, voles, and gophers are the primary mammal food base. Steep 

slopes and canyons with rocky cliffs characterize much of the owl’s habitat in the planning area 

(Map 28). 

A recovery plan was completed for the Mexican spotted owl in 1995 (USFWS 1995) and a revised 

recovery plan is currently being developed. Threats to Mexican spotted owls include loss and 

fragmentation of mixed-conifer, riparian and ponderosa pine habitats, as well as human disturbance that 

leads to nest or site abandonment or disruption of breeding (UDWR 2005a). 

Designated critical habitat was established for this species in 2001 and revised in 2004 (USFWS 2004). 

There are approximately 47,700 acres of designated critical habitat in the decision area, located on the 

decision area’s western boundary adjacent to Zion National Park and southeast of the town of Tropic 

(Map 28). However, not all of these acres contain the primary constituent elements of habitat as described 

in the recovery plan. The critical habitat designation clarified that areas within critical habitat boundaries 

are considered critical only when they contain or have the potential to contain habitat characteristics 

essential to the conservation of the species. For canyon habitats, the primary constituent elements include 

one or more of the following attributes: (1) cooler and often more humid conditions than the surrounding 

area, (2) clumps or stringers of trees and/or canyon walls with crevices, ledges or caves, (3) high percent 

of ground litter and woody debris, and (4) riparian or woody vegetation. The primary constituent elements 

related to forest structure include (1) a range of tree species, (2) a shade canopy created by the tree 

branches covering 40 percent or more of the ground, and (3) large dead trees with a trunk diameter of at 

least 12 inches (Federal Register 69 CFR 53181-5398). 

Southwestern Willow Flycatcher (Empidonax traillii extimus) was listed as an endangered species in 

1995. This bird is a neotropical migrant, which breeds primarily in the southwestern United States and 

winters in Central America and southern Mexico. In Utah, only three breeding sites (all near St. George) 

have been confirmed, although areas of probable breeding occur across the southern Utah counties 

(UDWR 2005a). Current range limits of the Southwestern willow flycatcher in Utah are not definitively 

known (Bosworth 2003). Critical habitat was designated in 2005; no critical habitat is present in the 

planning area (Federal Register vol. 70, no. 201). However, potentially suitable habitat for this species 
Chapter 3 Proposed RMP and Final EIS 

3-40 Kanab RMP 

exists in Garfield and Kane counties. The species is rare in southern Utah during the summer and is 

usually found in riparian habitats, especially in areas of dense willows associated with rivers and wetlands 

(Bosworth 2003). The majority of the dense willow stand riparian areas in the decision area are found in 

narrow canyons that are prone to flash flooding. These conditions limit the ability of the habitat to support 

nesting birds. The major factor in the decline of the flycatcher is likely the alteration or loss of its 

essential riparian habitat (UDWR 2005b). In addition, encroachment of exotic plant species, particularly 

tamarisk and Russian olive, into lowland riparian areas threatens to change the usable nature of the 

riparian habitats (UDWR 2005a).

Western Yellow-Billed Cuckoo (Coccyzus americanus occidentalis) is considered a riparian obligate 

and is usually found in large (greater than 25 acres) tracts of dense cottonwood or willow habitats 

(UDWR 2005b). The riparian areas in the decision area may provide habitat for this species. Distribution 

of the cuckoo is not well understood; the western population segment is limited to disjunct fragments of 

riparian habitat, and the known distribution within Utah is statewide but very scattered (UDWR 2005a). 

Population status and trends within the decision area are unknown; however, yellow-billed cuckoos have 

been documented adjacent to the planning area in Iron, Washington, and San Juan counties since 1983 

(Bosworth 2003). Yellow-billed cuckoos are one of the latest migrants to arrive and breed in Utah; they 

arrive in late May or early June and breed in late June through July (Parrish et al. 2002). Nesting habitat is 

classified as dense lowland riparian characterized by a dense sub-canopy or shrub layer (regenerating 

canopy trees, willows, or other riparian shrubs) within 330 feet of water (UDWR 2005b). Yellow-billed 

cuckoo nesting behavior may be closely tied to food abundance. Primary threats to the species include the 

loss and fragmentation of riparian corridors to invasive species, improper livestock management, and 

development (UDWR 2005a, Bosworth 2003). 

Utah Prairie Dog (Cynomys parvidens) was listed as an endangered species under the ESA, as amended 

on June 4, 1973. On May 29, 1984, the prairie dog was reclassified as a threatened species (49 Federal 

Register 22330–22334). Historically, the Utah prairie dog was found in southwestern and central Utah, 

and is endemic to Utah (UDWR 2005a). The habitat of a prairie dog consists of continuous grassland and 

other vegetation on flat plains. The Utah prairie dog is found at elevations from 5,400 feet on valley floors 

up to 9,500 feet in mountain mesa habitats. Three Utah prairie dog recovery areas have been established. 

One of these areas, the Paunsaugunt Recovery Area, is within the planning area. In 2002, eight Utah 

prairie dog complexes were reported in this recovery area on combined BLM, state, and private lands 

(BLM 2005a). 

The prairie dog lives both aboveground and underground. The most obvious feature of a prairie dog 

colony is the abundance of mounds and holes. Utah prairie dog habitat has been recorded in the northwest 

portion of the decision area (BLM 2003). Major threats to the species include direct habitat loss (through 

urban or public land development) and outbreak of the bubonic plague (UDWR 2005a). Prairie dogs are 

susceptible to several diseases that lead to their rapid decline and even to the disappearance of entire 

colonies. 

A recovery plan was completed for the Utah prairie dog in 1991 (USFWS 1991), and a Utah Prairie Dog 

Interim Conservation Strategy was completed in 1997 (Instruction Memorandum [IM] UT 2002-040). A 

current management practice for the prairie dog is a translocation program. Translocation of prairie dogs 

is authorized by the USFWS under the ESA, as amended. It is anticipated that translocations will be a 

major part of the future management of the Utah prairie dog. No critical habitat has been designated for 

the Utah prairie dog. 

Kanab Ambersnail (Oxyloma kanabense) was first collected in 1910 and listed as endangered in 1992. 

The gastropod has been reported in two localities in Utah, both in the extreme southern portion of Kane 

County. The larger population, reported to be extant, is located at Three Lakes; a much smaller 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-41 

population, reported as seemingly extirpated, occurred in Kanab Creek Canyon (UDWR 1999a). 

Although this species occurs within Kane County, there are no known populations located on public lands 

within the planning area, although potential habitat is present. All known locations are on private land. 

This species is a wetland snail whose habitat includes wet ledges with rocks and cypripediums associated 

with spring-fed lakes, marshes, and pools. However, UDWR surveyed potential habitat and found Kanab 

ambersnail only in areas with standing water and wet substrate (UDWR 2000a) The main threats to this 

species are habitat loss through development and habitat degradation (dewatering of the habitat through 

water diversion), direct destruction of the snails through trampling, and developments that alter habitat 

values (UDWR 1999a,UDWR 2005a). 

Coral Pink Sand Dunes Tiger Beetle (Cicindela limbata albissima) is a rare insect that occurs only in 

portions of the Coral Pink Sand Dunes of Kane County in southern Utah. More than 90 percent of the 

known population is located within Coral Pink Sand Dunes State Park. It is currently a Candidate species 

for federal listing. The Coral Pink Sand Dunes tiger beetle is a subspecies of the tiger beetle. It has 

striking coloration; the large, wing cases are predominantly white and much of the body and legs are 

covered with white hairs (BLM 2001b). The total adult population estimate for 2004 was 757, with a 95 

percent confidence range of 600 to 914. The 2004 population estimate was higher than the 2003 estimate 

of 595, but lower than the 2002 estimate of 2,944 (Knisley and Gowan 2005). 

A conservation plan was developed for the Coral Pink Sand Dunes Tiger Beetle in 1997 (Members of the 

Conservation Committee for the Coral Pink Sand Dunes Tiger Beetle 1997). The conservation plan 

consists of two parts. The first part focuses on land management within Coral Pink Sand Dunes Tiger 

Beetle habitat to prevent the need for federal listing under the ESA. The second part is a conservation 

strategy and agreement that identifies conservation and management objectives. The conservation strategy 

established conservation areas, directed continued monitoring and research of the tiger beetle, promoted 

conservation of the dune ecosystem and enhancement of tiger beetle populations, and created a public 

education program (BLM 2004c). 

Autumn Buttercup (Ranunculus aestivalis) is a federally listed plant that is endemic to (i.e., it occurs 

only in) the Sevier River Valley, Garfield County, Utah. The species is found only on private land within 

the planning area and there is no known occurrence on BLM-administered lands. A member of the 

buttercup family, this species is a finely pubescent, upright perennial herb. It is typically 11 to 24 inches 

tall, and its twice ternately divided leaves are largely in a basal cluster. Autumn buttercup produces 

abundant yellow flowers that can be seen from late July to early October. It is found in low, herbaceous, 

wet meadow communities on islands of drier peaty hummocks, and sometimes in open areas, at 

elevations ranging from 6,360 to 6,450 feet. The habitat has been greatly reduced from that of presettlement times by the diversion of water for irrigation and the introduction of domestic grazing animals. 

There are currently only two small populations of the autumn buttercup known to exist (UDWR 2005b). 

Siler Pincushion Cactus (Pediocactus sileri) was first listed on October 26, 1979, and is currently 

designated as threatened. Within the area covered by this listing, this species is known to occur primarily 

on BLM lands in Arizona and within Kane County and Washington County, Utah. This cactus is 

restricted to a specific soil type and has a very restricted range in desert scrub communities. The mean 

annual number of individuals in the decision area was 122 plants over a 5-year study period (Hreha and 

Meyer 2000). Threats to this species include disturbance from off-highway vehicle (OHV) use, livestock, 

insecticide spraying, and possibly mining. In addition, species decline has resulted from private collectors 

and commercial suppliers (USFWS 1979, Hreha and Meyer 2000). 

Welsh’s Milkweed (Asclepias welshii) is a federally listed threatened plant that occurs in Kane County, 

Utah. This species is known to occur only in the Coral Pink Sand Dunes and in the Sand Hills 8 miles 

northeast of the Coral Pink Sand Dunes. This species has been monitored since 1989 (Palmer 1989). 
Chapter 3 Proposed RMP and Final EIS 

3-42 Kanab RMP 

Monitoring in 2003 indicated a 15 percent increase in total stem counts from 2002 (Esplin 2003); 

however, long-term trends are correlated with precipitation (Esplin 2005). The stem counts in the drought 

years (2000–2003) in some plots were lower than the counts in the previous decade (Esplin 2005). Some 

plots located within more vegetated dunes have reduced stem counts as well (Esplin 2005). The plants 

grow on both the tops and sides of the dunes. Critical habitat has been designated and a recovery plan has 

been developed. Critical habitat includes about 4,000 acres of sand dune habitat in the Coral Pink Sand 

Dunes and the Sand Hills areas. The 2000 Vermilion Management Framework Plan (MFP) amendment 

addresses further management and protection of this species. 

Colorado River Fish. Four fish species that occur in the Colorado River system have been listed as either 

threatened or endangered. These are the bonytail chub (Gila elegans), humpback chub (Gila cypha), 

pikeminnow (Ptychocheilus lucius), and razorback sucker (Xyrauchen texanus). No existing or potential 

habitat for any of these species occurs near or within the Kanab planning area boundaries. No actions that 

would be authorized by implementation of the new RMP would affect existing or potential habitat for 

these species; therefore they will not be discussed further in this document. 

Sensitive Species 

This category of species includes those that are on the Utah BLM State Director’s Sensitive Species list. 

For sensitive animal species, this list includes those identified by the BLM and the UDWR. The State of 

Utah does not maintain an official sensitive plant species list; however, the BLM maintains a state 

sensitive plant list. These lists are subject to period change; new lists will be incorporated into the land 

use planning document through plan maintenance or amendments. Table 3-13 lists the sensitive species in 

the decision area. These species are managed as necessary to protect them and their habitat from loss in 

accordance with the Federal Land Policy Management Act (FLPMA) and BLM guidelines, and Federal 

Government directives. It should be noted that these species are known to occur within the planning area, 

but may or may not occur within the decision area. Following the table are narratives that provide a brief 

description of each sensitive species and its habitat. 

Table 3-13. Sensitive Animal and Plant Species 

Common Name Scientific Name BLM Status UDWR Status 

Amphibians 

Arizona Toad Bufo microscaphus Sensitive Wildlife species of concern 

Reptiles 

Desert Night Lizard Xantusia vigilis Sensitive Wildlife species of concern 

Birds 

Bald Eagle Haliaeetus leucocephalus Sensitive Wildlife species of concern 

Ferruginous Hawk Buteo regalis Sensitive Wildlife species of concern 

Greater Sage-Grouse Centrocercus urophasianus Sensitive Wildlife species of concern 

Long-Billed Curlew Numenius americanus Sensitive Wildlife species of concern 

Burrowing Owl Athenecunicularia Sensitive Wildlife species of concern 

Short-Eared Owl Asio flammeus Sensitive Wildlife species of concern 

Black Swift Cypseloides niger Sensitive Wildlife species of concern 

Lewis’ Woodpecker Melanerpes lewis Sensitive Wildlife species of concern 

Three-Toed Woodpecker Picoides tridactylus Sensitive Wildlife species of concern 

Northern Goshawk Accipiter gentilis Sensitive Conservation agreement 

species 

Grasshopper Sparrow Ammodramus savannarum Sensitive Wildlife species of concern 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-43 

Common Name Scientific Name BLM Status UDWR Status 

Mammals 

Fringed Myotis Myotis thysanodes Sensitive Wildlife species of concern 

Western Red Bat Lasiurus blossevillii Sensitive Wildlife species of concern 

Spotted Bat Euderma maculatum Sensitive Wildlife species of concern 

Townsend’s Big-Eared Bat Corynorthinus townsendii Sensitive Wildlife species of concern 

Allen’s Big-Eared Bat Idionycteris phyllotis Sensitive Wildlife species of concern 

Big Free-Tailed Bat Nyctinomops macrotis Sensitive Wildlife species of concern 

Pygmy Rabbit Brachylagus idahoensis Sensitive Wildlife species of concern 

Fish 

Colorado River Cutthroat 

Trout 

Oncorhynchus clarki 

pleuriticus Sensitive Conservation agreement 

species 

Bonneville Cutthroat Trout Oncorhynchus clarki utah Sensitive Conservation agreement 

species 

Leatherside Chub Gila copei Sensitive Wildlife species of concern 

Roundtail Chub Gila robusta Sensitive Conservation agreement 

species 

Bluehead Sucker Catostomus discobolus Sensitive Conservation agreement 

species 

Flannelmouth Sucker Catostomus latipinnis Sensitive Conservation agreement 

species 

Plants 

Lori’s Columbine Aquilegia loriae Sensitive Not Applicable 

Gumbo Milkvetch Astragalus ampullarius Sensitive Not Applicable 

Escarpment Milkvetch Astragalus stratiflorus Sensitive Not Applicable 

Meager Camissonia Camissonia exilis Sensitive Not Applicable 

Hole-in-the-Rock PrairieClover Dalea flavenscens epica Sensitive Not Applicable 

Utah Spurge Euphorbia nephradenia Sensitive Not Applicable 

Cataract Gilia Gilia latifolia imperialis Sensitive Not Applicable 

Paria Iris Iris pariensis Sensitive Not Applicable 

Zion Jamesia Jamesia americana zionis Sensitive Not Applicable 

Claron Pepperplant Lepidium montanum 

claroense Sensitive Not Applicable 

Cutler’s Lupine Lupinus caudatus cutleri Sensitive Not Applicable 

Chinle Evening Primrose Oenothera murdockii Sensitive Not Applicable 

Kane Breadroot Pediomelum epipsilum Sensitive Not Applicable 

Sandloving Penstemon Penstemon ammophilus Sensitive Not Applicable 

Cronquist Phacelia Phacelia cronquistiana Sensitive Not Applicable 

Atwood’s Pretty Phacelia Phacelia pulchella atwoodii Sensitive Not Applicable 

Chinle Chia Salvia columbariae argillacea Sensitive Not Applicable 

Kanab Thelypody Thelypodiopsis ambigua 

erecta Sensitive Not Applicable 

Tropic Goldeneye Viguiera soliceps Sensitive Not Applicable 

Pinnate Spring Parsley Cymopterus beckii Sensitive Not Applicable 

Alcove Bog-Orchid Habenaria zothecina Sensitive Not Applicable 

Note: These species may occur within the overall area of Kane and Garfield counties; however, they may or may not be present 

within the decision area. 

Sources: UDWR 2006a; BLM IM-UT-2003-027 (BLM Sensitive Plant Species List for Utah, August 2002) 
Chapter 3 Proposed RMP and Final EIS 

3-44 Kanab RMP 

Amphibians 

Arizona Toad (Bufo microscaphus) is present in Kane County, although the species is concentrated in 

the Virgin River basin in Washington County (UDWR 2005a). This species inhabits streams, washes, 

irrigated crop lands, reservoirs, and uplands adjacent to water. The Arizona toad lays eggs on the bottoms 

of shallow, slow-moving streams. The diet of adults consists mainly of insects and snails, whereas larvae 

(tadpoles) consume plant matter and organic debris (UDWR 2005c). Threats to this species include 

reduction of native vegetation and reduction in the extent of riparian corridors (UDWR 2005a) 

Reptiles 

Desert Night Lizard (Xantusia vigilis) is present within Garfield County. The desert night lizard is found 

in arid and semiarid rocky areas. Habitat consists of concealing, protective vegetation, such as yuccas and 

agaves, as well as rock crevices and dead brush. The desert night lizard eats a variety of insects and other 

small invertebrates (UDWR 2005c). Threats to this species include human disturbance (recreation) and 

development in available habitat (UDWR 2005a). 

Birds 

Bald Eagle (Haliaeetus leucocephalus), the national symbol of the United States, was first protected 

under the Bald Eagle Protection Act of 1940, then listed as an endangered species in most of the lower 48 

states in 1966 and again in 1973. Because it was listed in 1973, the bald eagle population has clearly 

increased in number and expanded in range throughout the contiguous 48 states. During a survey in 

January 2002, approximately 22 bald eagles were counted along the Sevier River within Kane and 

Garfield counties—17 adults and 5 immatures (BLM 2002c). The increase is a direct result of the ban on 

the use of DDT and other persistent organochlorines, habitat protection, and other recovery efforts. In 

1995 the USFWS reclassified the bald eagle under the ESA from endangered to threatened in the lower 

48 states (Federal Register 50 CFR, part 17, vol. 60, no. 133). The bald eagle was removed from the list 

of threatened and endangered species by the USFWS in June 2007. 

The bald eagle is found throughout Utah and more often during the winter than the summer. Habitat 

consists of communal winter roosting habitat and foraging habitat within the planning area. Feeding areas, 

diurnal perches, and night roosts are fundamental elements of bald eagle winter range. In Utah, eagles 

nest in mature cottonwoods. Wintering habitat exists within both Garfield and Kane counties. Fish and 

waterfowl are the primary sources of food for bald eagles, but they also will feed on rabbits, carrion, and 

small rodents. Bald eagles that winter in Utah number in the thousands, but the nesting population (9 

active nests in 2005) has not reached the recovery goal of 10 (UDWR 2005a). There is 1 confirmed bald 

eagle nest within the planning area located west of the town of Alton along US Highway 89; the nest is 

within the planning area, but is outside the decision area. Threats to the species include loss of lowland 

riparian habitats, which serve as both nest and roost habitat, as well as nest and roost abandonment that 

results from excessive human disturbance (UDWR 2005a). 

Ferruginous Hawk (Buteo regalis) is distributed throughout most of Utah, although it is rare and 

productivity may not be sufficient to maintain the state’s population (UDWR 2005a). Productivity in 

ferruginous hawks is directly correlated with the available prey base such as jackrabbits. Due to the cyclic 

nature of jackrabbit populations, ferruginous hawks may experience similar population booms and 

crashes. Breeding ferruginous hawks rely on grassland or shrub-steppe terrain and, in many parts of Utah, 

nest on the ecotone between these habitats and pinyon-juniper woodlands (UDWR 2005c). “The species 

is prone to abandon nest sites with...low levels of human disturbance” (UDWR 2005a, pp 6-25). Threats 

include human disturbance (recreation and mineral development) and loss of preferred pinyon-juniper 

woodland habitats (UDWR 2005a). 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-45 

Greater Sage-Grouse (Centrocercus urophasianus) brooding and winter habitat is present in both 

Garfield and Kane counties (Map 29), and populations are documented in both counties (UDWR 2002), 

both brooding and winter populations. Greater sage-grouse inhabit sagebrush plains, foothills, and 

mountain valleys. The Greater sage-grouse is an herbivore and insectivore, and is associated with both tall 

and short sagebrush types. Sagebrush, understory of grasses and forbs, and associated wet meadow areas 

are essential for optimum habitat. 

Sage-grouse use the same breeding ground or leks for several consecutive breeding seasons (UDWR 

2005c). The planning area contains habitat and leks for the southern-most population of Greater sagegrouse. There are two known leks in the decision area (one active and one historic) and seven known leks 

on adjacent lands within the planning area (three active, one inactive, and one historic). Habitat within the 

planning area could contain additional leks. UDWR monitoring indicates fairly level trends for sagegrouse cock use of leks on three of the active leks. On the fourth active lek, UDWR monitoring data 

indicate that use is declining using an 8-year trend, but that a 3-year trend indicates an increase in use. On 

the inactive lek in the planning area no sage-grouse cocks have been counted in 10 years, and there is 

concern that the population may be extirpated. No sage-grouse cocks have used the historic lek on the 

decision area in recent years, but grouse have been observed in the area. 

The USFWS began a formal status review after receiving three petitions to list the Greater sage-grouse 

range-wide as endangered or threatened (USFWS 2005). The USFWS publicly recommended on 

December 3, 2004, that the sage-grouse did not at that time warrant listing under the ESA. One of the 

greatest threats to the sage-grouse is the direct loss of the sagebrush steppe environment due to pinyonjuniper encroachment, mineral development, and invasive plants (UDWR 2005a). The BLM is analyzing 

a proposal to surface mine coal in the Alton area. The southern-most lek of the sage-grouse, located 

adjacent to public lands in this area, could be affected by development of the mine. Changes in function 

of the sagebrush steppe, including disrupted fire regimes and the lack of herbaceous understory, reduce 

the usable values of the existing habitat (UDWR 2005a). 

Long-Billed Curlew (Numenius americanus) are present within both Garfield and Kane counties. The 

Great Basin comprises a significant portion of their overall range and has been described as an area of 

great importance in maintaining breeding populations of long-billed curlews. Food sources are diverse, 

including crustaceans, mollusks, worms, toads, adult and larvae of insects, and sometimes berries. Longbilled curlews nest on the ground in dry grasslands where sufficient cover and abundant prey exist 

(UDWR 2005c). Threats associated with public land management include fragmentation of nesting 

habitat and human disturbance (UDWR 2005a).

Burrowing Owl (Athene cunicularia) prefer open areas within deserts, grasslands, and sagebrush steppe 

communities. Both primary and secondary breeding habitat exists in Garfield and Kane counties. Habitat 

consists of well-drained, level to gently sloping areas characterized by sparse vegetation and bare ground, 

such as moderately or heavily grazed pasture. Burrowing owls breed in pastures, hayfields, fallow fields, 

road and railroad rights-of-way (ROW), and in a number of urban habitats. They eat mainly terrestrial 

invertebrates, but also consume a variety of small vertebrates, including small mammals, birds, frogs, 

toads, lizards, and snakes (UDWR 2005c). Threats include fragmentation and loss of nesting habitat 

(UDWR 2005a). 

Short-Eared Owl (Asio flammeus) are present in both Garfield and Kane counties. In Utah, short-eared 

owls are distributed over most of the state; however, today they are less widespread than they were 

historically. The short-eared owl is an open-country, ground-nesting species that occupies grasslands. 

Populations of short-eared owls are largely dependent on the abundance of small mammals (e.g., voles) 

for prey (UDWR 2005c). Threats include reducing suitable habitat for nesting and prey, as well as loss 

and abandonment of nests from human disturbances (UDWR 2005a). 
Chapter 3 Proposed RMP and Final EIS 

3-46 Kanab RMP 

Black Swift (Cypseloides niger) habitat is present in Kane and Garfield counties, specifically in and 

around Zion National Park (UDWR 2005a). No known confirmed breeding locations are within Kane or 

Garfield counties. Black swifts require waterfalls for nesting. Typically the falls are permanent, but they 

may be intermittent if they flow throughout the breeding season. Black swifts are colonial nesters and 

may nest in groups of less than 10 pairs near and often behind waterfalls at elevations from 6,000 to 

11,500 feet. Foraging flocks, often associated with swallows or other swifts, may occur several miles 

from the nest site. Black swifts are aerial insectivores and feed exclusively on aerial insects (Parrish et al. 

2002). Human disturbances such as hiking to and around waterfalls may impact nesting (UDWR 2005a). 

Lewis’s Woodpecker (Melanerpes lewis) is present in both Kane and Garfield counties. Lewis’s 

woodpecker is a habitat specialist, with primary breeding habitat in ponderosa pine and open riparian 

areas. Winter habitat includes open woodlands and lowland riparian areas. Lewis’s woodpecker is a 

cavity nester that nests in dead or dying trees, often using previously excavated holes. The diet of the 

Lewis’s woodpecker is composed primarily of insect prey during the breeding season and nuts and berries 

during the fall and winter (UDWR 2005c). Threats include changes in habitat condition such as 

decreasing open forests needed for foraging and groundcover that is required by insect prey in riparian 

areas (UDWR 2005a). 

Three-Toed Woodpecker (Picoides tridactylus) is a permanent resident of coniferous forests above 

8,000 feet and is dependent on live and dead trees for foraging and nesting (UDWR 2005a). The species 

is fairly easily observed in the Uinta Mountains and in areas of Cedar Breaks National Monument. This 

species may be very common in areas associated with spruce bark beetle infestations and may nest in 

loose colonies; they play an important role in controlling such insect outbreaks (UDWR 2005c). Threats 

include loss of habitat from removal of dead trees (removing snags or salvage logging) as well as fire 

suppression that reduces the presence of fire-killed trees (UDWR 2005a). 

Northern Goshawk (Accipiter gentilis) is present within both Kane and Garfield counties. The northern 

goshawk prefers mature mountain forest (conifer and aspen) and riparian zone habitats. Nests are 

constructed in trees in mature forests; often nests previously used by northern goshawks or other bird 

species are re-used. Northern goshawks cruise low through forest trees to hunt, and may also perch and 

watch for prey. Major prey items include rabbits, hares, squirrels, and birds (UDWR 2005b). Threats 

include changes in connectivity among suitable habitat stands and the loss of large-diameter trees to fire, 

insects, or harvest (UDWR 2005a). 

Grasshopper Sparrow (Ammodramus savannarum) is limited primarily to the northernmost region of 

Utah in conjunction with native grassland and fields enrolled in the Conservation Reserve Program. 

However, potential breeding habitat for the species does exist in Kane and Garfield counties. The 

grasshopper sparrow is dependent on dry grassland, a habitat that is increasingly threatened by human 

development and conversion to cropland (UDWR 2005c). The species appears to nest only in ungrazed 

grasslands (UDWR 2005a). 

Mammals 

Fringed Myotis (Myotis thysanodes) occurs in Kane and Garfield counties. Fringed myotis roost in 

tightly packed clusters, using caves, mine tunnels, and buildings for day and night roosts. They are 

sensitive to human disturbances, especially when in maternity colonies. Important habitat areas for this 

species are lowland riparian areas and water courses (UDWR 2005c). Threats include the loss of riparian 

zones (UDWR 2005a). 

Western Red Bat (Lasiurus blossevillii) is very rare in Utah and is sparsely distributed within northcentral, central, and southwestern regions of the state. Western red bats roost in the foliage of cottonwood 

trees and are dependent on broad-leaf shrubs and trees in lowland riparian zones below 5,700 feet 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-47 

elevation. Loss of riparian habitat is the main threat to Western red bat (UDWR 2005c). In addition, the 

species is sensitive to human disturbance to caves and mines, although these are not the primary roost 

sites (UDWR 2005a). 

Spotted Bat (Euderma maculatum) is considered rare in Utah. Spotted bats can occupy many habitats but 

are most frequently found in dry, rough, desert terrain with roosts in rock crevices and under loose rocks 

or boulders (UDWR 2005c). Threats include decreases in prey base due to use of pesticides to control 

Mormon crickets, as well as local disturbances due to recreational rock climbing (UDWR 2005a). 

Townsend’s Big-Eared Bat (Plecotus townsendii) occurs throughout Utah in caves, abandoned mines, 

and occasional buildings. They are generally limited to elevations below 9,000 feet and often occur in 

scrub communities and pinyon-juniper woodlands (UDWR 2005a). Threats to Townsend’s big-eared bat 

are mainly loss of habitat through human disturbance, especially maternity colonies, and mine closures 

(UDWR 2005c, UDWR 2005a). 

Allen’s Big-Eared Bat (Idionycteris phyllotis) are known to occur in Kane and Garfield counties 

(UDWR 2005a). Allen’s big-eared bats occur in riparian woodlands of cottonwood and willow to forested 

mountain areas of pine and oak. The species is also found in pinyon-juniper woodland habitat or saltcedar. Maternity colonies are generally located in mine tunnels and boulder piles, and are susceptible to 

human disturbance (UDWR 2005c, UDWR 2005a). 

Big Free-Tailed Bat (Nyctinomops macrotis) is relatively rare in Utah, and its distribution is considered 

highly fragmented. Big free-tailed bats inhabit rugged, rocky terrain; roost in rock crevices and 

occasionally in caves, buildings, and tree holes; and forage in sagebrush flats. The wing morphology of 

big free-tailed bat necessitates a vertical drop for it to achieve flight, which requires very specific location 

sites for roosts (UDWR 2005c). Threats include pesticide use in foraging areas (UDWR 2005a). 

Pygmy Rabbit (Brachylagus idahoensis) occurs in isolated patches in the western half of Utah with some 

colonies present in the decision area. The species requires deep soils for burrowing, and tall, dense 

sagebrush for cover and food. Threats to pygmy rabbit include loss and/or deterioration of the sagebrush 

steppe habitat from encroachment by pinyon-juniper woodlands, changes in fire frequency due to fire 

suppression or introduction of perennial grasses, and developments fragmenting the habitat (UDWR 

2005c, UDWR 2005a). 

Fish 

Colorado River Cutthroat Trout (Oncorhynchus clarki pleuriticus) is a state conservation species. The 

decision area contains approximately 5 miles of historic habitat. Threats to the species include loss and 

fragmentation of stream and riparian habitats, hybridization, and disease (UDWR 2005a). However, no 

current habitat or populations exist within the decision area; therefore, this species is not discussed 

further.

Bonneville Cutthroat Trout (Oncorhyncus clarki utah) occurs in approximately 3 miles of one stream 

within the decision area (in western Garfield County), although historically they occupied approximately 

19 miles of stream. Bonneville cutthroat trout can be found in a number of habitat types, from high 

mountain streams and lakes to low-elevation grassland streams, all with a healthy riparian zone providing 

structure, cover, shade, and bank stability. Bonneville cutthroat trout consumes primarily insects and, in 

the case of larger individuals, small fish. Threats include loss or fragmentation of streams and riparian 

habitat, hybridization, and disease (UDWR 2005c, UDWR 2005a). 

Leatherside Chub (Gila copei) is endemic to the Bonneville Basin drainage. The species occurs in Utah 

Lake and Sevier River drainages, with introduced populations in the Colorado River Basin. Leatherside 
Chapter 3 Proposed RMP and Final EIS 

3-48 Kanab RMP 

chub occur in pools and low-velocity runs of creeks and small- to medium-sized rivers. Substrate 

requirements are coarse fines with lower percentages of sand-silt and gravel. Leatherside chub can live up 

to 5 years, can grow to 6 inches, and spawn in the summer. Threats to this species include loss of habitat 

diversity from erosion, channelization, riparian vegetation loss, predation from nonnative fish, and stream 

dewatering (UDWR 2005c, UDWR 2005a). 

Roundtail Chub (Gila robusta) habitat is found in tributaries of the Escalante River in the planning area. 

They spawn in the spring and summer, depending on water temperature (UDWR 2005a). Roundtail chub 

require rocky runs, rapids, and pools in creeks, small to large rivers, and large reservoirs in the Colorado 

River system. Roundtail chub eat aquatic and terrestrial insects, snails, crustaceans, fish, and sometimes 

algae (UDWR 2006b). Threats to roundtail chub in the planning area include dewatering of habitat, 

pollution, disease, habitat fragmentation, and competition from nonnative fish (NatureServe 2005, 

UDWR 2005a, UDWR 2006b). 

Bluehead Sucker (Catostomus discobolus) were documented in the Escalante River in the planning area 

and are still considered common in portions of this stream, although population declines have been 

observed in many Escalante River tributaries (UDWR 2006b). The species are omnivores, feeding on 

algae, plant debris, and occasionally invertebrates (UDWR 2006b). Bluehead sucker inhabit large rivers 

and mountain streams with variable turbidity and temperature (NatureServe 2005). Threats in this portion 

of the species’ habitat include dewatering streams and subsequent habitat fragmentation (UDWR 2006b, 

UDWR 2005a). 

Flannelmouth Sucker (Catostomus latipinnis) are present in the Escalante, Paria, and Virgin River areas 

in the planning area, although the current status in the Paria River is unknown (UDWR 2006b). The status 

throughout the Virgin River system is variable, but is protected by actions implemented by the Virgin 

River Recovery Implementation Program, including management of diversions to benefit native species. 

Flannelmouth sucker is a bottom feeder, consuming algae, other fragmented vegetation, seeds, and 

invertebrates (UDWR 2006b). The species lives within moderate to large rivers. Threats are limited in 

many of these drainages, but include habitat alteration and fragmentation due to development and 

dewatering, as well as hybridization and competition from nonnative species (NatureServe 2005, UDWR 

2006b, UDWR 2005a). 

Plants 

Lori’s Columbine (Aquilegia loriae) is in the buttercup family and is endemic to Kane County; however 

there are no known plants within the planning area. The only known locations are within GSENM. The 

species can be found in moist canyon walls, wash bottoms, and sand seeps in the Straight Cliffs, 

Moenave, Navajo, and possibly the Kaiparowits sandstone formations near ponderosa pine and oak 

communities (Utah Native Plant Society 2005). 

Gumbo Milkvetch (Astragalus ampullarius) is located within Arizona and within Kane and Washington 

counties, Utah. Habitat for this plant species is mixed desert scrub and juniper communities with clay 

soils (Utah Native Plant Society 2005). 

Escarpment Milkvetch (Astragalus stratiflorus) is endemic to Arizona and Kane and Washington 

counties, Utah. Habitat for this plant species includes interdune valleys, sandy depressions on ledges and 

terraces in streams channels, pinyon-juniper, ponderosa pine, and sandy desert scrub communities ranging 

in elevation from 4,900 to 6,600 feet (Utah Native Plant Society 2005). 

Meager Camissonia (Camissonia exilis) is endemic to western Kane County. Habitat for this plant 

species includes sagebrush, galleta, and pinyon-juniper communities from 5,000 to 6,900 feet in elevation 

(Utah Native Plant Society 2005). 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-49 

Hole-in-the Rock Prairie-Clover (Dalea flavenscens epica) is limited to a few counties within Utah, and 

is present in both Kane and Garfield counties. Habitat for the species is sandstone bedrock, sandy areas in 

blackbrush, and mixed desert scrub at elevations of 4,700 to 5,000 feet (Utah Native Plant Society 2005). 

Utah Spurge (Euphorbia nephradenia) is endemic to Utah and is present in both Kane and Garfield 

counties. There are no known plants within the decision area, although there is habitat. Habitat for this 

species includes mat-saltbush, blackbrush, ephedra, and mixed sandy desert scrub communities, mainly in 

the Tropic Shale and Entrada formations. The species can be found at elevations of 3,800 to 4,800 feet 

(Utah Native Plant Society 2005). 

Cataract Gilia (Gilia latifolia imperialis) is endemic to Utah and is present in Kane and Garfield 

counties. There are no known plants within the decision area, although there is habitat. Habitat for the 

species is shadscale and other mixed desert scrub communities. Cataract gilia is found at elevations of 

3,800 to 5,200 feet (Utah Native Plant Society 2005). 

Paria Iris (Iris pariensis) can be found in Kane County, Utah; however, the species has not been located 

anywhere for several years. Habitat for this species is grass-shrub communities at elevations of 4,600 feet 

(Utah Native Plant Society 2005). 

Zion Jamesia (Jamesia americana zionis) is endemic to Zion Canyon and may be found in Kane County, 

Utah. Habitat for the species is pinyon-juniper, oak and ponderosa pine communities, hanging gardens, 

sandstone crevices, and cliff sides. The species can be found at elevations of 4,200 to 6,000 feet (Utah 

Native Plant Society 2005). 

Claron Pepperplant (Lepidium montanum claroense) is endemic to the Paunsaugunt and Table Cliff 

Plateaus of Utah. The species can be found in Kane and Garfield counties. Habitat for the species is 

limited to sagebrush, pinyon-juniper, ponderosa pine, and bristlecone pine communities. The species is 

usually found on fine-textured substrates such as the Wasatch Limestone formation and at elevations of 

6,400 to 8,000 feet (Utah Native Plant Society 2005). 

Cutler’s Lupine (Lupinus caudatus cutleri) is endemic to Utah and can be found along the Cockscomb 

within Kane County. There are no known plants within the decision area, although there is habitat. 

Habitat for this species is limited to pinyon-juniper communities at 5,150 feet in elevation (Utah Native 

Plant Society 2005). 

Chinle Evening Primrose (Oenothera murdockii) is endemic to Utah and can be found within Kane 

County. There are no known plants in the decision area, although there is habitat. There are known 

locations within the GSENM. Habitat for this species is limited to pinyon-juniper communities on redpurple or gray clay silty barrens of the Chinle Formation, and possibly the adjacent Moenkopi Formation. 

The species can be found at elevations of 4,400 to 5,600 feet (Utah Native Plant Society 2005). 

Kane Breadroot (Pediomelum epipsilum) is endemic to the Colorado Plateau in Kane County, Utah. 

Habitat for this species is pinyon-juniper woodland and desert scrub communities on the Chinle and 

Moenkopi formations at elevations of 4,000 to 5,500 feet (Utah Native Plant Society 2005). 

Sandloving Penstemon (Penstemon ammophilus) is endemic to both Kane and Garfield counties of Utah. 

Habitat for this species is wind-blown sand deposits derived from Navajo sandstone, and ponderosa pine 

and mixed shrub communities at 5,900 to 7,200 feet in elevation (Utah Native Plant Society 2005). 

Cronquist Phacelia (Phacelia cronquistiana) is endemic to western Kane County, Utah. There are no 

known plants in the decision area, although there is habitat. There are known locations within the 
Chapter 3 Proposed RMP and Final EIS 

3-50 Kanab RMP 

GSENM. Habitat for the species is limited to clay outcrops in sagebrush, ponderosa pine and, pinyonjuniper communities. The species can be found at elevations of 6,300 to 6,900 feet (Utah Native Plant 

Society 2005). 

Atwood’s Pretty Phacelia (Phacelia pulchella atwoodii) is endemic to western Kane County, Utah. 

There are no known plants found within the decision area, although there is habitat. The species occurs in 

pinyon-juniper, oak, sagebrush, and serviceberry communities on soils derived from the Moenkopi and 

Carmel Formations. The species is limited to elevations of 5,100 to 5,500 feet (Utah Native Plant Society 

2005). 

Chinle Chia (Salvia columbariae argillacea) is endemic to western Kane County, Utah. There are no 

known plants found within the decision area, although habitat is present. The species is limited to sparsely 

vegetated pinyon-juniper communities on fine-textured saline clay soils and “gypsum boils” on the Chinle 

formation. The species can be found on alluvium or on colluvium slopes at elevations of 4,250 to 5,600 

feet (Utah Native Plant Society 2005). 

Kanab Thelypody (Thelypodiopsis ambigua erecta) is endemic to Kane County, Utah. The species is 

limited to pinyon-juniper and desert scrub communities on clay soils derived from purple Chinle shales. 

The plant can be found at elevations of 5,000 to 5,400 feet (Utah Native Plant Society 2005). 

Tropic Goldeneye (Viguiera soliceps) is endemic to Kane County, Utah. There are no known plants 

within the decision area, although there is habitat. The species is limited to mat saltbush communities on 

clay knolls and bluffs on Tropic Shale and Chinle formations. The species is limited to elevations of 

4,600 to 4,800 feet (Utah Native Plant Society 2005). 

Pinnate Spring Parsley (Cymopterus beckii) is endemic to San Juan and Wayne counties. However, the 

Utah BLM State Director’s Sensitive Plant Species List also notes that it is present in Garfield County. 

There are no known plants within the decision area, although there is habitat. The species is limited to 

sandy or stony places, pinyon-juniper–mountain brush, ponderosa pine–manzanita, conifer-oak, and 

Douglas fir communities. The species is limited to elevations of 5,575 to 7,050 feet (Utah Native Plant 

Society 2005). 

Alcove Bog-Orchid (Habenaria zothecina) is listed on the Utah BLM State Director’s Sensitive Plant 

Species list for Garfield County. There are no known plants within the decision area, although there is 

habitat. The species is limited to moist streambanks, seeps, and hanging gardens in mixed desert scrub, 

pinyon-juniper, and oakbrush communities. The species is limited to elevations of 4,000 to 6,200 feet 

(Utah Native Plant Society 2005). 

3.2.7 Fish and Wildlife 

The BLM works closely with the UDWR to manage habitat for fish and wildlife (including big game, 

upland game, waterfowl, neotropical migratory birds, small mammals, amphibians, and reptiles) to 

achieve and maintain suitable habitat for desired population levels and distribution within the decision 

area. The UDWR is responsible for managing wildlife population levels; the BLM is responsible for 

managing wildlife and fisheries habitat in a condition that will support desired levels of species. The 

BLM works cooperatively with the UDWR to maintain and reestablish populations of native species that 

have used the historic range located within the Kanab RMP boundary through habitat management and 

restoration. 

Fish and wildlife habitat is generally managed according to the guiding principles outlined by the BLM

Wildlife 2000, The Riparian-Wetlands Initiative for the 1990s, A Strategy for Future Waterfowl Habitat 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-51 

Management on Public Lands, Watchable Wildlife, and Recreational Fisheries Program and other 

species- and habitat-specific direction such as the National Sage-Grouse Habitat Conservation Strategy

(BLM 2004a). The BLM implements this general guidance through specific management actions 

associated with species in the project area. 

Wildlife Habitat Types 

Wildlife habitat needs vary significantly by species. Wildlife habitat can occur as continuous or 

disjunctive features and extend from low elevations to high elevations. Climate, precipitation, soils, and 

biota respond to varying elevations, slope, and aspect. Big game populations are managed based on 

habitat condition and the quality of the animals being produced. Population levels are linked to a variety 

of factors, including vegetation quality and quantity; adequate space, shelter, and cover; water 

distribution; and regional weather patterns and trends such as prolonged drought. As water availability 

and distribution affects wildlife populations, water developments, whether constructed primarily for 

livestock or wildlife, can improve water availability in wildlife habitat. 

Desert Scrub 

Desert scrub includes numerous upland vegetation communities with a shrubland component and a 

variable understory of grass and forbs. Herbaceous plants are vital to the majority of all wildlife species 

by providing food, cover, and structure. The thermal relief provided by scrub cover helps wildlife survive 

the rigors of summer heat and winter cold. It supplies browse, seeds, and cover for birds and small and 

large mammals. Intermingled areas of desert grasslands add diversity to vegetation and habitat structure 

in desert scrub communities. 

Sagebrush Steppe 

Sagebrush habitat is prevalent in the western and central portions of the decision area. At mid to lower 

elevations, big sagebrush is the dominant habitat type, providing important winter habitat for certain 

wildlife species (e.g., mule deer, pronghorn, and Greater sage-grouse) and localized yearlong habitat for 

sagebrush-obligate species (e.g., pygmy rabbit). Sagebrush also provides crucially important breeding, 

nesting, and brood-rearing habitat for these species. Intermingled occurrences of grasslands and several 

low sages add to the diversity of vegetation and habitat structure. Diversity of sagebrush age class is also 

important for wildlife. A mosaic of sagebrush age classes is preferable to a stand of sagebrush with the 

same age class for wildlife. Because sagebrush is a relatively short-lived species, in the absence of 

disturbance there is no recruitment of younger individuals; consequently, the stand has the tendency to 

become old and decadent, decreasing its habitat value for wildlife. As a result of the regional losses of 

sagebrush communities, and the number of sagebrush-obligate wildlife, maintenance and improvement of 

existing sagebrush habitat has become crucial for community structure and diversity and for providing 

crucial habitat for sagebrush-obligate species. 

Pinyon-Juniper Woodlands 

Pinyon-juniper woodlands are widely dispersed throughout the decision area and have expanded into 

sagebrush steppe and other vegetation communities (Section 3.2.5 [Vegetation]). Pinyon-juniper 

woodlands provide some wildlife habitat. Although understory vegetation is reduced beneath pinyonjuniper stands, they provide greater structural diversity than desert scrub or sagebrush steppe habitats. 
Chapter 3 Proposed RMP and Final EIS 

3-52 Kanab RMP 

Mixed Conifer 

Mixed conifer habitats in the field office area are located in upper elevations and mesic areas. These 

habitats contain security areas (i.e., hiding cover) for big game species and can provide important linkage 

corridors for wildlife movement between other seasonal habitats. 

Riparian/Wetland 

Riparian/wetland habitats are crucial components in the landscape because they provide various lifecycle 

requirements such as foraging, bird nesting and roosting, hiding cover, as well as travel corridors for 

numerous species. The riparian vegetation is often a corridor for animal migration and travel. A high 

degree of plant diversity typically occurs along the riparian corridors, exhibiting a variable density and 

composition of plants that leads to diversity of openness and groundcover. Invasive species such as 

tamarisk and Russian olive are a management concern because of their prolific seed production and high 

evapotranspiration rates. Tamarisk can quickly overtake a riparian area on introduction into that area 

because they produce a tremendous amount of seeds. These species then reduce the amount of available 

surface water and affect the health of riparian systems. 

Riparian vegetation moderates water temperatures and provides bank structures that limit erosion and 

provide overhead vegetation cover for fish. Intact riparian communities also slow overland flow, capture 

sediments, and provide a filter that enhances water quality. Water quality, especially in regard to such 

factors as sediment, temperature, and dissolved oxygen, also greatly affect fisheries habitat. 

Aspen 

Multi-seral stages of aspen and associated understory provide multiple benefits to many wildlife species. 

Many raptor species are adapted to aspen forest and the adjacent open brush, meadows, and grasslands 

that provide a vast array of prey species. The aspen ecosystem is considered of crucial importance to 

economically important big game species (e.g., elk and deer). Aspen ecosystems provide cover, calving, 

and fawning habitat for big game, and nesting habitat for migratory birds. Aspen also provides suitable 

vegetation for breeding and feeding areas.

Non-Vegetated (Cliff Talus) 

Talus slopes are steep slopes of exposed chunks of rock that offer both basking sites and crevices for 

hiding. Slopes with large boulders provide caves that may be large enough for a species such as a bobcat 

to occupy. Cliffs are faces of vertical exposed rock that sometimes have a talus slope at their base. Several 

raptor species and birds such as black swifts use cliff and talus areas for nesting and brood-rearing habitat. 

Peregrine falcons and golden eagles generally nest on rock outcrops and cliffs that range from 30 to 400 

feet high. Canyon and rock wrens nest in the fractured talus slope below cliff faces, particularly in areas 

that are interspersed with open, patchy forests of ponderosa pine, Douglas fir, and sagebrush steppe 

communities. 

Agriculture/Developed 

Agricultural land within the planning area is an aggregation of areas with grasses, legumes, or grasslegume mixtures planted for livestock grazing or the production of seed or hay crops. These areas provide 

important forage for big game and some migratory bird species as well as cover for smaller game species. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-53 

Ponderosa Pine 

Ponderosa pine forests provide habitats for various wildlife species. Snags in the mature pine forest 

provide a large number of species with nesting and roosting sites. Big game, such as deer and elk, also use 

the pine forests for food and shelter (Howard 2003). 

Oak/Mountain Shrub 

There are two types of mountain shrub communities within the planning area—mountain big sagebrush 

and mixed mountain shrub. These areas provide food and cover for mule deer, elk, blue grouse, black 

bear, and black-headed grosbeak. 

Wildlife 

The decision area contains a variety of habitats that have the biological and physical attributes that are 

important in the life cycles of many wildlife species. General habitat characterizations reflect vegetation 

resource condition, habitat quality relative to fragmentation or density of intrusion, and level of conflicts 

with competing resource issues or as indicated by population level. Ranking of relative habitat values to 

populations of individual species is as follows: 

• Crucial—Area that provides for “sensitive” biological and/or behavioral requisites necessary to 

sustain the existence of wildlife populations 

• High-Priority—Area that provides for “intensive” use 

• Substantial—Area that provides for “frequent” use 

• Limited—Area that provides for only “occasional” use. 

There can be crucial time periods in an animal’s life cycle during which protection from man’s 

disturbance is essential to the population’s survival. During those times, the species’ use area would be 

ranked as being of crucial value. 

Through cooperative transplants, introduction of elk, pronghorn, bighorn sheep, chukar, and turkey have 

historically occurred on lands within or adjacent to the decision area. The UDWR formally coordinates 

these activities with the BLM and other public and private entities on a case-by-case basis. Certain 

management activities may be augmented with cooperative efforts with non-profit conservation groups. 

In August of 2005, the Utah Division of Wildlife Resources (UDWR) changed its wildlife habitat 

classification system. Prior to 2005, the UDWR classification system distinguished between “critical” 

habitat (an area that provides for biological and/or behavioral requisites necessary to sustain the existence 

and/or perpetuation of a wildlife population) and “high value” (an area that provides for intensive use by 

the species). The UDWR has been criticized for using the term “critical”, as the same term refers to 

habitat Federally designated by the U.S. Fish and Wildlife Service as required by the Endangered Species 

Act (ESA). 

In previous BLM planning efforts, mitigation decisions (usually timing stipulations) for impacts to 

UDWR’s “critical” habitats have been integrated into the planning process. BLM rarely incorporated 

management decisions in its RMPs for “high value” habitats. UDWR changed its classification system to 

include “critical” habitat with “high value” habitat, in part to accommodate the limitations of having 

classifications that were of no practical value to land managers. The new term “crucial” habitat is defined 

by UDWR as “habitat on which the local population of a wildlife species depends for survival because 

there are no alternative ranges or habitats available. Crucial habitat is essential to the life-history 
Chapter 3 Proposed RMP and Final EIS 

3-54 Kanab RMP 

requirements of a wildlife species. Degradation or loss of crucial habitat will lead to significant declines 

in the wildlife population in question.” 

Crucial habitat boundaries appear larger on the wildlife maps in this Proposed Plan because they are a 

combination of UDWR’s old “critical” habitat and “high value” habitat, with some minor modifications. 

Timing stipulations for each of the species now apply to the whole crucial habitat area. It is important to 

note however, that the application of waivers, exceptions and modifications, as outlined in Appendix 3, 

will be taken into consideration and used where/when applicable for all surface disturbing activities in 

these areas. Alternative C in the Draft RMP/Draft EIS considered both of UDWR’s old classifications of 

critical and high value habitat. Minor boundary modifications have been made by UDWR prior to 

incorporating them into crucial habitat boundaries. 

Mule Deer 

Mule deer are present in portions of seven UDWR wildlife management units within the planning area. 

Crucial and high-value mule deer habitat is located in the western portions of Kane County and 

throughout Garfield County, largely coinciding with the western portions of the decision area (Map 2). 

Mule deer are migratory, moving seasonally between summer and winter ranges. Mule deer usually 

summer at high elevations and winter at low elevations. Loss and degradation of lower elevation winter 

range can limit mule deer populations (UDWR 2005a). Loss of winter range is a limiting factor on the 

western portions of the decision area (UDWR 2005d, UDWR 2005e). Throughout the remainder of the 

decision area, habitat decline is threatening the health of the mule deer herds (UDWR 2005f, UDWR 

2006c, UDWR 2005g, UDWR 2005h). The cause of habitat decline is generally associated with decadent 

sagebrush steppe and encroaching pinyon-juniper communities. 

Mule deer feed on forbs, grasses, and shrubs throughout the spring and summer months and primarily on 

shrubs during the fall and winter. Shrubs such as Wyoming big sagebrush, true mountain mahogany, 

fourwing saltbush, and antelope bitterbrush are important winter forage species. Mule deer fawn during 

the spring during their migration from the winter to the summer range. Mule deer populations throughout 

the decision area are approximately 80 percent of UDWR objectives; current population trends reflect an 

increase in herd numbers over the past 4 years. 

Mule deer have a high degree of fidelity to specific winter ranges where high population densities 

concentrate on relatively small areas. Because of the relatively small winter range area, high population 

densities, and the natural stress of winter survival, mule deer are vulnerable to stress caused by human 

activity in winter range areas. Mule deer are displaced an average of 600 feet from areas of human 

activity (Hiat and Baker 1981). 

Elk 

Crucial elk habitat exists in the eastern portions of the planning area in Garfield County. High-value elk 

habitat exists in the western portions of the planning area in both Kane and Garfield counties (Map 3). Elk 

are migratory, moving seasonally between summer and winter ranges. They summer at higher elevation 

ranges in aspen and conifers where their diet consists primarily of grasses and forbs. Elk calve during late 

spring and early summer in aspen-mountain browse intermixed vegetation types. Elk winter at mid to 

lower elevation ranges occupying the sagebrush and pinyon-juniper vegetation types where they 

congregate in herds of 50 to 200 or more. Human activity in elk winter range or transitional ranges adds 

stress to the natural stress of winter survival. Elk populations above the town of Escalante and in the 

southeast portion of the decision area are approximately 33 percent of UDWR objectives. Throughout the 

remainder of the decision area current populations slightly exceed UDWR objectives; current population 

trends reflect an increase in herd numbers over the past 4 years, except in the southeast portions of the 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-55 

decision area (Boulder area) where there was a nearly 75 percent decrease in the elk population between 

2004 and 2005, due to issues not related to BLM-managed habitat. 

Pronghorn 

Pronghorn are present in portions of three UDWR wildlife management units within the planning area. 

Crucial and high-value pronghorn habitat is located in many areas within Garfield County within the 

planning area, and within the eastern and southeastern portions of Kane County within the planning area 

(Map 4). Most of the habitat within Kane County is located within the UDWR Kaiparowits wildlife 

management unit, with habitat identified in the GSENM, the Glen Canyon National Recreation Area, and 

on Utah State Trust lands, although a small amount of high-value habitat extends within the Paria 

Canyon–Vermilion Cliffs Wilderness Area. A population of approximately 150 pronghorn occurs within 

this unit, reintroduced into the East Clark Bench area of GSENM over the past 5 years (UDWR 2006d). 

This is the only portion of the UDWR unit with an pronghorn population (UDWR 2006d). 

The largest areas of identified pronghorn habitat within or adjacent to the decision area are within the 

Panguitch Valley (Sage Hen Hollow and East Bench populations) and John’s Valley. There are 

approximately 600 pronghorn in these two areas (UDWR 2006e). Overall, the trend for these populations 

is increasing, although the increases appear to be occurring in the John’s Valley area, with population 

decreases occurring in the Panguitch Valley “due to several years of drought” (UDWR 2006e). Two 

supplemental transplants (25 animals in both 2004 and 2005) have boosted the Panguitch Valley 

population (UDWR 2006e). 

Pronghorn prefer open vegetative types, such as salt desert scrub, grassland, sagebrush steppe, and other 

treeless areas. Typically, pronghorn avoid slopes greater than 20 percent (Ockenfels et al. 1994). 

Pronghorn fawning occurs throughout the range of this species. Pronghorn diets consist of a variety of 

forbs, shrubs, and grasses. Forbs are of particular importance during spring and summer, whereas shrubs 

are more important during the winter. 

Desert Bighorn Sheep 

Both crucial and high-value habitat for Desert bighorn sheep is located along the eastern border of 

Garfield County and throughout Kane County, most of which is not in the decision area. However, there 

is a small amount of crucial Desert bighorn sheep habitat on the western edge of Kane County in the 

decision area. Desert bighorn sheep, which are considered yearlong residents of their range, do not have 

seasonal ranges as do mule deer and elk (Map 30). Bighorn sheep prefer open vegetation types such as 

low shrub, grassland, and other treeless areas typically associated with steep talus and rubble slopes. 

Bighorn diets consist of a variety of shrubs, forbs, and grasses. Bighorn sheep lambing occurs on steep 

talus slopes, typically within 1 to 2 miles of reliable water sources. 

Historically, Desert bighorn sheep occupied canyons and ranges in southern and eastern Utah. It is 

estimated that there were as many as 2 million bighorn sheep in North America at the beginning of the 

19th century, but today there are only about 70,000. This decline is thought to have taken place between 

1850 and 1900, and was caused by diseases introduced by domestic sheep, loss of habitat to livestock, 

and excessive hunting by humans. Since 1960 bighorn sheep have increased in number; however, their 

population levels are still lower than estimates of pre-European numbers. 

Bighorn sheep are extremely vulnerable to a variety of viral and bacterial diseases carried by livestock, 

principally domestic sheep. In some reported cases, bighorn sheep exposure to these diseases has resulted 

in the decimation of entire populations. These diseases are transmitted in numerous ways, including noseto-nose contact and wet soils associated with areas of concentrated use such as stock watering ponds. 
Chapter 3 Proposed RMP and Final EIS 

3-56 Kanab RMP 

Management of bighorn sheep is guided by the following BLM documents: Utah BLM Statewide Desert 

Bighorn Sheep Management Plan (BLM 1986), Revised Guidelines for Domestic Sheep and Goat 

Management in Native Wild Sheep Habitats (BLM 1998), Utah Bighorn Sheep Statewide Management 

Plan (UDWR 1999b), and corresponding UDWR herd management plans. 

Black Bear 

Black bear is currently the only species of bear inhabiting Utah. Black bears are native to and fairly 

common in Utah. High-value, substantial-value, and a smaller amount of crucial-value black bear habitat 

is located within the planning area. Black bears in Garfield and Kane counties are primarily in large 

forested areas. As a result of an increase in bear hunting, a statewide limited-entry permit system was 

implemented in 1990 that requires hunters to obtain permits and hunt within a specific unit (UDWR 

2000b). 

Cougar 

Cougar, or mountain lions, are found statewide in Utah, occupying habitat types ranging from rugged 

desert areas to above timberline. Crucial habitat is found throughout Garfield and Kane counties. The 

species is fairly common throughout Utah, but individuals are rarely seen because of their secretive 

nature. Seasonally, their movements follow their main prey—mule deer. Cougar will also feed on rabbits, 

elk, or other animals, but about 80 percent of their diet consists of deer. Cougars are active year-round, 

during day and night, although most activity occurs at dawn and dusk. They are hunted on a limited and 

closely monitored basis in Utah (UDWR 1999c). 

Furbearers 

Several furbearer species are found in the field office and are managed according to Utah Furbearers 

Regulations. Furbearers, as defined by the UDWR, include bobcats, raccoons, badgers, weasels, and 

beavers. Bobcats are fairly common in Utah, but are rarely seen because of their secretive nature. 

Upland Game 

Upland game species throughout the planning area include Gambel’s quail, blue grouse, mourning dove, 

band-tailed pigeon, ring-necked pheasant, and chukar partridge. In addition to upland bird species, the 

cottontail rabbit and snowshoe hare are also present. The habitat for these species varies and depends on 

season of use as well as on availability of food and shelter. 

Migratory Birds 

The overall decline of some migratory birds is well documented. Reasons for the decline are complex and 

include such factors as loss of habitat due to fragmentation, alteration, urban expansion, natural disasters; 

loss or alteration of habitat in non-breeding areas along migratory routes; and brood parasitism (Parrish et 

al. 2002). Numerous programs have been initiated to combat this decline. The North American Waterfowl 

Management Plan (NAWMP) was adopted by the United States and Canada to address the conservation 

and restoration of waterfowl and other migratory waterbirds, and their habitats. The international Partners 

in Flight (PIF) program, is a coordinated effort to document and reverse apparent declines in the 

populations of all non-game land birds that breed north of Mexico and then migrate to Mexico, Central 

and South America, or the Caribbean in the winter months. Executive Order 13186, signed in 2001, 

requires all federal agencies that might have a measurable negative effect on migratory birds to develop a 

Memorandum of Understanding (MOU) with the USFWS to promote the recommendations of NAWMP, 

the North American Bird Conservation Initiative, the North American Bird Conservation Act, and other 

migratory bird programs. The executive order further requires federal agencies to consider the effects that 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-57 

planned or authorized activities will have on migratory birds and their habitats and to consider migratory 

birds in their land use planning efforts. 

The Intermountain West Joint Venture (IWJV) was established to coordinate implementation and 

achievement of population and habitat objectives of the NAWMP within parts of 11 Western states, 

including all of Utah. In 2005, IWJV partners within the State of Utah merged and synthesized habitat 

goals and objectives of existing bird conservation plans into a coordinated planning document, entitled 

Coordinated Implementation Plan for Bird Conservation in Utah, which reflects the habitat priorities of 

all bird conservation programs in Utah. The plan identifies portions of three Bird Habitat Conservation 

Areas (BHCA) that occur within the planning area. Although BHCAs carry no authority, they are 

recognized by agencies as areas that contain important habitat for some species. In 1993 a PIF program in 

Utah was established to address the status of avian populations within the state and to provide data 

relevant to issues concerning the status of neotropical migratory birds. In addition, the USFWS, in 

compliance with the Fish and Wildlife Conservation Act, published Birds of Conservation Concern 2002, 

a report that identifies migratory and non-migratory bird species (beyond those already designated as 

federally threatened or endangered) that have the highest need for conservation initiatives. 

To date, these reports identify more than 400 species of birds within the State of Utah. Of these 400 

species, 231 have been recognized as regular breeders in the state and in need of consideration in the Utah 

Avian Conservation Strategy process. Of these 231 species, 132 (57%) are neotropical migratory birds, 

and 29 (12%) are considered state sensitive species, 2 of which are also federally listed as endangered and 

4 of which are federally listed as threatened (Parrish et al. 2002). Primary and secondary breeding habitat 

preferences were identified for each of the 231 species. Primary habitat is considered to be the nesting 

habitat most commonly used by a species; secondary breeding habitat is the second most common. Winter 

habitat preferences were also identified. 

Table 3-14 identifies both migratory and non-migratory species that could occur within the planning area; 

PIF or the USFWS have identified these species as needing special conservation actions. Conservation 

areas are based on species’ primary and secondary habitat types and those habitat types that occur within 

the planning area. Table 3-14 also identifies species’ primary, secondary, and winter habitats (habitat 

types have been combined within the vegetation categories identified in the Vegetation section of this 

document). To distinguish those species in relation to the planning area, a compilation of species 

identified in the documents mentioned above was created and was intersected with the Colorado Plateau 

physiographic region identified by the PIF program. 

Table 3-14. Migratory and Non-Migratory Bird Species 

Species 

PIF 

Priority 

Species 

FWS Birds of 

Conservation 

Concern 

Primary 

Breeding 

Habitat 

Secondary 

Breeding 

Habitat 

Winter Habitat 

American 

Avocet X X Riparian/Wetland Non-Vegetated Migrant 

Bald Eagle1 Riparian/Wetland Other Riparian/Wetland 

Bendire’s 

Thrasher X X Desert Scrub Desert Scrub Migrant 

Black-Chinned 

Sparrow X Desert Scrub Desert Scrub Migrant 

BlackThroated Gray 

Warbler 

X X Pinyon-Juniper 

Woodland 

Oak/Mountain 

Shrub Migrant 

Brewer’s 

Sparrow X X Sagebrush Steppe Desert Scrub Migrant 
Chapter 3 Proposed RMP and Final EIS 

3-58 Kanab RMP 

Species 

PIF 

Priority 

Species 

FWS Birds of 

Conservation 

Concern 

Primary 

Breeding 

Habitat 

Secondary 

Breeding 

Habitat 

Winter Habitat 

Broad-Tailed 

Hummingbird X Riparian/Wetland Riparian/Wetland Migrant 

Burrowing 

Owl1 Desert Scrub Sagebrush Steppe Migrant 

California 

Condor1 Non-Vegetated N/A Desert Scrub 

Ferruginous 

Hawk1 X X Pinyon-Juniper 

Woodland Sagebrush Steppe Sagebrush 

Steppe 

Flammulated 

Owl X Ponderosa Pine Mixed Conifer Migrant 

Gambel’s 

Quail X Desert Scrub Riparian/Wetland Desert Scrub 

Golden Eagle X Non-Vegetated Desert Scrub Desert Scrub 

Grace’s 

Warbler X Ponderosa Pine Mixed Conifer Migrant 

Grasshopper 

Sparrow1 Sagebrush Steppe Sagebrush Steppe Migrant 

Gray Vireo X X Pinyon-Juniper 

Woodland 

Oak/Mountain 

Shrub Migrant 

Greater SageGrouse1

 X X Sagebrush Steppe Sagebrush Steppe Sagebrush Steppe 

Lewis’s 

Woodpecker1

 X X Ponderosa Pine Riparian/Wetland Oak/Mountain Shrub 

Loggerhead 

Shrike X Desert Scrub Pinyon-Juniper 

Woodland Desert Scrub 

Long-Billed 

Curlew1 X X Sagebrush Steppe Other Migrant 

Lucy’s 

Warbler X Riparian/Wetland Desert Scrub Migrant 

Mexican 

Spotted Owl1

 X Non-Vegetated Non-Vegetated Non-Vegetated 

Mountain 

Plover1 X X Desert Scrub Desert Scrub Migrant 

Northern 

Goshawk1

 Ponderosa Pine Aspen Riparian/Wetland 

Northern 

Harrier X Riparian/Wetland Desert Scrub Other 

Peregrine 

Falcon1

 X Non-Vegetated Riparian/Wetland Riparian/Wetland 

Pinyon Jay X Pinyon-Juniper 

Woodland Ponderosa Pine Pinyon-Juniper 

Woodland 

Prairie Falcon X Non-Vegetated Desert Scrub Other 

Pygmy 

Nuthatch X Ponderosa Pine Aspen Ponderosa Pine 

Red-Naped 

Sapsucker X Aspen Mixed Conifer Riparian/Wetland 

Sage Sparrow X X Sagebrush Steppe Desert Scrub Desert Scrub 

Short-Eared 

Owl1 Wetland/Riparian Sagebrush Steppe Other 

Snowy Plover X Non-Vegetated Non-Vegetated Migrant 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-59 

Species 

PIF 

Priority 

Species 

FWS Birds of 

Conservation 

Concern 

Primary 

Breeding 

Habitat 

Secondary 

Breeding 

Habitat 

Winter Habitat 

Southwestern 

Willow 

Flycatcher1 Riparian/Wetland Riparian/Wetland Migrant 

Swainson’s 

Hawk1

 X Other Aspen Migrant 

Virginia’s 

Warbler X X Oak/Mountain Shrub 

Pinyon-Juniper 

Woodland Migrant 

Williamson 

Sapsucker1

 X Mixed Conifer Aspen Migrant 

Yellow-Billed 

Cuckoo1

 X X Riparian/Wetland Other Migrant 

1

 Federally listed, BLM, or state sensitive species.

Source: IWJV 2005, Parrish et al. 2002, USFWS 2002 

Raptors 

There are many species of raptors found within the planning area, several of which are offered special 

protection by the state and/or Federal Government. These raptor species are discussed further in the 

Special Status Species section. Raptors are also commonly migratory species. The Migratory Birds 

section above also addressed raptors in relation to their nature as migratory birds. Special habitat needs 

for these raptor species include the protection of nest sites, foraging areas, and roosting or resting sites. 

Specifically, there are raptors in the Pugh Canyon area (Golden eagle and peregrine falcon) that are 

especially sensitive to disturbances from OHV use in the area. Buffer zones are usually recommended 

around raptor nest sites during the early spring and summer when raptors are raising their young. Annual 

raptor inventories monitor raptor nests and populations. This includes monitoring active nests, as well as 

raptor nests in various conditions of inactivity or abandonment. 

Special habitat needs relative to raptors are generally associated with limiting disturbance during the 

nesting season and maintaining small mammal populations as a prey base. Electrocution from powerlines 

and environmental contaminants continue to be a threat to some raptor species in the decision area. 

Other Wildlife Species 

There is a lack of information on small mammals, such as rodents and bats, as well as on amphibians and 

reptiles in the planning area. Databases maintained by the Utah Natural Heritage Program document 

general occurrences and the potential for many of these groups of wildlife, but site-specific inventories 

have not been conducted for most of the field office. However, as inventories are conducted, new 

occurrences and range extensions are being discovered. 

Fish Species 

Fisheries habitat includes perennial and intermittent streams that support fish through at least a portion of 

the year. The condition of fisheries habitat is related to riparian habitat condition and stream channel 

characteristics. Previous stocking efforts by UDWR have established many non-native fish species in 

streams to provide for sport fishing opportunities. Aquatic invertebrates and amphibians are integral 

components of warm and cold fish communities. 
Chapter 3 Proposed RMP and Final EIS 

3-60 Kanab RMP 

3.2.8 Wildland Fire Ecology 

Fire is an inherent component of ecosystems and historically has played an important role in the 

promotion of plant succession and the development of plant community character. Control of fires during 

the past century has changed plant communities and resulted in conditions that may sustain large-scale 

fires when natural ignition of vegetation occurs. 

Fires within the planning area are both naturally occurring and used as a management tool. Naturally 

occurring fires are widely distributed in terms of frequency and severity. Historically, the area has 

displayed a moderate to high frequency of fires, averaging 47 fires per year and burning an average of 

573 acres per year. During the 10-year period 1991–2001, the planning area averaged 86 fires per year, 

burning an average of 448 acres annually. 

Sources of Fire 

The weather and fuel structure in the planning area provide an opportunity for ignition from frequent 

summer storms. Lightning accounts for at least 78 percent of all fire starts. Careless smoking, vehicle 

exhaust, escaped agricultural burning, and unattended campfires account for the majority of humancaused fires. Equipment usage is also responsible for starting some fires. 

Range of Potential Fire Behavior 

Fires typically are categorized on the basis of period of occurrence, size class, regime, and condition 

class. The fire season for the planning area is usually late April to early November. The most critical fire 

conditions correspond with the hot summer period, which is characterized by low moisture and latesummer thunderstorms. Over the decade for which data are available (1991–2001), the large majority of 

wildfires have been less than 0.1 acre in size. From 1991 to 2001, more than 99 percent of the wildfires 

that occurred within the planning area were Size Class A (0.25 acre), B (0.25–10 acres), C (10–99 acres), 

or D (100–299 acres) incidents (Table 3-15). Only two wildfires were representative of the other three 

size classes (E, 300–999 acres, F, 1,000–4,000 acres, G, greater than 5,000 acres). 

Table 3-15. Fire Occurrence (Size and Acreage), 1991-2001 

Size Class A B C D E F G 

# Fires 604 222 26 9 1 1 0 

# Acres 64 295 850 1,343 724 1,204 0 

Source: Kanab Field Office Files 

The five fire regime classes reflect the frequency and severity of burns (Table 3-16). Historically, the 

most prolific firespread events have been wind-driven, especially in the brush plant cover types. Plumedominated fires have occurred, particularly during very dry years in the older stands of pinyon-juniper 

and mixed conifer stands. Rates of firespread through the canopies of sagebrush can exceed 3 miles per 

hour, while the rate of firespread through mixed conifer and pinyon-juniper stands of 0.5 mile per hour 

are not uncommon. Periods of better-than-average moisture tend to keep the light fuels (i.e., grasses) 

green, which helps curtail firespread. The invasion of annual grasses, such as cheatgrass, is changing the 

fire environment by altering the frequency of fire in fire regimes composed of native vegetation. Light 

fuels available to burn through the height of the fire season are becoming more abundant by way of the 

species morphology. Much of the timbered land in the planning area experiences long intervals between 

fire events. Burn severity in these communities tends to be moderate to severe, resulting in stand 

replacement of the dominant species. Examples of these vegetation types are high-elevation subalpine fir 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-61 

and spruce and some pinyon-juniper stands in the western portion of the planning area. Examples of a 

more moderate to frequent return interval are sage/grasslands and lower elevation shrub communities. 

Table 3-16. Fire Regimes Within the Planning Area 

Fire Regime Acres Percent 

I (0–35 year frequency and low- to mixed-severity surface fires most common) 907,000 31 

II (0–35 year frequency and high-severity–stand-replacement fires) 1,258,000 43 

III (35–100+ year frequency and mixed-severity fires) 2,800 <1 

IV (35–100+ year frequency and high-severity–stand-replacement fires) 114,900 4 

V (>200 year frequency and high-severity–stand-replacement fires) 496,800 17 

Unclassified 132,100 5 

Source: Kanab Field Office Files 

Table 3-17 shows the acreages within the planning area for condition classes defined in terms of the 

relative risk of losing one or more key components that define an ecological system based on five 

ecosystem attributes—disturbance regimes (patterns and frequency of insect, disease, fire), disturbance 

agents, smoke production, hydrologic function (sedimentation, stream flow), and vegetation attributes 

(composition, structure, and resilience to disturbance agents). 

Table 3-17. Condition Class Definitions and Acreages 

Condition Class Fire Regime Example Management Options 

Condition Class 1 

Acres: 243,200 

8 percent of planning area 

Fire regimes are within an historical range and the risk of losing key ecosystem 

components is low. Vegetation attributes (species composition and structure) are 

intact and functioning within an historical range. Where appropriate, these areas can 

be maintained within the historical fire regime by treatments such as fire use. 

Condition Class 2 

Acres: 598,900 

21 percent of planning area 

Fire regimes have been moderately altered from their historical range. The risk of 

losing key ecosystem components is moderate. Fire frequencies have departed 

from historical frequencies by one or more return intervals (either increased or 

decreased). This results in moderate changes to one or more of the following: fire 

size, intensity, and severity, and landscape patterns. Vegetation attributes have 

been moderately altered from their historical range. Where appropriate, these areas 

may need moderate levels of restoration treatments, such as fire use and hand or 

mechanical treatments, to be restored to the historical fire regime. 

Condition Class 3 

Acres: 1,937,400 

67 percent of planning area 

Fire regimes have been significantly altered from their historical range. The risk of 

losing key ecosystem components is high. Fire frequencies have departed from 

historical frequencies by multiple return intervals. This results in dramatic changes 

to one or more of the following: fire size, intensity, and severity, and landscape 

patterns. Vegetation attributes have been significantly altered from their historical 

range. Where appropriate, these areas may need high levels of restoration 

treatments, such as hand or mechanical treatments, before fire can be used to 

restore the historical fire regime. 

Unclassified 

Acres: 131,700 

4 percent of planning area 

The unclassified category includes five SWReGAP land cover types that are not 

conducive to being ranked in a fire regime. Unclassified land cover types include 

barren, lava, urban, water, and agricultural. 

Source: Kanab Field Office Files 

Types of Vegetation Susceptible to Fire 

Wildfire in many of Utah’s vegetation communities was historically a regular occurrence that helped 

define species composition, structure, and productivity (Bradley et al. 1992, Paysen et al. 2000). Thus, 
Chapter 3 Proposed RMP and Final EIS 

3-62 Kanab RMP 

many plants that make up these communities are adapted to withstand wildland fire. Grasslands, 

sagebrush, mountain shrub, aspen, and mixed conifer forests are examples of fire-adapted communities in 

Utah. In contrast, frequent wildland fire is not part of the normal ecology of other vegetation communities 

with long fire return intervals, such as salt desert scrub and blackbrush, which typically are not dominated 

by fire-adapted species (Paysen et al. 2000). Fire in these communities is generally viewed as detrimental 

because plant succession may take decades to recover, and in some instances may never recover. 

The presence of invasive nonnative species can alter the resource character and values across the 

landscape. The presence of large populations of invasive annual grasses (e.g., cheatgrass) are known to 

alter (i.e., shorten) fire return intervals and may expand their range and coverage after fires. For additional 

descriptions of these invasive vegetation types in the planning area, refer to the Vegetation section. 

Salt Desert Scrub 

Salt desert scrub is characterized by salt-tolerant succulent shrubs, including greasewood, ephedra, 

shadscale, fourwing saltbush, and threadleaf rubber rabbitbrush. Common grasses include inland 

saltgrass, alkali sacaton, bottlebrush squirreltail, and Indian ricegrass. The invasive species, cheatgrass, 

halogeton, tall peppergrass, Russian thistle, and Russian knapweed, can be found either scattered 

throughout or predominant within salt desert scrub, which generally has low productivity, naturally sparse 

understory vegetation, and light fuels. 

Fire frequency has been estimated at 35 to more than 300 years for the salt desert scrub vegetation type 

and is classified as Fire Regime V. Because of the risk of losing key ecosystem components and of the 

risk of greatly increased fire regimes as invasive annual grasses dominate, salt desert scrub is typically 

classified as Fire Regime Condition Class (FRCC) 3. 

A lack of continuous cover (fuels) made fire rare to nonexistent in salt desert scrub communities. 

Historically, these communities did not burn often enough or in patches large enough to support 

dominance of fire-adapted plants. Most salt desert scrub species do not readily regenerate following fire. 

At present, cheatgrass has invaded large portions of Utah’s salt desert scrub communities, and now 

provides sufficient fuel loading to support large, fast-moving fires. Where cheatgrass has invaded, native 

salt desert scrub communities have been permanently lost or are at high risk of being lost. Further 

expansion of invasive species (e.g., cheatgrass, tall peppergrass, and Russian knapweed) following fire is 

a major concern for salt desert scrub communities. 

Pinyon-Juniper Woodland 

The relatively vast area covered by this vegetation type is in part due to previous (< 100 years ago) 

overgrazing (which reduces competition) and historic fire suppression in range communities—primarily 

in grasslands and sagebrush and, to a lesser extent, in forested communities. It is estimated that pinyonjuniper woodlands have increased 10-fold over the past 130 years throughout the Intermountain West 

(Miller and Tausch 2001). Old-growth pinyon-juniper woodland is estimated to be less than 10 percent of 

the current area classified as pinyon-juniper woodland (Miller and Tausch 2001). These old-growth areas 

are often restricted to fire-safe habitats (e.g., steep, dissected and rocky terrain, and in areas with thin, 

substrates along ridges). 

Fire frequency has been estimated at 200 to more than 300 years for old-growth pinyon-juniper (Romme 

et al. 2002 and Goodrich and Barber 1999) and would be classified as Fire Regime V. Most of the area 

where pinyon-juniper woodland currently dominates was historically characterized by fires burning 

approximately every 20 to 100 years (Kitchen 2004, Miller and Tausch 2001); this would characterize the 

Fire Regime as II. These areas in Utah are typically described by FRCC 2 (greater than 7,000 feet in 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-63 

elevation) or FRCC 3 (less than 7,000 feet). FRCC 3 areas are characterized by dense stands of pinyon 

and juniper, scarce understory, and high potential for cheatgrass invasion following fire. FRCC 2 areas 

are encroached pinyon-juniper woodland, but are less dense than in FRCC 3 areas and are at less risk of 

cheatgrass invasion following fire. 

Because juniper is a non-sprouter and is thin-barked when young, fire was the major historical cause of 

destruction for young juniper trees. However, adult juniper trees in mature stands are difficult to burn 

because the understory is usually sparse (older trees succumb to fire when 60 percent of the crown is 

scorched). Pure juniper stands need 35 mph winds or greater to carry wind through the canopy (Winward 

et al. 1997). Fire is known to have been the most important natural disturbance that affected the 

distribution of juniper and/or pinyon-juniper woodlands before the introduction of livestock in the 19th 

century (Miller and Rose 1999). Burkhardt and Tisdale (1976) and Tirmenstein (1999) concluded that fire 

frequencies of 30 to 40 years would help keep juniper from expanding into mountain big sagebrush 

communities. 

Sagebrush 

Fire frequency varies for the different sagebrush species and subspecies, but is considered to be between 

20 and 100 years depending on precipitation, elevation, sagebrush species, and associated vegetation. 

Although sagebrush does not resprout with fire, it is a prolific seeder, and studies show that burned soil 

and sagebrush seed have higher germination rates. Pre-European settlement stand-replacing fire 

frequencies for low-elevation sagebrush are estimated to vary from 60 to 110 years (Whisenant 1990, 

Peters and Bunting 1994, Miller et al. 2001). For mountain big sagebrush, pre-European settlement standreplacing fire frequencies have been estimated to vary between 10 and 25 years (Houston 1973, Harniss 

and Murray 1973). Sagebrush, characterized by Fire Regime II, is considered to be generally a FRCC 2 

area if it is above 6,500 feet and FRCC 3 if it is below 6,500 feet because of the high risk of losing key 

ecosystem components following fire due to cheatgrass invasion. 

Most sagebrush species do not sprout after fire and most plants are killed by low- to high-intensity fires. 

This is true of all three subspecies of big sagebrush common throughout Utah. Generally, the herbaceous 

understory composition does not determine the intensity and severity of wildland fires—sagebrush itself 

is the primary fire carrier. The high canopy cover associated with late, mature sagebrush stands likely 

facilitated historic stand-replacing fires. However, the pre-fire understory is an important determinant of 

post-fire response. A sagebrush stand with a robust understory of native grasses and forbs would 

generally be replaced after fire with native perennial grassland. Degraded sagebrush stands with poorly 

evolved native understories are most vulnerable to colonization by invasive species after fire. Because 

sagebrush seeds generally are not transported far from the parent plant, unburned areas within large burn 

areas are often the most important source of seed material for natural recruitment and re-establishment of 

sagebrush (Tirmenstein 1999, Howard 1999, Johnson 2000). 

Grasslands 

Grassland types include native perennial grasslands, seedings of native species, exotic perennial grasses 

(primarily crested wheatgrass), and some cheatgrass. A discussion on cheatgrass is included in this 

section because of its significant role in Utah’s grassland ecology. 

Because native grasslands are often seral to sagebrush, fire regimes are similar—Fire Regime II. 

Perennial grasses respond vigorously to fires of various severities by resprouting from basal growing 

points following fire. The primary determinant of fire response in native perennial grasslands is fire 

residence time. Fast, high-intensity fires have a short residence time and seldom cause substantial 

mortality to native perennial bunchgrasses. Slow backing fires have a longer residence time and greater 
Chapter 3 Proposed RMP and Final EIS 

3-64 Kanab RMP 

severity; mortality to native perennial bunchgrasses may be high under these conditions. With most 

natural ignitions, the predominant firespread would be as fast-moving as headfire. 

Wherever cheatgrass dominates, the prevailing FRCC is 3 due to the loss of key ecosystem components 

such as native species. The fire regime of cheatgrass-dominated sites is the historical fire regime of that 

site before it was invaded by cheatgrass. Where cheatgrass has invaded a salt desert scrub community, the 

fire regime would be Fire Regime V. 

The establishment of cheatgrass in a wildland community fosters much more frequent fire return intervals 

by extending the time during which the community is susceptible to wildland fire ignitions. In the 

summer, cheatgrass dries out 4 to 6 weeks earlier than perennial grasses and forms a fine-textured, highly 

flammable fuel. After cheatgrass dominates a site, the fire regime is altered to more frequent standreplacing fires such as the cheatgrass fire regime. Shortened natural and historical fire rotations affect 

perennial vegetation by killing the tops of the plants and allowing less time and fewer growing seasons 

between recurrent fires. Cheatgrass seed production can be affected by prescribed fire when it is applied 

during the brief period between the purple stage and the stage when the seeds are dropped. 

Blackbrush 

Historically, fires in blackbrush were infrequent. This ecosystem is at moderate risk of losing key 

ecosystem components due to fire. It is characterized by Fire Regime V and FRCC 2. After cheatgrass 

dominates a blackbrush site, the site is then FRCC 3. Recent experience on Utah BLM land has shown 

that blackbrush does not respond favorably to fire. In addition, most of the blackbrush in Utah has 

suffered substantial dieback due to recent drought conditions. Burning has promoted succession to 

grassland by destroying the biological crust that stabilizes the soil. The biological crust provides 

important soil microflora that apparently are required for blackbrush survival or reestablishment (Paysen 

et al. 2000). Frequent large fires can be problematic from a management standpoint because recovery can 

take more than 4 decades or, in some cases, there is no recovery (Wright and Bailey 1982, Paysen et al. 

2000). Blackbrush is often found in monocultures with little occurrence of other plants present; therefore, 

seedbanks are often deprived of other plant species. 

Mountain Shrub 

Mountain shrub is a highly diverse community made up in part of Gambel oak, chokecherry, serviceberry, 

currant, mountain snowberry, elderberry, bitterbrush, and mountain sagebrush. Stand-replacing fire 

frequency ranges from 25 to 100 years in mountain shrub (Gruell and Loope 1974), although return 

intervals may vary widely with elevation, aspect, site moisture, and the associated forest or woodland 

type. Mountain shrubs are classified as Fire Regimes I, II, and IV depending on the dominant species. 

FRCCs also vary with the dominant species, although most mountain shrub communities are in FRCC 2 

because of some missed fire return intervals, moderate risk of losing key ecosystem components, and 

moderately altered vegetation attributes. However, some mountain shrub communities at lower elevations 

(less than 6,500 feet) are classified as FRCC 3 because of the high risk of cheatgrass invasion following 

fire. 

Most species of mountain shrubs resprout following low- to moderate-severity fire. Sprouting mountain 

shrub communities generally recover following wildland fire and are considered fire tolerant. Mountain 

sagebrush and bitterbrush do not resprout and, depending on the severity of the fire, may be completely 

removed from a site. Evidence shows that bitterbrush may benefit from low-severity fire (Winward et al. 

1997). 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-65 

Mixed Conifer 

Major forest community types of mixed conifer include Douglas fir, lodgepole pine, Englemann spruce, 

and subalpine fir (although none of these species except Douglas fir grow in the decision area). Fire 

frequencies in mixed conifer forests range from 100 to 300 years. These forests are characterized by a 

combination of understory and complete stand-replacement fire regimes (Arno 2000). Mixed conifer is 

classified as Fire Regime III or IV depending on elevation and related dominant species. For example, 

conifer-shrub communities that occur at lower elevations that have pure conifer stands would be 

characterized by Fire Regime III. Because of the longer historic fire return intervals and well-functioning 

vegetation attributes, mixed conifer is classified as FRCC 1 when associated with Fire Regime IV, and as 

FRCC 2 when associated with Fire Regime III. 

This mixed-severity fire regime often results in a mosaic pattern of stand structure and fuels. Past stand 

burn mosaics tend to increase the probability that subsequent fires will also burn in a mixed pattern (Arno 

2000). Dead woody fuels often accumulate on the ground in a haphazard manner. The greatest fuel 

loadings tend to occur on the most productive sites, which are predominantly stand-replacement fire 

regimes. 

Ponderosa Pine 

Fire frequency for ponderosa pine communities ranges from 5 to 25 years, with low- to mixed-severity 

fires. Ponderosa pine forests in Utah are classified as Fire Regime I and FRCC 3. These forests have 

typically missed between 5 and 10 fire cycles in the years of fire suppression and could be at risk for 

cheatgrass invasion if not properly managed. Otherwise, the associated understory species exclude 

cheatgrass. Ponderosa pines have thick bark, which protects them from serious damage from surface fires; 

it is considered the most fire-adapted conifer in the West (Bradley et al. 1992). 

Riparian and Wetland 

Historically, fire in riparian communities would have been infrequent, variable, and small in size. Highly 

mosaic burn patterns would have resulted from the higher moisture content that is generally present in 

riparian areas and species, but stand-replacing burns would likely have occurred only during extreme 

drought periods. These riparian communities are in a Fire Regime IV with most areas presently in FRCCs 

2 and 3. Lower elevation riparian areas would be in FRCC 3 because of the higher incidence and potential 

of invasive species. 

Fremont cottonwood communities are characterized by a late seral stage (e.g., all mature to late-mature 

trees) with little or no representation of younger age classes and are not typically fire-adapted. Narrowleaf 

cottonwood is a somewhat fire-adapted species that may resprout from roots if the stands are not decadent 

and they occur in areas where the water table remains reasonably high throughout the growing season. 

The life history and ecology of cottonwoods are intimately tied to flooding, erosion, and deposition on the 

floodplains because the seeds germinate and establish only on bare, moist alluvium. Willow species 

typically sprout vigorously following a fast-moving fire. Slow-moving fires are generally more damaging, 

presumably due to greater heat transfer to root crowns. 

Aspen 

Fire frequencies in aspen range between 25 to 100 years with mixed severity (Gruell and Loope 1974). 

Aspen is characterized by Fire Regime IV and FRCC 2. Fire regimes and vegetation structure have been 

moderately altered from historical conditions. Pure stands of aspen are particularly susceptible to 

mortality of aboveground stems from fire of low severity even though aspen is well adapted to 

regeneration by sprouting after fire (Jones and DeByle 1985, Mutch 1970). Aspen stands do not easily 
Chapter 3 Proposed RMP and Final EIS 

3-66 Kanab RMP 

burn and often act as natural fuelbreaks during wildland fires. Fires in young aspen stands tend to be lowintensity surface fires unless there is a large amount of understory fuel. In older stands, during the 

warmest and/or driest months of the year, abundant fuels can lead to higher-intensity fires. Decadent 

aspen stands and other areas with thin, acidic soils may be less vigorous at regenerating via suckering and 

may tend to support conifers even after fire (Howard 1996). 

Characterization 

The fuel structure in the planning area is gradually changing as a result of historic management practices 

and invasion of nonnative annual grasses, primarily cheatgrass (Bromus tectorum). In areas where fuels 

are continuous, there is the potential for fires to spread rapidly during the height of the average fire 

season. Much of this area is typically grouped in Fire Regimes I and II, but many of the pinyon and 

juniper stands have much older stand characteristics, which often have heavier fuel accumulations and 

burn with stand-replacement fire behavior. There are many areas where sparse fuels and other natural 

barriers limit fire spread. Most are dry sites where the vegetation is of a moderate to old age class 

distribution. 

The moderate to long return fire interval, fire exclusion and other management practices, and increased 

human use and incursion into these areas have rendered many of the forested areas in peril of large severe 

wildland fires. These forests have achieved a level of vegetation stocking and dead and down fuel loads to 

exacerbate large fire spread through the dry seasons of the year. Recent insect and wind episodes have 

increased fuel loadings in localized areas to critical levels. 

3.2.9 Cultural Resources 

Cultural resources are sensitive, irreplaceable resources with potential public and scientific uses, and are 

an important and integral part of our national heritage. Cultural resources constitute “a definite location of 

human activity, occupation, or use identifiable through field inventories (i.e., surveys), historical 

documentation, or oral evidence” (BLM-M-8110). The term “cultural resource” also includes “historic, or 

architectural sites, structures, or places with important public and scientific uses, and may include definite 

locations (i.e., sites or places) of traditional cultural or religious importance to specified social and/or 

cultural groups. Cultural resources are concrete, material places and things that are located, classified, 

ranked, and managed through the system of identifying, protecting, and utilizing for public benefit” 

(BLM-M-8110). Archaeological resources, a subset of cultural resources, are “any material remains of 

human life or activities that are at least 100 years of age, and that are of archaeological interest” as further 

defined in 43 CFR 7.3. Native American religious concerns, a critical element noted in Appendix 5 of the 

BLM National Environmental Policy Act (NEPA) handbook, are addressed in the Social and Economic 

features section 3.5.2. 

Current Conditions 

Within the decision area, a variety of cultural resource site types attributed to culturally distinct 

chronological periods ranging from more than 10,000 years ago to the present have been discovered and 

there is a high potential for finding additional resources. Archaeological investigations started with the 

Harvard-sponsored Claflin-Emerson expeditions in the late 1920s led by Noel Morss and the 1926 work 

by Neil Judd (Geib et al. 2001, Janetski 2002). Later work centered around what is called “salvage...and 

industrial development archaeology” (Geib et al. 2001:41) with the very large Glen Canyon Project, 

which included archaeological survey and excavation of large areas surrounding what is now Lake 

Powell. In response to increased coal production and new legislation since the 1970s, inventories have 

traditionally been conducted to support site-specific surface-disturbing projects, such as mineral and 

energy development, to comply with the requirements of Section 106 of the National Historic 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-67 

Preservation Act (NHPA) and other cultural resource preservation laws. In addition, academic institutions 

have performed research excavations, although such scientific investigations were limited. Previous 

cultural resource inventories have not led to the investigation of the variety of environmental and 

ecological ranges present, thereby underrepresenting known current cultural resource sites. Intensive 

cultural resource inventories that meet Utah Class III standards (i.e., 15-meter transect intervals) have 

been completed on only approximately 57,000 acres. A Class II inventory of the BLM portion of the 

Coral Pink Sand Dunes was completed in summer 2008. No cultural sites were identified by the new 

inventory. 

Within the decision area a total of 1,023 cultural resource sites are listed in the State Historic Preservation 

Office (SHPO) database. Cultural resources are classified into site types based on physical or cultural 

characteristics identified as components or occupations. At the broadest level, cultural resource sites are 

categorized as containing either prehistoric or historic components. Because geographic locations ideal 

for human use may remain constant from one period to another, Table 3-18 lists both the number of sites 

with single, identified occupations and the number of identified cultural components, because cultural 

materials from one site may be attributed to several time periods. In steep, rugged terrain or in extensive 

sage flats, site densities may be as low as 2–3 sites per square mile. In other areas, especially on benches 

or terraces near water sources, and in areas favored by the prehistoric Anasazi, site densities may exceed 

70 sites per square mile. Prehistoric sites can be associated with one or more of four cultural traditions—

Paleo-Indian, Archaic, Formative (Fremont and Ancestral Puebloan), and Post-Formative (Geib et al. 

2001). There are 779 prehistoric sites from the various cultural traditions in the decision area. Many of the 

sites (312) cannot be associated with a specific prehistoric time period. This category usually includes 

sites with prehistoric artifacts, but that lack any diagnostic artifacts that would enable dating to a specific 

time period, such as pottery or projectile points. These sites are often small, simple scatters of chippedstone debris. There are 326 sites that date primarily to the Formative Period. Formative Period sites are 

the most archaeologically visible sites with diagnostic artifacts, often with evidence of architecture and 

pottery. Historic sites are cultural resources in the period following 1776 A.D. and are organized either 

chronologically or functionally. There are only 27 sites with evidence of historic occupations. Sites with 

more than one component are listed as multi-component sites, and many sites lack any description of 

cultural affiliation. 

Table 3-18. Cultural Time Periods 

Cultural 

Time 

Period 

Timeframe # Sites 

Median 

Site Size 

(acres)* 

# Identified 

Occupations Characteristics 

Paleo-Indian Before 

7,000 B.C. 1 > 1 2 

Big-game subsistence patterns. No 

dated sites from this period, although 

projectile points from this period 

have been recovered. Paleo-Indian 

sites are significant due to scarcity. 

Archaic 7,000 B.C. – 

A.D. 1 92 4.7 104 

Hunting and gathering lifestyle likely 

with well-established seasonal 

rounds for resource procurement. 

Projectile points and camps have 

been found and further discoveries 

are likely. 
Chapter 3 Proposed RMP and Final EIS 

3-68 Kanab RMP 

Cultural 

Time 

Period 

Timeframe # Sites 

Median 

Site Size 

(acres)* 

# Identified 

Occupations Characteristics 

Formative A.D. 1 – 

A.D. 1250 326 2.3 447 

Introduction of bow and arrow, 

ceramics, and farming with 

associated sedentary lifestyle and 

population growth. As a result, more 

permanent settlements and 

associated cultural resources remain 

from these cultures. Scientific 

uncertainty still remains concerning 

their origin and disappearance. 

Identification of additional sites would 

be scientifically beneficial. 

PostFormative A.D. 1250 – 

A.D. 1776 48 1.9 86 

Return to hunting-gathering traditions 

with limited use of ceramics and 

horticulture. Diagnostic artifacts 

include small unnotched or sidenotched projectile points and 

Southern Paiute Brownware 

ceramics. Later traits also include 

equestrian rock art motifs, European 

trade goods, wickiups, and a 

possible increase in the use of 

obsidian. Identification of additional 

sites would be beneficial to further 

research. 

Historic After ca. 

1776 27 2.8 50 

Euro-American settlement patterns 

associated with agriculture, 

homesteading, limited ranching, 

farming, minerals development, and 

transportation. 

MultiComponent Multiple 102 3.6 

Multi-component sites are sites 

occupied over at least two 

identifiable time periods within the 

same geographical boundaries (e.g., 

an Anasazi site with a Historic 

campsite). 

Unknown 

Aboriginal Unknown 312 2.6 

Unknown Aboriginal sites are sites 

with prehistoric-type artifacts, but 

that lack diagnostic materials, 

making assignment to a specific 

prehistoric time period impossible. 

No Affiliation Unknown 115 1.2 No cultural affiliation information is 

given on the IMACS site form. 

* Median size of sites larger than 1 acre. 

Sources: Geib et al. 2001, McFadden 1996 and 2001, Spangler 2001, Kanab Field Office Cultural Files, Utah Division of State 

History Files 

The size of the cultural sites was determined using the geographic information system (GIS) database of 

the KFO. The database codes sites as either points (< 1 acre), polygons (> 1 acre), or lines (linear sites 

such as roads). Specific size information is not readily available for the 769 sites that are less than 1 acre 

because they are recorded as points in the GIS dataset. The 249 sites with site size information average 

6.5 acres, although the median is only 2.6 acres, and the range is 0.05 acre to 72.2 acres. Table 3-18 

breaks out the size by time period. There are only five linear sites, ranging in length from 0.24 mile to 7.8 

miles, with an average of 2.1 miles and a mean of 0.7 mile. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-69 

Cultural resources, including prehistoric and historic sites, structures, or objects, and places considered 

important to Native Americans or other cultural groups, are managed according to laws, regulations, and 

current BLM policy. 

Within the decision area, only the Cottonwood Canyon Cliff Dwelling site has formally been listed on the 

National Register of Historic Places (NRHP), which occurred in 1980. Nearly half of the sites in the 

decision area (n = 481) have either been recommended as eligible for listing on the NRHP (n = 388) or 

have been determined to be eligible for listing on the NRHP by the SHPO (n = 93). There are 350 sites 

that have been recommended not eligible for listing on the NRHP, and thus released from consideration 

for further protection. In addition, those sites where data are insufficient to make an eligibility 

determination (n = 171) are treated as though they were eligible until supporting information shows 

otherwise. 

Characterization 

Factors regarding cultural resources include the presence and condition of cultural sites, landscapes, or 

places of traditional use. The trend and forecast of cultural resources in the planning area varies because 

of the diversity of terrain, geomorphology, access, visibility, and past and current land use patterns. 

Adherence to Section 106 of the NHPA and the BLM policy of avoiding impacts to cultural resources 

provides for the continued identification and preservation of cultural resource sites. Research-based 

surveys and Class II inventories have been conducted, and much information has been obtained to help 

identify the characteristics of the planning area (Geib et al. 2001, McFadden 1996 and 2001, Spangler 

2001). Most surveys take place in compliance with Section 106 of the NHPA, meaning the surveys are 

conducted as needed to identify cultural resources in a project-specific context and generally are not 

statistically valid samples of a region. 

Exposed sites and their associated artifacts, features, and/or structures are easily disturbed by natural 

elements such as wind and water erosion, natural deterioration and decay, animal and human intrusion, 

and development and maintenance activities. Vandalism of the site or collection of cultural artifacts (i.e., 

unauthorized digging and “pothunting”), which are illegal under the Archaeological Resources Protection 

Act, has been documented. Archaeological and historic sites are known to be deteriorating from a variety 

of causes. Collectively, these agents have adversely affected many known cultural resources. 

More than 57 percent of the recorded cultural resources in the decision area have been judged to be in 

either “excellent” or “good” condition, no doubt related to the remoteness and the rugged terrain that limit 

access to many areas. Almost 25 percent are considered to be in “fair” condition, and approximately 7 

percent are listed as “poor.” The remaining have no condition information listed. 

3.2.10 Paleontological Resources 

Paleontological resources constitute a fragile and nonrenewable scientific record of the history of life on 

earth. It is BLM policy to manage paleontological resources for scientific, educational, and recreational 

values, and to protect or mitigate these resources from adverse impacts. 

Significance of Paleontological Resources Within the Decision Area 

The fossils found in the rocks and unconsolidated deposits of the decision area are mostly the remains and 

traces of terrestrial organisms. The majority of these fossils date to between 65 million and 250 million 

years ago. This period, known as the Mesozoic, is one of the most fascinating chapters in earth history. 

Called informally the “Age of Dinosaurs,” the Mesozoic Era saw the rise of mammals, modern snakes 

and lizards, modern amphibians, dinosaurs, turtles, crocodiles, marine reptiles, birds, flowering plants, 
Chapter 3 Proposed RMP and Final EIS 

3-70 Kanab RMP 

and many kinds of insects. Rock layers in the region faithfully record local life and surface conditions on 

land for much of this time, giving scientists who study fossils (paleontologists) exceptional opportunities 

to learn more about this crucial time of biological development. Rocks dating to the latter part of the 

Mesozoic, known as the Cretaceous (65 to 144 million years ago), that crop out in the nearby GSENM 

have already proven to contain one of the best terrestrial fossil records for this time in the world. Similar 

rock strata occur in the decision area and have similar potential to help understand these ancient 

ecosystems that foreshadowed our modern world. Although the scientific value of fossils, especially 

vertebrates, is what drives many management decisions, these resources are also enjoyed by many in the 

general public as objects of wonder and beauty. Only scientists from qualified institutions can legally 

collect vertebrate fossils from public lands. 

Paleontological Resources by Geologic Formation 

Paleontological resources are integrally associated with the geologic rock units (i.e., formations) in which 

they are located. Fossils found in one location may be expected to occur elsewhere in the formation along 

the same stratigraphic horizon (Gillette and Hayden 1997). The geographic extent of the decision area 

contains approximately 19 formations at the surface, most of which are known to be or are likely to be 

fossiliferous. A comprehensive paleontological resource inventory of these formations has not been 

completed within the decision area, but a review of paleontological research on formations contained 

within the planning area has identified the types of fossil resources that could occur. Table 3-19 identifies 

these formations, their predominant depositional environments, the types of fossils present, and the 

formation’s potential to contain paleontological resources. The geologic Map of the planning area (Map 

21) displays these formations in relation to its boundary. It should be noted that the table reflects only the 

amount of paleontological work conducted in certain areas. Other areas, formations, or facies within a 

formation may also contain fossils, but have not been examined and evaluated. 

Table 3-19. Geologic Formations Present in the Decision Area 

Formation 

Age Formation Name Depositional Environment Fossils Present Potential 

Surficial Alluvium and Colluvium Fluvial, and 

Lacustrine Vertebrate Medium 

Basalt Flows and Cones Volcanic Vertebrate Low 

Surficial Eolian Eolian Vertebrate Low 

Surficial Landslide Gravitational and 

Mass Flow Vertebrate Low 

Volcanic Rocks (including basalt, 

rhyolite, andesite, and tuffaceous 

rocks) 

Volcanic Vertebrate Low 

Neogene 

Sevier River Formation Fluvial, Lacustrine Vertebrate, 

Invertebrate Medium 

Brianhead Group Fluvial, Volcanic, 

and Lacustrine Invertebrates Medium 

Paleogene 

Claron Formation Lacustrine and 

Fluvial 

Vertebrate, 

Invertebrate, Plant, 

Trace Plant 

Medium 

Kaiparowits Formation Fluvial and 

Lacustrine 

Vertebrate, 

Invertebrate, Plant, 

Trace Vertebrate, 

Cretaceous High 

Wahweap Formation Fluvial and 

Lacustrine 

Vertebrate, 

Invertebrate, Plant, 

Trace Vertebrate, 

High 
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Kanab RMP 3-71 

Formation 

Age Formation Name Depositional Environment Fossils Present Potential 

Straight Cliffs Sandstone 

Fluvial, Coastal 

Mires, 

Beach/Marginal 

Marine, Marine 

Vertebrate, 

Invertebrate, Plant, 

Trace Vertebrate, 

Trace invertebrate, 

High 

Tropic Shale Marine 

Vertebrate, 

Invertebrate, Plant, 

Trace Invertebrate 

High 

Dakota Formation 

Fluvial, 

Lacustrine, 

Coastal Mires, 

Beach/Marginal 

Marine, Marine 

Vertebrate, 

Invertebrate, Plant, 

Trace Plant 

High 

Henrieville Sandstone 

fluvial, Eolian, 

Beach/Marginal 

Marine 

Plant Low 

Entrada Sandstone 

Eolian, 

Beach/Marginal 

Marine, Fluvial 

Plant, Trace 

Vertebrate Medium 

Carmel Formation/Page 

Sandstone 

Marine, 

Beach/Marginal 

Marine, Fluvial 

Invertebrate, Plant, 

Trace Invertebrate, 

Trace Vertebrate 

Medium 

Temple Cap Sandstone Eolian None Identified Medium 

Navajo Sandstone Eolian, Lacustrine 

Vertebrate, 

Invertebrate, Plant, 

Trace Vertebrate, 

Medium 

Jurassic 

Kayenta Formation Fluvial, Eolian 

Vertebrate, 

Invertebrate, Plant, 

Trace Vertebrate, 

Trace invertebrate 

High 

TriassicJurassic Moenave Formation Fluvial, Lacustrine 

Vertebrate, Plant, 

Invertebrate, Trace 

Vertebrate, Trace 

Invertebrate 

High 

Chinle Formation Fluvial, Lacustrine 

Vertebrate, 

Invertebrate, Plant, 

Trace Vertebrate, 

Trace Invertebrate 

High 

Triassic 

Moenkopi Formation Beach/Marginal 

Marine, Marine 

Vertebrate, 

Invertebrate, Plant, 

Trace Vertebrate 

Medium 

Permian Kaibab Limestone Marine Vertebrate, 

Invertebrate Medium 

Sources: Stokes 1986, Hintze 1988, Doelling et al. 1989, Gillette and Hayden 1997, Winkler 1990, Foster et al. 2001, Titus 2005

Paleontological Resources Potential 

The potential for paleontological resources varies by formation and within formations. The potential for 

paleontological resources throughout the region was determined by reviewing published literature, 

coupled with BLM paleontologist knowledge of unpublished work in the area. Paleontological research 

not completed in the decision area, but within formations that occur throughout the planning area and the 

GSENM, provided additional support for determining the paleontological resources potential. Based on 

this review, it was determined that all surficial deposits had a low potential for fossils based on the 
Chapter 3 Proposed RMP and Final EIS 

3-72 Kanab RMP 

general potential for Pleistocene megafauna. Few megafaunal sites are known, but if any with diagnostic 

material are found, they would be of high significance. Jurassic formations have mostly low-to-moderate 

potential; Cretaceous formations have high potential for paleontological resources. Site-specific variations 

within individual formations may result in lower potential in certain areas. As research continues 

throughout the area, the paleontological potential of such areas will be further refined. The potential for 

paleontological resources across the planning area is noted through the use of the following three class 

definitions (Map 31): 

• High—Areas that are known to contain vertebrate fossils or noteworthy occurrences of 

invertebrate or plant fossils. Consideration of paleontological resources will be necessary if the 

BLM review of available information indicates that such fossils are present in the area. 

• Medium—Areas with exposures of geological units or settings that have high potential to contain 

vertebrate fossils or noteworthy occurrences of invertebrate or plant fossils. The presence of 

geologic units from which such fossils have been recovered elsewhere may require further 

assessment of these same units where they are exposed in the area of consideration. 

• Low—Areas that are very unlikely to produce vertebrate fossils or noteworthy occurrences of 

invertebrate or plant fossils based on their surficial geology, igneous or metamorphic rocks, 

extremely young alluvium, colluvium, or aeolian deposits, or the presence of deep soils. 

However, if possible it should be noted at what depth bedrock may be expected to determine if 

fossiliferous deposits may be uncovered during surface-disturbing activities. 

Paleontological Localities 

Reports of fossils throughout the planning area date to the early 20th century. Most of these references to 

fossil resource locations have no site identification or they provide only vague explanations to fossil 

locations (Gillette and Hayden 1997). Extensive scientific exploration in the region has increased 

dramatically in the past 15 to 20 years (Gillette and Hayden 1997). Most of this research, however, has 

taken place in the GSENM. As of May 10, 2005, only 19 of the 1,175 Kane County localities contained in 

the Utah Geological Survey’s database are known to occur in the decision area, while more than 950 are 

documented within the GSENM (Hayden 2005). In Garfield County, there are 846 localities. Two of 

these, which date back to the mid-20th century, are documented in the decision area, while 538 are in the 

GSENM (Hayden 2005). It should be noted that 167 localities between the two counties have not had 

their exact location identified, and thus the land status has not been determined. The lack of localities is 

not due to the lack of fossils, but to a lack of research. The scientific significance of fossils found adjacent 

to the decision area on Forest Service lands, state lands, and the GSENM demonstrate the potential for 

new localities. In addition, field inventories conducted within the decision area have identified 

scientifically significant specimens. Research of the decision area’s paleontological resources has been 

minimal, but it is expected that as research increases, the number of localities will increase as well. 

Fossils in the region represent a diverse array of plants, invertebrates, and vertebrates. Numerous 

scientifically significant types of specimens have been found on adjacent Forest Service, state, and BLM 

lands (primarily in the GSENM), in formations that also occur in the decision area. It is anticipated that 

the demand for paleontological resources for research purposes will continue to be high in the region, 

with the majority of new localities focused on the GSENM. However, continued research at existing 

localities, as well as identifying new localities, is anticipated. 

3.2.11 Visual Resources 

The planning area includes parts of the Colorado Plateau and Colorado Plateau/Basin and Range 

Transition physiographic provinces, resulting in a broad range of visual settings. Rugged basalt cliffs in 

the north give way to the sandstone buttes, mesas, canyons, and vistas of the western Grand Staircase 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-73 

physiographic subunit in the south. Other visual features scattered throughout the planning area include 

sand dunes, vast desert plateaus, and mountain overlooks. Several State Scenic Byways and State Scenic 

Backways cross portions of the decision area, providing views of the vistas, cliffs, and rural settings. Paria 

Canyon, along the Arizona border, is a designated wilderness area. The canyon is deep, with steep 

colorful walls, and is known for its scenic qualities. The proximity of undeveloped landscapes to two 

national parks, a national monument, a national recreational area (NRA), and four state parks also 

contributes to the importance of visual resource management (VRM). 

The current VRM inventory identifies the existing scenic values in the decision area. The inventory 

includes an evaluation of scenic quality, analysis of sensitivity, and delineation of distance zones. Based 

on these three factors BLM-administered lands are placed into one of four VRM inventory classes (Table 

3-20). The inventory classes represent the relative value of the visual resources. Class I and Class II 

resources are the most sensitive, Class III resources are moderately sensitive, and Class IV resources are 

the least sensitive (Table 3-21). 

Table 3-20. VRM Inventory Classes 

VRM Inventory Class Acres 

I 21,400 

II 165,900 

III 169,200 

IV 197,500 

Table 3-21. Visual Resource Inventory Class Definitions 

Classification Objective 

I To preserve the existing character of the landscape. The level of change to the characteristic 

landscape should be very low and must not attract attention. 

II To retain the existing character of the landscape. The level of change to the characteristic 

landscape should be low. 

III To partially retain the existing character of the landscape. The level of change to the 

characteristic landscape should be moderate. 

IV To provide for management activities that require major modification of the existing character of 

the landscape. The level of change to the characteristic landscape can be high. 

Source: BLM Handbook H-8410-1, Visual Resource Inventory 

The decision area contains many areas with a high degree of scenic quality and a high level of visual 

sensitivity as noted below. Scenic quality is rated as level A, level B, or level C, with level A having the 

highest scenic quality and level C the lowest. Much of the area has been rated scenic quality level B, 

which means the area is dominated by a moderate level of visual appeal. The higher mesas and landforms, 

as well as WSAs, have been rated as level A (high level of visual appeal), a few valleys and lowlands 

have been rated as level C (low level of visual appeal). In general, high scenic quality within the decision 

area is a product of the area’s varied topography, striking geology, and cultural history. These visual 

resources are appreciated by the local population as well as by the visiting public, both of whose numbers 

are steadily increasing. Areas with high visual sensitivity are the result of the high degree of visitor 

interest in and public concern for a particular area’s visual resources, an area’s high degree of public 

visibility, the level of use of an area by the public, and the type of visitor that an area receives. Most of 

the area has been determined to be moderately to highly sensitive, the most sensitive areas located along 

the scenic byways and in the most remote, undeveloped areas. Distance zones measure the relative 

visibility from travel routes or observation points with zone one being the closest to a point or route and 
Chapter 3 Proposed RMP and Final EIS 

3-74 Kanab RMP 

zone three being the furthest. Virtually all of the area has been determined to be in distance zones one and 

two, zone one being along the byways and highways. None of the area has been determined to lie in the 

“seldom seen” distance zone three. 

The main locations within the decision area that have both outstanding scenic quality and high visual 

sensitivity include, but are not limited to, the following: 

• Coral Pink Sand Dunes/Moquith Mountain WSA area (including Water Canyon and Cottonwood 

Point) 

• East Fork of the Virgin River/Parunuweap WSA (including The Barracks) 

• North Fork Virgin River/Orderville Canyon WSAs (including Clear Creek Mountain) 

• Hog Canyon and Trail Canyon areas 

• The White Cliffs 

• The Vermilion Cliffs (including Pugh Canyon and Willis Canyon) 

• The Pink Cliffs. 

There are portions of the decision area that are within the viewshed of Bryce Canyon National Park. To 

protect the “significant visual resources of the Park as well as its visibility” several areas adjacent to the 

park were “determined to be unsuitable for surface coal mining operations, including surface impacts 

incident to underground mining which would be visible from Bryce Canyon National Park” (OSM 1979). 

This secretarial decision recognizes and protects these scenic values, providing restrictions on coal mining 

in eight townships adjacent to Bryce Canyon National Park. In addition, the secretarial decision directs 

that “under no circumstances should this decision become the only basis for protection of the values for 

which Bryce Canyon National Park was established and I direct that these park values be taken into 

account in future decisions by the bureaus of this Department on mining plans and permit applications 

for other activities on undesignated Federal lands near the park.” 

There are several areas of high scenic quality and visual sensitivity that are associated with travel 

corridors and recreational routes within the planning area. There are four Scenic Byways, one AllAmerican Road (National Scenic Byway system), and three State Scenic Byways that pass through the 

decision area (see Special Designation section for more information). There are also hundreds of miles of 

trails where users can enjoy the scenery. 

3.2.12 Non-WSA Lands with Wilderness Characteristics 

Because WSAs were established in the 1980s, designation of wilderness in Utah has become a prominent 

state and national issue. For more than 20 years, the public has debated about which lands have 

wilderness characteristics and should be considered by Congress for wilderness designation. As a result of 

the debate (and significant passage of time since the BLM’s original inventories), in 1996 the Secretary of 

the Interior directed the BLM to take another look at some of the lands in question. In response to the 

direction of the secretary, the BLM inventoried these lands, and approximately 2.6 million acres of public 

land statewide (outside existing WSAs) were found to have wilderness characteristics, including the 

appearance of naturalness and outstanding opportunities for primitive recreation or solitude (1999 Utah 

Wilderness Inventory, BLM 1999a). 

In September 2005, the BLM and the State of Utah, the Utah School and Institutional Trust Land 

Administration, and the Utah Association of Counties (collectively “Utah”) reached an agreement 

negotiated to settle a lawsuit originally brought in 1996 by Utah, challenging the BLM’s authority to 

conduct new wilderness inventories. The settlement stipulated that the BLM’s authority to designate new 

WSAs expired no later than October 21, 1993. The BLM, however, does have the authority to conduct 

inventories for characteristics associated with the concept of wilderness and to consider management of 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-75 

these values in its land use planning process. The BLM’s Land Use Planning Handbook (H-1601-1) 

states that decisions on whether or not to protect wilderness characteristics are to be considered during 

planning. This section addresses lands outside existing WSAs that have been identified as having 

wilderness characteristics. 

There are areas in the decision area outside existing WSAs that were determined by the BLM in the 1999 

Utah Wilderness Inventory (BLM 1999a) to have wilderness characteristics. In addition to this, since 

1999 and during scoping for this land use plan (LUP), members of the public submitted information 

suggesting that additional areas outside of existing WSAs have wilderness characteristics and should be 

managed to preserve those values. A BLM interdisciplinary team evaluated the information for each of 

these areas to determine if the submitted information presented new information that the BLM had not 

considered in previous reviews. This evaluation included analysis of topographic Maps, a review of 2006 

digital aerial photos, other GIS information including county road data (previously verified as part of 

travel plan formulation), BLM files for such resource uses as range improvements and community pits, 

and professional judgment. The review identified impacted areas, as well as those areas that appeared 

relatively free of impacts on naturalness. The Kanab Field Office also made field trips to some of the 

areas. For these areas, the GIS review was used to confirm the field data. Summaries of these analyses 

were prepared for each evaluated area. 

In evaluating areas for their wilderness characteristics, the Kanab Field Office took into consideration the 

language of the 1964 Wilderness Act, and concluded that a size criterion is an important indicator of 

whether or not outstanding opportunities for solitude and/or primitive recreation exist. Areas of less than 

5,000 acres are generally not large enough to provide for these opportunities. Also, because the size 

criterion had been used for all previous wilderness inventories, applying it here allowed for consistency in 

both application and findings. The size criterion of 5,000 acres was applied only to "stand-alone" units; 

that is, units not contiguous with other federal lands previously determined to possess wilderness 

characteristics (e.g., designated wilderness, WSAs, and National Park Service and U.S. Forest Service 

lands that are administratively endorsed for wilderness). Units that are contiguous to federal lands with 

wilderness characteristics as identified above were evaluated for naturalness alone. Opportunities for 

solitude and primitive recreation were assumed to be present in association with the larger contiguous 

area. 

As a result of the 1999 Utah Wilderness Inventory and the subsequent interdisciplinary review of new 

information, the BLM determined that all or portions of 10 non-WSA areas, totaling approximately 

89,780 acres, have wilderness characteristics because they appear natural and provide outstanding 

opportunities for solitude or primitive and unconfined recreation (Table 3-22, Map 32). The BLM also 

determined that 43,135 acres (all of 5 areas and portions of 9 areas) did not have wilderness 

characteristics. Most of the non-WSA lands with wilderness characteristics are adjacent to existing WSAs 

or are areas the BLM previously inventoried and identified as having wilderness characteristics. There are 

no existing fluid mineral leases in these areas. 

Table 3-22. Non-WSA Lands Evaluated for Wilderness Characteristics 

Area Name 

Evaluated Acres 

Determined Not to Have 

Wilderness Characteristics1

Evaluated Acres 

Determined to Have 

Wilderness Characteristics1

Black Hills 2,100 0 

Canaan Mountain 3,200 7,000 

Carcass Canyon 250 220 

East of Bryce 0 860 

Heaps Canyon 4,100 0 
Chapter 3 Proposed RMP and Final EIS 

3-76 Kanab RMP 

Area Name 

Evaluated Acres 

Determined Not to Have 

Wilderness Characteristics1

Evaluated Acres 

Determined to Have 

Wilderness Characteristics1

Little Valley Canyon 4,100 0 

Moquith Mountain 1,300 10,900 

North Escalante Canyons 40 0 

Orderville Canyon 2,300 2,700 

Paria/Hackberry 20 0 

Paria/Pine Hollow 5 900 

Parunuweap Canyon 8,800 5,700 

Upper Kanab Creek 1,200 43,600 

Vermilion Cliffs 15,400 11,100 

Wide Hollow 320 6,800 

Total 43,135 89,780 

Notes: 

1 Includes acres only in decision area. 

2 Acres may differ from those identified in Utah Wilderness Inventory (BLM 1999a) due to use of GIS-generated 

figures. 

Sources: BLM 1999a, Kanab Field Office files 

The resource condition of each of the areas listed in Table 3-22 is described below. This includes 

discussion of the current resource values and uses that are present in each of the areas. The 1999 Utah 

Wilderness Inventory and wilderness files in the KFO contain additional information on these areas. 

Evaluated areas that the BLM determined did not contain wilderness characteristics are not addressed 

further in this document. 

Black Hills 

The Black Hills area (2,100 acres) is located northwest of Escalante in south-central Garfield County. The 

area is bordered by the Dixie National Forest on the north and by public lands on the other sides. On 

public lands, the area is bounded by well-used roads that provide access to the national forest, as well as 

an approximately 0.25-mile route on the northern edge of the area. The area is characterized by steep 

ledges and numerous broken sandstone cliffs. Vegetation is dominated by pinyon-juniper woodlands and 

scattered ponderosa pine. Primary uses of the area include recreational equestrian, hiking, camping, 

hunting, and livestock grazing. Supplemental values include archaeology, geology, scenic opportunities, 

and wildlife habitat and viewing. 

Canaan Mountain 

The Canaan Mountain area is located in eastern Washington and western Kane counties about 30 miles 

east of St. George. The area is located on the north, south, and east sides of the Canaan Mountain WSA 

and shares the same rolling foothills and sandy terraces found within the WSA. In addition, some of the 

area shares a border with Zion National Park lands that are under formal wilderness consideration. The 

area has a mixture of pinyon-juniper woodland and sagebrush vegetation. The area is used mainly for 

ranching and recreation, with a considerable amount of OHV use. There are more than 11 miles of routes 

within areas determined not to have wilderness characteristics (3,200 acres) and 8 miles of routes within 

the areas determined to have wilderness characteristics (7,000 acres). Approximately 0.8 mile of the 

Eagle Crags hiking trail is within the area. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-77 

Carcass Canyon 

The Carcass Canyon area is located in south-central Garfield County, south and southeast of the town of 

Escalante. Although the inventoried area contains 27,400 acres with wilderness characteristics, most of it 

is located in the GSENM and is outside the decision area; 220 acres within the decision area have 

wilderness characteristics. The area is composed mainly of pinyon-juniper woodlands interspersed with 

sagebrush and grassland benches. The area may contain scattered and inconspicuous fences, earthen stock 

reservoirs, corrals, salting locations, recreation intrusions, and overgrown seismic lines. There are 3 miles 

of routes in the portion determined to not have wilderness characteristics (250 acres). The area receives 

light hiking and hunting use. Lack of vegetative cover and topographic screening reduces opportunities 

for solitude in lower portions of the area adjacent to the boundary of the unit. 

East of Bryce 

The East of Bryce area (860 acres) is located in western Garfield County between Bryce Canyon National 

Park and the town of Tropic. The area is composed entirely of public land. The area consists of a portion 

of a large mesa providing overviews of Tropic Valley to the east and Bryce Canyon National Park to the 

west. Several moderate drainages cut into the mesa from the south and east. The vegetation is 

predominantly pinyon and juniper woodland on the mesa top and finger ridge, with sagebrush and shrubs 

on the south and east hillsides. The area is used for recreational opportunities, including hiking, 

backpacking, and photography from access points within Bryce Canyon National Park and the town of 

Tropic. 

Heaps Canyon 

The Heaps Canyon area (4,100 acres) is located northwest of Escalante in south-central Garfield County. 

The area is bordered by the Dixie National Forest on the west and by private land and State Route (SR) 12 

on the south, with public lands to the north separated by a well-used road that provides access to the 

national forest. The area is characterized by steep ledges and numerous broken sandstone cliffs. 

Vegetation is dominated by pinyon-juniper woodlands and scattered ponderosa pine. The area is used for 

recreation (equestrian use, hiking, camping, and hunting) and livestock grazing. Supplemental values 

include archaeology, geology, scenic opportunities, and wildlife habitat and viewing. 

Little Valley Canyon 

The Little Valley Canyon area (4,100 acres) is located northwest of Escalante in south-central Garfield 

County. The area is bordered by the Dixie National Forest and a State of Utah section on the northwest, 

by private land and a State of Utah section on the southeast, and by public lands on the other two sides 

separated by well-used roads that provide access to the national forest. The area is characterized by steep 

ledges and numerous broken sandstone cliffs. Vegetation is dominated by pinyon-juniper woodlands and 

scattered ponderosa pine. The area is used for recreation (equestrian use, hiking, camping, hunting, and 

fishing) and livestock grazing. Supplemental values include archaeology, geology, scenic opportunities, 

and wildlife habitat and viewing. 

Moquith Mountain 

The Moquith Mountain area is located in Kane County and is bordered by the city of Kanab on the east 

and by the Moquith Mountain WSA on the west. The area consists primarily of a long high mesa indented 

by several finger-like canyons and drainages. The Vermilion Cliffs is the most prominent feature in the 

area, with sandstone escarpments, rimrock mesas, and numerous indented canyons and drainages. The 

area is currently used for hunting, livestock grazing, OHV riding, and utility access for the Fredonia 

(Arizona) watershed. There are 5.5 miles of routes within areas determined to not have wilderness 
Chapter 3 Proposed RMP and Final EIS 

3-78 Kanab RMP 

characteristics (1,300 acres) and 2 miles in areas determined to have wilderness characteristics (10,900 

acres). 

North Escalante Canyons 

The North Escalante Canyon area is located in central Garfield County south and southeast of the town of 

Boulder. The area contains 20,900 acres with wilderness characteristics, all of which are within the 

GSENM and outside the decision area. The 40 acres located in the decision area, directly south of the 

town of Boulder, were determined to not have wilderness characteristics. The portion of the area in the 

decision area contains washes and drainages that form a linked network, providing a variety of routes to 

and from the Escalante River. Hikes to the Escalante River are available throughout the entire area, 

providing opportunities for primitive recreation and views of scenic landscapes. However, the acreage 

within the decision area and the adjacent landownership patterns result in the 40 acres not meeting 

evaluation criteria. 

Orderville Canyon 

The Orderville Canyon area, comprising several areas, is located in the northwest region of Kane County 

about 10 miles north of SR 9. Three major areas make up the Orderville Canyon area: one area is located 

north of Orderville Canyon, another area is south of the canyon, with each of these adjacent to the 

Orderville Canyon WSA, and the third is located directly east of the North Fork Virgin River WSA. The 

two areas adjacent to the Orderville Canyon WSA are bordered on the west by Zion National Park. Other 

boundaries for all three areas include private land and substantial vehicle ways. There is an isolated parcel 

(approximately 50 acres) in the Jolley Gulch area located between the Parunuweap Canyon WSA and the 

remainder of the major Orderville Canyon areas. This small unit is located along the western boundary of 

Kane County; its south and west boundary borders Zion National Park. The unit is located approximately 

2 miles north of Highway 9 and is part of a 160-acre parcel of isolated public lands surrounded on the 

north and east by private land. The area has been proposed for exchange, and local recreation resorts use 

an OHV route on the boundary of the area for OHV riding to the boundary of Zion National Park. There 

are 10 miles of routes within the areas determined not to have wilderness characteristics (2,300 acres) and 

9 miles of routes within the areas determined to have wilderness characteristics (2,700 acres). 

The area east of the North Fork Virgin River WSA straddles the North Fork of the Virgin River, with a 

route running along the south side of the river. The terrain slopes gently away from the river and has 

sparse pinyon and juniper woodlands and understory brush with some ponderosa pine along the lower 

slopes. The area is a key access point to the narrows hike in Zion National Park and is also used for 

camping, livestock grazing, and big game hunting. 

The areas adjacent to the Orderville Canyon WSA have terrain consisting of steep canyons and drainages, 

canyon rims, broad hollows, rounded peaks, and flat benches. A pinyon-juniper woodland and ponderosa 

pine cover most of the inventory area. The understory consists of mountain mahogany, serviceberry, 

Gambel oak, cliffrose, and silver buffaloberry. The lower portion of the area is covered by mountain 

shrub vegetation, with oak, big sagebrush, serviceberry, pinyon pine, juniper, and manzanita, with some 

bitterbrush and rabbitbrush. The areas are used for woodcutting, camping, livestock grazing, big game 

hunting, and OHV riding. 

Paria/Hackberry 

The Paria/Hackberry area is located in north central Kane County southeast of the town of Tropic. The 

entire area contains 25,780 acres with wilderness characteristics, all of which are within the GSENM and 

outside the decision area. The 20 acres of the inventory unit located in the decision area were determined 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-79 

to not have wilderness characteristics because of the limited size of the area and because its relationship 

to adjacent landownership patterns did not evaluation criteria. 

Paria/Pine Hollow 

The Paria/Pine Hollow area (900 acres) is composed of several units adjacent to the Paria Canyon–

Vermilion Cliffs Wilderness Area. The area is characterized by canyon uplands, with the tops and edges 

of mesas bordering the Paria River. Vegetation is composed of salt desert scrubs and shadscale. The 5-

acre Pine Hollow area is directly adjacent to the Buckskin Gulch trailhead and is in the bottomland of 

drainages dominated by sagebrush. Land uses in these areas are largely limited to livestock grazing and 

primitive recreation, although there is 1 mile of inventoried route within the easternmost Paria unit. 

Parunuweap Canyon 

The Parunuweap Canyon area is located in Kane County about 20 miles northwest of Kanab. Some of the 

inventory area is located north and east of Parunuweap Canyon; the remainder is southwest of the canyon. 

The area is bounded by private land boundaries, roads, well-defined vehicle ways, Parunuweap Canyon 

WSA, and Zion National Park. The terrain consists of canyon rims and drainages, separated by flat 

sagebrush bench lands or thick pinyon-juniper woodlands. Pockets of ponderosa pine and sandstone 

outcroppings are scattered throughout the area. The most prominent feature in the inventory area is Harris 

Mountain, a topographic formation that extends into the Parunuweap Canyon WSA. The area is currently 

used for woodcutting, big game hunting, camping, livestock grazing, and OHV riding. There are 42 miles 

of routes within the areas determined not to have wilderness characteristics (8,800 acres) and 11 miles of 

routes within areas determined to have wilderness characteristics (5,700 acres). 

Upper Kanab Creek 

The Upper Kanab Creek area is located 15 miles north and northwest of Kanab. The western portion is 

adjacent to a number of communities located in Long Valley; the eastern part is within the GSENM. The 

Upper Kanab Creek area is exceptionally scenic, forming the backdrop for tourists traveling Highway 89 

between Zion National Park, Bryce Canyon National Park, and the North Rim of the Grand Canyon. 

Upper Kanab Creek area is divided into two distinct areas by the prominent White Cliffs. These cliffs are 

one of the principal steps in the Grand Staircase cliff lines between the Grand Canyon and Bryce Canyon. 

Topography away from the cliffs is characterized by rolling hills and eroded draws. In the open canyons 

there is a combination of ponderosa pine and areas of colorful sandstone or sand dunes; the lower 

elevations contain large, dense stands of pinyon and juniper. There are also areas of scattered ponderosa 

pines and stretches of riparian vegetation along the perennial reaches of Kanab Creek. A large part of the 

area is north of the wells that supply culinary water for Kanab. The area is used for livestock grazing and 

recreation. There are approximately 5 miles of routes within the areas determined not to have wilderness 

characteristics (1,200 acres) and 72 miles of routes within the areas determined to have wilderness 

characteristics (43,600 acres). 

Vermilion Cliffs 

The Vermilion Cliffs area is located north and northeast of Kanab between Highway 89 and Johnson 

Canyon Road. The red sandstone cliffs along the area’s southern boundary form the backdrop to the 

eastern entrance of Kanab along Highway 89. The area is composed of sandstone cliffs, incised valleys, 

and colorful sandstone outcrops. Vegetation is dominated by pinyon-juniper woodlands, with scattered 

ponderosa pine and understory brush similar to that in the Upper Kanab Creek area. The area is used for 

livestock grazing and recreation. The area borders canyons with route systems popular to local and 

destination OHV use. There are approximately 71 miles of routes within the areas determined not to have 
Chapter 3 Proposed RMP and Final EIS 

3-80 Kanab RMP 

wilderness characteristics (15,400 acres) and 4 miles of routes within the areas determined to have 

wilderness characteristics (11,100 acres). 

Wide Hollow 

The Wide Hollow area (6,800 acres) is located northwest of Escalante in south-central Garfield County. 

The area is bordered by the Dixie National Forest on the northwest, by private land on the southeast, and 

by public lands on the other two sides separated by well-used roads that provide access to the national 

forest. The area is characterized by steep ledges and numerous broken sandstone cliffs. Vegetation is 

dominated by pinyon-juniper woodlands and scattered ponderosa pine. Use of the area is dominated by 

equestrian recreation use, hiking, camping, hunting, fishing, and livestock grazing. There is a 0.1-mile 

route in the eastern portion of the area. Supplemental values include archaeology, geology, scenic 

opportunities, and wildlife habitat and viewing. 

3.3 RESOURCE USES

The public lands administered by the KFO are managed for multiple uses. Multiple use management 

includes management for resource uses as well as for resource values. Resource uses involve activities 

that use the natural, biological, and/or cultural components of the decision area such as mineral 

development, livestock grazing, forestry and woodland harvest, and recreation. The decision area is 

viewed as some of the remaining lands in the region where traditional commercial uses and relatively 

unrestricted recreational activities can still occur. These lands are considered by many to be vital to 

meeting the developing needs of neighboring communities, private lands, and contributing to the 

economic and social well-being of the area. 

The following sections discuss resource uses in the decision area and include, where information is 

available, a discussion of the following three factors: 

• Current Use—Level and locations of use

• Forecast—Anticipated demand for use—the Reasonably Foreseeable Development (RFD)

• Key features—Areas of high potential for use. 

3.3.1 Forestry and Woodland Products 

There are approximately 478,000 acres available for forest and woodland product harvest in the decision 

area. Fuelwood harvest is the most common use of forest or woodland resources in the decision area. 

Individuals cutting firewood for personal use represents the greatest demand on the woodland resource. 

Historically, pinyon pine was the preferred species for fuelwood; more recently, juniper is increasingly 

used for fuelwood. Seasonal Christmas tree harvesting by local residents is also a common use of the 

woodland resource. Harvesting trees for posts is another type of woodland product use. Trees harvested 

for posts are generally found on the more productive pinyon-juniper sites where the soils are deep and 

well drained. These areas are generally associated with pinyon-juniper woodlands that have encroached 

into the sagebrush steppe. 

Table 3-23 shows the amount of woodland products harvested over the past 4 years. Based on existing 

demand for harvest, forests and woodlands provide ample opportunities to meet continued demand for 

harvest of woodland products (i.e., posts, fuelwood, and Christmas trees). 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-81 

Table 3-23. Woodland Product Harvest 

Woodland 

Product 2001 2002 2003 2004 2005 2006 

# Cords of Fuelwood 574 462 598 605 386 380 

# Cedar Posts 3,553 3,547 2,490 3,347 4,905 3,321 

# Christmas Trees 149 142 94 87 143 101 

Source: Kanab Field Office Files 

3.3.2 Livestock Grazing 

The Kanab, Utah, area was settled in the 1860s. Although some farming did occur, settlers found the area 

more suitable for livestock grazing than for subsistence farming because of the primitive and harsh 

conditions. There was neither intensive grazing management on the public lands nor established livestock 

numbers or seasons of use during the early settlement period. As a result, the number of cattle, sheep, and 

horses rapidly increased until the early 1900s. During this period of rapid stock increase, livestock 

grazing became a regulated and permitted activity on national forests. Non-forest federal lands continued 

to be treated as a “commons,” in which those who moved their stock onto the range first each season 

secured the use of new forage growth. During this period of unregulated use, rangeland resources and 

ecological conditions experienced significant harm from overgrazing. Overgrazing resulted in changes to 

vegetation communities, especially at lower elevations that were used for winter grazing. Control of these 

ranges did not occur until 1934. After enactment of the Taylor Grazing Act in 1934, grazing allotments 

were created and the number and kind of livestock and season of use were established for the area. In 

1946 the BLM was established. During the late 1950s and early 1960s, range surveys were completed on 

the public lands to determine the amount of forage being produced. Following these surveys, grazing 

capacity for the allotments was adjudicated. The number of livestock authorized on most of the allotments 

was decreased to meet sustained rangeland production objectives. 

A federal court agreement on April 11, 1975, required the BLM to prepare grazing environmental impact 

statements (EIS) on public grazing lands over a 10-year period. To comply with this agreement, the 

Kanab/Escalante Grazing EIS was prepared in 1981, and the data were used to make adjustments in 

number and season of use. 

There are a total of 119 allotments in the decision area (Map 33), which include BLM-administered land 

and land managed by other federal agencies, the State of Utah, and private entities. The KFO has 

administrative responsibility for the federal acres within these allotments. Table 3-24 lists these 

allotments, each allotment’s federal acreage, the kind of livestock permitted for the allotment, the active 

permitted use allocated to domestic livestock, and the forage allocated to wildlife. 

Table 3-24. Livestock Grazing Allotments 

Allotments Number Federal 

Acres 

Livestock 

Kind1

Active 

Livestock 

Permitted Use 

(AUMs) 

Suspended 

Livestock 

Permitted Use 

(AUMs) 

Wildlife 

Allocation 

(AUMs) 

Total 

AUMs 

Allocated 2

Alton 24002 392 C 5 15 5 10 

Art Canyon 24003 8,927 C 352 198 344 696 

Bald Knoll 24004 6,741 C 215 197 148 363 

Barracks Point 24005 8,140 C 170 249 262 432 

Big Flat 15031 6,464 C 529 0 * 529 
Chapter 3 Proposed RMP and Final EIS 

3-82 Kanab RMP 

Allotments Number Federal 

Acres 

Livestock 

Kind1

Active 

Livestock 

Permitted Use 

(AUMs) 

Suspended 

Livestock 

Permitted Use 

(AUMs) 

Wildlife 

Allocation 

(AUMs) 

Total 

AUMs 

Allocated 2

Black Mountain 24007 1,255 C 42 92 78 120 

Brown Canyon 24011 1,591 C 122 0 46 168 

Buck Knoll 24012 4,134 C 153 116 300 453 

Buck Pasture 24013 2,708 C 100 70 64 164 

Bunting Canyon 14014 339 C 4 19 6 10 

Burnt Cedar Point 24015 3,054 C 105 223 180 285 

Burnt Flat 24016 897 C 20 46 48 68 

Carmel Junction 24021 3,356 C 14 198 21 35 

Cave Creek 24092 645 C 16 0 61 77 

Chris Spring 34022 7,265 C 216 473 160 376 

Circleville Canyon 00809 4,280 C 88 0 * 88 

Clay Flat 24023 5,286 C 210 120 119 329 

Coal Hollow 04165 536 C 22 17 ** 22 

Coal Mine 24024 250 C 4 36 6 10 

Cogswell Point 04156 10 C 0 0 ** 0 

Coop Creek 24025 477 C 20 59 15 35 

Cottonwood Spring 24027 7,888 C 555 119 183 738 

Cougar Canyon 24028 1,468 C 55 0 36 91 

Cove (Alton) 24029 158 C 10 0 21 31 

Cove (Circleville) 00810 12,662 C 231 0 9 240 

Dog Valley 00812 9,704 C 336 280 * 336 

Driveway 00011 860 C 20 0 18 38 

Dry Lake 24033 1,796 C 74 46 94 168 

Dry Wash 24034 1,977 C, H 206 0 80 286 

Dump 24032 215 C 8 72 12 20 

Eight Mile Gap 24035 571 C 15 10 27 42 

Eight Mile Pass 05304 440 C 17 19 ** 17 

Elbow Springs 24037 2,352 C 50 134 77 127 

Elephant Cove 24038 7,604 C 432 194 304 736 

F.A.R. 24046 4,492 C 100 422 115 215 

Farm Canyon 24040 3,262 C 243 0 122 365 

Fish Tail 24042 3,039 C 230 58 87 317 

Flume Hollow 24045 806 C 7 42 37 44 

Gardner Hollow 24049 2,192 C 30 18 87 117 

Glendale Bench 24051 1,735 C 130 0 170 300 

Gordon Point 14098 329 C 40 30 47 87 

Graveyard Hollow 25048 1,206 S 75 0 * 75 

Harris Flat 24058 4,292 C 268 45 181 449 

Hawkins Wash 15005 7,878 C 552 165 * 552 

Hay Canyon 04155 709 C 50 50 60 110 

Hillsdale 25035 1,483 C 140 0 * 140 

Hogs Heaven 04154 1,404 C 50 490 136 186 

Isolated Tracts 14062 1,028 C 65 16 89 154 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-83 

Allotments Number Federal 

Acres 

Livestock 

Kind1

Active 

Livestock 

Permitted Use 

(AUMs) 

Suspended 

Livestock 

Permitted Use 

(AUMs) 

Wildlife 

Allocation 

(AUMs) 

Total 

AUMs 

Allocated 2

John. R. Flat 24063 9,862 C 258 75 291 549 

Johnson Spring 00012 618 C 15 0 ** 15 

Johnson Ranch 24066 5,118 C 265 335 110 375 

Kanab Creek 24067 4,023 C 85 266 138 223 

Kanab Creek 

Custodial 00005 65 C 9 39 *** 9 

Kane Springs 24068 15,271 C 253 651 457 710 

Kinnikkinnic Spring 14069 5,031 C 90 140 167 257 

Levanger Lakes 14070 872 C 33 0 43 76 

Limekiln Creek 15029 3,773 C 70 0 * 70 

Limestone Canyon 25047 1,535 C 67 0 * 67 

Lost Spring 24074 1,028 C 4 0 15 19 

Lower Herd 04101 820 C 25 140 61 86 

Lower Hog Canyon 14075 2,486 C 52 116 33 85 

Lower North Fork 04157 813 C 10 19 36 46 

Lower Sink Valley 04112 2,441 C 35 238 *** 35 

Lydia 24077 2,083 C 58 158 171 229 

Lydia's Canyon 24010 466 C 0 0 41 41 

Marshall Canyon 25027 909 C 30 0 * 150 

Meadow Canyon 24080 6,061 C 25 74 132 157 

Mill Creek 00010 12,209 C 301 0 429 730 

Muggins Flat 04162 638 C 12 0 13 25 

Neuts Canyon 24087 2,419 C 112 62 237 349 

North Fork 04160 366 C 15 1 14 29 

Oak Springs 14088 2,797 C 87 231 121 208 

Old Fort 14089 2,202 C 7 27 20 27 

Orderville Gulch 24090 4,824 C 200 50 366 566 

Pine Spring 24093 8,498 C 448 202 30 478 

Poverty Flat 24094 9,603 C 416 0 400 816 

Red Butte 24095 5,046 C 196 232 226 422 

Red Canyon 14096 11,910 C 448 52 417 865 

Red Hollow 14097 1,156 C 40 62 76 116 

Red Knoll 04140 5,879 C 175 550 243 418 

Robinson Creek 14099 524 C 24 61 37 61 

Rock Canyon 25046 8,281 C 484 0 * 484 

Rocking Chair 14100 1,572 C 61 92 175 236 

Roller Mill 15030 1,883 C 184 0 * 184 

Sagehen Hollow 25045 5,812 C 444 147 * 444 

Sandy Creek 25052 8,461 C 688 0 * 688 

Sanford Bench 25028 9,570 C 1,081 0 * 1,081 

Sawmill 25049 539 C 30 0 * 30 

Seeps 14107 2,199 C 30 422 281 311 

Sethy's Canyon 04108 7,295 C 262 373 224 486 

Sevier 15006 652 C 34 40 * 34 
Chapter 3 Proposed RMP and Final EIS 

3-84 Kanab RMP 

Allotments Number Federal 

Acres 

Livestock 

Kind1

Active 

Livestock 

Permitted Use 

(AUMs) 

Suspended 

Livestock 

Permitted Use 

(AUMs) 

Wildlife 

Allocation 

(AUMs) 

Total 

AUMs 

Allocated 2

Sevier River 25036 2,308 C 340 0 * 340 

Shearing Corral 00007 4,023 C 100 0 * 100 

Sheep Spring 04142 3,474 C 223 279 111 334 

South Canyon 25044 18,355 C 900 0 * 900 

Spencer Bench 04113 7,023 C 97 129 160 257 

Spring Hollow 04151 573 S 9 0 0 9 

Spry 05007 8,528 C 449 302 * 449 

Sugar Knoll 04117 2,686 C 112 0 48 160 

Sunnyside 04118 410 C 14 0 14 28 

Sunset Cliffs 04103 2,014 C 188 0 * 188 

Syler Knoll 04122 442 C 6 104 16 22 

Table Mountain 04104 2,296 S 89 247 181 270 

Tebbs Hollow 25053 3,961 C 319 0 * 319 

Thompson Point 04123 1,549 C 64 0 39 103 

Three Mile Creek 25051 2,666 C 200 0 * 200 

Toms Canyon 04164 240 C 5 0 *** 5 

Trail Canyon 04125 6,924 C 110 100 158 268 

Trail Well 14126 1,329 C, H 88 0 16 104 

Upper Hog 04128 4,183 C 100 183 98 198 

Upper North Fork 04158 714 C 10 80 73 83 

Upper Place 04129 1,581 C 23 29 69 92 

Upper Sink Valley 04163 4,806 C 311 134 141 452 

Virgin River 04131 3,922 C, H 230 0 122 352 

Water Canyon 04132 3,398 C 48 0 51 99 

Willis Canyon 04143 1,675 C 16 0 13 29 

Yellowjacket 04137 7,378 C 241 998 315 556 

Zion 04138 11,085 C 270 1167 519 789 

Zion Park 04159 1,263 C 0 162 42 42 

TOTAL 434,713 - 18,241 13,107 11,045 29,286 

Notes: 

1

 Livestock Kind Key: C = cattle; H = horse; S = sheep 

2

 Total = Sum of “Active Livestock Permitted Use” and “Wildlife Allocation” 

* For allotments within the CBGA RMP, big game will be provided 1,220 AUMs of forage in the short term and up to 2,042 AUMs of 

forage in the long term. However, these AUMs are not allotment specific; they are allotted decision area wide. 

** Wildlife AUMs not allotted in these allotments. 

*** Wildlife AUMs included only in the portion of the decision area administered by KFO. 

Source: Kanab Field Office Grazing Files 

In 2004, there were 136 permits to use these allotments. Grazing permits are usually issued for a 10-year 

period and periodically undergo a renewal process. Active permitted use, or the maximum number of 

Animal Unit Months (AUM) available for use given appropriate conditions, is identified by permit during 

this renewal process. Grazing allotments are monitored periodically to ensure proper stocking rates to 

prevent overgrazing forage on the allotments. In addition, allotments are inventoried periodically and 

evaluated to determine if standards are being met and if they comply with the Standards for Rangeland 

Health. Livestock grazing is managed in accordance with Standards for Rangeland Health and Guidelines 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-85 

for Grazing Management for BLM Lands in Utah. By regulation, if the Standards for Rangeland Health

are not being met, and livestock grazing is determined to be a significant contributing factor, appropriate 

actions must be taken that will result in significant progress being made toward meeting the standards 

within timesframes specified in the regulations. 

Although active permitted use in the decision area is 18,241 AUMs, active use, which is forage the 

permittees paid to use in a given season or year, was only 8,895 AUMs (49 percent of active permitted 

use) during fiscal year 2006. Active use has averaged 42 percent of active permitted use. This discrepancy 

between active permitted use and active use AUMs is attributable to a number of variables. Seasonal 

changes in precipitation and temperature result in more or less available forage. Over the last 5 years, the 

area has experienced severe drought conditions, requiring a reduction in grazing use to maintain range 

condition. In addition, fluctuations in the beef or sheep markets can make grazing less profitable. 

Permittees may also take voluntary nonuse for a variety of reasons, resulting in AUMs that are available 

but not purchased for livestock use. These variables can result in the perception that forage is being 

underutilized, when actually the range is simply being managed for a sustained forage yield. The majority 

of forage use is attributed to cattle (more than 97 percent of 116 allotments), with sheep (more than 2 

percent of 3 allotments) and horses (more than 2 percent of 3 allotments) comprising the remainder of 

domestic livestock use. Domestic livestock forage use over the last 13 years is shown in Table 3-25. 

Table 3-25. Domestic Livestock Forage Active Use 

Number of Operators Active Use 

Year1 

Cattle & 

Horse Sheep Total2 Cattle & Horse 

Sheep & 

Goats Total 

1994 86 7 86 17,349 246 17,595 

1995 88 8 89 19,096 215 19,311 

1996 89 8 90 21,677 279 21,956 

1997 97 7 96 22,572 379 22,951 

1998 94 8 94 21,486 215 21,701 

1999 92 8 94 19,013 215 19,228 

20003 77 7 81 8,304 197 8,501 

20013 74 6 77 10,653 153 10,806 

20023 73 6 77 6,431 161 6,592 

20033 68 6 74 4,831 163 4,994 

20043 66 2 68 6,005 92 6,097 

20053 75 3 77 8,114 115 8,229 

20063 83 3 84 8,763 132 8,895 

Average4 73.7 4.7 76.9 7,585.9 144.7 7,731 

Notes: 

1

 Figures are by Federal Government fiscal year (October 1–September 30). 

2

 Difference between total permits and operators denotes some operators with multiple permits. 3

 The 1996 designation of GSENM did not reduce the number of allotments administered by the KFO until FY 2000. Current 

administration of allotments by GSENM and KFO began in FY 2000. Prior to FY 2000 use figures include the existing 

decision area and GSENM. After FY 2000 (inclusive), use data represent livestock grazing only in the decision area 

administered by the KFO. 4

 Average is limited to the last seven years of sole Kanab Field Office administration. It should be noted that trends extrapolated 

from these data are not necessarily representative of average conditions, as the area experienced drought conditions from 

1999-2004. 

Source: Kanab Field Office Grazing Files
Chapter 3 Proposed RMP and Final EIS 

3-86 Kanab RMP 

As stated above, livestock grazing use within the region has significantly decreased from its peak in the 

early part of the last century. For the most part, these declines are due to reductions in use to more closely 

reflect the range’s carrying capacity, thereby improving rangeland health. Present levels of demand for 

forage resources are anticipated to continue. In the short term, active use in the decision area is 

anticipated to increase because of improving range condition and range recovery from recent drought. In 

the long term, forage demand is anticipated to continue at current levels. 

3.3.3 Recreation 

The planning area is divided into three distinct physiographic subdivisions—the Grand Staircase, the 

Kaiparowits Plateau, and the Southern High Plateaus. The types of recreational opportunities are directly 

related to the unique characteristics of these subdivisions. Recreation activity occurs in developed and 

undeveloped areas, in both the front and backcountry. 

Management of recreation is guided by BLM regulations and policy, federal and state laws, current and 

emerging trends in public demand for activities and opportunities, and the physical and natural 

environment surrounding any given area. The intent of the various laws, policy, and guidelines is to meet 

public demand for outdoor land-based recreation opportunities, while also preventing or minimizing 

adverse impacts to the natural and cultural elements of Utah’s public lands. 

Recreation Visitation 

The BLM reports recreation visitation estimates using the Recreation Management Information System 

(RMIS). RMIS estimates participation in 65 types of recreation activities recorded at BLM sites and 

areas, based on registrations, permit records, observations, and professional judgment. Visitation is 

estimated by the number of participants/visitors as well as visitor-days. Visitors are the actual number of 

people who take part in a recreational activity. A visitor-day is a common recreation unit of measure used 

among federal agencies and represents an aggregate of 12 visitor-hours at a single site or area. Table 3-26 

lists the RMIS figures for the decision area for fiscal years 2001–2006. 

It is important to note that the visitation figures in Table 3-26 are only estimates and do not reflect actual 

visitation occurring in any given year for specific activities in specific areas. Many areas lack direct 

visitation monitoring facilities such as traffic counters or visitor registers. Direct monitoring by BLM staff 

is focused on areas of greater use or conflict. Discrepancies in actual use are also a result of the remote 

nature of much of the decision area that does not receive frequent monitoring. In addition, many of the 

popular use areas/trails are not designated and there is currently no way to accurately determine the actual 

amount of recreational use these areas receive. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-87 

Table 3-26. Recreation Visitation 

Oct 1, 00- 

Sep 30, 01

Oct 1, 01- 

Sep 30, 02

Oct 1, 02- 

Sep 30, 03

Oct 1, 03- 

Sep 30, 04

Oct 1, 04- 

Sep 30, 05

Oct 1, 05- 

Sep 30, 06 Activity 

Visitors Visitor Days Visitors Visitor Days Visitors Visitor Days Visitors Visitor Days Visitors Visitor Days Visitors Visitor Days 

Backpacking 12,027 60,071 30,008 150,021 15,000 75,000 15,711 78,555 12,800 64,000 20,000 100,000 Bicycling – Mountain1 500 250 621 312 751 376 844 425 780 390 920 459 Camping 8,882 19,063 9,903 21,798 11,509 25,665 12,360 27,748 11,599 26,040 14,746 31,588 Hiking/Walking/Running 15,782 10,798 34,026 25,900 19,644 13,688 20,720 14,234 24,738 14,344 36,726 22,134 Horseback Riding 2,258 865 2,696 1,048 3,235 1,303 3,468 1,348 3,205 1,243 3,846 1,504 Hunting – Big Game 18,247 23,660 22,256 28,879 27,108 35,278 29,815 38,792 28,044 36,531 32,463 42,243 OHVs (Cars/Trucks/ Sport Utility Vehicles) and AllTerrain Vehicles 37,391 24,264 43,960 27,935 51,800 32,267 56,102 34,604 52,684 32,337 63,380 39,321 Picnicking 832 347 649 270 640 267 659 275 582 243 397 166 Endurance Horse Racing 0 0 0 0 0 0 67 134 0 0 0 0 Snow Play – General 2,260 732 2,720 883 3,300 1,075 3,612 1,178 3,404 1,111 3,966 1,291 Staging/ Comfort Stop 11,802 984 11,834 986 13,019 1,085 14,558 1,213 6,461 538 8,025 669 Viewing – Scenery and Other and Photography 11,020 3,453 13,470 4,335 16,494 5,331 17,982 5,839 22,549 7,842 29,536 10,449 Environmental Education and Nature Study 0 0 0 0 10 80 0 0 3,352 838 5,285 1,321 Vending Services 0 0 138 12 442 37 0 0 0 0 948 79 Total 121,001 144,487 172,281 262,379 162,952 191,452 175,898 204,345 170,198 185,457 220,238 251,224 

Notes: 1 – Oct 1, 05 – Sep 30, 06 includes 21 visitors and 9 visitor-days for “Bicycling – Road”. Source: BLM 2006b (RMIS) 
Chapter 3 Proposed RMP and Final EIS 

3-88 Kanab RMP 

During the past several years, participation in some recreational activities has substantially increased. 

More recreationists participate in OHV riding than in any other form of recreation use, although 

backpackers spend more visitor-days in the area. Big game hunting also receives comparatively high 

levels of use, both in the number of participants and the number of visitor-days. Other common recreation 

activities, either in number of participants or in visitor-days, include hiking, camping, and 

sightseeing/viewing nature. Most recreation use in the decision area is dispersed (125,948 visitors and 

223,454 visitor-days in 2006), although site-specific recreation (e.g., developed campgrounds and 

trailheads) also receive high levels of use (35,779 visitors and 27,768 visitor-days in 2006). Public lands 

adjacent to Kanab and other communities throughout the planning area receive regular use from residents. 

Demand for a variety of recreation opportunities in these areas is high, as evidenced by OHV use in the 

Hog Canyon area and increasing OHV use of Squaw Trail adjacent to Kanab, and equestrian and OHV 

use in the areas north of Escalante. 

Increased recreation use within the decision area can be largely attributed to the increasing number of 

visitors to neighboring state and national parks, the GSENM, and other surrounding recreation areas. In 

addition, increased recreation use can be attributed to population growth in Kane County and nearby 

areas, particularly St. George, the Wasatch Front, and Las Vegas, Nevada. 

The majority of recreation activities within the decision area occur primarily during the spring, summer, 

and fall. However, a steady increase in winter recreation has been occurring, particularly in the Coral Pink 

Sand Dunes where tubing by local residents has increased. 

OHV use has become one of the fastest growing recreational activities. Consequently, existing 

management efforts and processes, which were developed to address OHV use levels 20 years ago, are 

often inadequate. Because of the significance of OHV use, it is addressed in the Transportation section. 

There are many areas within and near the decision area that provide unique recreational opportunities and 

have become high-use recreational destination areas. Coral Pink Sand Dunes State Park, established in 

1963, encompasses 3,730 acres. It provides a unique setting for camping, hiking, and OHV use. In 2002, 

the Utah State Parks and the BLM initiated a partnership to manage Coral Pink Sand Dunes resources and 

recreational facilities. Both agencies signed a formal agreement intended to ensure that the area’s 

outstanding natural features were adequately protected from the adverse impacts of recreational use and to 

provide sustainable public recreation opportunities consistent with the management recommendations 

jointly developed by both entities. The Moquith Mountain area adjacent to the state park receives high 

levels of recreation use as well. Recreation use in this area includes “spill-over” use from the state park, 

as well as trail-based and heritage recreation (South Fork Indian Canyon Pictographs) unique to this area. 

Recreation use in this area has been increasing over the last several years and is anticipated to continue to 

increase. 

The Paria Canyon–Vermilion Cliffs Wilderness Area is a well-known area for primitive recreation 

opportunities. Recreation in the area includes dispersed use (28,890 visitors and 125,524 visitor-days in 

2006) as well as trail and campground use (10,899 visitors and 3,148 visitor-days in 2006). Recreation 

use in this area has been increasing for several years. 

Other parts of the decision area that have been identified as receiving increased recreational use include 

the Parunuweap Canyon WSA, North Fork Virgin River WSA, and Orderville Canyon WSA. These areas 

provide opportunities for primitive recreation and access to trails in Zion National Park. It should also be 

noted that adjacent national parks (Zion and Bryce Canyon) have experienced increased visitation and are 

now experiencing visitor overflows. Consequently, many of these displaced recreationists are seeking 

additional recreation and camping opportunities outside these areas and are turning to the nearby public 

lands to serve their needs. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-89 

Recreation Management Areas 

Recreation management areas are the BLM’s primary means for managing recreational use of the public 

lands. Public lands are identified either as a Special Recreation Management Area (SRMA) or an 

Extensive Recreation Management Area (ERMA). SRMAs are areas that require a recreation investment, 

where more intensive recreation management is needed, and where recreation is a principal management 

objective. These areas often have high levels of recreation activity or are valuable natural resources. 

ERMAs constitute all public lands outside of SRMAs and other special designation areas. ERMAs are 

areas where recreation is nonspecialized, dispersed, and does not require intensive management. 

Recreation may not be the primary management objective in these areas, and recreational activities are 

subject to few restrictions. There are no identified SRMAs in the decision area. 

Developed Recreation Sites 

Developed recreation sites are areas that incorporate visitor use with infrastructure. As defined in the 

Utah Standards for Public Land Health Guidelines for Recreation Management, infrastructure of 

developed recreation sites includes amenities such as roads, parking areas, and facilities that protect the 

resource and support the recreation user in his or her pursuit of activities, experiences, and benefits. 

Visitor use infrastructure is a management tool that can minimize resource impacts, concentrate use, and 

reduce visitor conflicts. Developed recreation sites help accomplish these goals. 

There are two developed campgrounds within the planning area, Ponderosa Grove Campground and 

Whitehouse Campground. Ponderosa Grove Campground is located along Hancock Road between 

Highway 89 and Yellowjacket Road, and is adjacent to Moquith Mountain WSA. It has seven individual 

sites and two group sites with parking available at each site. Facilities include vault restrooms, picnic 

tables, fire pits, and trash cans. There is no water available. Whitehouse Campground is located about 2 

miles by gravel road from Paria Contact Station, off Highway 89, about 45 miles east of Kanab. It is 100 

yards from the Paria River and has five individual sites with one common parking area. Facilities include 

vault restrooms, picnic tables, and grills. There are no trash cans and there is no water available. Although 

the KFO administers both the Paria Contact Station and Whitehouse Campground, they are actually 

located within the GSENM. In addition, there are some trailheads throughout the decision area for both 

motorized and non-motorized trails. 

Special Recreation Permitting 

As authorized by the Land and Water Conservation Fund Act, there are five types of uses for which 

special recreation permits (SRP) are required—commercial, competitive, vending, individual or group use 

in special areas, and organized group activity and event use. SRPs are issued to outfitters, guides, 

vendors, recreation clubs, and commercial competitive event organizers that provide recreational 

opportunities or services without using permanent facilities. SRPs are also issued for competitive and 

organized group events. SRPs may be issued for 10 years or less, with annual renewal. The permits are 

issued to manage visitor use, protect natural and cultural resources, and accommodate commercial 

recreational uses. Demand for SRPs has been increasing within the decision area; the BLM issued 

approximately 20 SRPs in each year from 2004 to 2006 for activities that include big game hunting 

outfitting, OHV tours and events, outfitter-led recreation in the Paria Canyon–Vermilion Cliffs 

Wilderness Area, and canyoneering. 

The BLM also issues SRPs for noncommercial use in certain special areas where a permit system for 

individual use would achieve management objectives. This includes the Paria Canyon–Vermilion Cliffs 

Wilderness Area, river use, and backcountry hiking or camping areas, or any area where it is determined 

that resources and/or visitors require special management and control measures for their protection. Large 
Chapter 3 Proposed RMP and Final EIS 

3-90 Kanab RMP 

non-commercial group activities outside of developed campgrounds could require an SRP, if necessary to 

meet planned resource management objectives or resource conditions. If the group or activity does not 

warrant an SRP, a letter of agreement (less formal approach) is often used (e.g., for Boy Scout groups and 

Sierra Club campouts). The BLM issues non-commercial recreation use permits (RUP) for individual 

and/or group use of the decision area’s two fee-site developed campgrounds. Table 3-27 identifies the 

RUPs and SRPs issued by the KFO in Fiscal Years 2001–2005. Ponderosa Grove and White House 

Campgrounds have been operating at approximately 32 and 60 percent of year-round capacity, 

respectively (the maximum number of RUPs that theoretically could be used if every site were occupied 

every night of the year). It is important to note that Ponderosa Campground receives most of its visitation 

during the late spring to early fall seasons; the different environmental conditions (e.g., elevation and 

geography) at Whitehouse Campground allow it to receive higher levels of visitation into early spring and 

late fall. During the remainder of the year, both campgrounds receive lower levels of visitation. 

Table 3-27. Kanab Field Office RUPs and Individual SRPs: FY01–05 

FY01 FY02 FY03 FY04 FY05

Ponderosa Grove Campground 

RUPs1 1,300 1,014 1,000 1,030 910 

White House Campground RUPs1 1,275 1,106 1,233 843 980 

Individual SRPs for Day Use in 

Paria Canyon 3,803 4,716 4,183 4,211 4,066 

Individual SRPs for Overnight Use 

in Paria Canyon2 779 896 911 853 849 

Note: 

1 – Use is limited spatially to the number of sites available and seasonally to the seasons of high recreation use in the area.

Therefore, these figures represent the level of use these sites incur mainly during the recreation season, not the level of 

recreation demand (number of days at capacity, percent of capacity per day, or number of visitors who were not able to use a 

site due to full capacity). 

2 – No more than 20 overnight permits available any given day, so figures do not reflect recreation demand in this area, but the 

level of recreation use. 

Source: Kanab Field Office Recreation Files 

3.3.4 Transportation 

Development of the existing transportation system in the decision area has been associated with providing 

access for resource uses such as mineral development, livestock grazing and management, and recreation. 

Increased demand for access to public lands, combined with research on the impacts of roads on resources 

and resource uses, has increased the need for a well-designed and well-managed transportation system. 

There are no backcountry airstrips in the decision area. 

The transportation system includes state, county, and BLM system roads, some of which receive regular 

maintenance. For portions of the transportation system roads that cross BLM-administered land, various 

government entities and individuals acquire ROWs from the BLM. Issuance of ROWs is based on access 

needs and resource considerations. State and county system roads (depending on class of the road) are 

usually constructed and maintained to higher standards than BLM roads and provide the primary arterial 

and collector road systems for access to and through BLM lands. These larger roads are not maintained by 

the BLM. 

In addition to arterial and collector routes, there are numerous smaller routes throughout the decision area 

that connect more remote locations to the larger roads. These routes are used for recreational purposes, 

access to range improvements, access to mineral development, and access to inholdings not managed by 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-91 

the BLM. Most of these routes are not paved and approximately 85 percent are unimproved; that is, they 

have a dirt, gravel, or sand surface. The BLM has ground-truthed the existing routes/ways with global 

positioning system (GPS), using state and county route data to ensure that all existing routes/ways are 

included for consideration in the planning process. Based on this inventory, there are 1,478 miles of 

routes/ways (Map 34) within the decision area. 

Although most access across public land is accomplished informally as casual use along existing routes, 

administrative access is made available on a case-by-case basis, usually along specific identified routes. 

Administrative access is made available for emergency purposes, BLM access to manage resources, and 

for persons engaged in valid uses such as mining claims, mineral leases, livestock grazing, recreation, and 

other uses. 

SITLA Lands 

Throughout much of the State of Utah, the state owns and manages four isolated sections in each 36-

section township. These are generally Sections 2, 16, 32, and 36, and are ordinarily 1 mile square (640 

acres). They are primarily administered by the Utah School and Institutional Trust Lands Administration 

(SITLA) for the purpose of economic support of the state’s public schools and institutional trust funds. 

Activities on state land generally are not substantially different from those on the surrounding land 

administered by BLM. Many of the SITLA lands generate funds through grazing permits, right-of-way 

easements and permits, and hydrocarbon or other mineral leases. 

Many BLM lands with management restrictions, such as Wilderness Study Areas (WSA), have state lands 

that are adjacent to or within their boundaries. State lands that are completely or almost entirely 

surrounded by BLM lands with management restrictions, or are in conjunction with administratively 

endorsed National Park Service lands, are termed state inholdings. 

Existing access to inheld state lands varies. Some of the parcels have direct access through cherrystemmed or boundary roads of WSAs. Inheld parcels may or may not currently have access, depending 

upon whether or not existing vehicle routes lead to them. BLM policy, as required by the Cotter decision, 

is that “the state must be allowed access to the state school trust lands so that those lands can be 

developed in a manner that will provide funds for the common school.” This decision confined the issue 

of access to situations directly involving economic revenues generated for the school trust. For example, 

if a holder of a state oil and gas lease on a parcel of state land that is completely surrounded by a WSA 

requires access to develop that lease, BLM must grant the leaseholder reasonable access with 

consideration given to minimize impacts on wilderness character.

Off-Highway Vehicles 

OHVs are used within the area for recreational and non-recreational use. Much of the non-recreational 

OHV use, or administrative use, involves OHVs driven by local ranchers for administration of their 

grazing operations. Administrative OHV use occurs in association with permitted uses as described above 

and is determined on a case-by-case basis. OHV use has become a popular method of recreation in itself, 

as well a means of transportation while hunting, fishing, or camping. 

OHV use has become a significant issue because of the increase in the number of users who participate in 

this recreation opportunity and because of concerns related to the potential resource degradation that can 

result from high levels of unmanaged use in sensitive areas. During public scoping, more than 25 percent 

of all comments received related to transportation and access or OHV use. Over the past 20 years, OHV 

use has become one of the fastest growing recreation activities in southwest Utah, drawing thousands of 

visitors each year. Visitors are drawn to these areas to experience the numerous roads and trails available 
Chapter 3 Proposed RMP and Final EIS 

3-92 Kanab RMP 

for OHV use, the diverse backcountry opportunities and spectacular scenery that the area provides, and 

the challenging OHV opportunities the landscape and terrain provides. This is evident by an increased 

demand for SRPs for group OHV events over the past 2 to 3 years. This trend is expected to continue. 

The number of OHV registrations in Utah has increased significantly over the past several years, as have 

registrations in Garfield and Kane counties. Local and statewide OHV registrations are shown in Table 

3-28. The registration data show why OHV use is perceived as one of the fastest growing activities; more 

OHVs are being registered and it is reasonable to assume that more are being used. Unfortunately, 

visitation data on OHV use is particularly difficult to collect because of the dispersed nature of the 

activities. In addition, the number of registrations may not accurately portray actual OHV use. The actual 

number of OHV users could be higher based on use of OHVs registered outside the planning area.

Table 3-28. OHV Registrations by County, 1998–2005 

County 1998 1999 2000 2001 2002 2003 2004 2005 % Change 

1998–2005 

Garfield 267 297 359 353 585 569 745 772 189 

Kane 306 410 428 499 777 873 1,167 1,088 256 

State of 

Utah 51,686 80,469 91,596 95,569 127,556 124,954 161,350 152,841 196 

Source: DNR 2004 

When the existing LUPs were completed, the level of OHV use in the decision area did not warrant 

extensive management restrictions. As a result, much of the area is open to cross-country use, although 

the majority of use occurs along existing routes, ways, or other areas that are already disturbed. OHV 

management in some areas no longer adequately addresses the issues that have arisen as a result of 

increased OHV use, which has resulted in some conflicts. Conflicts between OHV use and livestock 

grazing, non-motorized recreation, wildlife, and other sensitive values were identified during public 

scoping. The concern was raised that increased OHV use should be planned for in terms of providing a 

transportation system with varied opportunities (both motorized and non-motorized). Several federal, 

state, and county agencies in the region have cooperated in developing trail systems to provide these 

varied opportunities. The Paiute All-Terrain Vehicle and Great Western Trail Systems located the north 

and east of the planning area are examples of trail systems that allow for increased OHV use while 

minimizing impacts. In cooperation with state and federal agencies (including the BLM), the Garfield 

County Trails group is currently designing a county-wide system of motorized and non-motorized trails to 

meet local needs and to attract the re-creating public as an economic enhancement for the county. Local 

OHV clubs have also been working with the BLM to sign and manage OHV use in the Hog Canyon 

drainage near Kanab. These efforts reflect the demand for OHV opportunities. 

Although most of the decision area is currently open to cross-country OHV use, some locations receive 

intensive OHV use based on landscape characteristics, accessibility, or support facilities. One such area is 

Coral Pink Sand Dunes State Park and the adjacent public lands. Intensive use in and around the Coral 

Pink Sand Dunes has resulted in changes in management over the past 10 years to decrease impacts from 

OHV use. A travel restriction action, followed by an amendment to the Vermilion MFP, addressed such 

impacts. Other travel restriction actions were the result of addressing impacts in WSAs and the Hog 

Canyon area. The Sand Hills area, located just north of Kanab, receives intensive OHV use. Increasing 

OHV use in this area, which is currently managed as open to cross-country use, has resulted in impacts to 

resources and in conflicts between public land users. 
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Kanab RMP 3-93 

3.3.5 Lands and Realty 

The lands and realty program is a support program to all other resources and resource uses. The goals of 

the lands and realty program are to manage the public lands to support the goals and objectives of other 

resource programs, provide for uses of public lands in accordance with applicable laws and regulations 

while protecting sensitive resources, and improve management of the public lands through land tenure 

adjustments. The program responds to requests for ROWs, permits, leases, withdrawals, and land tenure 

adjustments from other programs or outside entities. The frequency of such requests is anticipated to 

increase as neighboring communities grow and the demand for use of public lands increases. As a result, 

future management of the lands and realty program will likely become more intense, complex, and costly. 

The primary responsibilities of the lands and realty program include land tenure adjustments, withdrawal 

review, ROWs, and other land use authorizations. The following sections describe the current conditions 

and status of lands and realty within the decision area. 

The planning area is composed of approximately 2,847,200 acres, of which 19 percent (554,000 acres) are 

BLM-administered public surface lands. Approximately 406,400 acres are privately owned, 185,400 acres 

are administered by the State of Utah (either as state parks or as school trust lands), and 1,701,400 acres 

are administered by other federal agencies (Map 1 and Table 3-29). The Bankhead-Jones lands are special 

use lands administered by the U.S. Forest Service (USFS) and that provide for endowment and support of 

colleges for the benefit of agriculture and the mechanical arts. 

Table 3-29. Surface Land Ownership in the Planning Area 

Ownership Acres Percent of Planning 

Area 

BLM 554,000 19 

Private 406,400 14 

Utah State Parks 7,600 <1 

State of Utah (School Trust) 177,800 6 

U.S. Forest Service 1,159,300 41 

National Park Service 531,600 19 

Bankhead-Jones Lands 10,500 <1 

Total 2,847,200 

Source: Kanab Field Office GIS 

The BLM administers the leasing of the mineral estate underlying USFS, National Park Service, and 

Bureau of Reclamation withdrawn lands, although mineral management decisions on these lands are 

coordinated with the appropriate surface agency. The mineral estate of many of the private land parcels 

was reserved to the U.S. Government at the time they were patented. In these cases, the mineral estate is 

administered by the BLM and the surface estate is administered by private landowners. 

Land Tenure Adjustments 

Land tenure adjustments are often associated with accommodating public and private needs, fulfilling 

State of Utah entitlements, community expansion, consolidating public land, acquiring and protecting 

important resources, acquiring access to public lands, or serving a national priority. All land tenure 

adjustments must be in conformance with applicable LUPs and be subject to valid and existing rights. The 

BLM uses several authorities to make land tenure adjustments through disposal and acquisition. 
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3-94 Kanab RMP 

Lands can be disposed of through sales, exchanges, state quantity grants, color of title, state In Lieu 

selections, desert land entries, Carey Act entries, patents under the Recreation and Public Purposes Act 

(R&PP), or through federal legislation. Public lands have potential for disposal when they are isolated 

and/or difficult to manage. Disposal actions are usually in response to public request, such as community 

expansion. Disposals result in a title transfer, wherein the lands leave the public domain. All disposal 

actions are coordinated with adjoining landowners, local governments, and current land users. Disposal 

actions require a site-specific environmental analysis in accordance with NEPA (unless the disposal is a 

result of federal legislation and is exempted from NEPA review). The NEPA analysis may reveal resource 

conditions that could not be mitigated to the satisfaction of the authorized officer and may therefore 

preclude disposal. Public sales are managed under the disposal criteria set forth in Section 203 of FLPMA 

and the Federal Land Transaction Facilitation Act. Public lands determined suitable for sale are offered on 

the initiative of the BLM unless their disposal was directed by federal legislation. The lands are not sold 

at less than fair-market value. Specific lands suitable for sale must be identified in the applicable LUP. 

Any lands to be disposed of through sale that were not identified in the LUP would require a plan 

amendment before a sale could occur. Lands can also be disposed of as directed by federal legislation. 

Two examples include the following: 

• Legislation was passed in approximately 1986 that included a provision authorizing the sale of 

public land within the town limits of Kanab City. Approximately 240 acres of public land were 

sold to Kanab City under this authority. 

• In October 1998, President Clinton signed into law the Utah Schools and Land Exchange Act 

(P.L. 105-335), which resulted in conveyance of more than 47,000 acres of public lands (both 

surface and mineral estates) within the KFO to the State of Utah. 

Disposal actions were considered in previous LUPs. The Vermilion MFP identified approximately 100 

acres of public lands that would be made available for potential disposal to satisfy the requirements of the 

Public Sale Act of 1968. However, the recommendation did not consider other requirements that must be 

met in adjudicating the applications for disposal. The Cedar-Beaver-Garfield-Antimony RMP provided 

direction to develop a disposal plan in which approximately 1,000 acres of public land within the decision 

area would be made available for disposal over the life of the plan. A total of 50,495 acres of public land 

within the decision area have been disposed of (through exchanges, FLPMA land sales, and R&PP sales) 

since the existing LUPs were prepared. Future disposal actions are anticipated as lands are identified for 

consideration for disposal to consolidate public land, facilitate community expansion, and remove from 

federal jurisdiction land parcels that are isolated or difficult to manage. 

Acquisition of lands can be pursued to facilitate various resource management objectives. Acquisitions, 

including easements, can be completed through exchange, purchase, or donations or receipts from the 

Federal Land Transaction Facilitations Act sales or exchanges. Land exchanges are initiated in direct 

response to public demand, or by the BLM to acquire sensitive resources and/or improve management of 

the public lands. Exchanges are considered on a case-by-case basis where the exchange is in the public 

interest and where acquisition of the non-federal lands will contain higher resource or public values than 

the public lands being disposed of. A total of 3,393 acres of private and state land within the decision area 

have been acquired by the BLM since the existing LUPs were prepared. Future land acquisitions are 

anticipated as opportunities arise to acquire access to public lands and protect important resources. 

Withdrawals 

A withdrawal is a formal land designation that withholds an area of federal land from settlement, sale, 

location, or entry under some or all of the public land laws for the purpose of limiting those activities to 

maintain public values or to reserve an area for a particular public purpose. Section 204(l) of FLPMA 

requires the review of existing withdrawals to determine if they are still serving the purposes for which 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-95 

they were made. If the withdrawals are no longer serving their intended purpose, they are to be revoked 

and the lands opened or partially opened to the uses that were previously prohibited. If withdrawals are 

determined to still be meeting the purposes for which they were made, they are recommended for 

extension for a specific term. If it is determined by a withdrawal review that a withdrawal should be 

revoked or terminated, or a withdrawal expires, the land does not automatically open to operation of the 

public land law(s) to which the land was closed. An opening order would be published to notify the public 

when and to what extent the land would be opened, consistent with planning decisions. An opening order 

may be incorporated in a public land order or termination order that revokes or terminates a withdrawal or 

may be published in the Federal Register as a separate document. The BLM can make recommendations 

to designate, revoke, or extend withdrawals, but only the Secretary has the authority to actually take these 

actions. 

A total of 83 current withdrawals exist within the decision area. Table 3-30 shows the type, number, and 

total acres by withdrawal type. 

Table 3-30. Existing Withdrawals within the Decision Area 

Withdrawal Type Number Acres 

Public Water Reserves 80 3,191

Administrative Sites 2 200 

Designated Wilderness 1 21,200 

Total 83 24,591 

Source: Kanab Field Office Lands Records 

Rights-of-Way 

A total of 202 ROWs exist within the decision area, authorizing construction, operation and maintenance 

of powerlines, telephone lines and fiber-optic cables, irrigation and culinary water facilities and pipelines, 

mineral material sites for federal aid highways, communication sites, ditches and canals, pipelines for 

mineral resources, roads, highways, and other similar uses (Table 3-31). These ROWs have been granted 

to various towns, cities, counties, individuals, companies, organizations, government agencies, and other 

entities. Whenever feasible, the BLM encourages joint use and placement of new facilities in existing use 

areas that have already been disturbed, such as existing communication sites, roads, and highways. Table 

3-31 shows the type and number of existing ROWs. 

Table 3-31. Existing Rights-of-Way within the Decision Area 

ROW Type Number 

Roads 70

Powerlines 59 

Communication Uses 10 

Telephone Lines 22

Water Facilities1 23

Stream Gauging Stations 1

Water Pipelines 12

Oil and Gas Pipelines 1 

Misc. ROWs2 3

Railroads 1 

Total 202 
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3-96 Kanab RMP 

ROW Type Number 1 Includes reservoirs, diversion structures, sediment basins, storage tanks, and associated ditches, canals, 

pipelines, and/or access roads. 

2, Department of Transportation maintenance shed; trails and trailhead; corral. 

Source: BLM staff compilation and review of LR2000 

Two ROW corridors have been established under previous LUPs with the intent of preventing random 

proliferation of major industrial transportation and utility systems throughout the planning unit for which 

they were proposed. The Vermilion and Zion MFPs established a utility corridor that is 33 miles long, 1⁄2 

mile wide, and covers approximately 9,500 acres of public lands. All types of utility and transportation 

systems are allowed within this corridor. The Cedar-Beaver-Garfield-Antimony RMP established one 

corridor (1 mile wide and approximately 8 miles long within the decision area) for power transmission 

lines. This corridor was analyzed for establishment of power transmission lines and is designated for that 

purpose. Any use authorization other than for electrical transmission lines will require a separate analysis. 

One additional utility corridor has also been established by federal legislation. P.L. 105-355 (enacted in 

1998) designated a 740-foot utility corridor along U.S. Highway 89; the portion within the decision area 

extends from the GSENM boundary north to Mount Carmel Junction. 

Although established corridors exist, this does not preclude the location of transportation and 

transmission facilities in other areas if environmental analysis indicates that the facilities are compatible 

with other resource values and objectives. Further identification of corridors may not necessarily mandate 

that transportation and transmission facilities would be located there, particularly if they are not 

compatible with other resource uses, values, and objectives in and near the corridors, or if the corridors 

are saturated. ROWs are issued with use stipulations and other mitigation measures to minimize impacts 

to resources. 

Communication sites host communication equipment and facilities for various uses, such as television, 

radio, microwave, seismograph, cellular, and Internet. There are five established communication sites 

within the decision area, plus one additional site where only administrative (i.e., governmental) use is 

authorized. Table 3-32 lists these communication sites and their uses. 

Table 3-32. Communication Sites within the Decision Area 

Site Name Type of Use User Acres 

Television and FM translators Western Kane County Special Service 

District 1.0 

Wireless Internet Xpressweb Orderville TV Site 

Cellular South Central Utah Telephone 

Orderville South Microwave South Central Utah Telephone 1.0 

Television and FM Translators Western Kane County Special Service 

District 19.7 

2-Way Radio South Central Utah Telephone 0.1 

Cellular Western Wireless Corp. 

2-Way Radio BLM 10.0 

TV Hill 

Wireless Internet Xpressweb 

Vermilion Seismograph University of Utah 0.1 

Hatch Television and FM Translators Hatch Town Corp. 1.0 

Escalante Cellular South Central Utah Telephone 0.03 

Source: BLM LR2000 
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Kanab RMP 3-97 

Leases, Permits, and Easements 

Three different types of leases have been issued within the decision area—R&PP leases, leases issued 

under Section 302(b) of FLPMA, and airport leases. A total of four R&PP leases exist, authorizing the 

development and use of a storage facility, shooting range, parking lot, nature park, nature trail, rodeo 

grounds, mountain park, and campsites. In addition, two other areas have been classified as suitable for 

lease under the R&PP Act. Two airport leases have been issued—one for the Panguitch Airport and one 

for the Bryce Canyon Airport. 

Permits can be issued under two authorities: FLPMA (Land Use Permits) and Mineral Leasing Act 

(Temporary Use Permits). Permits authorize short-term uses of public lands that usually involve little or 

no land improvements, construction, or investment. 

BLM policy is to acquire easements to improve access to public lands. The BLM has acquired seven 

easements for roads and trails under authority of FLPMA. 

3.3.6 Minerals and Energy 

The BLM minerals management program falls into three categories: leasable minerals, locatable minerals, 

and salable minerals. Leasable minerals include oil and gas, coal, and geothermal resources. Locatable 

minerals include uranium-vanadium, antimony, gypsum, and limestone. Salable minerals or mineral 

materials include sand and gravel, stone, clay, and humate. Some information from the Mineral Potential 

Report for the Kanab Planning Area (BLM 2005d) is included below. More specific information about 

past and potential development, as well as the reasonably foreseeable development scenario, is contained 

in the report. 

Leasable Minerals 

Oil and Gas 

Only limited exploration and development for oil and gas has occurred within the planning area. As of 

2005, there is only one producing oil field, the Upper Valley field, which was discovered in 1964 (BLM 

2005d). Based on the cumulative oil production through 2004, which falls in the range of 25 to 50 million 

barrels, the field is classified as a medium-sized field. Four CBNG holes were drilled in the planning area 

from 2002 through 2004. As of 2005, there are 23 authorized oil and gas leases, comprising 65,535 acres 

of the planning area (Map 35). There are no applications for permit to drill (APD) oil and gas wells within 

the decision area. 

Since the 1960s, approximately 68 oil and gas–related wells have been drilled in the region, 57 of which 

were drilled on federal mineral estate (Table 3-33). The last well drilled on federal mineral estate was in 

the 1990s. 

Table 3-33. Oil and Gas Wells Drilled in the Kanab Field Office (1960s–2000s) 

Subsurface Ownership Decade 

Federal State Private 

1960s 26 (primarily USFS) 1 5 

1970s 18 (primarily USFS) 0 2 

1980s 10 (primarily USFS) 0 2 

1990s 1 0 0 
Chapter 3 Proposed RMP and Final EIS 

3-98 Kanab RMP 

Subsurface Ownership 

2000s 0 0 4 

Source: Sprinkel 1999 (Utah Geologic Survey Digital Geologic Resources Atlas of Utah) 

The following five plays have been identified in the planning area: 

• Late Proterozoic/Cambrian Play 

• Paleozoic Devonian-Pennsylvanian Play 

• Permo-Triassic Unconformity Play 

• Cretaceous Sandstone Play 

• Cretaceous Coal Bed Gas Plays. 

The Permo-Triassic Play and the Devonian-Pennsylvanian Play are rated high (H) for development 

potential, and the Cretaceous Sandstone Play is rated moderate (M) for development potential. The Late 

Proterozoic/Cambrian Play and Cretaceous Coal Bed Gas Plays are rated low (L) for development 

potential. 

Based on historic drilling rates and development potential, the Utah Geological Survey estimates that a 

reasonably foreseeable development scenario would be 70 new exploration wells and 20 new 

development wells during the next 20 years. The reasonably foreseeable development scenario includes 

the discovery of one new petroleum field. If more fields are discovered, higher levels of drilling and 

disturbance would likely occur (BLM 2005d). 

Coal 

Kane County and Garfield County contain 54 percent and 22 percent of Utah’s coal resources, 

respectively. Areas of coal development potential are shown on Map 36. The Alton coal field is an area of 

high development potential for coal. The Cannonville and Skutumpah areas of the Alton coal field and the 

portions of the Kaiparowits Plateau and Kolob coal fields with thicker coals are rated as having moderate 

development potential, while all other coal-bearing areas are rated as having low development potential 

(BLM 2005d). 

Coal production in Kane County was about 70,000 short tons through 1971. No coal production has 

occurred in either county since 1971 (Utah Energy Office 2004). The Escalante, Paria, Zion, and CedarBeaver-Garfield-Antimony MFPs/RMP identified areas unsuitable for coal leasing, based on criteria in 43 

CFR 3461.5 and areas identified as unsuitable in a 1980 Secretarial Decision. 

There are presently no coal leases within the decision area. In the past, 31 coal leases have been issued, 

but no mining ever occurred before termination or expiration of the leases. As of November 2006, the 

BLM has received and is processing a lease to surface mine 40 million tons of coal in the Alton coal field. 

A site-specific EIS is being developed to analyze the impacts of development of the mine. 

Geothermal 

No geothermal resources with high or moderate development potential have been identified in the 

planning area. Areas of low geothermal potential exist near the Sevier fault and near Quaternary volcanic 

centers. No development of geothermal resources is predicted to occur in the next 15 years. Geothermal 

development interest could be affected if renewable energy portfolio standards and incentives are 

legislatively adopted (BLM 2005d). 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-99 

Locatable Minerals 

There is a low development potential for locatables within the decision area. As of fall 2005, there are 14 

authorized mining claims in the decision area. Six claims are actively being mined under the authority of 

43 CFR 3809, and include one notice of intent and one plan of operations. The operations are small in 

scale and are associated with alabaster carving stone and septarian concretions (nodules). 

Uranium-Vanadium 

Little uranium production has come from the planning area. Known deposits are generally small and low 

grade, and the potential for finding undiscovered large, high-grade deposits is low. The development 

potential for uranium-vanadium is rated low. Thus, no exploration or development activity is expected in 

the next 15 years (BLM 2005d). 

Antimony 

There have been several mining claims and studies performed related to antimony within the planning 

area. The small size of the identified deposit and the remoteness of the area make future attempts at 

producing antimony unlikely. The development potential of antimony is rated low. Thus, no antimony 

exploration or development activity is expected in the next 15 years (BLM 2005d). 

Gypsum 

Only small-scale mining and minor prospecting for gypsum has occurred (BLM 2005d). The 

development potential of large-scale bulk gypsum operations is rated as low (Map 37). Thus, only smallscale gypsum exploration and development activity is expected in the next 15 years (BLM 2005d). There 

are a number of claims in Dry Valley being worked to extract sculpture-quality alabaster (gypsum). 

Location and development of small alabaster mines is expected to continue at current levels. 

Limestone 

There has been little mining of limestone in the planning area, and only minor prospecting for limestone 

has occurred. The development potential for limestone deposits is rated moderate because the existing 

deposits lack good resource definition and there are better-defined deposits closer to the major Utah 

markets. No limestone exploration or development activities are expected in the planning area in the next 

15 years (BLM 2005d). 

Septarians 

Active mining for septarian nodules is occurring on BLM mining claims and State of Utah gemstone 

leases in the Mt. Carmel area. Development potential is rated high at mine prospects and moderate in 

other areas where concretion-bearing Tropic Shale is present. Increasing exploration and development 

activity is expected. 

Salable Minerals 

At the time of preparation of this plan, there are 16 BLM mineral material pits authorized within the 

decision area; 12 of the pits are available to the public and 4 available only for Federal Highway 

Administration use. On average, 30–50 over-the-counter mineral permits are issued annually. 
Chapter 3 Proposed RMP and Final EIS 

3-100 Kanab RMP 

Sand and Gravel 

Sand and gravel historically have been some of the most significant mineral commodities mined from the 

planning area (Doelling et al. 1989). The single greatest use has been for highway construction (Doelling 

1975, Doelling et al. 1989), and most past mining has been near existing roads. With the creation of the 

GSENM in 1996, future sand and gravel production from Garfield and Kane counties will be focused 

even more on the planning area because mineral material disposals are no longer authorized in the 

GSENM. 

The development potential for sand and gravel deposits in the planning area is rated high in areas of past 

or present sand and gravel extraction, as well as at sites where the proper host formations are found within 

3 miles of a paved road (Map 38). Sand and gravel development potential is moderate where the host 

formations are more than 3 miles from a paved road, and low where the host formations are 

administratively restricted from future development. Continued exploration and development activities 

for sand and gravel are expected in the planning area in the next 15 years at a level that increases slightly 

from past rates. Most of the activity would be in the areas of high development potential, but some would 

also occur farther from paved roads to allow maintenance of unpaved county roads (BLM 2005d). 

Stone 

Early settlers in the planning area used fieldstone and quarry stone mostly for home and building 

construction. A small number of building/dimension stone quarries remain active and there are several 

that are inactive or abandoned. In addition, there are a small number of decorative stone quarries, as well 

as quarries for rip-rap. The development potential for stone is rated high at past and present quarry sites 

and moderate outside these areas where the host formations occur (Map 39). Stone exploration or 

development activity is expected to continue during the next 15 years at rates slightly higher than historic 

activity levels (BLM 2005d). 

Clay 

Several small mines are known to have produced clay from the Garfield County portion of the planning 

area (Doelling 1975). The development potential for clay is rated high at past and present extraction sites 

and moderate outside these areas where the host formations are present (Map 39). No clay exploration or 

development activity is expected during the next 15 years (BLM 2005d). 

Humate 

No known exploration or development activities for humate have occurred in the planning area. The 

development potential for humate is rated low. No humate exploration or development activity is 

expected during the next 15 years (BLM 2005d). 

Renewable Energy Resources 

As part of the BLM’s proposed National Energy Policy Implementation Plan, the BLM and the 

Department of Energy’s National Renewable Energy Laboratory conducted an assessment of renewable 

energy resources on BLM lands in the western United States. The results of the assessment were 

published in a recent report, Assessing the Potential for Renewable Energy on Public Lands, 2003. The 

BLM/National Renewable Energy Laboratory team used GIS data to assess the potential for concentrating 

solar power (CSP), photovoltaics, wind, biomass resources, and geothermal energy on public lands. The 

team used several GIS data screening criteria to consider factors that would impact the economic and 

technical feasibility of renewable power production. This would help to determine the true potential of an 

area to produce renewable energy. Screening criteria used in the assessment included access to roads and 
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Kanab RMP 3-101 

transmission facilities, available land surface, site condition, land use restrictions, distance to population 

centers, government policies, and regional market conditions. The primary goal of the assessment was to 

identify BLM planning units in the western United States with the highest potential for development of 

renewable energy. 

The results of the assessment indicate that the decision area is not considered an area of overall high 

potential for development of renewable energy, although it is identified as having some potential for 

renewable resources. The raw potential for solar, wind, and biomass energy are quite high in some 

portions of the decision area; however, the potential for development of these resources declines 

considerably when the data screens are applied. This indicates that the energy resources are present, but 

various factors would reduce the concentration, production, and transmission of this energy. There are no 

renewable energy facilities currently present. 

The potential for direct solar power is considered high throughout the decision area (5 to 6 kilowatt hours 

per square meter per day), with particularly high concentrations in the eastern portion (7 kilowatt hours 

per square meter per day). This potential is limited to relatively small areas in the southwestern and 

northwestern portions of the decision area (with a CSP of 5 to 6 kilowatt hours per square meter per day) 

when the data screens are applied. The same is true for concentration of photovoltaics, which is directly 

related to CSP. Wind energy as high as Power Class 6 is present in the northern and northwestern portions 

of the decision area, but this potential area is reduced to only the northwestern corner (with Power Class 

rankings of 4 to 6) when the data screens are applied. However, this small area of high wind energy could 

be a high potential production area. The decision area appears to have potential for biomass energy 

production in the northern and west-central portions, and this potential is relatively unaffected when the 

data screens are applied. This area was not identified as an area with any measurable potential for 

geothermal energy production. Although the decision area was not identified as an area with overall high 

potential for renewable energy production, the results of the assessment show that the area does have 

some potential to produce such energy, which could increase in importance as the demand for renewable 

energy increases. 

3.4 SPECIAL DESIGNATIONS

Special designation areas are designated to protect or preserve their unique values or uses. These areas 

therefore require management different from that applied to the surrounding public lands. This section 

identifies the various special management areas within the decision area and addresses the qualities or 

uses that have resulted in their designation. The types of special designation include areas of critical 

environmental concern (ACEC), Wilderness, WSAs, Wild and Scenic Rivers (WSRs), and Scenic 

Byways. 

3.4.1 Areas of Critical Environmental Concern 

ACECs are defined in FLPMA, Section 103(a) as “areas within the public lands where special 

management attention is required (when such areas are developed or used or where no development is 

required) to protect and prevent irreparable damage to important historic, cultural, or scenic values, fish 

and wildlife resources or other natural systems or processes, or to protect life and safety from natural 

hazards.” The BLM prepared regulations for implementing the ACEC provisions of FLPMA. These 

regulations are found at 43 CFR 1610.7-2. The BLM also developed policy on ACECs that can be found 

in 45 FR 57318 and BLM Manual 1613. An ACEC’s management is determined at the time of its 

designation and serves to protect and manage the relevant and importance (R&I) values, resources, 

processes, systems, or hazards (collectively values). ACECs are also protected by the provisions of 43 
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3-102 Kanab RMP 

CFR 3809.1-4(b)(3), which require an approved plan of operations for activities under the mining laws 

except for casual use. 

Established in 1986, there is one existing ACEC, the 220-acre Water Canyon/South Fork Indian Canyon 

ACEC, in the southwest corner of the decision area. Although the ACEC is considered a single ACEC, it 

is divided into two separated portions. The 50-acre South Fork Indian Canyon is the northern portion of 

the ACEC; the 170-acre Water Canyon is the southern portion. The R&I values for which the ACEC was 

designated include relict desert riparian vegetation, wildlife, and scenic values. 

Five nominated ACECs were determined to meet the relevance and importance criteria and are considered 

potential ACECs in this planning process. The potential size of each area and the associated relevant and 

important values are listed in Table 3-34. It should be noted that the Cottonwood Canyon potential ACEC 

acres include the acreage of the existing Water Canyon/South Fork Indian Canyon ACEC. The ACEC 

Evaluation Report (Appendix 14) contains more information on the potential ACECs and the associated 

R&I values, threats, and potential management. 

Table 3-34. Potential Areas of Critical Environmental Concern 

Potential ACEC Acres with Relevant 

and Important Values Relevant and Important Values 

Cottonwood Canyon 3,800 Scenic, Cultural, Wildlife, Natural Processes 

Welsh’s Milkweed 1,300 Scenic, Geology (Sand Dunes), Coral Pink 

Sand Dunes Tiger Beetle, Welsh’s Milkweed 

Vermilion Cliffs 23,400 Scenic, Cultural, Wildlife, Natural Processes 

White Cliffs 26,000 Scenic, Cultural, Wildlife, Natural Processes 

Parunuweap Canyon 6,100 Scenic, Cultural, Wildlife 

TOTAL ACRES 60,600 

Source: Kanab BLM 

3.4.2 Wild and Scenic Rivers 

The National Wild and Scenic River System (NWSRS) was created by the Wild and Scenic Rivers Act of 

1968. The purpose of the act was to preserve in their free-flowing condition certain selected rivers of the 

nation, which, with their immediate environments, have outstandingly remarkable scenic, recreational, 

geologic, fish and wildlife, historic, cultural, or other similar values. Section 5(d)(1) of the act directs 

federal agencies to consider the potential for national wild, scenic, and recreational river areas in all 

planning for the use and development of water and related land resources. The wild and scenic river 

(WSR) review process is incorporated into the planning process for the Kanab RMP and includes the 

evaluation of a river’s eligibility, tentative classification, and suitability for congressional designation into 

the national system of rivers (Appendix 13). 

Eligibility and tentative classification consist of an inventory of existing conditions. Eligibility is an 

evaluation of whether a river or river segment is free-flowing and has one or more outstandingly 

remarkable values (ORV). If found eligible, a river is analyzed as to its current level of development (e.g., 

water resources projects, shoreline development, and accessibility) and segmented accordingly. Each river 

segment is given one of three tentative classifications—“wild,” “scenic,” or “recreational”—based on the 

degree of development. The final procedural step, suitability, provides the basis for determining whether 

to recommend a river as part of the national system by considering such factors as manageability, current 

uses, and other management options. Fifteen river segments have been determined eligible for designation 

into the national system of rivers. Table 3-35 identifies these segments, their ORVs, the acres associated 

with the river corridor, and the percent of the river corridor in the decision area. 
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Kanab RMP 3-103 

Table 3-35. Rivers Determined Eligible for Designation into the National Wild and Scenic 

Rivers System 

Segment 

Name 

Outstandingly 

Remarkable Value(s) 

Miles in 

Decision 

Area 

Corridor in 

Planning 

Area 

(acres) 

Corridor in 

Decision 

Area 

(acres) 

% of 

Corridor in 

Decision 

Area 

North Fork 

Virgin River 

Scenic, Recreational, 

Wildlife 2.2 500 430 86 

East Fork Virgin 

River (three 

segments) 

Scenic, Cultural, 

Recreational, Fish, Wildlife, 

Historical, Ecologic 

13.5 2,510 2,510 100 

Orderville Gulch 

(Esplin Gulch) 

Scenic, Recreational, 

Wildlife, Ecologic 3.2 640 590 92 

Meadow Creek/ 

Mineral Gulch Scenic, Recreational 9.2 1,780 1,760 99 

Deep Creek Scenic 0.7 210 130 62 

Cottonwood 

Creek 

Recreational, Cultural, 

Wildlife 1.1 320 280 87 

Indian Canyon Scenic, Recreational, 

Ecologic 0.7 160 140 88 

South Fork 

Indian Canyon 

Scenic, Recreational, 

Ecologic 1.8 490 450 92 

North Branch of 

South Fork 

Indian Canyon 

Scenic, Recreational, 

Cultural, Ecologic 0.4 110 90 82 

Water Canyon Scenic, Recreational, 

Ecologic 3.2 710 710 100 

Hell Dive 

Canyon 

Scenic, Recreational, 

Cultural, Ecologic 1.4 350 350 100 

Paria River Scenic, Wildlife, 

Recreational 4.8 1,090 1,020 100 

Three Mile 

Creek Fish 3.7 850 770 91 

Totals 45.9 9,720 9,230 95 

The segment of the Paria River in Utah was found to be eligible in the Final Arizona Statewide Wild and 

Scenic Rivers Legislative Environmental Impact Statement, December 1994. This is the portion of the 

Paria River located within the Paria Canyon–Vermilion Cliffs Wilderness. 

Appendix 13 contains a description of the WSR review process, as well as an evaluation of each eligible 

river segment. No river segments within the decision area have been designated into the National Wild 

and Scenic River System (NWSRS) by Congress. 

3.4.3 Wilderness 

The Wilderness Act of 1964 established the National Wilderness Preservation System for the purpose of 

preserving a representative sample of ecosystems in a natural condition for the benefit of future 

generations. With the passage of FLPMA in 1976, Congress directed the BLM to inventory, study, and 

recommend which public lands under its administration should be designated wilderness. The FLPMAmandated wilderness review process was completed in Utah in October 1991. 
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3-104 Kanab RMP 

The Paria Canyon–Vermilion Cliffs Wilderness was designated by Congress on August 28, 1984 as part 

of the Arizona Wilderness Act of 1984. The 111,600-acre wilderness area is in the southeast portion of 

the decision area at the Arizona and Utah state lines, with portions of the wilderness area located in each 

state (Map 40). The 21,200 acres in Utah are managed by the KFO. There are 90,400 acres in Arizona, 

which are managed by the Arizona Strip Field Office. The designating legislation closed the wilderness 

area to all forms of appropriation under the United States mining laws and all laws pertaining to mineral 

leases to reflect Arizona Wilderness Act of 1984. 

3.4.4 Wilderness Study Areas 

The Wilderness Act of 1964 established a national system of lands for the purpose of preserving a 

representative sample of ecosystems in a natural condition for the benefit of future generations. Until 

1976, lands considered for, and designated as, wilderness were managed by the National Park Service, the 

USFS, and the USFWS. With the passage of FLPMA in 1976, Congress directed the BLM to inventory, 

study, and recommend which public lands under its administration should be designated wilderness. The 

BLM’s wilderness review process was carried out in the three steps described in the following paragraph. 

The first step, inventorying public lands to determine which lands had wilderness characteristics, was 

done with extensive public involvement. Lands found to have wilderness characteristics were 

administratively designated as WSAs. The second step involved studying the WSAs to determine their 

suitability for wilderness designation. In Utah, that study included the preparation of a statewide 

wilderness EIS. The Utah Statewide Wilderness Study Report, published October 1991, reported the 

results of the study and made recommendations to Congress through the President about which areas 

should be designated wilderness, which is the third step. The final recommendation for wilderness 

designation was forwarded to Congress June 22, 1992. Congress has not yet acted on that 

recommendation. This completed the FLPMA-mandated wilderness review process. 

From the recommendations in the Utah Statewide Wilderness Study Report, five WSAs were identified in 

the decision area. A discussion of the current wilderness characteristics and other resource values and 

uses in each WSA can be found in the Wilderness Study Report (BLM 1991b). These five WSAs account 

for approximately 53,900 acres (10 percent) of the decision area (Map 40 and Table 3-36). 

Table 3-36. Wilderness Study Areas 

Proposal Name Area (in acres)1 

North Fork Virgin River 1,050 

Orderville Canyon 1,950 

Parunuweap Canyon 30,800 

Canaan Mountain 4,3002 

Moquith Mountain 15,200 

Acquired Lands Managed as WSA 600 

Total 53,900 

Notes: 

1) Acres differ from those identified in the Utah Statewide Wilderness Study Report due to the use 

of GIS-generated figures. 

2) Includes acres only in decision area. 

Source: BLM 1991a 

The five WSAs, established under the authority of Section 603(c) of FLPMA, are being managed to 

preserve their wilderness values according to the BLM Interim Management Policy for Lands Under 
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Kanab RMP 3-105 

Wilderness Review (IMP), and will continue to be managed in that manner until Congress either 

designates them as wilderness or releases them for other uses. 

Management of WSAs is similar to, but generally less restrictive than, management of designated 

wilderness areas. The Federal Onshore Oil and Gas Leasing Reform Act of 1987 closed lands within 

BLM wilderness study areas to oil, gas, or geothermal leasing (30 U.S.C. 226-3(a)2). Some of the many 

activities that are allowed in WSAs include hunting, fishing, travel with motorized vehicles on 

inventoried ways (unless otherwise restricted through land use planning), camping, hiking, horseback 

riding, and livestock grazing. 

Motorized travel in the WSAs has been a controversial issue and a management concern. Unauthorized 

cross-country OHV activity as well as unauthorized use of closed routes remains a concern. There are 32 

miles of inventoried ways in the Parunuweap Canyon (23 miles) WSA and the Moquith Mountain (9 

miles) WSA that were included in the 1993 Wilderness Inventory EIS. Due to the remote nature and lack 

of inventoried ways, OHV impacts in the Orderville Canyon WSA and the North Fork Virgin River WSA 

are limited. There are no ways in the Canaan Mountain WSA; however, there are several adjacent or 

cherry-stemmed routes. There can be periodic disturbances associated with OHV use adjacent to these 

areas that are accessed by inventoried ways. 

In isolated areas of the Parunuweap Canyon, Moquith Mountain, and Canaan Mountain WSAs, OHV use 

is increasing and some impacts are occurring to riparian vegetation and other resources. Some OHV use is 

occurring off existing inventoried ways in these WSAs. If OHV use off inventoried ways continues to 

increase at the current rate observed, impairment to these WSAs could result. If OHV drivers do not 

comply with the OHV travel limitations in any of the WSAs and future impacts result that could impair 

wilderness values, the BLM will implement additional management actions, which could include 

additional OHV travel restrictions or closure to OHV use. 

The Utah West Desert Land Exchange Act of 2000 (West Desert Act) ratified the “Agreement for 

Exchange of Lands, West Desert State-Federal Land Consolidation” between the Secretary of the Interior 

and the Governor of Utah. Section 6 of that agreement states “...if any portion of the transferred lands are 

wholly or partially encompassed within a wilderness study area created pursuant to Section 603 of 

FLPMA...then those lands shall be administered, subject to valid existing rights, pursuant to applicable 

statutes and regulations governing wilderness study areas....” One section of land within the planning 

area, adjacent to the Canaan Mountain WSA, was included in the land exchange (Map 40). Thus, pursuant 

to the West Desert Act, this area is managed in accordance with all laws and regulations applicable to 

WSA management (IMP), but is not included in the WSA acreage totals. In addition, guidance from RMP 

decisions specific to the Canaan Mountain WSA, including OHV designations, apply to this area. 

Only Congress can designate the WSAs established under Section 603 of FLPMA as wilderness or 

release them for other uses. The current status of WSAs will not change in the Kanab RMP process; 

however, an understanding of the WSAs and the reasoning for their designation will provide insight into 

current management procedures and issues that must be addressed during the RMP process. The 

following is a brief description of each WSA gathered from the Utah Statewide Wilderness Study Report. 

North Fork Virgin River WSA (1,050 acres) 

The North Fork Virgin River WSA is located in western Kane County along the eastern boundary of Zion 

National Park, approximately 45 miles northwest of Kanab. The area is roughly 2 miles long from north 

to south and 1 mile wide east to west (Map 40). The WSA consists entirely of BLM-administered public 

land and does not include any state, private, or split-estate inholdings. The WSA is bordered by state and 

private land except on the southwest where it adjoins Zion National Park.
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3-106 Kanab RMP 

The WSA is located in the Grand Staircase physiographic province at the southern end of the High 

Plateaus section of the Colorado Plateau physiographic province. Elevations within the WSA range from 

approximately 5,400 feet on the canyon floor to 6,900 feet in the northern part of the WSA. The North 

Fork of the Virgin River flows westward through a canyon in the southern part of the WSA. The segment 

of the Virgin River within the WSA is 1.5 miles long. Most of the area is covered by mountain shrub 

vegetation consisting of pinyon, juniper, scrub oak, and other kinds of brush and bunchgrasses. The 

remainder of the WSA is dominated by pinyon-juniper woodland with brush, forbs, and some ponderosa 

pine. 

The WSA is essentially natural, and largely appears as an untouched bench cut by a deep canyon system 

with outstanding scenic values equal to those of Zion National Park. The canyon floor provides 

outstanding opportunities for solitude. Screening by vegetation and terrain is excellent because the canyon 

floor is well below the upper bench lands. The canyon is sinuous, and thick vegetation covers parts of the 

canyon floor. The remaining portion of the WSA slopes gently southward and provides little topographic 

screening. 

Orderville Canyon WSA (1,950 acres) 

The Orderville Canyon WSA is in western Kane County along the eastern boundary of Zion National 

Park, about 40 miles northwest of Kanab (Map 40). The WSA consists entirely of BLM-administered 

public land. The WSA does not include any state, private, or split-estate inholdings. The WSA is bordered 

by private land on the east. On the north and south, the boundary generally excludes the old logging area 

and logging trails found at the edges of the upper canyon rims. The western boundary of the WSA is 

contiguous with the boundary of Zion National Park for about 1.5 miles. 

The WSA is located in the Grand Staircase physiographic province at the southern end of the High 

Plateaus section of the Colorado Plateau physiographic province. The topography of the WSA is rugged, 

with elevations ranging from about 5,100 feet on the canyon floor to 6,600 feet at the southwest edge of 

the WSA. The WSA contains a 2-mile segment of the upper Orderville Canyon (Orderville Gulch) and its 

several tributary canyons. Most of the area is covered by pinyon-juniper woodland with a sparse 

understory of brush, forbs, and grasses. The remainder of the WSA is dominated by mountain shrub. 

The WSA is in a natural condition and is an untouched deep canyon system with outstanding scenic 

values reminiscent of neighboring Zion National Park. The opportunity to experience outstanding solitude 

exists in the deeply entrenched, 1,167-acre Orderville Canyon. Some of the side canyons are narrow and 

moderately vegetated with oak brush, ponderosa pine, pinyon, and juniper, providing both topographic 

and vegetative screening, resulting in outstanding opportunities for solitude. The upper bench area does 

not offer comparable opportunities. 

Parunuweap Canyon WSA (30,800 acres) 

The Parunuweap Canyon WSA is located in western Kane County, about 25 miles northwest of Kanab. 

The WSA is an irregularly shaped unit, roughly 10 miles at the maximum from north to south and 10 

miles from east to west. The study area includes 30,800 acres of BLM-administered public land (Map 40). 

There are two inholdings (2 separate sections, totaling 1,253 acres) within the WSA boundary. No private 

or split-estate lands are within the WSA. The western boundary of the WSA is contiguous with Zion 

National Park for approximately 4.8 miles. The northern boundary is partly along fields, chainings, and 

topographic contours, and partly along the periphery of state and private lands. The southern boundary 

generally follows roads. 
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Kanab RMP 3-107 

The WSA is characterized by the main, east-west–oriented Parunuweap Canyon and other steep tributary 

canyons that are surrounded by buttes and mesas. The southwestern part of the WSA is a relatively flat 

area. Elevations range from about 4,800 feet in the bottom of the East Fork of the Virgin River Canyon to 

6,600 feet on Harris Mountain at the southern end of the WSA. Vegetation is almost entirely pinyonjuniper woodland with a sparse understory of shrubs, and a few scattered stands of ponderosa pine. 

Opportunities for solitude vary considerably throughout the WSA; however, the deeper, more irregular 

canyons and areas of eroded sandstone offer the best opportunities. In addition, small areas with sand 

dunes and the more densely vegetated parts of the WSA also provide opportunities for seclusion and 

solitude. Opportunities for primitive and unconfined recreation occur in portions of the WSA, including 

backpacking, rock climbing, photography, and sightseeing. 

Canaan Mountain WSA (4,300 acres) 

The Canaan Mountain WSA is located in southeastern Washington County and southwestern Kane 

County, about 70 miles east of St. George, Utah. Of the 47,170 acres of the WSA, approximately 42,870 

acres are in Washington County, and 4,300 are in Kane County. The WSA is 10 miles from north to 

south, and 10 miles from east to west (Map 40). The WSA borders the BLM Cottonwood Point 

Wilderness in northwestern Arizona for about 5 miles along the Arizona state line, and adjoins Zion 

National Park on the WSA’s northeast boundary for about 4 miles. The WSA consists of 47,170 acres of 

BLM-administered land. There is no private land in the WSA. The WSA is bordered by public (BLM), 

state, NPS, and private lands, and a road along part of the eastern boundary. 

Canaan Mountain is the largest undisturbed plateau top or tableland remaining in southwestern Utah. It 

has a quality of remoteness and naturalness not found elsewhere in the immediate region. The WSA is in 

the Vermilion Cliffs portion of the Grand Staircase, at the southern edge of the High Plateaus section of 

the Colorado Plateau physiographic province. Canaan Mountain, a sheer plateau that rises 2,000 feet 

above surrounding land to an elevation of 7,340 feet, is the dominant feature of the WSA. Also found 

within the WSA are shallow lakes, springs, and 4 miles of perennial streams. Most of the surface of the 

WSA is rock and bare soil; vegetation covers only about 20 percent of the WSA. Ponderosa pinemountain shrub is the dominant vegetative type, occupying about 75 percent of the vegetated portion of 

the WSA. Pinyon-juniper woodland covers approximately 19 percent, and sagebrush and riparian plants 

occupy the remainder of the vegetated portion of the study area. 

Moquith Mountain WSA (15,200 acres) 

The Moquith Mountain WSA is located in southwestern Kane County just north of the Arizona state line 

and about 4 miles west of Kanab. No split-estate lands (federal surface, non-federal mineral) are in the 

WSA. The Coral Pink Sand Dunes State Park borders most of the WSA on the west. The Kaibab Indian 

Reservation in Arizona borders the WSA for 5.25 miles on the south, and roads and non-federal lands 

border the unit on the north and east. 

Five distinct landforms comprise the WSA. In the central part are the Vermilion Cliffs, a “step” in the 

Grand Staircase in the southern end of the High Plateaus of the Utah section of the Colorado Plateau 

physiographic province. The north side of the Vermilion Cliffs terrace includes a portion of the Coral 

Pink Sand Dunes and an escarpment above the dunes. The upper part of the WSA is a rocky tableland 

covered with pinyon-juniper woodlands. Elevations range from 5,000 feet in the southeast at the foot of 

the cliffs to 7,000 feet on the top of Moquith Mountain in the southwest corner of the WSA. 

In general the southern portion and parts of the eastern segment of the WSA provide the greatest 

opportunity for solitude. There are several short steep canyons in the cliffs on the western side of Moquith 
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3-108 Kanab RMP 

Mountain and there is the summit of Moquith Mountain where isolation, sandstone outcroppings, and 

ponderosa pine provide screening and opportunities for solitude. Opportunities for primitive and 

unconfined recreation exist within the WSA, including hiking, backpacking, horseback riding, hunting, 

photography, and sightseeing. The WSA includes such features as perennial streams, hanging gardens, 

isolated stands of ponderosa pine and aspen, large alcoves, shifting sand dunes, and prehistoric sites. 

3.4.5 Other Designations 

Designation and management of scenic byways can occur at local, state, or national levels. Because of the 

number of visitors to state and national parks and monuments, the use of these roadways has resulted in 

issues that public land management can address. The following is a description of the seven byways that 

are either entirely or partially included within the decision area (Map 41). 

National Trails 

National Historic Trails are “extended trails which follow as closely as possible and practicable the 

original route or routes of travel of national historical significance” (NPS 2001a). The purpose of the 

National Historic Trails is “the identification and protection of the historic route and its historic remnants 

and artifacts for public use and enjoyment” (NPS 2001a). 

The Old Spanish National Historic Trail, designated December 4, 2002, by the Old Spanish Trail 

Recognition Act of 2002, is a 2,700-mile trade route extending from Santa Fe, New Mexico, to Los 

Angeles, California, passing through the states of Colorado, Utah, Arizona, and Nevada. The trail splits 

into two routes before entering Utah, and continues through the State of Utah within the planning area 

(Map 41). The trail corridor is defined topographically based on local land features because no actual trail 

tread or associated sites have been identified within the decision area. 

The Armijo Route enters Utah north of Page, Arizona, in an area that is now part of Glen Canyon NRA, 

and crosses the Colorado River at the Crossing of the Fathers. The Armijo Route re-enters Arizona along 

Kanab Creek near Fredonia, Arizona. The route then re-enters Utah just west of Colorado City, heading to 

the Virgin River where it continues southwest into Arizona. 

The Northern Route of the Old Spanish National Historic Trail enters Utah near Moab, splits into two 

sections at Fremont Junction, and rejoins near the town of Circleville just north of the planning area. 

From there the Northern Route continues southwest along the Sevier River and U.S. Highway 89, through 

the Markagunt Plateau along SR 20 in the decision area, and into the Parowan Valley, where it heads 

southwest out of Utah to rejoin the Armijo Route south of St. George, Utah. 

National Scenic Byways 

The National Scenic Byways (NSB) Program was established under the Intermodal Surface 

Transportation Efficiency Act of 1991, and reauthorized in 1998 under the Transportation Equity Act for 

the 21st Century. Under the program, the U.S. Secretary of Transportation recognizes certain roads as 

National Scenic Byways or All-American Roads based on their archaeological, cultural, historic, natural, 

recreational, and scenic qualities. All-American Roads must exhibit multiple intrinsic qualities. For a 

highway to be considered for inclusion within the NSB Program, it must provide safe passage for 

passenger cars year-round, it must be designated a State Scenic Byway, and it must have a current 

corridor management plan in place. Installation of offsite outdoor advertising (e.g., billboards) is not 

allowed along byways. There is one All-American Road (SR 12); Garfield County has mobilized the 

effort to nominate Brian Head/Panguitch Lake Byway as a National Scenic Byway. 
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Kanab RMP 3-109 

All American Road – Scenic Byway 12 (State Route 12) 

This 180-mile scenic byway was recently awarded the prestigious designation of All-American Highway, 

the highest designation for any U.S. road. SR 12 is 1 of only 20 All-American Highways in the entire 

nation. From US Highway 89 south of Panguitch, SR 12 winds east through some of the most varied 

scenery in Utah. Beginning in Red Canyon, SR 12 winds through the northern portion of Bryce Canyon 

National Park and the Dixie National Forest, past Kodachrome Basin State Park, through the GSENM and 

its Escalante Canyons, crosses over aspen-covered Boulder Mountain, and ends up in Torrey, just 5 miles 

west of Capitol Reef National Park. Throughout its length, SR 12 intersects the decision area several 

times. In addition, the byway’s scenic viewshed includes portions of the decision area away from the 

constructed road. 

Utah Scenic Byways 

Similar to National Scenic Byways, Utah State Scenic Byways are highways that have been designated by 

official state declaration for their scenic, historic, recreational, cultural, archaeological, or natural 

qualities. The byways are paved roads that are generally safe year-round for passenger cars. Installation of 

offsite outdoor advertising (e.g., billboards) is not allowed along byways. There are four Utah Scenic 

Byways within the planning area. 

Zion Park Byway (State Route 9) 

The 54-mile Zion Park Byway (SR 9) byway extends east from I-15 to meet US Highway 89 at Mount 

Carmel Junction. Between these two points, the byway passes through the valley of the Virgin River and 

winds through Zion National Park. The byway enters the decision area at the eastern boundary of the 

park, where it drops down to Long Valley and the intersection with US Highway 89 at Mt. Carmel 

Junction. 

Markagunt High Plateau Byway (State Route 14 from Cedar City to US Highway 89) 

The Markagunt High Plateau Byway (SR 14) is one of the most traveled areas in southern Utah. Accessed 

off I-15 at Cedar City, this 40-mile byway ascends through a narrow canyon, passes Cedar Breaks 

National Monument, the Ashdown Gorge, and the Zion Overlook. From the summit, the byway continues 

into Dixie National Forest to Cedar Mountain and several points of interest, including Navajo Lake. The 

Markagunt Scenic Byway is known for its cultural, historical, natural, recreational, and scenic attractions. 

Although the byway never crosses the decision area, the area is within the byway’s viewshed. 

Brian Head/Panguitch Lake Byway (State Route 143) 

The 55-mile Brian Head/Panguitch Lake Byway (SR 143) extends from Parowan to Panguitch. 

Ascending to an elevation of 10,000 feet through Parowan Canyon, the route travels past Brian Head 

Resort and Cedar Breaks National Monument. From the Dixie National Forest the byway enters the 

decision area southwest of Panguitch. This byway is currently working toward NSB designation. 

Kanab/Mt. Carmel Byway (US Highway 89) 

From Kanab, the Kanab/Mt. Carmel Byway follows US Highway 89 north through Three Lakes Canyon 

to its junction with SR 12. The road ascends though the Grand Staircase’s White, Pink, and Vermilion 

Cliffs, providing access to Coral Pink Sand Dunes State Park and scenic views of Zion National Park. On 

the northern stretches of the route, the road crosses a forested mountain valley. Red Canyon’s pink cliffs 

and formations are visible on both sides of the road. The 60-mile route ends in the Dixie National Forest’s 
Chapter 3 Proposed RMP and Final EIS 

3-110 Kanab RMP 

Red Canyon. US Highway 89 travels through much of the decision area. The byway’s scenic viewshed 

includes portions of the decision area away from the constructed road. 

Utah Scenic Backways 

State Scenic Backways are roads that do not generally meet federal safety standards for safe year-round 

travel by passenger cars and have been designated by official state declaration for their scenic, historic, 

and recreational qualities. Utah Scenic Backways often require use of four-wheel drive, and road 

conditions vary with factors such as season and weather. There are two Utah Scenic Backways within the 

decision area. 

Johnson Canyon/Alton Amphitheater 

The 32-mile Johnson Canyon/Alton Amphitheater Scenic Backway is in south-central Utah. It begins 9 

miles east of Kanab on US Highway 89 and heads north where it rejoins US Highway 89 at Glendale. An 

alternate route extends north to Alton, 9 miles north of Glendale. The backway travels through much of 

the eastern part of the decision area, forming a portion of the boundary with the GSENM. 

Ponderosa/Coral Pink Sand Dunes 

Ponderosa/Coral Pink Sand Dunes Scenic Backway provides a 12-mile scenic drive in southwest Utah. It 

begins at the junction of Hancock Road with US Highway 89 about 7 miles north of Kanab. The backway 

heads south through the decision area, connecting with Yellowjacket Road and continuing south to Coral 

Pink Sand Dunes State Park. 

BLM Back Country Byways 

The Back Country Byway Program was developed by the BLM to complement the National Scenic 

Byway Program. These byways highlight the spectacular nature of the western landscapes. Back Country 

Byways vary from narrow, graded roads that are passable only during a few months of the year to twolane paved highways with year-round access. There are no BLM backcountry byways or backways in the 

decision area. 

3.5 SOCIAL AND ECONOMIC FEATURES

The following sections include discussions of socioeconomic conditions, Native American religious 

concerns, and hazardous materials and public safety. The discussion of socioeconomic conditions 

includes a short summary of the Socioeconomic Baseline Report (BLM 2005b). Native American 

religious concerns are discussed in detail and include information on tribal interests in the planning area, 

noting features not described in the cultural resources section, such as treaty-based subsistence uses, 

traditional use areas, and rights of access. Hazardous materials and public safety are addressed by 

identifying hazardous materials or hazardous waste disposal facilities. 

3.5.1 Socioeconomic Conditions 

Much of the socioeconomic data available for this study is available only at the county level; therefore, 

the socioeconomic study area is defined as all of Garfield and Kane counties. When the data or 

information presented are specifically for the planning area, this is noted. Map 42 shows the boundaries of 

the socioeconomic study area and the planning area, as well as key features such as land ownership and 

local communities. More detail on socioeconomics, in addition to the information in this section, is 

provided in the Socioeconomic Baseline Report. Garfield and Kane counties share prehistory, settlement 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-111 

patterns, history, culture, and economics. The first non-Indian historic communities in the socioeconomic 

study were Kanab and Panguitch, which were settled in the mid 1860s by Mormon pioneers, then 

abandoned, and resettled in the early 1870s. A few years after Panguitch was resettled, settlers began 

moving eastward, founding smaller settlements, including Escalante in 1876, and Boulder, the most 

isolated town in Utah until the mid-1930s when the Escalante Road was constructed. Both counties in the 

socioeconomic study area have ties to the pioneers who settled the area, and the influence of these 

pioneers remains strong today. 

Historically, settlers used the vast rangeland to raise livestock. Garfield County also developed a large 

lumber industry, which remains important to the county today. In the 1920s and 1930s Kane County 

catered to film production and was called “Little Hollywood.” About the same time, the establishment 

and development of national parks brought tourism to both counties. The service and tourism industries of 

Kane County, and to a lesser extent Garfield County, increased further with the Glen Canyon Dam project 

and the creation of Lake Powell. Tourism has become an increasingly important component of the local 

economy, with greater access and greater national interest in the natural beauty of southern Utah. 

The socioeconomic study area is sparsely populated because of its isolation, aridity, and ruggedness. 

Garfield County averages less than one person per square mile, making it the least dense county in Utah. 

The entire study area is only slightly more dense, and is considerably less dense than the state as a whole 

(27.2 persons per square mile). 

Historical population data for each county and the socioeconomic study area from 1940 to 2005 and 

population projections from 2010 to 2030 are plotted in Figure 3-12. From 1970 to 2003, Kane County’s 

population increased by 3,487—a 142 percent increase, Garfield County’s population increased by 44 

percent, and the study area’s population increased by 87 percent. Kane County’s population increased 

faster than the state and the national growth rate; Garfield County’s population increased more slowly 

than the state’s but outpaced that of the nation (EPS 2005). Kane County’s population overtook that of 

Garfield County, reflecting growth that resulted from Kane County’s proximity to the growth center of St. 

George, Utah. However, according to the latest population estimates from the Utah Governor’s Office of 

Planning and Budget, Garfield County experienced a modest population decline (118 persons, or 2 

percent) from 2000 to 2005, while Kane County’s population growth flattened considerably. The State of 

Utah expects growth rates in both counties to continue at historic 1970 to 2000 rates, and to continue 

growing at those rates through the RMP planning period. 

Kane County had a positive net migration rate of 12.1 percent in the 1980s and the same rate in the 1990s, 

which means more people moving into the county than leaving. Conversely, Garfield County experienced 

negative net migration, which means more people moving out than coming in. However, Garfield 

County’s percentage of people moving out relative to moving in decreased during the 1990 to 1999 period 

to negative 0.3 percent, compared with negative 5.8 percent from 1980 through 1989. 
Chapter 3 Proposed RMP and Final EIS 

3-112 Kanab RMP 

Figure 3-12. Socioeconomic Study Area Population Trends and Projections 

-

2,000

4,000

6,000

8,000

10,000

12,000

14,000

16,000

18,000

1940 1945 1950 1955 1960 1965 1970 1975 1980 1985 1990 1995 2000 2005 2010 2015 2020 2025 2030

Years

Population

Study Area

Kane 

Garfield 

Note: Dashed lines indicate population projections by the State of Utah for 2005 to 2030. Values for 2015 and 2025 are straight-line 

interpolations of 2010, 2020, and 2030 projections. All other data points are from the source. 

Source: Utah Governor’s Office of Planning and Budget (2004a), State of Utah Demographic and Economic Analysis, Utah 

Population Estimates Committee 

In the socioeconomic study area there is little land that is privately owned. Most (88 percent) is 

administered by the Federal Government. The BLM manages the largest portion of federal land in the 

socioeconomic study area (2.69 million acres), USFS manages 1.16 million acres, and NPS manages 0.89 

million acres. 

A statewide social survey was conducted by Utah State University (USU) in 2007 to assess the ways in 

which Utah residents use and value public land resources and their views about public lands management. 

A complete analysis of the results had not been completed as of February 2008. “Public lands,” as 

described in the study, consist of not only BLM, but all federal and state managed lands. Surveys were 

mailed to a random sample of residents of all 29 Utah counties. According to the authors, the study and 

sample sizes are designed to produce results generalizable at the statewide level, with generalization 

increasingly risky as the sample area diminishes. For example, the data may lose much of its 

generalizability at the individual county level, but increase as additional counties are aggregated into the 

sample. The areas sampled do not necessarily coincide with field office planning area boundaries, because 

that was not the focus of the study. Nonetheless, the study provides current and interesting results not 

available elsewhere, and shows the dependence of local communities on public lands for a variety of 

economic and recreational pursuits. Appendix 10 contains initial summary results for Kane and Garfield 

counties lying within the Kanab Field Office. There is nothing in the preliminary USU results that affect 

the formulation of alternatives in Chapter 2 or the analysis of impacts in Chapter 4. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-113 

Economic Characteristics 

Levels of and changes in the labor force and unemployment provide information on the relative health of 

the local economy. Kane and Garfield counties, as well as the state as a whole, showed increases in the 

labor force over the 10-year period from 1994 to 2003, but the socioeconomic study’s annual average rate 

increase in the labor force (0.6 percent) was lower than the state’s (1.7 percent). From 1990 to 2003, the 

unemployment rate for the study area was higher than that for the state and nation, and showed more 

volatility (fluctuation) throughout the 1990s. The average unemployment rate for the 14-year period was 

7.9 percent for the study area, 4.2 percent for Utah, and 5.6 percent for the United States. 

Total personal income was more than $230 million in 2002, an increase of more than $60 million 

(inflation adjusted) since 1992. This represents a total real personal income growth of 3.5 percent 

annually over 10 years. Labor income has consistently accounted for the greatest percentage of personal 

income for the study area; however, non-labor income has increased substantially in importance over 

recent decades.1 The percentage of total personal income derived from labor decreased considerably from 

75 percent in 1970 to 59 percent in 2002. The annual percentage increase in labor income over this period 

was 2.9 percent, but investment income and transfer payments grew at faster annual rates, increasing by 

5.1 percent and 5.3 percent, respectively. These trends are similar to state and national trends. 

The distribution of income by industry provides a good indication of the relative economic importance of 

various industries in the socioeconomic study area. Figure 3-13 and Figure 3-14 show trends in labor 

wages and salaries for nine industry groups from 1980 to 2000. In both counties, the services sector and 

the government sector provided the greatest amounts of wages and salaries in the study area, and both 

show substantial upward trends. In Garfield County, both mining and construction earnings declined 

substantially in the early 1980s, and have not gone back up. In Kane County, the trade industry has 

provided substantial and increasing amounts of wages and salaries. Manufacturing declined in Garfield 

County in the early 1990s, but increased substantially in Kane County in the late 1990s. Agricultural 

wages and salaries have been volatile in both counties, including some periods of negative earnings. 

Wages and salaries from other sectors have been relatively low, and essentially flat, over the 2-decade 

period. 

 

1 Personal income consists of labor and nonlabor income. Labor income is derived from wages, salaries, and self-employment 

income. Nonlabor income includes investment income and transfer payments. Investment income is gained from rents, 

dividends, and interest earnings. Transfer payments are largely derived from social security benefits, Medicare and 

Medicaid benefits, and other income support and assistance. 
Chapter 3 Proposed RMP and Final EIS 

3-114 Kanab RMP 

Figure 3-13. Trends in Wages and Salaries by Industry for Garfield County, 1980–2000 

$(2,000)

$-

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

$16,000

$18,000

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

Year

Thousands of 2002 Dollars

Farm & Ag Services

Mining

Construction

Manufacturing

TCPU

Trade

FIRE

Services

Government

TCPU is Transportation, Communication, and Public Utility employment. 

FIRE is Finance, Insurance, and Real Estate employment. 

Farm & Ag Services data were not available for 1987,1988,1998–2000. Data gaps are due to data disclosure restrictions of the 

Bureau of Economic Analysis. 

Non-agricultural industries source: State of Utah Governor’s Office of Planning and Budget 2004b. 

Farm & Ag Services source: EPS (2005), using U.S. Department of Commerce Bureau of Economic Analysis data (Regional 

Economic Information System 2002 CD Table CA05). 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-115 

Figure 3-14. Trends in Wages and Salaries by Industry for Kane County, 1980–2000 

$(2,000)

$-

$2,000

$4,000

$6,000

$8,000

$10,000

$12,000

$14,000

$16,000

$18,000

$20,000

1980

1981

1982

1983

1984

1985

1986

1987

1988

1989

1990

1991

1992

1993

1994

1995

1996

1997

1998

1999

2000

Year

Thousands of 2002 Dollars

Farm & Ag Services

Mining

Construction

Manufacturing

TCPU

Trade

FIRE

Services

Government

TCPU is Transportation, Communication, and Public Utility employment. 

FIRE is Finance, Insurance, and Real Estate employment. 

Farm & Ag Services data were not available for 1987,1988, 1998–2000. Data gaps are due to data disclosure restrictions of the 

Bureau of Economic Analysis. 

Non-agricultural industries source: State of Utah Governor’s Office of Planning and Budget. 

Farm & Ag Services source: EPS (2005), using U.S. Department of Commerce Bureau of Economic Analysis data (Regional 

Economic Information System 2002 CD Table CA05). 

Demographic Characteristics 

The ethnic makeup of the socioeconomic study area is predominantly white (95.5 percent in the 2000 

census), as it is for the state (89.2 percent). Garfield and Kane counties are similar in ethnic makeup, and 

there are only slight differences in ethnic composition between the study area and the state. The study 

area has a higher percentage of whites and a smaller percentage of Hispanics or Latinos than the state. 

The percentages of other ethnic groups in the study area are small and similar to those of Utah as a whole. 

The median household income in the 2000 census was $32,400 in Garfield County and $31,500 in Kane 

County, compared with $42,100 for the state and $38,700 for the nation. However, median household 

income increased more rapidly during the 1990s in the socioeconomic study area (105 percent) compared 

with the state (96 percent) and the nation (76 percent). 

Both counties had a higher rate of individuals below the poverty level than did the state and the nation in 

the 1990 census. However, in the 2000 census, poverty rates in Garfield County (8.1 percent) and Kane 

County (7.9 percent) were less than those of the state (9.4 percent) and the nation (12.4 percent). 
Chapter 3 Proposed RMP and Final EIS 

3-116 Kanab RMP 

The median age for individuals in Garfield County in the 2000 census was 33.8 years, which is an 

increase from 31.3 years in the 1990 census. Kane County’s median age in 2000 was 39.1 years—a 

substantial increase from 30.8 years in 1990. Both counties have a higher median age than Utah (27.1 in 

2000). Kane County’s median age is also higher than that of the nation (35.3 in 2000). The high figure 

and sharp increase in median age for Kane County can be explained by the spillover of retirees migrating 

to the St. George area. 

Resource Uses and Values 

The Forestry and Woodland Products section of this chapter provides details about these uses of BLM 

lands. There are no commercial saw timber operations within the decision area. There is limited 

commercial and non-commercial harvesting of fuelwood. The KFO sold an average of 560 cords of wood 

per year in 2001 through 2004. In addition, there is harvesting for Christmas trees and posts. 

Calculation of the value of livestock grazing within the decision area is based on the 5-year average of 

authorized AUMs since management has been tracked (2000 through 2004; see the Livestock Grazing 

section of this chapter), and assumes that all authorized AUMs were in fact used. Authorized AUMs in 

this period averaged 7,239 for cattle, and 153 for sheep and goats. The average value of production per 

AUM in 2003 dollars for the State of Utah is $41.22 for cattle AUMs and $22.93 for sheep AUMs, based 

on the methodology described in the Socioeconomic Baseline Report. Applying these values to the 

authorized AUM figures shows that the average value of production for livestock grazing within the 

decision area in recent years is $298,400 for cattle and $3,500 for sheep and goats, or $301,900 total. 

Combined with information on livestock production across the entire socioeconomic study area, these 

data show that 2.6 percent of the most recent 5-year annual average of cash receipts for livestock and 

livestock products ($11,502,000) can be attributed to grazing on BLM lands. However, this small 

percentage figure may not reflect the full significance of grazing on BLM lands. For example, this grazing 

could be critical to certain operators at certain times of the year when other forage or feed is unavailable 

or expensive. 

The Recreation section of this chapter provides information on recreational use within the decision area. 

The BLM’s RMIS database of recreational activity data indicate that during 2001 through 2006, the 

activities with the most participants were (in descending order) OHV use, big game hunting, 

hiking/walking/ running, backpacking, and viewing. The activities with the highest visitor-days (12 hours 

of activity) were (in descending order) backpacking, big game hunting, OHV use, camping, and 

hiking/walking/running. The RMIS data show a peak in overall visitation in federal Fiscal Year 2002, 

followed by 3 years of somewhat lower, but increasing use. Total visitor numbers increased to a peak in 

2006, and visitor-days were near peak in Fiscal Year 2006. 

Other recreational visitation numbers for the socioeconomic study area have declined in the past several 

years, mirroring trends for the state and nation. Figures from the Utah Division of Travel Development 

(2005) indicate visitation to most state and national parks in the study area peaked during 1999 through 

2000, and in most cases has declined since. The State Division of Parks and Recreation (2003) attributes 

these recent decreases in visitation to slumping global economy and decreased tourist travel following the 

September 11, 2001, terrorist attacks. The state also notes that despite the decrease in visitation, 

recreation- and tourism-related sectors have substantial potential for growth. Long-term increases in 

recreation visits are likely as a result of projected state and regional population growth, interest in the 

world-class recreational resources of southwestern Utah, and an aging population that will demand 

increased opportunities for leisure and recreation. 

Recreation is an important part of the local economy. When non-local recreationists come to the area, 

their expenditures within the area represent inflows of money, which generate jobs and income. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-117 

Recreation-related expenditures especially support the services sector, which is the second-largest sector 

of the local economy, for wages and salaries in both Garfield and Kane counties, as shown in the figures 

above. The Utah Division of Travel Development (2005) estimates that there were 1,916 travel- and 

tourism-related jobs in the socioeconomic study area in 2003. According to the division, 44 percent of 

total employment in Garfield County was in tourism-related jobs, and 37 percent in Kane County. The 

division estimates that travelers spent a total of $82.9 million in the study area in 2003, resulting in $1.7 

million in tax revenues to local governments. Recreational use of BLM public lands is no doubt the basis 

for an important component of this economic activity. 

Lands and realty actions and policies, detailed in the Lands and Realty section of this chapter, have 

important socioeconomic effects. Land disposals, ROWs, leases, permits, and easements allow for 

economic activity and community expansion and may further the economic development of communities 

within the planning area or serve other important social purposes. Withdrawals and land acquisitions may 

protect important resources of economic or social significance to the public. 

Lands and realty actions also have important implications to public finance. Disposal of BLM lands to 

private ownership may reduce Payments in Lieu of Taxes (PILT) by the Federal Government to local 

government, but also may result in payments of property taxes to local government by the new private 

property owner(s). Acquisition of private land by the BLM would reduce property taxes paid to local 

governments, but would typically increase PILT payments. 

Mineral and energy development on lands and federal mineral estate managed by the KFO currently 

includes 23 authorized oil and gas leases on 65,500 acres. Drilling activity has declined steadily since the 

1960s, with only one well drilled on federal property in the 1990s. There is some renewed interest in oil 

and gas in the area, but there are presently no APDs. Most of the 30 previous leases for coal development 

were closed out in the 1980s and 1990s. Currently there are no authorized coal leases, although one 

request has been filed. There are 11 active mining claims, 1 active notice, and 1 active plan of operations 

for locatable minerals. For mineral materials (e.g., sand and gravel), 10 free use permits are active, and 75 

to 100 over-the-counter permits are issued each year. The Minerals and Energy section of this chapter 

provides additional information on these uses, and the Socioeconomic Baseline Report provides 

information on economic values. 

Lands in the decision area contribute to the livelihoods of area residents through subsistence uses as well 

as through market-based economic production and income generation. Public lands provide products of 

value to households at no or low cost (permit fees). These products include fuelwood, Christmas trees, 

wood posts, livestock raised for household consumption, pine nuts, and mineral materials such as sand 

and gravel. Additional products with subsistence value may include fish, game, plants, berries, seeds, and 

more. Products of BLM lands are of special value to low-income households. In addition, use of these 

products is often part of family traditions and it sustains local culture. 

Public Finance 

Lands and federal mineral estate managed by the KFO affect local, state, and Federal Government 

budgets to the extent they produce mineral royalties, taxes, PILT, fees, and other revenues, or result in 

government expenditures for management, law enforcement, and other activities. This topic is discussed 

in detail in the Socioeconomic Baseline Report and summarized below. 

The Federal Government’s Minerals Management Service collects royalties and rents from leases of 

federal lands for production of coal, oil, gas, and other minerals. The Minerals Management Service also 

collects bonuses on certain leases. The federal mineral estate in the socioeconomic study area produces 

low mineral revenue compared with that in other parts of Utah. In state Fiscal Year (July 1–June 30) 
Chapter 3 Proposed RMP and Final EIS 

3-118 Kanab RMP 

2004, Garfield County generated $604,000 in oil and gas royalties, rents, and bonuses and Kane County 

generated $194,800. The entire state generated $134.4 million. 

The KFO collects fees and other revenue for a variety of other uses of BLM lands. These revenue sources 

include ROW rents, recreation fees, grazing fees, various permit fees, and more. Most of the revenues 

from sales of land and vegetative materials, along with ROW rents, go to the federal treasury, but 

recreation fees are retained by the KFO. A portion of the revenue generated from mineral material permits 

is returned to the county of origin. Section 3 grazing permit fees associated with federal AUMs generate 

revenue for the U.S. Treasury, of which 12.5 percent is returned to the local Grazing Board via the state in 

which the AUMs are located. This money is then disbursed to local ranchers through the local Grazing 

Board, using a 40/60 matching-funds formula, for use in range improvements and maintenance projects 

(See Taylor Grazing Act Section 10). 

Fifty percent of federal revenues from oil and gas royalties, rents, and bonuses are returned to the state of 

origin. In Utah, these revenues are channeled through the Utah Department of Community and Economic 

Development to various state funds and other state and local agencies. In the State of Utah’s fiscal year 

2004, Utah received $399,400 generated by the federal mineral estate in Garfield and Kane counties. 

The State of Utah collects several taxes and fees that derive from natural resources on both private and 

public lands. These include the mining severance tax, oil and gas severance tax, oil and gas conservation 

fee, and income taxes on mineral production income. Due to the relatively low level of mineral and 

energy development in the socioeconomic study area, the state earns minimal revenue from its taxes and 

fees. 

Much of the state’s federal oil and gas royalty, rent, and bonus revenue is disbursed to local governments. 

The primary means for the disbursements are through the Utah Department of Transportation (UDOT), 

the Permanent Community Impact Fund, and the Special Service Districts Fund. Only the UDOT funds 

are directly proportional to the federal mineral revenue produced by each county. In State of Utah fiscal 

year 2004, Garfield County received $148,900 through UDOT; Kane County received $53. Kane County 

generated primarily bonus revenue, which unlike royalty and rental revenue is deposited into state 

discretionary funds rather than the “pass-through” UDOT fund. 

Another source of local funds based on natural resources is taxes on natural resource properties. Local 

governments assess real and personal property, but the State of Utah assesses the value of natural resource 

property, specifically oil and gas wells, metal mines, coal mines, sand and gravel mines, and non-metal 

mines. County treasurers then set and collect taxes from these properties. On public lands, the values and 

taxes are based on the higher of (a) the value of equipment on the site or (b) discounted cash flow from 

production if the well or mine is producing. These properties may be located on either private or public 

land. Table 3-37 shows the amounts collected by the socioeconomic study counties in 2003. These figures 

reflect all lands in the two counties; a breakdown for BLM lands is not available. The total local taxes 

charged against natural resource properties in the study area were about $154,400 in 2003, which 

represents 1.5 percent of the $9,949,000 in total local property taxes collected in the socioeconomic study 

area. 

Table 3-37. Local Property Taxes Charged Against Natural Resource Properties, 2003 

County Oil and Gas 

Extraction 

Metal 

Mines 

Coal 

Mines 

Sand and 

Gravel 

Non-Metal 

Mines 

Total 

Natural 

Resource 

Garfield County $67,885 $53,556 $0 $8,582 $0 $130,023 

Kane County $0 $0 $0 $19,670 $4,673 $24,342 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-119 

County Oil and Gas 

Extraction 

Metal 

Mines 

Coal 

Mines 

Sand and 

Gravel 

Non-Metal 

Mines 

Total 

Natural 

Resource 

Study Area $67,885 $53,556 $0 $28,252 $4,673 $154,365 

Source: Utah State Tax Commission (2004), 2003 Annual Statistical Report, Local and Centrally Assessed Property 

A source of local government revenue directly attributable to the public lands in each of the counties is 

PILT. PILT payments are made by the Federal Government to compensate counties for lost property tax 

revenue attributed to federal lands. PILT payments to Garfield and Kane counties in recent years are 

shown in Table 3-38. In Fiscal Year 2004, PILT payments for all federal lands in the two counties totaled 

nearly $942,000. These payments cannot be readily attributed to BLM versus other federal lands. 

Table 3-38. Payments in Lieu of Taxes, 1999–2004 

County 1999 2000 2001 2002 2003 2004 

Garfield 

County $209,702 $224,873 $357,580 $375,382 $416,983 $428,693 

Kane County $274,860 $342,723 $420,052 $432,522 $499,106 $513,297 

Study Area $484,562 $567,596 $777,632 $807,904 $916,089 $941,990 

Source: BLM (2004b), Payments in Lieu of Taxes website, Total Payments and Total Acres by State/County 

Federal Government expenditures related to federal lands benefit the local economy because federal 

salaries to land management staff who reside in the socioeconomic study area and federal contracts to 

businesses located in or with employees residing in the study area represent inflows of money to the study 

area. During the federal Fiscal Years 2001 through 2004, total KFO salaries averaged $803,500 per year. 

During the same period, the KFO paid an average of $179,600 per year in contracts to local firms. 

Management of BLM-administered land may affect state and local budgets. For example, recreation on 

public lands requires some support from local government for road maintenance, law enforcement, and 

search and rescue. It is difficult to separate expenditures related to BLM-administered land from 

expenditures related to other land. Additional types of state and local expenditures that may be affected 

by public land use include emergency medical services, wildlife management, fire management, solid 

waste collection and disposal, and public utilities. 

Environmental Justice 

EO 12898, Federal Action to Address Environmental Justice in Minority Populations and Low-Income 

Populations, requires federal agencies to identify and address disproportionately high and adverse human 

health and environmental effects of federal programs, policies, and activities on minority and low-income 

populations. 

Relevant census data for the two counties within the socioeconomic study were collected to determine 

whether populations residing in the study area constitute an “environmental justice population” by 

meeting either of the following criteria: 

• At least one-half of the population is of minority or low-income status 

• The percentage of population of minority or low-income status is at least 10 percentage points 

higher than for the entire State of Utah. 
Chapter 3 Proposed RMP and Final EIS 

3-120 Kanab RMP 

As shown by the figures in the Demographic Characteristics section of this chapter, neither county has 

populations that meet either criterion. Thus, at the county level, no populations within the study area meet 

the criteria to be subject to environmental justice considerations. It is possible that some highly localized 

minority or low-income populations exist. 

Although not in the socioeconomic study area of Kane and Garfield counties, Utah, the Kaibab-Paiute 

Tribe reservation is adjacent to the planning area along the Utah-Arizona border. In July 2005, the 

Kaibab-Paiute Tribe signed a memorandum of agreement (MOA) formalizing cooperating agency status 

with the KFO. 

The Kaibab-Paiute Tribe reservation is within the Kaibab census-designated place. According to Census 

data from 2000, more than half of the population in the Kaibab CDP, 54.9 percent, was American Indian, 

with 43.6 percent being white. Most whites, 58.2 percent, live in the community of Moccasin, which is 

not on reservation lands. 

The Kaibab-Paiute Tribe also had a very high individual poverty rate at 31.6 percent, a high family 

poverty rate at 29.7 percent, and a low per capita income at $7,951. Family size did not seem to play an 

important role in the tribe’s poverty rates and low per capita income. The tribe’s average family size was 

3.51, only slightly higher than the national average. 

Values and Attitudes 

Today, although fewer families earn their livelihood solely from livestock production or natural resources 

such as timber and minerals than in previous times, the descendents of the area’s settlers still have strong 

connections to the land. Access to public land and resources, whether for earning a living or for recreating, remains important to the local people. These connections to the land are as obvious as the 

cultural importance of livestock grazing and as subtle and unknown (to non-residents) as the tradition of 

“Eastering,” in which local families at Easter time roll eggs down sand hills, the winner declared by 

having the last egg to break. 

Economic and social connections to public land use were often mentioned in the public scoping process 

for the RMP, which occurred in early 2005. Comments were often related to OHV use and route 

designations, livestock grazing, recreation, and general access to public lands. Many of those who made 

comments were concerned that increased restrictions would lead to a change in their traditional use of the 

public lands surrounding their communities. Many also expressed a desire to maintain or expand the local 

economies by allowing the most economically beneficial resource uses to occur. Some of the resource 

uses mentioned to have economic benefits included mineral development, grazing, tourism, and OHV 

use. 

Some respondents identified public land use as a way of life for local communities. In particular, many of 

these individuals felt that it was important that grazing on public lands be recognized as a historically 

important use of land that is worth preserving. There were comments that differed from this point of view 

in terms of the sustainability of grazing on public lands, but no individuals or groups denied the historical 

importance of grazing. 

Some individuals indicated that management decision processes were not accounting for costs associated 

with some resource uses. Among the costs mentioned were environmental remediation for mineral 

development sites, range management for livestock grazing, and management for OHV use. In addition to 

management costs, many respondents raised concerns about the environmental impacts of many activities 

on public lands. These concerns were voiced by individuals residing within and outside the 

socioeconomic study area. Given the statewide and national significance of resources in the decision area, 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-121 

many individuals outside the socioeconomic study area have strong values and attitudes about the 

management of BLM-administered lands. Other common concerns indicated perceived conflicts between 

motorized and non-motorized uses, between resource development and primitive recreational experiences, 

and between other uses of public lands. 

Interests in BLM Lands 

Based on economic and social connections to BLM lands, several broad types of use are defined for the 

purposes of social impact analysis in Chapter 4. These categories reflect the many different interests that 

exist in use of BLM lands, and are characterized by a distinct set of opinions and perceptions about BLM 

lands and the effects of various land management policies and actions. To some degree these categories 

can be aligned with different social groups, but at the same time, many specific individuals or 

organizations may have multiple interests and would probably view themselves as being classified into 

more than one category. Seven types of interest have been defined for consideration in the impact 

analysis, as follows: 

• Local traditional use—People who would see themselves as having this interest in public lands 

include individuals who place a high value on using BLM lands to gather fuelwood, Christmas 

trees, wood posts, pine nuts, and other products for personal use or small-scale commercial 

purposes. Typically these people are local residents. Such gathering often helps supplement and 

stretch household incomes. In addition, these activities preserve family traditions and sustain 

local culture. This interest category also encompasses Sunday afternoon drives and other 

dispersed uses and enjoyment of BLM land by local residents. 

• Motorized recreation—This category includes individuals and groups with interests in both onand off-highway motorized uses. The first type includes road-based sightseeing, often referred to 

as “windshield tourism,” such as tour buses and automobile tourists who drive primary and 

secondary roads, stopping occasionally to take in special sights or in local towns for gas or food. 

The second type of motorized recreation includes OHV use, which is often categorized as 

“destination tourism,” in which the travelers have in mind activities at specific locations, and 

often stay in the locale for multiple days, generally resulting in larger local expenditures. 

• Non-motorized recreation—Individuals and groups with this interest engage in hiking, 

backpacking, horseback riding, mountain-biking, and other activities based around non-motorized 

off-road travel. Often this interest is characterized by a search for solitude or escape from 

developed sites, machines, and other aspects of day-to-day life. This interest typically reflects 

“destination tourism.” 

• Outfitter-based recreation—The primary distinguishing characteristic of this category of use and 

interest is the hiring of second parties—outfitters or guides—as a way to improve the 

recreationist’s experience. Typically, but not always, this is related to hunting. The hiring of 

outfitters or guides results in additional local expenditures, and is a special case of “destination 

tourism.” 

• Livestock grazing—People with interests in this category often believe that livestock grazing on 

public lands is important not only economically but also culturally and socially. People sharing 

this interest want to support the livelihoods and traditions associated with grazing and ranching, 

which they view as central to the vitality and values of local communities. 

• Natural resource development—This interest encompasses commercial development and use of 

the resources found on BLM lands. Individuals and groups with this interest support mining, 

timber harvesting, and other traditional resource uses, and believe that the income and jobs 

generated by these activities are crucial to the local economy. 

• Preservation—People aligned with the preservation interest tend to value and prioritize the 

protection of natural resources and general ecosystem health. This can include both local 

residents and non-locals who emphasize the special scenic and ecological values of the area. 
Chapter 3 Proposed RMP and Final EIS 

3-122 Kanab RMP 

3.5.2 Tribal Interests 

Archaeological evidence indicates the natural resources in the decision area have been used by Native 

Americans for thousands of years by a wide variety of cultural traditions (see Chapter 3 Section 3.2.9 – 

Cultural Resources). Many contemporary Native American tribes maintain they are descents of the 

peoples who once occupied this area, including but not limited to the Southern Paiute, Navajo, Hopi, Ute, 

and Zuni Tribes. Because of this traditional connection, many of these tribes hold a deep interest in the 

decision area’s resources, as well as the use of those resources. However, strong place attachments 

can occur whether or not direct lineage is established (Stoffle et al. 2004). 

Bands of the Southern Paiute Tribe most recently inhabited and used the area prior to European 

settlement. Spangler (2001) summarizes both the archaeological and ethnographic evidence of the 

Southern Paiute’s use of the GSENM and the surrounding areas, which include the decision area. The 

Bands of the Southern Paiute Tribe reservations were all created by Executive Order between 1873 and 

1917. Supreme Court cases have affirmed that, “all Executive Order tribes shall have and be treated as 

Treaty tribes.” These Executive Orders established the Kaibab Paiute, Shivwits, Moapa, and Las Vegas 

reservations. The Kaibab-Paiute Reservation is located entirely within Arizona and is surrounded 

by the BLM’s Arizona Strip FO on the west, south and east. The State of Utah forms the 

reservation’s northern boundary, with the majority of the land along the boundary within decision 

area. The Kaibab-Paiute Tribe has requested that some lands in the decision area, along the 

state boundary, be made available for disposal to the Tribe.

General areas, specific species, and/or specific sites could be important to contemporary Native American 

tribes for their traditional uses, or their sacred or religious/spiritual association. Archaeological remains of 

prior Native American cultures, especially burials, rock art, and habitations, are often 

religiously/spiritually significant to current tribes. In addition, the physical resources of the area can be 

important for both traditional uses (e.g., continuing traditional gathering of ceremonial or subsistence 

vegetation, use of areas for ceremonial purposes) and for association with use by prior Native American 

cultures (e.g., springs and water sources, areas important due to a concentration of important resources). 

These areas/sites are generally not known or discussed outside of the affected community but may be 

present in the decision area. 

Historical Native American consultation efforts, as well as the consultation efforts associated with this 

planning effort, have not identified specific areas or resources of Native American religious concern in 

the decision area. This includes traditional cultural properties, treaty-based subsistence use areas, 

traditional use areas, and rights of access. A recent ethnography was conducted by the GSENM for the 

Paiute Tribe (Stoffle et al. 2001). Although this ethnography did not include lands in the planning area, 

one of its key findings is that water plays an important part in the Paiute’s life and beliefs. This is 

supported by Spangler’s (2001) research for the GSENM Class I cultural overview. Springs and rivers 

provided the water and other resources that the Paiute depended on for survival. Sources of water, 

specifically springs, are a potential area of Native American religious concern. In addition, contemporary 

Native American tribes are sensitive to disturbance and loss of archaeological sites, as many tribes 

maintain these sites are evidence their progenitors and could therefore be religiously/spiritually 

significant. 

The Kanab Field Office coordinates and officially consults regularly with these various Native American 

tribes/groups to identify and consider their concerns in BLM land use planning and decisionmaking. 

Further consultation (as part of this planning effort and during implementation of the RMP) will be 

required to identify and protect specific sites or areas. 
Proposed RMP and Final EIS Chapter 3 

Kanab RMP 3-123 

3.5.3 Hazardous Materials and Public Safety 

There are no known occurrences of hazardous materials or approved hazardous waste disposal facilities 

within the decision area. Hazardous materials are defined as any material that, because of its quantity, 

concentration, or physical or chemical characteristics, may pose a real hazard to human health or the 

environment. Hazardous materials include flammable or combustible material, toxic material, corrosive 

material, oxidizers, aerosols, and compressed gases. 

Management of hazardous materials, substances, and waste (including storage, transportation, and spills) 

will be conducted in compliance with 29 CFR 1910, 49 CFR 100-185, 40 CFR 100-400, Comprehensive 

Environmental Response Compensation and Liability Act, Resource Conservation and Recovery Act, 

Superfund Amendment Reauthorization Act, Toxic Substances Control Act, Clean Water Act, and other 

federal and state regulations and policies regarding hazardous materials management. 

Databases of previous mining operations exist for the decision area, but no formal inventories for 

abandoned mine lands have occurred. Because of previous mining operations throughout the decision 

area, there is a potential for physical safety hazards and/or environmental issues. 
Chapter 3 Proposed RMP and Final EIS 

3-124 Kanab RMP 

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 Introduction 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-1 

CHAPTER 4—ENVIRONMENTAL CONSEQUENCES OF 

THE PROPOSED KANAB RESOURCE 

MANAGEMENT PLAN 

4.1 INTRODUCTION

This chapter evaluates potential environmental impacts that could occur from implementing the Proposed 

Resource Management Plan (RMP) described in Chapter 2. Potential impacts considered in this chapter 

include ecological (such as the effects on natural resources and on the components, structures, and 

functioning of affected ecosystems), aesthetic, historic, cultural, economic, social, and health impacts (40 

Code of Federal Regulations [CFR] 1508.8). The baseline used to determine the potential impacts is the 

current resource condition described in Chapter 3. 

4.1.1 Organization of Chapter 4 

The impact analysis is organized by resource program and discloses the potential impacts on each 

resource program from implementing the Proposed RMP. Although a resource or resource use is not 

specifically identified, the impacts from these are discussed. For example, vegetation treatments are 

proposed under soil resources, water resources, vegetation, and livestock grazing management decisions; 

however, the impacts from vegetation treatments are referred to collectively. Similarly, in the alternatives, 

restrictions are placed on oil and gas leasing by a number of resources, such as areas of environmental 

concern (ACEC), non–Wilderness Study Area (WSA) lands with wilderness characteristics, special status 

species, and fish and wildlife resources. However, where possible, the impacts that would result from 

these restrictions are grouped and addressed collectively. 

The introductory section of each resource program establishes the scope of the analysis, describes the 

general types of impacts discussed in the analysis, and presents the assumptions associated with that 

resource program that were used throughout the analysis. Impacts on each resource program from 

implementing the Proposed RMP are grouped by impact type. Following analysis of each resource, a 

summary of the impacts from the Proposed RMP is presented, as well as disclosure of potential 

irreversible and irretrievable commitment of resources, unavoidable impacts, and the relationship between 

local, short-term uses and long-term productivity. The chapter concludes with a discussion of cumulative 

impacts, organized by resource program. 

4.1.2 Types of Impacts 

The following analysis focuses on identifying types of impacts and estimating their potential effects on 

the resources, resource uses, special designations, and support programs. This chapter uses the terms 

impacts and effects interchangeably and the terms increase and decrease for comparison purposes. The 

terms used to describe impacts are presented in Table 4-1. Cumulative impacts and methodologies used in 

the cumulative analysis are discussed in Section 4.6. 

Table 4-1. Types of Impacts 

Type Description 

Direct Impacts 

Effects that are caused by the action and occur at the same time and place. Examples include 

elimination of original land use through erection of a structure. Direct impacts may cause 

indirect impacts, such as ground disturbance resulting in suspension of dust. 
Introduction 

Chapter 4 Proposed RMP and Final EIS 

4-2 Kanab RMP 

Type Description 

Indirect Impacts 

Effects that are caused by the action but occur later in time or are farther removed in 

distance, yet are still reasonably foreseeable and related to the action by a chain of cause 

and effect. Indirect impacts may reach beyond the natural and physical environment (e.g., 

environmental impact) to include growth-inducing effects and other effects related to induced 

changes in resource users (e.g., social impact). 

Cumulative 

Impacts 

Effects that result from the incremental impact of the action when it is added to other past, 

present, and reasonably foreseeable future actions, regardless of what agency (federal or 

non-federal) or person undertakes such other actions. Cumulative impacts can result from 

individually minor but collectively significant actions that take place over time. 

This analysis considers the context, intensity, and duration of an impact. Context relates to environmental 

circumstances at the location of the impact and in the immediate vicinity, affected interests, and the 

locality. Intensity refers to the severity or extent of the impact or magnitude of change from existing 

conditions. Duration refers to the permanence and longevity of the impacts, which is described as short 

term or long term. Short term is defined as anticipated to end within the first 5 years after the action is 

implemented. Long term is defined as lasting more than 5 years after the action is implemented, or 

beyond the planning time frame addressed in the RMP. 

For ease of reading, impacts presented are direct, broad (occurring within the decision area), and long 

term, unless otherwise noted as indirect, localized, or short term/temporary. Potential significant impacts 

are also identified in the impact analysis. Because an impact may be perceived as beneficial or adverse, 

these terms are not used in defining impacts. 

4.1.3 General Analytical Assumptions 

Several assumptions were made in the analysis regarding level of land use activity, resource condition, 

and relationships between resources. Potential impacts and their significance were determined based on 

these assumptions. The following general assumptions were used in the analysis; additional assumptions 

are presented under each resource topic, but apply to the analysis as a whole: 

• Management actions proposed in the Proposed RMP apply to public lands only. 

• The impact analysis applies only to the decision area; however, the cumulative impact analyses 

consider potential actions on affected resources/uses regardless of ownership and administration 

and beyond the planning area boundaries. 

• The alternatives would be implemented over the life of the plan in accordance with laws, 

regulations, and standard management guidelines. 

• Funding would be available to fully monitor and implement the management actions. 

• BLM policies, including Standards for Rangeland Health and Guidelines for Grazing 

Management for BLM Lands in Utah (Standards and Guidelines), would be applied as 

appropriate. These would assess rangeland health and provide strategies to achieve desired 

resource conditions and management objectives. 

• Best management practices (BMP) are tools that would minimize or mitigate site-specific impacts 

on resources and would be applied and adjusted on a case-by-case basis. 

• Mitigation requirements would prevent or limit direct impacts associated with land use activities 

or would reclaim the land after the activity has been completed. 

• Projected levels of activity for land use would change based on historical trends, existing land use 

authorizations such as leases or permits, and statements of interest in land use by individuals and 

industry organizations. 

• Public land users would comply with the decisions and allocations contained in the alternatives. 
 Introduction 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-3 

• Actions associated with emergencies or public safety would be performed at the discretion of the 

Authorized Officer. 

• All acreages and percentages presented in this chapter pertain to the entire decision area unless 

otherwise stated. 

4.1.4 Determining Significance of Impacts 

Determining the significance of impacts is complex, particularly at the RMP planning level. The 

significance of a resource or impact is dynamic and may change during the planning period. Significance 

can be real and supportable by fact, or perceived and perhaps not fully supportable even with rigorous 

study. For this analysis, the approach to establishing significance was based on legal issues, public 

perception, and professional judgment. The significance of the impacts of implementation-level decisions 

will be determined on the basis of more site-specific analysis and further consideration of the context and 

intensity of impacts, as explained in the Council on Environmental Quality’s (CEQ) Significance Criteria 

found at 40 CFR 1508.27. 

4.1.5 Critical Elements 

The BLM National Environmental Policy Act Handbook (H-1790-1) requires that all environmental 

impact statements (EIS) address certain topics, which the BLM refers to as Critical Elements of the 

Human Environment. The list of critical elements in the BLM handbook has been expanded by BLM 

Instruction Memoranda (IM) and by Executive Orders (EO). These elements are presented in Table 4-2 in 

the order in which they appear in Chapters 3 and 4, followed by corresponding Relevant Authorities and 

the status of the critical element in this document. 

Table 4-2. Critical Elements

Critical Element Relevant Authority Status 

Air Quality The Clean Air Act as amended (42 United 

States Code [U.S.C.] 7401 et seq.) Addressed in its own section 

Farm Lands (prime or 

unique) 

Surface Mining Control and Reclamation 

Act of 1977 (30 U.S.C. 1201 et seq.) 

As noted in the soils section in Chapter 

3 of the Draft RMP/EIS, none are 

present in the decision area; therefore, 

they are not addressed in Chapter 4 

Water Quality 

(Drinking/Ground)1 

Safe Drinking Water Act, as amended (42 

U.S.C. 300f et seq.) 

Clean Water Act of 1977 (33 U.S.C. 1251 

et seq.) 

Colorado River Basin Salinity Control Act 

of 1974, as amended 

Addressed in the Water Resources 

section 

Floodplains EO 11988, Floodplain Management 

Addressed generally in the Water 

section 

(No projects or activities are proposed 

in the RMP that would result in 

diversions in or placement of permanent 

facilities on active floodplains of major 

rivers) 

Wetlands/Riparian Zones EO 11990, Protection of Wetlands Addressed in the Vegetation section 
Introduction 

Chapter 4 Proposed RMP and Final EIS 

4-4 Kanab RMP 

Critical Element Relevant Authority Status 

Invasive, Non-Native 

Species1

Federal Noxious Weed Act of 1974, as 

amended 

Endangered Species Act of 1973, as 

amended 

EO 13112, Invasive Species

Addressed in the Vegetation section 

Threatened or 

Endangered Species 

Endangered Species Act of 1973 as 

amended (16 U.S.C. 1531) Addressed in its own section 

Cultural Resources National Historic Preservation Act as 

amended (16 U.S.C. 470) Addressed in its own section 

Areas of Critical 

Environmental Concern 

Federal Land Policy and Management Act 

of 1976 (FLPMA) (43 U.S.C. 1701 et seq.) Addressed in its own section 

Wild and Scenic Rivers Wild and Scenic Rivers Act as amended 

(16 U.S.C. 1271) Addressed in its own section 

Wilderness FLPMA and Wilderness Act of 1964 (16 

U.S.C. 1131 et seq.) Addressed in its own section 

Environmental Justice1 EO 12898, Federal Actions to Address 

Environmental Justice in Minority 

Populations and Low-Income Populations 

Addressed in the Social and Economic 

section 

Native American 

Religious Concerns 

American Indian Religious Freedom Act of 

1978 (42 U.S.C. 1996) 

EO 13007, Indian Sacred Sites 

Addressed in the Social and Economic 

and Cultural Resource sections 

Wastes (Hazardous or 

Solid) 

Resource Conservation and Recovery Act 

of 1976 (42 U.S.C. 6901 et seq.) 

Comprehensive Environmental Response, 

Compensation, and Liability Act of 1980 

as amended (42 U.S.C. 9615) 

Addressed in the Social and Economic 

section 

1

Critical element added by Interim Guidance—Changes to the List of Critical Elements of the Human Environment (IM-1999-178) 

in the BLM National Environmental Policy Act Handbook

Source: BLM H-1790-1, Appendix 5

4.1.6 Incomplete or Unavailable Information 

CEQ regulations implementing the National Environmental Policy Act (NEPA) require agencies 

evaluating effects on the human environment in an EIS to identify incomplete or unavailable information, 

if that information is essential to a reasoned choice among alternatives (43 CFR 1502.22). 

As is typical in programmatic planning efforts, site-specific data is used to the extent possible and may 

not be entirely available; however, this data is not essential for a reasoned choice among alternatives. The 

best available information pertinent to management actions was used to develop this Proposed RMP/Final 

EIS. Considerable effort has been made to acquire and convert resource data—from both BLM and 

outside sources—into digital format for use in the plan. However, certain information was unavailable for 

use in developing this plan, usually because inventories have not been conducted or are not complete. For 

these resources, estimates were made regarding the number, type, and significance of these resources 

based on previous surveys and existing knowledge. Some of the major types of unavailable data include 

the following: 

• Air quality baseline data within the decision area 
 Introduction 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-5 

• Detailed soil surveys throughout the decision area (should be completed within the planning 

period, including characteristics to help determine fragile soil characteristics) 

• Field inventories for some wildlife and special status species occurrence, condition, and trend 

• Complete inventories (of the entire field office) for cultural and paleontological resources 

• Native American traditional use areas 

• Inventory of abandoned mines 

• Direct recreation visitation based on actual use and economic expenditure data associated with 

such use. 

In addition, some impacts cannot be quantified given the proposed management actions. Where such a 

gap occurs, impacts are projected in qualitative terms or, in some instances, are described as unknown. 

Subsequent implementation-level and project-level analysis will provide the opportunity to collect and 

examine site-specific inventory data required to determine appropriate application of the RMP guidance. 

In addition, ongoing inventory efforts by the BLM and other agencies continue to update and refine the 

information used to implement this plan. 

Potential impacts of certain land use activities can be compared visually and numerically among the 

alternatives by using geographic information system (GIS) data. Due to differences in the level of detail 

between GIS datasets, small errors in acreage calculations and analysis overlays can occur. To reduce the 

potential for such errors and resulting inconsistencies within the analysis, acreage figures were rounded 

according to a graduated scale. As such, acreage calculations used in this analysis are approximate 

projections used for comparison of alternatives and analytic purposes only; they do not reflect exact 

measurements of on-the-ground resources and actions. 
Air Quality 

Chapter 4 Proposed RMP and Final EIS 

4-6 Kanab RMP 

4.2 RESOURCES

4.2.1 Impacts on Air Quality 

This section presents the impacts on air quality from implementation of the Proposed RMP. A qualitative 

emission comparison approach was selected for the Kanab RMP analysis of impacts on air quality. This 

approach was selected because of uncertainties about the number, nature, and specific location of future 

sources and activities. The emissions calculations were based on the best available engineering data and 

assumptions; air, visibility, and emission inventory procedures; and professional and scientific judgment. 

However, assumptions were used when specific data or procedures were unavailable. A general statement 

about National Ambient Air Quality Standards (NAAQS) and Utah Ambient Air Quality Standards can 

be made for this qualitative analysis. This emission comparison approach is defensible and provides a 

sound basis for comparing base year air quality emissions with those expected to be produced from the 

Proposed RMP. 

Maximum potential near-field particulate matter (PM) emissions from traffic on unpaved roads and well 

pad construction were used to estimate emissions for PM2.5 and PM10 impacts. Maximum air pollutant 

emissions from each gas well would be temporary (i.e., occurring during a 12-day construction period) 

and would occur in isolation, without significantly interacting with adjacent well locations. PM emissions 

from well pad and road maintenance and construction would be minimized by applying water and/or 

chemical dust suppressants. The control efficiency of these dust suppressants was computed at 50 percent 

during construction. 

For any future project, potential air quality impacts will include local, state, tribal, and federally enforced 

legal requirements to ensure that site-specific activities do not generate emissions that contribute to an 

exceedance of the NAAQS, Prevention of Significant Deterioration (PSD) increments, or other regulatory 

standards. 

A direct relationship between emissions and visibility impairment does not exist, and so the qualitative 

emissions analysis cannot be used to assess potential visibility impacts on nearby Class I areas from 

activities within the decision area. However, implementation and compliance with the State 

Implementation Plan, specifically Section XVII, Visibility Protection, is expected to result in meeting 

visibility goals under all management alternatives. In addition, site-specific EISs and Environmental 

Assessments (EA) will include a quantitative visibility analysis, if warranted by the project. 

The emissions inventory was developed for the decision area using calculations based on the best 

available information about activities on BLM land provided by the Kanab Field Office (KFO). The 

calculations used emissions factors that are accepted and recognized by state and federal regulatory 

agencies. This analysis selected two time frames to evaluate future emissions. The time frames reflect the 

current base year conditions and the long-term impacts. It is assumed that all, if any, increases in 

emissions will be constant and linear in time. The inventory time frames are: 

• Current emissions (using the year 2006 as a basis) 

• 20-year potential emissions for the long term (2026). 

The analysis is based on the following assumptions: 

• Emission factors recommended by the U.S. Environmental Protection Agency (EPA) (EPA 1995) 

are appropriate for all activities. 
 Air Quality 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-7 

• Activity factors (i.e., the quantification of activity for each resource, such as oil and gas 

development, miles of routes maintained, vegetation treatments, and vehicle miles driven), 

including reasonably foreseeable developments (RFD), are appropriate for the base year and 

future time frame. 

• Any anticipated recreational growth would follow growth trends for Utah over the past 10 years. 

• For the qualitative analysis, only emissions from BLM-administered activities are included. (For 

the cumulative analysis, emissions calculated from the State of Utah are discussed.) 

• Coal production will be 2 to 3 million tons per year for a total of 40 million tons over the life of 

the mine. Because underground coal mining does not have emission factors, surface mining 

factors are used (this is a conservative case assumption). 

• Criteria pollutants and Hazardous Air Pollutants (HAP) are included in the calculations. 

• Prescribed fire emissions are estimated using the Simple Approach Smoke Estimation Model 

(Sestak and Riebau 1988). 

The most conservative case assumptions for air quality were used for the qualitative analysis. When a 

range of activity factors was assumed, the upper limit of the range was used to complete calculations for 

future time frames. 

Emissions were calculated for the following activities: oil and gas development, lands and realty actions, 

livestock grazing, off-highway vehicle (OHV) use, maintenance of roads (emissions associated with 

exhaust and particulate matter from the operation of graders and other maintenance vehicles on unpaved 

roads and road shoulders), coal and salable mineral development, vegetation management, and prescribed 

burning. Although wildfires can occur in the decision area and may impact air quality, emissions from 

these sources were not included in the calculations because these are not considered human-caused 

sources and, unlike prescribed burns, are not under the control of the BLM. 

Table 4-3 provides the base year emissions that are used to compare air quality impacts. Increase in air 

emissions is anticipated from the long-term BLM activities. The table is broken down by activity and 

shows emissions for the base year. Emissions are calculated on an annual basis (tons per year). 

Using the well numbers, individual tables for all BLM activities in the decision area were calculated in 

linked spreadsheets. Because oil and gas field activities occur in phases (e.g., exploration, development, 

production, and closure), the components that must be included in emissions calculations are complex. 

These assumptions and calculations are available on an emissions CD. To understand the elements and 

assumptions used in the emissions please refer to the emissions CD, which is available from the BLM 

KFO. The assumptions and inputs used for each resource area are identified in the first two tabs of each 

major spreadsheet. 

Table 4-3 summarizes the total BLM emissions, estimated for the base year (2006) and Table 4-4 

summarizes the total BLM emsissions for the long term (2026). The tables are broken down by activity 

and show emissions for the time frame referenced (e.g., base year and long term). Emissions are 

calculated on an annual basis (tons per year). In addition, for both the base year and the long-term time 

frames, emissions were calculated for each alternative. 

Because this air quality analysis is qualitative, it is not possible to determine the specific impacts of 

resource activities on air quality. No air emissions are expected as a result of implementing the Proposed 

RMP for the following resources, resource uses, and designations, and therefore they are not discussed in 

the air quality impacts discussion: water resources, special status species, visual resources, and other 

designations (i.e., National Historic Trails, National Scenic Byways, State Scenic Byways, Utah Scenic 

Backways, and BLM Backcountry Byways). 
Air Quality 

Chapter 4 Proposed RMP and Final EIS 

4-8 Kanab RMP 

The assessment of climate changing pollutant emissions and climate change is in its formative phase; 

therefore, it is not yet possible to know with confidence the net impact to climate. However, the 

Intergovernmental Panel on Climate Change (IPCC 2007) recently concluded that “warming of the 

climate system is unequivocal” and “most of the observed increase in globally average temperatures since 

the mid-20th century is very likely due to the observed increase in anthropogenic [man-made] greenhouse 

gas concentrations.” 

The lack of scientific tools designed to predict climate change on regional or local scales limits the ability 

to quantify potential future impacts. Currently BLM does not have an established mechanism to 

accurately predict the effect of resource management-level decisions from this planning effort on global 

climate change. However, potential impacts to air quality due to climate change are likely to be varied. 

For example, if global climate change results in a warmer and drier climate, increased particulate matter 

impacts could occur due to increased wind blown dust from drier and less stable soils. Cool season plant 

species’ spatial ranges are predicted to move north and to higher elevations, and extinction of endemic 

threatened/endangered plants may be accelerated. Due to loss of habitat, or due to competition from other 

species whose ranges may shift northward, the population of some animal species may be reduced. Less 

snow at lower elevations would be likely to impact the timing and quantity of snowmelt, which, in turn, 

could impact aquatic species. In the future, as tools for predicting climate changes in a management area 

improve and/or changes in climate affect resources and necessitate changes in how resources are 

managed, BLM may be able to re-evaluate decisions made as part of this planning process and adjust 

management accordingly. 

Proposed RMP 

The air quality monitoring activities, which include construction of monitoring stations and vehicular 

travel to service the monitoring stations, would have minimal impact on air resources. Air quality 

monitoring would be the responsibility of the lessee. Information obtained from monitoring likely would 

add to the knowledge base on which future air-related decisions would be made. 

Wildland fires and prescribed fires would cause short-term emissions of PM and carbon monoxide (CO) 

that could be spread over large portions of the decision area depending on the size of the fire and on wind 

conditions. In addition, PM emissions, CO, nitrogen oxides (NOx), and hydrocarbons (which include 

HAPs) would result from use of heavy equipment during fire-suppression activities. Emissions would 

include those generated by internal combustion engines and non-vehicular emissions. The use of heavy 

equipment on unpaved and paved roads would cause emissions of PM, CO, NOx, and hydrocarbons. 

The various construction activities authorized under lands and realty for rights-of-way (ROW) (e.g., 

powerlines, communication sites, transmission lines, pipelines projects) produce PM emissions. Soil 

disturbing activities, including grading, bulldozing, trench digging, and travel on unpaved roads, are 

considered the main causes of the emissions. Exhausts from vehicular travel and emissions from 

equipment use also would occur. 

Livestock grazing and support of grazing activities, which includes trucking livestock into and out of the 

decision area and checking livestock range improvements and fences, generate both vehicular exhausts 

and dust. These emissions are also produced by construction activities and travel on unpaved and paved 

roads. 

Air emissions would be produced during all phases of oil and gas development, including exploration, 

well development, production, and well and road reclamation. Emissions of PM, CO, NOx, sulfur dioxide 

(SO2), and hydrocarbons (including HAPs) would occur during exploration and development from traffic 

on unpaved and paved roads and during well development and completion from well flaring and 
 Air Quality 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-9 

associated emissions. Also, during well development, drilling and construction activities using heavy 

equipment would cause PM emissions and gaseous emissions. Air emissions are probable during gas 

production. Emissions of NOx and CO from compression activities (burning of natural gas) would occur. 

PM, CO, NOx, and hydrocarbon emissions (volatile organic compounds [VOC]) would be produced from 

any glycol operations and flashing. Any flaring would cause PM, CO, NOx, SO2, and hydrocarbon 

emissions (including HAPs). During well abandonment and road closure, PM emissions would be caused 

by travel on unpaved roads and demolition activities. 

Air emissions would be produced during mining operations and reclamation activities. During coal and 

salable mineral mining activities, PM emissions would be produced from overburden removal, blasting, 

truck loading, bulldozing, grading, storage piles, and travel of heavy equipment over unpaved roads. 

Vehicular exhausts (CO, NOx, SO2, and hydrocarbons) would result from heavy equipment and vehicular 

travel. 

The major recreational impact on air quality would be from use of OHVs, including all-terrain vehicles 

(ATV) and off-highway motorcycles. Use of this popular recreational equipment would cause fugitive 

PM dust emissions from traffic on unpaved trails and vehicular exhausts of PM, CO, NOx, and 

hydrocarbons. 

Upward trends in populations within and surrounding the decision area would create the potential for 

long-term additional increases in emissions from many other resource management programs. 

The maintenance of unpaved roads and shoulders of paved roads would cause PM emissions and 

emissions from vehicular exhausts. The primary source of these PM emissions is road graders. 

Vegetation management and manipulation and the equipment used for these activities (e.g., fire engines 

and bulldozers) could cause dust from unpaved roads. Prescribed fires used for vegetation treatment could 

cause similar particulate and gaseous emissions as detailed in the previous discussion of emissions 

associated with wildland and prescribed fires. Areas receiving vegetation treatment could add short-term 

increases in PM until the vegetation recovers sufficiently to stabilize exposed soil. 

Construction activity to manage wildlife and fish habitat would contribute PM to air emissions. To a 

lesser degree, CO, NOx, SO2, and hydrocarbons would be generated by vehicular exhaust. These impacts 

would be short term. 

Because a quantitative relationship between the expected air emissions calculated above and the 

subsequent potential impacts on the air quality values of visibility, atmospheric deposition, or ozone are 

not known, it is not possible to draw any conclusions about the potential impacts expected on these air 

quality values. The BLM intends to make quantitative estimates required for project-specific EISs. 

Emissions were calculated for all existing activities and oil and gas well development for the base year 

(2006) to compare the potential increase in emissions from these activities over a 20-year time horizon 

(2026). Table 4-3 displays a summary of total emissions estimated by the BLM for the base year (2006) 

broken down by activity. Emissions are calculated on an annual basis (tons per year). The total estimated 

emissions calculated for 2006 are 2,694 tons. 

Table 4-3. Base Year (2006) Emissions Inventory for the Decision Area (tons per year) 

Activity PM10 PM2.5 NOx SO2 CO VOC HAPsb

Oil and Gas Well Development and Exploration 

Oil and Gas – Construction 14 3 37 1 9 1 0 
Air Quality 

Chapter 4 Proposed RMP and Final EIS 

4-10 Kanab RMP 

Activity PM10 PM2.5 NOx SO2 CO VOC HAPsb

Oil and Gas – Operations 7 2 23 0 21 18 2 

Oil and Gas – Maintenance 0 0 0 0 0 0 0 

Sub-Total: Oil and Gasc 21 5 60 1 30 20 2 

Non-Oil and Gas Well Activities 

Coal Mining 318 318 409 45 724 38 4 

Lands and Realty 2 0 1 0 0 0 0 

Livestock Grazing 9 1 1 0 0 0 0 

Off-Highway Vehicles (OHV)a 7 7 3 - 616 225 22 

Road Maintenance 0 0 0 0 0 0 0 

Salable Minerals 3 0 - - - - - 

Vegetation 3 1 5 1 1 0 0 

Prescribed Burning 152 126 

Sub-Total: Non-Oil and Gas Well Activitiesc 494 455 418 46 1,342 263 26 

Grand Total: Baseline (2006) – Existing 

Developmentc 514 460 478 47 1,372 283 28 

Notes: 

In December 2006 the Federal Government adopted new PM standards, which tighten the 24-hour fine particle (PM2.5) standard

from 65 micrograms per cubic meter (μg/m3) to 35 μg/m3 and retained the current annual fine particle standard at 15 

μg/m3

. The existing 24-hour PM10 standard of 150 μg/m3 was retained and the annual PM10 standard was revoked due to 

a lack of evidence linking health problems to long-term exposure to coarse particle pollution. Although the Federal 

Government adopted the new standards, the states have not yet engaged in rule making to adopt the new standards. a

 PM2.5 assumed = PM10 for this activity. b HAPs = Hazardous Air Pollutants; assumed = VOCs * 0.1. 

c

 Total emissions are rounded to the nearest whole number; emissions less than 1 ton per year are designated as 0. 

Table 4-4 summarizes total and specific pollutant emissions for the Proposed RMP. These emissions were 

estimated for the base year (2006) time frame and for the long-term 20-year horizon. The total emissions 

for the Proposed RMP increase over time from the base year of 2,694 tons per year of pollutants to 3,554 

tons per year by 2026. 

Given the low ambient concentrations that exist in the decision area for some of the pollutants, it is 

expected that the increase in emissions of CO, NOx, SO2, PM10, and PM2.5 for the Proposed RMP would 

not cause any exceedance of state or federal ambient air quality standards. 

Table 4-4. Proposed RMP Long-Term (2026) Emissions Inventory 

for the Decision Area (tons per year) 

Activity PM10 PM2.5 NOx SO2 CO VOC HAPsb

Oil and Gas Well Development and Exploration 

Oil and Gas – Construction 14 3 37 1 9 1 0 

Oil and Gas – Operations 12 3 28 0 23 22 2 

Oil and Gas – Maintenance 1 0 0 0 0 0 0 

Sub-Total: Oil and Gasc 27 6 65 1 32 24 2 
 Air Quality 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-11 

Activity PM10 PM2.5 NOx SO2 CO VOC HAPsb

Non-Oil and Gas Well Activities 

Coal Mininga 318 318 409 45 724 38 4 

Lands and Realty 2 0 1 0 0 0 0 

Livestock Grazing 9 1 1 0 0 0 0 

Off-Highway Vehicles (OHV)a 15 15 7 - 1,223 448 45 

Road Maintenance 0 0 0 0 0 0 0 

Salable Minerals 3 0 - - - - - 

Vegetation 3 1 5 1 1 0 0 

Prescribed Burning 152 126 

Sub-Total: Non-Oil and Gas Well Activities 501 462 422 46 1,949 487 49 

Grand Total: Long Term (2026)c 528 468 488 47 1,981 511 51 

Notes: 

a

 PM2.5 assumed = PM10 for this activity. b

 HAPs = Hazardous Air Pollutants; assumed = VOCs * 0.1. 

c

 Total emissions are rounded to the nearest whole number; emissions less than 1 ton per year are designated as 0. 

Summary 

A qualitative emission comparison approach was selected for the air quality impact analysis. This analysis 

shows that under the Proposed RMP, there will be little to no impacts. The emissions calculations were 

based on the best available engineering data and assumptions, on air, visibility, and atmospheric 

deposition data, on emission inventory procedures, and on professional and scientific judgment. However, 

where specific data or procedures were not available, assumptions were made. There are limitations 

associated with this approach. However, given uncertainties about the number, nature, and specific 

location of future sources and activities, the emission comparison approach is defensible and provides a 

sound basis for comparing alternatives. 

The criteria pollutants addressed in this analysis include NO2, SO2, CO, PM10, and PM2.5. 

The emissions inventory results and qualitative impacts for the Proposed RMP are shown in Table 4-4. 

The total emissions for the Proposed RMP increase over time from the base year of 2,694 tons per year of 

pollutants to 3,554 tons per year by 2026. Table 4-5 shows the increase in emissions for from the baseline 

year to the long term in 2026. The table also shows the percent increase in emissions from the base year 

to the long term, and the percent increase for the Proposed RMP. 

Table 4-5. Increase in Annual Air Emissions from 2006 Conditions in the Decision Area 

(tons per year)

Time Frame PM10 PM2.5 NOx SO2 CO VOC HAPs 

Proposed RMP 

2026 

Percent increase in emissions from 

base year 

14 

(3%) 

8 

(2%) 

10 

(2%) 

0 

(0%) 

609 

(44%) 

228 

(81%) 

23 

(82%) 

Percent increase in emissions from 

current management 

–1 

(0%) 

–1 

(0%) 

0 

(0%) 

0 

(0%) 

–83 

(–4%) 

–30 

(–6%) 

–3 

(–6%) 
Air Quality 

Chapter 4 Proposed RMP and Final EIS 

4-12 Kanab RMP 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

Impacts on the air quality resource in the decision area are not irreversible or irretrievable. However, 

committed actions that consume PSD increments would use up available PSD increments for other 

proposed sources. For this EIS, there are no proposed or reasonably foreseeable actions by the BLM that 

will require PSD permitting. 

There will be no loss of long-term productivity due to short-term uses proposed in the alternatives. 

Activities planned will produce some level of air emissions even with mitigation. However, none of the 

activities proposed in this EIS will produce unavoidable adverse impacts on the air quality resource. 
 Soil Resources 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-13 

4.2.2 Impacts on Soil Resources 

This section discusses impacts on soils from implementing the Proposed RMP. Soils, especially in 

sensitive soil areas, are susceptible to impacts from surface disturbance and compaction, which can lead 

to accelerated erosion, soil loss, and reduced productivity. Management actions involving ground 

disturbing activities that reduce vegetation cover, and using vehicles and heavy machinery could 

contribute to soils impacts. Management actions that restrict surface disturbing activities could protect 

soil resources, especially on soils identified as fragile. 

This analysis was based on the following assumptions: 

• Sensitive soils would be managed to minimize erosion above natural levels and maintain soil 

productivity. 

• Soil resources would be managed to help maintain site productivity. 

Although management actions would be designed to minimize impacts, and BMPs and other necessary 

protection measures would be implemented, there are greater inherent risks when surface disturbing 

activities occur on soils identified as fragile. The analysis considered the location of fragile soils and the 

potential proposed locations of management activities. 

Impacts on soil resources would occur from activities associated with transportation management, 

vegetation, wildland fire ecology, minerals and energy, and livestock grazing. Soils management actions 

and actions that prohibit surface disturbing actions such as management associated with ACECs, wild and 

scenic rivers (WSR), non-WSA lands with wilderness characteristics, fish and wildlife, and special status 

species habitat could maintain or improve soil conditions. 

Under the Proposed RMP, impacts on soil resources are not anticipated as a result of implementing 

management actions for the following resources and designations: air quality, paleontological resources, 

and other designations. 

Proposed RMP 

Wildland Fire 

In the short term, loss of vegetative cover due to wildland fire could affect soil quality through the loss of 

soil structure and temporary reduction in porosity of soils in the impacted areas. The reduction in porosity 

and loss of structure could result in a decrease in infiltration rates and increased erosion and runoff 

(Ralston and Hatchell 1971). However, BMPs associated with wildland fire ecology management actions 

would reduce impacts associated with soil loss and the potential for sediment loading and sedimentation. 

Erosion control measures and seeding may be proposed as post-fire treatments (emergency stabilization 

and rehabilitation [ESR] or other) to stabilize these sites and to contain and control soil loss. 

Where it is expected that fire severity could adversely impact sensitive soils, an appropriate management 

response (AMR) would be implemented. Some level of ground disturbing activities associated with 

suppression, prescribed fire, and non-fire fuel treatments would be likely to occur. Indirect impacts 

include potential soil loss from wind and water erosion.

Over the long term, as areas within the decision area are treated and experience fire return intervals closer 

to historic fire return intervals, a trend toward less severe wildland fires would occur, resulting in fewer 

impacts on soils (including microbial populations, soil temperatures, and the chemical and physical 
Soil Resources 

Chapter 4 Proposed RMP and Final EIS 

4-14 Kanab RMP 

structure of the soil). Wildland fire ecology management actions would continue to allow for aggressive 

fire suppression in areas with sensitive soils and where fire has not played a significant role in the past. 

To foster healthy native understory communities and to maintain and/or improve soil resources and 

reduce erosion potential over the long term, planned fire management and fuel reduction actions would be 

implemented. These actions could also decrease the potential for destruction of biological crusts by severe 

fire events. Planned actions (prescribed fire and non-fire fuel treatments) could also continue to reduce the 

likelihood of severe wildland fires and subsequent loss of soil structure, altered porosity, and altered 

infiltration rates. As the role of fire returns to a more natural pattern, there would be fewer indirect 

impacts from large, severe wildland fires, including a reduction in wind and water erosion. 

Fragile Soil Areas 

Implementing site-specific restrictions and/or mitigations for surface disturbing activities (e.g., open to oil 

and gas leasing subject to moderate constraints [controlled surface use]) and not allowing cross-country 

OHV use in fragile soil areas would help minimize the risk of soil erosion. Prioritizing land treatments in 

fragile soil areas with the objective of reducing erosion would help maintain or improve vegetation 

conditions, maintain or reduce erosion rates and improve soil productivity. More than 80 percent of the 

areas with identified fragile soils (5,100 acres) would be prioritized for such treatment. 

Actions that Actively Affect Vegetation 

Vegetation treatments on an average of no more than 22,300 acres annually would decrease vegetation 

cover, which could reduce soil protection from rain, surface runoff, and wind erosion in the initial year 

after treatment. Mitigations based on site-specific soil characteristics, plus initial growth of desired plant 

species would reduce these short-term impacts. Over the long term, these treatments should improve 

vegetation health and cover, maintain soil resources, and improve soil productivity. However, if less than 

an annual average of 4,650 acres were treated, shrublands generally would convert into woodlands and 

reduce understory vegetation. The loss of understory vegetation could, over the long term, increase the 

susceptibility of soil resources to erosion. 

Similar to vegetation treatments, managing areas for forest and woodland product harvest could result in 

short-term increases in erosion and soil loss. However, long-term results would be to maintain soil 

resources and allow understory vegetation to be established or restored. 

Actions Resulting in Soil Disturbance or Compaction 

Implementing BMPs, erosion control measures, and other decisions that mitigate surface disturbing 

activities would reduce or minimize water and wind erosion, stabilize soils, reduce soil compaction, and 

maintain soil productivity. Managing livestock grazing according to the Standards and Guidelines would 

help to meet soil resource objectives and reduce soil erosion. Localized removal of plant cover, soil 

compaction, and lower infiltration rates could occur in areas of livestock concentration and trailing. 

However, these impacts would be site specific, short term, and localized. Adhering to the grazing 

guidelines and managing to maintain or make progress toward the Standards for Rangeland Health would 

help maintain or improve existing soil conditions and help prevent impacts from becoming significant. 

It is anticipated that development of coal resources would result in the total disturbance of 3,600 acres 

over the 20-year planning horizon (Appendix 15), which could result in localized loss of topsoil, removal 

of plant cover, and soil compaction. However, applying BMPs to and reclaiming land concurrently with 

the coal mining (approximately 100 acres per year) would reduce these impacts on soil resources. In 

addition, site-specific NEPA analysis of the impacts on soil resources is required prior to approval of a 

coal lease. 
 Soil Resources 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-15 

The magnitude and intensity of the impacts from surface disturbing activities would decrease based on 

more restrictions and stipulations on surface disturbing activities, including increasing restrictions on oil 

and gas activities and establishing ROW avoidance and exclusion areas. Management actions for 

resources and resource uses that apply stipulations to surface disturbing activities could help reduce soil 

erosion. These management actions include areas open to oil and gas leasing subject to moderate 

constraints (timing limitations, CSU) (296,200 acres), areas open to oil and gas leasing subject to major 

constraints (no surface occupancy [NSO]) (83,400 acres), and areas closed to oil and gas leasing (79,000 

acres) (Map 14). The RFD (Appendix 15) projects a total of 90 wells (70 exploration and 20 new 

production wells) could be drilled during the next 20 years, which could result in a future surface 

disturbance of 2,070 acres, with 906 acres of disturbance from seismic operations. Approximately 2,370 

acres of the total 2,976 acres would be reclaimed (Appendix 15) over the long term. Applying BMPs 

identified in Appendix 1, such as promptly reclaiming disturbed areas and establishing vegetation cover 

on disturbed areas, would further reduce soil erosion. 

In addition to oil and gas leasing stipulations, locatable mineral withdrawals (9,500 acres) and mineral 

material closures (105,000 aces) could similarly help reduce soil erosion by restricting surface 

disturbances. The Cottonwood Canyon ACEC and suitable WSR corridors would be recommended for 

withdrawal from locatable minerals activities (Map 12) and closed to mineral material disposals (Map 

16). In addition, areas managed as no surface disturbing actions (23,800 acres), areas with seasonal 

limitations on surface disturbing actions (407,500 acres) (Map 19), and ROW exclusion areas (75,700 

acres or 14 percent) (Map 11) would further restrict surface disturbing activities. 

Visual Resource Management (VRM) Class I areas (76,000 acres, 14 percent) would limit the amount of 

surface disturbance, which would indirectly maintain soil resources. Areas designated as VRM Class I 

would be managed to preserve the existing landscape characters; thus, there would be little or no surface 

disturbance that could contribute to increased soil compaction, soil loss, and erosion. Reclamation would 

be expected to stabilize soils and reduce or eliminate long-term soil erosion. 

Impacts on soils from cross-country OHV use would nearly be eliminated because the number of acres 

open to OHV use would be 1,000 acres, mainly in areas with naturally disturbed soils such as sand dunes. 

Instead of cross-country OHV use, OHV use would be limited to 1,403 miles of designated routes on 

528,000 acres (95 percent), indirectly protecting nearby soils from increased erosion by focusing impacts 

on compacted surfaces that have already been impacted. Closing 25,000 acres (5 percent) to OHV use 

likely would reduce OHV-related soil impacts in these areas. 

Recreation (Not Including OHV Use) 

Although identification of and development within Special Recreation Management Areas (SRMA) 

(95,100 acres, 17 percent) could result in soil compaction in some areas, increasing management presence 

would decrease campsite establishment or expansion and decrease the associated impacts on soils of 

compaction and overland erosion. Motorized activities in SRMAs (except for the Moquith Mountain 

Dunes Recreation Management Zone [RMZ], which is open to cross-country OHV use) could increase 

use on routes, which could indirectly protect nearby soils from increased erosion because surface 

disturbance would be focused in areas that have already been impacted. Non-motorized activities in 

SRMAs would be more dispersed, which could have site-specific impacts in areas of concentrated use. 

Proper management and public education would reduce the intensity and magnitude of these impacts on 

soil resources. 

Dispersed recreation activities and special recreation permits (SRP) could have site-specific impacts in 

areas of concentrated use. Impacts could include a reduction in plant cover, soil compaction, and loss of 

soil productivity. However, restrictions attached to SRPs would minimize these impacts. 
Soil Resources 

Chapter 4 Proposed RMP and Final EIS 

4-16 Kanab RMP 

Summary 

Surface disturbing activities could remove vegetation and topsoil and result in compaction or loss of some 

of the exposed soil surface, resulting in the majority of impacts on soil resources. Management actions 

that limit surface disturbing activities or implement BMPs (Appendix 1) and mitigation measures would 

protect and maintain current soil resources and minimize erosion. The Proposed RMP would help protect 

soil resources by limiting cross-country OHV use and placing restrictions on mineral development. 

Vegetation treatments would decrease vegetation cover, which could reduce soil surface protection from 

rain, surface runoff, and wind erosion in the initial year after treatment. Over the long term, treatments 

would improve vegetation health and cover, maintain soil resources, and improve soil productivity. 

Vegetation treatment management actions under the Proposed RMP would improve soil condition by 

improving vegetation and decreasing the potential for soil loss and erosion. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

Implementation of management actions would not result in irreversible or irretrievable loss of resources. 

Surface disturbing activities could remove vegetation, increase erosion, and contribute to soil loss. 

However, management actions and BMPs are intended to reduce the magnitude and results of these 

possible impacts. 

The short-term use of soil resources generally would not affect long-term productivity where BMPs are 

appropriately applied. BMPs could include reclaiming disturbed areas to the extent possible, establishing 

vegetation cover as soon as possible, or designing facilities to minimize surface disturbance. 

Surface disturbing activities could result in unavoidable adverse impacts. Although these impacts would 

be mitigated to the extent possible, some unavoidable impacts would occur. Loss of soil resources to 

other uses, such as transportation and mineral and energy development, could result in a long-term loss of 

site-specific soil productivity on approximately 8,426 acres associated with such development, although 

after mitigation such impacts would be limited to 4,056 acres. 
 Water Resources 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-17 

4.2.3 Impacts on Water Resources 

This section presents potential impacts on water resources from implementing the Proposed RMP. The 

discussion of impacts on water resources is limited to the effects of surface disturbing activities on water 

quality and watershed health. Activities that disturb the land surface, decrease vegetation cover, or 

otherwise alter land surface cover would potentially affect water quality and watershed health. Watershed 

health is characterized by watersheds that are in, or making significant progress toward, properly 

functioning physical condition (including their upland, riparian/wetland, and aquatic components) where 

soil and plant conditions support infiltration and soil moisture storage and where the release of water is in 

balance with climate and landform and maintains or improves water quality, water quantity, and timing 

and duration of flow (BLM 1997a). 

The analysis is based on the following assumptions: 

• Substantial surface disturbance to soil, including compaction of soil or loss of vegetative cover, 

could increase water runoff and downstream sediment loads, thereby degrading water quality, 

altering channel structure, and affecting overall watershed health. 

• The degree of impact attributed to any one disturbance or series of disturbances would be affected 

by several factors, including location within the watershed, time and degree of disturbance, 

existing vegetation, soil type, and precipitation. 

• Restrictions on surface disturbing activities should help protect and maintain current water quality 

and minimize erosion and sedimentation. 

• A change of pollutants in surface waters could affect other beneficial uses (e.g., stock-watering, 

irrigation, fisheries/aquatic life, recreation, and/or drinking water supplies). 

Under the Proposed RMP, impacts on water resources are not anticipated as a result of implementing 

management actions for the following resources and designations: air quality, paleontological resources, 

and other designations. 

Proposed RMP 

Activities on Fragile Soils 

Implementing site-specific restrictions and/or mitigations for surface disturbing activities (e.g., open to oil 

and gas leasing subject to moderate constraints [CSU]) and not allowing cross-country OHV use in fragile 

soil areas would help minimize the risk of soil erosion and sedimentation. Allowing surface disturbance 

in fragile soil areas and mitigating impacts would not affect water quality or watershed health. Prioritizing 

land treatments in fragile soil areas with the objective of reducing erosion and restoring watersheds would 

help maintain water quality by reducing the amount of sediment loading from these saline soils to nearby 

streams from disturbed fragile soil areas. More than 80 percent of the areas with identified fragile soils 

(5,100 acres) would be prioritized for such treatment. 

Planned Actions that Affect Vegetation 

Vegetation treatments, including vegetation treatments for ecological purposes, rangeland treatments, or 

non-fire fuels treatments, on an average of no more than 22,300 acres annually would decrease vegetation 

cover and increase overland flow and sediment loading in the initial year after treatment. Short-term soil 

exposure and reduced vegetation cover could affect watershed health by reducing water infiltration rates 

and increasing overland flow and sediment loading, which could affect water quality parameters, 

including turbidity, temperature, and nutrient loading. Mitigations based on site-specific characteristics 

and initial growth of desired plant species would reduce these short-term impacts. Over the long term, 

these treatments should improve vegetation health and cover, which would reduce overland flow and 
Water Resources 

Chapter 4 Proposed RMP and Final EIS 

4-18 Kanab RMP 

sediment loading. However, if less than an annual average of 4,650 acres were treated, then shrublands 

would convert into woodlands and reduce understory vegetation. The loss of understory vegetation could, 

over the long term, increase the susceptibility of resources to erosion, which could increase the potential 

for an increase in sedimentation and a decrease in water quality. 

Managing livestock grazing according to the Standards and Guidelines would eliminate long-term 

impacts from site-specific, short-term disturbance associated with concentrated livestock use. Erosion of 

exposed soils resulting from short-term concentrated grazing use would decrease, resulting in stabilized 

soils and less site-specific erosion so that areas meet Standards for Rangeland Health. This would 

improve water quality and decrease siltation and sediment loading of streams. Minimizing site-specific 

erosion and minimizing any reduction in plant cover would reduce long-term sediment loading to nearby 

creeks and springs. 

Wildland Fire 

In the short term, the potential increase in wildland fire acres (including wildland fire use), prescribed 

fire, and non-fire fuel treatments could increase runoff, erosion, and stream temperatures. Increased 

erosion and runoff could result in greater nutrient concentration and turbidity in surface waters. 

Disturbance associated with prescribed fire and non-fire fuel treatments would be evaluated through an 

environmental planning and review process that would consider impacts related to surface runoff, soil 

loss, and sediment input to surface waters. Often these impacts are short term and conditions return to 

pre-fire levels or better once vegetation is reestablished. 

The wildland fire ecology management actions would allow more flexibility in planned activities to 

manage fuel loads and would implement resource protection measures to reduce potential effects on water 

resources. Potential impacts on water resource issues would be considered before implementing 

prescribed burns, non-fire fuel treatments, or ESR efforts.

In the short term, minor impacts on groundwater quality may result from altered water absorption patterns 

(due to a decrease in vegetation cover following wildland fire or fuel treatments) and soil compaction 

(due to mechanical equipment). In addition, infiltration capacity could temporarily decrease after a fire 

due to the formation of a hydrophobic soil layer. Altered water infiltration rates could temporarily 

increase or decrease the chemical levels (i.e., dissolved solids) in shallow aquifers (Allison et al. 1994). 

The impact on groundwater would depend on the depth to groundwater below ground surface and the type 

of sediments or bedrock through which it passes. The possible changes in the infiltration capacity of soils 

would depend on fire severity, soil type, pervasiveness of vegetation root structures, and vegetation’s 

ability to reoccupy a site following fire. 

Over the long term, wildland fires would tend to be less severe, resulting in relatively fewer impacts on 

storm flows and nutrient and sediment loads. A trend toward fewer severe wildland fires would help 

maintain soil stability and could enhance overall watershed health. Some areas would have a more 

sustainable supply of woody debris or stream bank vegetation, both of which would tend to also increase 

stream bank stability. 

Over the long term, planned fire actions and eventual restoration of natural fire regimes could improve 

water resources by reducing the risk of high-severity wildland fire and promoting self-sustaining native 

vegetation types. The wildland fire ecology management actions would reduce erosion potential over the 

long term by fostering a healthy, native understory. These actions would allow more flexibility in 

implementing and timing planned actions that would protect water resources.
 Water Resources 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-19 

Planned (BLM) or Permitted (BLM-Approved) Actions Requiring Surface Disturbance 

Water resource management actions, including implementing BMPs and erosion control measures, and 

vegetation management actions regarding riparian areas would help to meet watershed objectives and 

reduce erosion and sediment loading to nearby streams and rivers. Applying the BMPs to surface 

disturbing activities (Appendix 1) would help maintain water quality and watershed health by decreasing 

siltation and sediment loading to nearby streams. 

Reclamation of surface disturbances should increase plant cover and reduce erosion and sediment loading 

to nearby streams and rivers. Requiring reclamation of surface disturbances would help maintain water 

quality and watershed health. 

Continuing to implement the Upper Sevier River Watershed Management Plan would assist in meeting 

watershed objectives and minimizing potential impacts on water quality and watershed health. 

Managing oil and gas in the areas surrounding the Kanab culinary water wells as open to oil and gas 

leasing subject to moderate constraints (timing limitations, CSU) (296,200 acres) would help protect 

surface water and groundwater quality from oil and gas development. In these areas, well placement 

would be relocated to eliminate potential contamination or pollution sources, and design standards would 

be implemented to prevent contaminated discharges to groundwater. 

Applying BMPs to oil and gas activities, designing road crossings to allow fish passage, and 

incorporating erosion control stipulations in coal mining plans would help to meet watershed objectives, 

reduce erosion and sediment loading to nearby streams and rivers, and maintain water quality. 

Encouraging treatment and onsite or offsite beneficial use of produced water from coalbed natural gas 

(CBNG) activities could protect surface water and groundwater quality and avoid the potential for 

increased salinity. Not allowing produced water to be discharged in the Colorado River Basin could 

protect the water quality of the Colorado River and avoid the potential for increased salinity. 

The development of coal resources would be anticipated to result in the total disturbance of 3,600 acres 

over the 20-year planning horizon, which could result in site-specific increases in overland flow and 

sedimentation. However, applying BMPs to and reclaiming disturbed areas concurrently with the coal 

mining would reduce these impacts on water resources. In addition, site-specific NEPA analysis of the 

impacts on water resources is required prior to approval of the coal lease. 

Impacts on water resources from cross-country OHV use would nearly be eliminated because only 1,000 

acres would be open to use, mainly in areas with naturally disturbed soils such as sand dunes. Instead of 

cross-country OHV use, OHV use would be limited to 1,403 miles of designated routes on 528,000 acres 

(95 percent). OHV use on designated routes would maintain existing vegetation and soil resources by 

focusing impacts on existing linear disturbances that have already been affected. Closing 25,000 acres (5 

percent) to OHV use would eliminate OHV-related water impacts in these areas. 

Maintaining or improving stream habitat for Bonneville cutthroat trout, roundtail chub, bluehead sucker, 

and flannelmouth sucker and restoring riparian habitat for the Southwestern willow flycatcher could help 

maintain water quality in these areas by reducing the amount of sediment entering the stream and by 

stabilizing stream banks. 

Closing the Water Canyon Allotment to livestock grazing (48 animal unit months [AUM]) would help to 

protect Fredonia’s municipal water supply by removing contamination sources. 
Water Resources 

Chapter 4 Proposed RMP and Final EIS 

4-20 Kanab RMP 

Applying Stipulations to Surface Disturbing Activities 

Increasing stipulations on oil and gas exploration and development activities could help protect and 

maintain current water quality and reduce sedimentation resulting from surface disturbing activities. 

Management actions for resources and resource uses that apply stipulations to surface disturbing activities 

include areas open to oil and gas leasing subject to moderate constraints (timing limitations, CSU) 

(296,200 acres), areas open to oil and gas leasing subject to major constraints (NSO) (83,400 acres), and 

areas closed to oil and gas leasing (79,000 acres) (Map 14). The RFD (Appendix 15) projects a total of 90 

wells (70 exploration and 20 new production wells) could be drilled during the next 20 years, which could 

result in a future surface disturbance of 2,070 acres and 906 acres of disturbance from seismic operations. 

Approximately 2,370 acres of the total 2,976 acres would be reclaimed (Appendix 15) over the long term. 

Applying BMPs identified in Appendix 1, such as promptly reclaiming disturbed areas and establishing 

vegetation cover on disturbed areas, would help to maintain current water quality and reduce 

sedimentation. 

Areas within 330 feet of riparian/wetland areas are included in the acres open to oil and gas leasing 

subject to major constraints (NSO). Not allowing surface occupancy near riparian/wetland areas would 

protect stream banks and water quality from surface disturbing activities by retaining vegetation that 

would help trap sediment before it reaches nearby streams and rivers. 

In addition to oil and gas leasing stipulations, stipulations on locatable mineral withdrawals (9,500 acres) 

and mineral material closures (105,000 aces) would similarly help protect and maintain current water 

quality and reduce sedimentation by restricting surface disturbances. The Cottonwood Canyon ACEC and 

suitable WSR corridors would be recommended for withdrawal from locatable minerals (Map 12) and 

closed to mineral material disposals (Map 16). In addition, areas managed as no surface disturbing actions 

(23,800 acres) and areas with seasonal limitations on surface disturbing actions (407,500 acres) would 

further restrict surface disturbing activities (Map 19). These actions would help protect existing water 

quality of the streams and rivers in these areas by retaining vegetation and reducing erosion. 

Management protecting the scenic and cultural relevant and important (R&I) values within the 

Cottonwood Canyon ACEC (3,800 acres, less than 1 percent) would help protect the water quality and 

watershed health of the culinary water source by reducing the possibility of surface disturbing activities 

and limiting contamination and pollution sources. Within this ACEC this water is used by the city of 

Fredonia, Arizona, as a primary source of culinary water. 

Recreation (Not Including OHV Use) 

Identification of and development within SRMAs (95,100 acres, 17 percent) could result in soil 

compaction or reduction of vegetation cover in some areas, which could result in increased overland flow 

and sediment loading to nearby streams and rivers. These impacts would be more likely in SRMAs with 

motorized activities. In SRMAs with non-motorized activities, the impacts would be more site specific in 

areas of concentrated use. Increasing the frequency of patrols in SRMAs and public education could 

decrease associated recreation impacts on water quality. 

Dispersed recreation activities and SRPs could have site-specific impacts such as a reduction in plant 

cover and soil compaction in small, localized, and isolated areas, which would result in a small increase in 

overland flow and sediment loading to nearby streams and rivers. However, restrictions attached to SRPs 

would minimize these impacts on water resources. 
 Water Resources 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-21 

Summary 

Surface disturbing activities could reduce watershed health and water quality. Management actions that 

limit surface disturbing activities or implement BMPs and mitigation measures could protect and maintain 

current water quality and minimize erosion and sedimentation. The Proposed RMP would restrict surface 

disturbing activities, which would help protect soil resources. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of water resources under the Proposed 

RMP. Long-term impacts on water quality and watershed health could be restored. 

Short-term use of an area to accommodate energy and minerals, ROWs, and cross-country OHV use 

could result in site-specific increases in sedimentation that could affect water quality and water resources. 

The limited extent of foreseeable development, mitigating management actions, and application of BMPs 

would minimize decreases in long-term productivity from short-term uses. 

Surface disturbing activities could result in unavoidable adverse impacts, although these impacts could be 

decreased by applying BMPs and site-specific mitigation efforts. 
Vegetation 

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4-22 Kanab RMP 

4.2.4 Impacts on Vegetation 

This analysis addresses potential impacts on vegetation (consisting of upland vegetation, riparian/wetland, 

and forests and woodlands) from implementing the Proposed RMP. This analysis focuses on those 

management alternatives or actions that have the potential to directly or indirectly disturb or remove 

vegetation that could result in a reduction or loss of structure, function, or diversity within a vegetation 

community, or that have the potential to facilitate the establishment and enhancement of vegetation 

communities. 

Upland vegetation communities include oak/mountain shrub (15,100 acres), desert scrub (22,300 acres), 

and sagebrush steppe (145,900 acres), which together constitute 34 percent of the decision area. 

Riparian/wetlands communities constitute 70 miles and 390 acres within the decision area. Forest and 

woodland communities include aspen (350 acres), mixed conifer (550 acres), ponderosa pine (4,200 

acres), and pinyon-juniper woodland (324,800 acres), which together constitute 60 percent of the decision 

area. 

The effects of management actions on upland vegetation, riparian/wetland areas, and forests and 

woodlands may vary widely, depending on a variety of factors such as the type of soils, moisture, 

topography, and plant reproductive characteristics. Impacts on vegetation resources also vary depending 

on the seral stage and composition of the vegetation communities discussed in Chapter 3. The 

composition of a plant community changes over time as a result of interactions with a variety of factors, 

such as climate, resource uses, and disturbance. Surface disturbance can result in the most immediate 

direct impact on an area by removing existing vegetation and thus increasing opportunities for 

establishment of noxious weeds and invasive species. This could in turn reduce vegetation diversity, 

production, desirable plant cover, and overall ecological health of vegetation communities. Decreased 

ecological health would make vegetation communities less resilient to disease, drought, fire, invasive 

species invasion, and other natural disturbances/stressors. Indirectly, surface disturbance could increase 

erosion rates, modify soil composition, and alter water flow patterns across the landscape. On the 

contrary, implementing vegetation treatments (mechanical, fire, biological, and chemical), managing 

vegetation/ecological resources to meet desired vegetation conditions, and limiting or restricting surface 

disturbances could generally improve vegetation/ecological conditions. Although short-term losses of 

vegetation cover would occur, over the long term these actions would help remove undesirable species, 

increase species diversity and age class, improve vegetation composition and structure, and increase 

vegetation cover and ecological condition. This would result in healthier vegetation communities that are 

more capable of retaining moisture and nutrients and resisting disease, invasive species invasion, drought, 

and other natural disturbances/stressors. 

The analysis is based on the following assumptions: 

• Adequate vegetative ground cover and species composition for site stabilization would typically 

occur within 5 to 10 years in sagebrush/grass communities, depending on climate, soil, and site 

potential. 

• Plant communities would be managed toward achieving a mix of species composition, cover, and 

age classes. 

• The degree of impact attributed to any one disturbance or series of disturbances would be affected 

by several factors, including location within the watershed; the type, time, and degree of 

disturbance; existing vegetation; and precipitation. 

• Noxious and invasive weeds would continue to try and invade and spread as a result of surface 

disturbing activities, vehicle traffic, recreational activities, wildlife and livestock grazing, and 

natural causes. 
 Vegetation 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-23 

• Weed and pest control would be carried out in coordination with the appropriate county, public, 

and private interests. 

• Climatic fluctuation would continue to affect the health and productivity of plant communities on 

an annual basis. 

The analysis of vegetation, which includes structure, productivity, vigor, percent cover, density, and 

species composition, was based on likely changes relative to movement toward or away from desired 

vegetation conditions. In the absence of quantitative data, professional judgment was used, and impacts 

are sometimes described using ranges of potential impacts or using qualitative terms, if appropriate. 

Particular emphasis was on vegetation communities with the greatest sensitivity to changes in structure 

and species composition and that are most at risk from potentially severe mortality events such as 

drought, insects, and disease infestation. 

Under the Proposed RMP, impacts on vegetation would not be anticipated as a result of implementing 

management actions for the following resources and designations: air quality, cultural resources, 

paleontological resources, and other designations. 

Proposed RMP 

Surface Uses and Disturbances 

Grazing by livestock and/or wildlife can alter upland vegetation communities by removing portions of 

plants (degree of alteration would depend on the extent of the removal), length of grazing period, and 

climatic conditions. Grazing animals’ hooves could trample plants and compact soils from concentrated 

use. Grazing by livestock and/or wildlife can lead to trampling and/or removal of seedlings and 

understory vegetation and could hinder regeneration and diversity within forests and woodlands. 

Concentrated grazing can alter vegetation structure and species composition (Kimball and Schiffman 

2003, Howery 1999). Managing livestock grazing according to the Standards and Guidelines would 

minimize long-term impacts from concentrated livestock use. Trampling and altered vegetation structure 

would decrease, resulting in vegetation communities that are meeting or moving toward ecological site 

potential. 

Proper grazing could improve the ecological conditions of upland communities by reducing vegetation 

removal, decreasing erosion, and reducing opportunities for establishment of noxious weeds and invasive 

species. In riparian areas, monitoring grazing use and making adjustments could maintain or improve the 

ecological condition of riparian/wetland communities by reducing vegetation removal, decreasing 

erosion, and reducing opportunities for establishment of noxious weeds and invasive species. In forests 

and woodlands, monitoring grazing use and making adjustments could also minimize excessive removal 

of vegetation if it inhibits diversity and regeneration. 

Using livestock grazing to enhance ecosystem health and/or help accomplish resource objectives on 

allotments (e.g., noxious/invasive weed control and hazardous fuel reduction) on a case-by-case basis 

could maintain and/or improve upland vegetation conditions and reduce cheatgrass and other invasive 

weeds. In forests and woodlands, this action would reduce fuel loads and noxious and invasive weeds, 

leading to improved health of these communities. 

Land exchanges and disposals could reduce fragmentation of BLM-administered lands. This could 

improve the BLM’s ability to implement management actions that result in increased diversity or that 

improve ecological health of upland communities, riparian/wetland areas, and forests and woodlands. 

Surface uses and disturbances would be restricted in the Proposed RMP and would occur in areas open to 

oil and gas leasing subject to standard terms and conditions (95,400 acres), open for mineral material 
Vegetation 

Chapter 4 Proposed RMP and Final EIS 

4-24 Kanab RMP 

sales (475,500 acres, 86 percent), open to locatable mineral entry (519,900 acres, 94 percent), and open to 

cross-country OHV recreation use (1,000 acres, less than 1). The initial surface disturbance from mineral 

exploration activities combined with the development of roads, pipelines, and drill pads per well pad 

would amount to 23 acres during the planning horizon (Appendix 15). Although about 80 percent of the 

initial disturbance area would be reclaimed within the planning horizon, approximately 20 percent of the 

disturbed area would be devoid of vegetation for the life of the well. Areas disturbed and then reclaimed 

would increase the amount of early successional vegetation in these communities. The improvement of 

roads associated with mineral development would also remove vegetation. Increased vehicle travel to well 

pads could increase the spread of noxious weeds. Anticipated mineral exploration and development of 90 

oil and gas wells would result in an estimated 2,976 acres (2% of upland vegetation within the decision 

area) of initial surface disturbance over the 20-year planning horizon. After reclamation, the amount of 

disturbance area would be reduced to 607 acres, which represents the anticipated amount of long-term 

surface disturbance. The long-term disturbance of 607 acres would result in relatively minor impacts on 

vegetation, because it would comprise only 0.3 percent of upland vegetation within the decision area. The 

development of coal resources would be anticipated to result in the total disturbance of 3,600 acres (2% of 

upland vegetation within the decision area) over the 20-year planning horizon, which would result in 

temporary vegetation removal in these areas. However, because reclamation is estimated to occur 

concurrently with mining, the long-term disturbance would result in relatively minor impacts on 

vegetation. 

Avoiding (106,670 acres) or excluding areas (75,700 acres) from ROW development could decrease the 

extent of related vegetation removal associated with these activities. Collocating ROWs would further 

reduce surface disturbances and removal of vegetation. In addition, surface disturbance would not be 

allowed within 330 feet of riparian/wetland areas and mitigation would be implemented where 

appropriate on a site-specific basis for oil and gas authorizations and energy ROWs, which would 

minimize and mitigate these impacts on riparian/wetland communities. 

SRMA management actions in the Proposed RMP would help to reduce impacts from recreational 

opportunities. Management of the Kanab Community SRMA (OHV RMZ), Paria SRMA (Canyons 

RMZ), Moquith Mountain SRMA, and Escalante SRMA (57,400 acres, 10 percent) would further 

emphasize recreational opportunities and consequently increase the potential for vegetation removal. 

However, implementing surface use restrictions within the SRMAs and increasing the management of 

these areas would help to reduce the degree of impact from recreational and other uses. Encouraging 

primitive types of recreation and prohibiting surface disturbance from oil and gas development in the 

Kanab Community SRMA (non-motorized RMZ), Paria SRMA (uplands RMZ), Orderville Canyon 

SRMA, and North Fork Virgin River SRMA (37,700 acres, 7 percent) would help to reduce impacts on 

vegetation communities from recreational use. 

The commercial harvest of forest and woodland products and associated surface disturbances would 

remove seedlings, understory vegetation, and mature trees where harvest occurs. Protecting riparian areas 

from all surface uses and disturbances through protective stipulations and not allowing surface 

disturbance within 330 feet of riparian/wetland areas would minimize the potential for these impacts on 

riparian/wetland communities. Monitoring riparian conditions, as needed, for any surface uses that could 

affect riparian areas would help ensure that appropriate action to protect these vegetation communities are 

taken before functioning conditions become impaired. Over the long term, the harvest of forest and 

woodland products would increase penetration of light to understory vegetation (i.e., grasses and forbs) 

and could also increase diversity, composition, and structure, reduce fuel loads, and maintain a variety of 

successional stages. This, in turn, would make forests and woodlands more resilient to disease, drought, 

fire, invasion by non-native species, and other natural disturbances/stressors. 
 Vegetation 

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Kanab RMP 4-25 

Limits or Restrictions on Surface Uses and Disturbances 

Implementing BMPs to minimize detrimental impacts on soils and water quality from ground disturbing 

activities and maintaining and/or enhancing riparian areas through project design features and/or 

stipulations would help to reduce soil erosion, surface runoff, and sedimentation of streams. This would 

help to maintain or improve upland vegetation and riparian/wetland communities. Making necessary 

management adjustments to meet watershed objectives (e.g., Upper Sevier River Watershed Management 

Plan, Standards for Rangeland Health, and Utah Riparian Management Policy [UT 2005-091]) and 

protecting municipal water supplies through restricting OHV and livestock grazing where necessary in 

key watershed areas generally would maintain or improve upland vegetation and riparian/wetland 

communities and reduce trampling and/or removal of understory vegetation in key watershed areas. 

Incorporating design and operation stipulations on new or amended ROWs as necessary to protect 

riparian and aquatic resources, and to monitor riparian conditions, as needed, for any surface disturbing 

activity, would maintain or improve upland vegetation conditions and riparian/wetland communities and 

could reduce removal of vegetation. 

Management actions for resources and resource uses that apply stipulations to surface disturbing activities 

could help maintain or improve upland, riparian, and forest and woodland conditions. These management 

actions include areas open to oil and gas leasing subject to moderate constraints (timing limitations, CSU) 

(296,200 acres), areas open to oil and gas leasing subject to major constraints (NSO) (83,400 acres), and 

areas closed to oil and gas leasing (79,000 acres) (Map 14). 

In addition to oil and gas leasing stipulations, stipulations on locatable mineral withdrawals (9,500 acres) 

and mineral material closures (105,000 aces) could similarly help maintain or improve upland, riparian, 

and forest and woodland conditions. The Cottonwood Canyon ACEC and suitable WSR corridors would 

be recommended for withdrawal from locatable minerals (Map 12) and closed to mineral material 

disposals (Map 16). In addition, areas managed as no surface disturbing actions (23,800 acres), areas with 

seasonal limitations on surface disturbing actions (407,500 acres) (Map 19), ROW exclusion areas 

(75,700 acres) (Map 11), and areas closed to OHV recreation use (25,000 acres) would further restrict 

surface disturbing activities. These restrictions would help reduce associated impacts on upland 

vegetation, riparian/wetland communities, and forests and woodlands. 

Management of special status species could affect vegetation though habitat improvements and land use 

restrictions. Controlling surface disturbing and disruptive activities to minimize impacts on identified 

crucial habitat for sensitive species, applying BMPs to avoid or reduce habitat fragmentation, prohibiting 

surface disturbing activities within 1⁄2 mile of active or suitable Utah prairie dog habitat, applying a CSU 

stipulation to relocate well placement in federally listed and candidate plant species occupied and suitable 

habitat, and applying an NSO stipulation within 1⁄2 mile of Greater sage-grouse leks would all help to 

maintain or improve upland, riparian, and forest and woodland conditions. These actions could also 

constrain vegetation treatments (including fire use), treatment methods, and size of the treatment; 

however, applying exceptions, waivers, or modifications to treatments (Appendix 3) could allow 

treatments that improve habitat. Maintaining or improving stream habitat in special status fish habitat 

would help to maintain or improve the composition and vegetation cover in upland and riparian 

communities. 

Cross-country OHV use would be precluded in fragile soil areas and additional efforts would be 

conducted to reclaim areas subject to surface disturbances and temporary roads. This would further 

reduce soil erosion and maintain or improve upland and riparian communities. 

Implementing mitigation measures to minimize impacts on water quality and prohibiting surface 

discharge of produced water in the Colorado River Basin would reduce soil and salt loads to water 
Vegetation 

Chapter 4 Proposed RMP and Final EIS 

4-26 Kanab RMP 

sources and help maintain appropriate stream discharge rates. This would in turn maintain or enhance the 

composition of upland and riparian communities. Not allowing new surface disturbing activities within 

330 feet of riparian/wetland areas generally would maintain or improve upland and riparian vegetation 

conditions. 

Implementing additional measures to manage and improve vegetation, including managing vegetation 

resources to achieve 51 percent or more of the potential natural community (PNC) and using the full 

range of vegetation treatment methods and tools, could improve vegetation health. Vegetation resources 

would be managed to achieve 51 percent or more of PNC, which would create a target for rehabilitation 

efforts that could increase the extent of successfully rehabilitated areas. Restoring forest and woodland 

old-growth stands to a pre-fire-suppression condition could increase tree spacing and encourage 

understory vegetation in these areas. 

VRM Class I areas would increase to 76,000 acres (14 percent) and VRM Class II areas would increase to 

94,400 acres (17 percent) under the Proposed RMP. This would further reduce the extent of surface 

disturbance and thereby reduce related surface and vegetative disturbance. 

Management prescriptions associated with ACECs would restrict surface uses that could otherwise result 

in removal and disturbance of vegetation. Managing the Cottonwood Canyon ACEC (3,800 acres) as a 

VRM Class II area and requiring NSO stipulations on new oil and gas leases would reduce the extent of 

surface disturbance in the ACEC in upland and riparian communities and forests and woodlands. 

Managing WSRs would include surface use restrictions. Such restrictions would reduce surface 

disturbance and related vegetation removal, and thereby help to maintain existing upland and 

riparian/wetland communities. Only six eligible river segments (5,530 acres of river corridors, 1 percent) 

would be determined suitable and managed to protect their outstandingly remarkable values (ORV)), freeflowing nature, and tentative classification. 

Vegetation Management and Habitat Manipulation 

Management of vegetation resources generally would enhance upland communities, riparian/wetland 

communities, and forests and woodlands. Continued implementation of noxious weed and invasive 

species control actions to prevent and control their spread would reduce competition with desirable plant 

species and help maintain or improve the health of these three vegetation communities. Applying the 

Standards for Rangeland Health to all uses in management of rangelands would help manage surface uses 

properly and help maintain or improve vegetation conditions. 

Habitat improvements for special status species and fish and wildlife could maintain or improve 

vegetation conditions. However, surface disturbance restrictions intended to protect special status species 

and fish and wildlife, such as prohibiting disruptive activities within 1⁄2 mile of bald eagle nests and 

Mexican spotted owl nests, could also restrict opportunities for vegetation treatments, including fire use, 

but applying exceptions, waivers, or modifications to treatments (Appendix 3) could allow treatments that 

improve habitat. 

Vegetation treatments (e.g., wildlife habitat treatments, watershed treatments, livestock rangeland 

treatments, fuels treatments, and stewardship contracting) on an annual average of no more than 22,300 

acres (446,000 acres over the life of the plan), using the full range of vegetation treatment methods and 

tools (i.e., prescribed fire, mechanical, chemical, biological, woodland product removal, and wildland fire 

use), would help maintain or improve the health of vegetation communities. Prioritizing treatments to 

restore areas functioning at less than 51 percent of PNC, restore areas with noxious weeds and/or invasive 

plants, maintain previously treated areas, and achieve other objectives identified in this RMP likely would 

further improve vegetation conditions in upland areas and riparian/wetland areas. Treatments would be 
 Vegetation 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-27 

conducted in areas containing ponderosa pine, which likely would increase tree spacing, improve 

vegetation diversity, reduce fuel loads, and reduce the potential for larger crown fires and associated loss 

of ponderosa pine stands. Prioritizing rehabilitation efforts and management adjustments in functioning 

at-risk and then non-functioning riparian areas would create a process to maintain or improve vegetation 

conditions in upland and riparian communities and forests and woodlands. 

Prioritizing land treatments to reduce soil loss by watershed and reclaiming associated disturbances would 

further maintain or enhance vegetative conditions. Allowing vegetation treatments in fragile soil areas 

where such treatments would over the long term reduce erosion and restore watersheds would maintain or 

improve vegetation conditions in fragile soil areas. In addition, these actions would help to reestablish 

seedlings and understory vegetation and retain soil moisture and nutrients. 

Wildland Fire 

Using wildland fire and prescribed fire to protect, maintain, and enhance resources could help improve 

vegetation conditions. Frequent, low-intensity fires are necessary to rejuvenate aspen stands, minimize 

understory fuel loads that could otherwise lead to larger crown fires, and minimize pinyon-juniper 

encroachment. Fire use through an AMR would also reduce the occurrence of catastrophic fires and 

stand-replacing fires and thereby help to maintain desired vegetation cover. Fire use would help increase 

vegetative diversity and resistance to disease and insect pest infestations because it would help improve 

the ecological health of treated vegetation communities. This type of fire management could decrease the 

risk of establishment of noxious weeds and invasive plant species over the long term. 

Suppressing wildland fires in upland and riparian communities could limit fire from functioning in its 

natural role, which could reduce resistance to disease and insect pest infestations and increase the risk of 

uncharacteristically large or intense wildfires that could alter upland and riparian communities. In forest 

and woodland communities, suppressing wildland fire can alter natural disturbance regimes, which in turn 

can alter the distribution and health of aspen, ponderosa pine, and pinyon-juniper woodlands. This could 

also reduce resistance to disease and insect pest infestations and increase the risk of stand-replacing 

wildfire. However, using non-fire fuels treatments could reduce the potential for these impacts to occur. 

Although suppression actions can create surface disturbances and remove vegetation, implementing ESR 

actions after suppression activities could help to mitigate these impacts and foster regeneration of desired 

communities. 

Summary 

Vegetation treatment management actions under the Proposed RMP would provide measures to manage 

and improve vegetation, which would generally maintain or improve the overall health of vegetation 

communities. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of vegetation resources under any of the 

alternatives. Long-term impacts on vegetation structure, composition, and health could be restored. 

Short-term use of an area to accommodate energy and minerals, ROWs, and cross-country OHV use 

could result in long-term loss of vegetation diversity and increases in noxious and invasive species that 

could deteriorate the health of the vegetation community. The limited extent of foreseeable development, 

mitigating management actions, and application of BMPs would minimize the decreases in long-term 

productivity from short-term uses. 
Vegetation 

Chapter 4 Proposed RMP and Final EIS 

4-28 Kanab RMP 

Surface disturbing activities could result in unavoidable adverse impacts, although these impacts could be 

mitigated to the extent possible. Permanent conversion of areas to other uses such as transportation and 

mineral and energy development would decrease vegetated areas. Applying BMPs, site-specific 

mitigation efforts, and restoration would decrease these impacts to the degree possible. Permanent 

mineral developments and their associated infrastructure would be mitigated to the extent possible to 

minimize loss of range resources. 
 Special Status Species 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-29 

4.2.5 Impacts on Special Status Species (Threatened, Endangered, 

and Sensitive) 

This analysis focuses on impacts on special status species, including federally listed species, federal 

proposed and candidate species, BLM sensitive species, and Utah sensitive species, as a result of 

management actions that affect species or their populations and changes to the condition of their habitats. 

Although some data on known locations and habitats within the decision area are available, the data is 

neither complete nor comprehensive on all special status species known to occur or on potential habitat 

that might exist. Known and potential special status species and habitat locations were considered in the 

analysis; however, the potential for species to occur outside these areas was also considered and, as a 

result, some impacts are discussed in more general terms. Impacts on other fish and wildlife species and 

their habitats are addressed in the Fish and Wildlife section. 

Various laws, regulations, and policies require that special status species be fully analyzed in any BLM 

decision that could affect those species or their habitat. Analysis would include inventory, monitoring, 

evaluation, and identification of mitigation of effects. Mitigation actions would include project relocation 

or redesign (avoidance), monitoring, and site-specific mitigation. 

Although information on locations of all special status species sites in the decision area is incomplete, the 

analysis considers the management alternatives and their potential to directly or indirectly affect special 

status species resources, as noted above. The number of species that could be affected by various actions 

is directly correlated with the degree, nature, and quantity of surface disturbing activities in the decision 

area. Impacts are quantified where possible. In the absence of quantitative data, best professional 

judgment was used. Some of the decisions in this document are programmatic; others may be 

implemented immediately (i.e., route designation, oil and gas leasing stipulations and conditions). To 

ensure preservation of specific species, further analyses will be required at the implementation level 

following site-specific species inventories. 

Three general categories of impacts would be anticipated to be the most influential on special status 

species and their habitat—habitat alteration, fragmentation, and/or loss; displacement; and habitat 

enhancement. Habitat alteration occurs when decisions change the existing habitat character. Surface 

disturbing activities, development, or other activities that degrade habitat could lead to habitat alteration, 

fragmentation, or loss. Habitat alteration, fragmentation, and loss may affect the usable ranges and routes 

for special status species wildlife movement. In addition, loss of habitat for pollinators of special status 

plants could result in the decline or loss of special status plant populations. Special status species wildlife 

displacement occurs when land use activities result in the movement of wildlife into other habitats, 

increasing stress on individual animals, and increasing competition for habitat resources. Impacts on 

special status species from displacement depend on the location, extent, timing, and/or the intensity of the 

disruptive activity or human presence. Occurrences of these disruptive activities in areas adjacent to 

special status species habitat cause displacement of special status species wildlife. Impacts from 

displacement could be greater for special status species wildlife with limited existing habitat and/or a low 

tolerance for disturbance. Habitat maintenance and enhancement can maintain or improve the condition of 

vegetation and levels of forage species and maintain existing erosion rates or reduce soil loss through 

vegetation treatments and restrictions on surface disturbing activities. 

The following assumptions were used in the analysis: 

• Local populations are naturally affected by non-human-caused factors such as climate, natural 

predation, disease outbreaks, natural fire regimes, and competition for available habitat from 

other native species. 
Special Status Species 

Chapter 4 Proposed RMP and Final EIS 

4-30 Kanab RMP 

• Ground disturbing activities could lead to modification (positive or negative), loss (short-term or 

long-term), or fragmentation of special status species habitat and/or loss or gain of individuals, 

depending on the amount of area disturbed, species affected, and location of the disturbance. 

• Changes in air, water, and habitat quality could lead to direct impacts and could have cumulative 

impacts on species survival. 

• Impacts on special status species could be more significant than impacts on non–special status 

species. 

• The U.S. Fish and Wildlife Service (USFWS) would be consulted on any action that could 

potentially affect any listed plant or animal species or their habitat. 

In accordance with Section 7(a) 2 of the Endangered Species Act of 1973 (ESA), as amended, the BLM 

KFO initiated Section 7 consultation with the USFWS. This process involves preparing a biological 

assessment (BA) that includes impact analyses and subsequent determinations for all federally listed and 

proposed species. The BA considers potential project-related effects (direct and indirect) on each species 

and its habitat from the management actions presented in the Proposed RMP. Additional consultation 

with the USFWS would still be required for all implementation-level activities if they would be 

implemented within suitable or potentially suitable habitat for federally listed species. 

Under the Proposed RMP, impacts on special status species are not anticipated as a result of 

implementing management actions for the following resources and designations: air quality and other 

designations. 

Proposed RMP 

Habitat Alteration, Fragmentation, and/or Loss 

Some of the goals and wildland fire ecology decisions provide for the restoration of historical habitats and 

native plant species and to enhance, maintain, and protect ecological resources. Short-term loss of habitat 

would be offset by long-term effects of rehabilitation activities, protection of ecological resources (from 

effective fire suppression), and reduction of fuels (following prescribed fire, non-fire fuel treatment, or 

implementation of wildland fire use). The subsequent, gradual return to a more natural fire regime would 

result in long-term habitat enhancement.

Effects of fire on special status species and their habitat vary widely depending on the vegetation type 

with which the species is associated and the size and intensity of the fire, fuel type, location, topography, 

season, and duration. For example, special status species habitat associated with aspen is less likely to be 

destroyed or severely altered by wildland fires than special status species associated with sagebrush, 

because aspen stands do not easily burn and often act as natural fuel breaks during wildland fires. Most 

sagebrush species do not sprout after fire, and most plants are killed by low- to high-intensity fires. The 

result of wildfire in special status species habitat associated with native grasslands would be similar to 

that in sagebrush because native grasslands are usually seral to sagebrush, and so have a similar fire 

regime. Wildfire in most mountain shrub communities would be similar to that in aspen stands because 

most species of mountain shrubs resprout following low- to moderate-severity fire. Sprouting mountain 

shrub communities generally recover following wildland fire and are considered fire-tolerant. Highseverity fire can destroy large areas of habitat and make the recovery of those habitats a long-term 

process. Both low- and high-severity wildland fires can destroy important habitat, displace animal 

species, and inflict direct mortality. However, low-severity fires have the potential to enhance and sustain 

a more natural and beneficial habitat. Wildland fire suppression activities have the highest potential for 

effects on special status species because resource protection measures would not necessarily be fully 

implemented due to risks to firefighters or public safety, and because emergency fire suppression action 

sometimes requires a quick response without detailed, site-specific data or analysis. Examples of impacts 

from wildfires include heat stress or mortality to special status plants from wildland fire operations; 
 Special Status Species 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-31 

damage to the seedbank of special status plants from severe fire or mechanical disruption during fire 

suppression operations; and removal of key habitat components for nesting, denning, foraging, roosting, 

or cover due to equipment use or operational tactics. Prescribed fire could have similar effects; however, 

due to site-specific project plans for prescribed fire, the BLM would minimize or avoid these effects. 

With suppression being implemented where unplanned wildfire is not desirable, and wildland fire use, 

prescribed fire, and non-fire fuel treatments being used to minimize fuel loading, vegetation communities 

and wildlife habitats would transition over time to more closely reflect conditions associated with a 

habitat’s natural fire regime. This would create a more balanced (diverse) and stable ecosystem that 

would have a reduced threat of severe wildland fire. 

Authorized excavation of cultural sites and paleontological localities could result in localized loss of 

special status species habitat. The short- and long-term impacts associated with these actions would not be 

detrimental to the species and their associated habitat given the limited footprint of such actions on the 

landscape. 

Unlike permitted activities (e.g., mineral exploration and development, ROWs, SRPs, and forestry and 

woodland harvest) that are subject to site-specific environmental review and monitoring, recreation and 

OHV activity would have limited special status species reviews before each use, which could result in 

effects to special status species as dispersed use increases over time. Dispersed recreation users could 

inadvertently trample special status plant species or damage special status species habitats while camping, 

hiking, or exploring. Humans, pets, and vehicles could also act as dispersal agents for invasive weeds, 

which degrade special status species habitat. Although damage to special status species habitats would 

continue to be monitored, impacts from dispersed use would not be apparent until after the damage has 

occurred, which would then be appropriately mitigated to the extent practical and feasible. 

Constructing new trails and recreation facilities, which would be subject to site-specific environmental 

NEPA review, could introduce new areas of surface disturbance and concentrate human presence, 

depending on the location of the trails/facilities, in sensitive special status species habitat. This could 

decrease special status species populations or cause special status species displacement and provide 

avenues for the spread of noxious weeds, which could result in modification of a special status species 

forage base. 

Managing OHV use throughout the majority of the decision area (528,000 acres, 95 percent) as limited to 

1,403 miles of designated routes would minimize surface disturbances to special status species and their 

habitats, greatly reducing surface disturbance of special status species habitat. The 1,000 acres open to 

cross-country OHV use would occur within areas that have been subject to disturbance over the past 

several years, either through natural processes (e.g., sand dunes) or human use (e.g., topsoil pit). 

Continued disturbance in the topsoil pit would not result in any additional loss of habitat values causing 

little to no effects on special status species and associated habitat. In the case of the Coral Pink Sand 

Dunes tiger beetle, Knisley and Gowan (2005) determined that a decline in population numbers was likely 

a result of ensuing drought in the area and that the presence of the protected area did not prevent wide 

swings in beetle abundance. They did determine, however, that the protected area may play a critical role 

during years of low abundance because when populations are low, beetles concentrate in the protected 

areas, and having a refuge from OHV activity is critical given the small population. In the case of Welsh’s 

milkweed, because the milkweed is a pioneer species and prefers unvegetated dune sites, as communities 

expand from vegetated areas into unvegetated dunes individual plants could be affected by uses in these 

areas. 

Precluding cross-country OHV use in Greater sage-grouse nesting and brood-rearing habitat would 

prevent habitat alteration or loss from OHV activity. Seasonally limiting OHV use within nesting and 

roosting sites for special status species raptors would provide protection to these species during sensitive 
Special Status Species 

Chapter 4 Proposed RMP and Final EIS 

4-32 Kanab RMP 

life stages, and protection of habitat would occur outside of the seasonal limits due to OHV use being 

limited to designated routes. Prohibiting motorized use in and through islands of vegetation in designated 

critical habitat for Welsh’s milkweed (790 acres) would provide immediate protection for the species; 

however, indirect effects of the shifting nature of the dunes could result in difficulty monitoring and OHV 

user self-policing, which could result in take of some plants. Esplin (2005 and 2006) determined that 

Welsh’s milkweed moves with the dunes and is, therefore, more susceptible to stem damage from OHV 

use (plants were shown to survive with damage); however, no reliable correlation could be made in his 

research between OHV use and decreasing stem counts. Esplin (2005 and 2006) concluded that Welsh’s 

milkweed thrives and competes best in actively moving dunes and that the most likely factor affecting 

survival of the plant is competition from other vegetation. Closing an overall 25,000 acres and 75 miles of 

routes to OHV use would provide protection of special status species and associated habitat from OHV 

impacts. 

Precluding cross-country OHV use and avoiding ROWs with high-profile structures within 1 mile of 

active leks or in nesting and brood-rearing habitat would provide protection to sage-grouse habitats. 

Managing oil and gas leasing as open to leasing subject to major constraints (NSO) within 1⁄2 mile of leks 

would provide direct protection to leks from surface disturbance associated with oil and gas development, 

and allowing no surface disturbing or otherwise disruptive activities within 2 miles of active Greater sagegrouse leks during strutting and nesting and brood-rearing seasons would minimize or eliminate 

disturbance during sensitive periods. Avoiding insecticide use during the early development stages of 

sage-grouse chicks would increase their survivability. 

Permitted surface disturbing activities cause habitat alteration, fragmentation, and/or loss depending on 

the type, amount, and location of activity. Habitat fragmentation occurs when a contiguous habitat is 

broken up (fragmented) by surface disturbing activities, causing a reduction in usable ranges; disruption 

of movements among habitats, transitional areas, and breeding areas; isolation of smaller, less mobile 

species; and increase in habitat generalists that are characteristic of disturbed environments (Harris 1991). 

Allowing oil and gas leasing subject to the standard terms and conditions on 95,400 acres could result in 

fragmentation through reduction of usable habitat and disruption of movements among habitats, 

transitional areas, and breeding areas associated with the construction of access roads, facilities, and 

wells. Oil and gas exploration and development activities would disturb approximately 2,976 acres over 

20 years. Approximately 2,370 acres would be reclaimed within 20 years. Authorized wells would not be 

anticipated to adversely affect species populations; however, population function could decline and 

become significant as development increases. Species that have expansive habitat requirements in areas 

that do not restrict mineral activity, such as the BLM Sensitive Greater sage-grouse and other sagebrushobligate species could be indirectly affected by loss of important habitat components resulting from 

introduction of noxious and invasive weeds, and conversion of large areas to early seral vegetation as well 

pads are reclaimed. Disturbance to habitats could displace special status species and the possible longterm habitat deterioration could eliminate potential habitat that might otherwise foster expansion of 

special status species from current territories. On the contrary, conversion of large expanses to early seral 

vegetation could provide additional habitat that fosters some special status species, such as the Utah 

prairie dog. Big game winter range oil and gas development timing limitation stipulations would 

indirectly provide temporary refuge for special status species sensitive to activity that may occur in 

conjunction with these areas; however, it would not provide long-term protection of habitat. 

Stipulations on disturbance in special status species habitat would decrease the potential for the impacts 

from surface disturbance associated with oil and gas exploration and development. In general, areas open 

to oil and gas leasing subject to moderate constraints (timing limitations, CSU) (296,200 acres) would 

enable the BLM to provide some protection of special status species habitat by controlling where 

development activities occur; however, overall reduction in usable habitat and disruption of movements 

among habitats associated with the construction of access roads, facilities, and wells could still occur in 
 Special Status Species 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-33 

these areas. Areas open to oil and gas leasing subject to major constraints (NSO) (83,400 acres) would 

protect and enhance special status species habitat characteristics from oil and gas development activities. 

Closing areas (79,000 acres) to oil and gas leasing consistent with BLM interim management policy 

would protect and enhance special status species habitat characteristics from oil and gas development 

activities. 

Forest and woodland harvest, road construction, facility construction, other mineral development and 

construction of associated facilities, and ROW construction could result in the loss of special status 

species habitat. Special status species habitat losses include potential habitat for special status species 

plants; cover for small mammals and reptiles; winter concentration, nesting, and foraging habitat for 

birds; and roost and foraging areas for bats. In addition, the loss of habitat for pollinators of special status 

plants could result in the decline or loss of special status plant populations. Seclusion areas for special 

status wildlife species would become smaller, more fragmented, and dispersed in these areas, which could 

lead to a decrease in special status species wildlife populations as a result of habitat loss. Surface 

disturbing activities could increase sediment delivery to streams, which could interfere with the life 

history requisites of special status fish. Excluding outstanding natural areas and areas of recent surface 

reclamation from wood product disposal, prohibiting cutting of standing ponderosa pine, and maintaining 

live or dead standing trees would reduce the effect of commercial forest and woodland product harvest on 

special status species habitat and provide direct protection to some species of special status raptors. These 

measures would also reduce or eliminate displacement of raptors from nesting areas. Forest and woodland 

product harvest would be allowed in the entire decision area on a case-by-case basis. However, the 

current and anticipated low demand for forest and woodland products would result in minimal impacts. 

Management of locatable minerals and mineral materials would result in short-term localized and indirect 

impacts on special status species and associated habitat through surface disturbance and habitat loss. 

Impacts would be minimal for locatable mineral development because a plan of operation, including a 

reclamation plan, is required prior to development of locatable minerals. Surface disturbance from 

development of locatable minerals and mineral materials would be approximately 1,050 acres over 20 

years; site-specific impacts would be addressed prior to development. The development of locatable 

minerals and mineral materials could cause localized impacts on special status species through the 

disturbance of habitat. 

In general, ROW development (including powerlines, pipelines, wind and solar projects, and 

communication sites) would disturb habitats that could be occupied by special status species where ROW 

developments are authorized. Most ROWs would be located in common (within existing or shared 

ROWs), which would result in concentrated surface disturbances and habitat deterioration or loss. Special 

status plants would be most affected by ROW development due to their inability to seek alternative 

habitats, whereas the majority of special status wildlife could seek alternative habitats if available. ROWs 

located in common could also reduce the degree of habitat fragmentation within the decision area if 

properly located outside of or on the fringe of special status species habitat. Locating ROWs in common 

could actually increase habitat loss or fragmentation if improperly located through habitat. 

Designing road crossings to support fish passage in areas that support fish would allow for areas to be 

recolonized from a neighboring population and allow natural movement of fish populations in fisheries. 

This could also allow for movement of more aggressive introduced species into special status fish species 

habitat. 

Displacement 

Recreation activity likely would have an effect on special status species and their habitats. Motorized use 

would have greater effects than non-motorized use. Users could introduce noise that could disturb species 

during sensitive periods, which could indirectly affect reproduction or cause species to abandon areas, 
Special Status Species 

Chapter 4 Proposed RMP and Final EIS 

4-34 Kanab RMP 

such as nest sites or areas containing key habitat components containing important food sources. Stress 

inflicted on species could also deteriorate species health, which could affect survivability. Displaced 

wildlife incurs a physiological cost through excitement (preparation for exertion) and/or through 

locomotion. A fleeing or displaced animal incurs additional costs through loss of food intake and 

potential displacement to lower quality habitat. Chronic or continuous disturbance could result in reduced 

animal fitness and reproductive potential, and abandonment of young (mortality) (Geist 1978). Effects 

likely would be greater in areas that receive frequent and/or intense recreation use; however, the number 

of areas of frequent and/or intense recreation use is small. Areas that would be subject to more visitation 

would include easily accessible locations, such as along major roads, near communities, or in areas that 

offer attractive opportunities for recreation. Although damage to special status species habitats would 

continue to be monitored, impacts from dispersed use would not be apparent until after the damage has 

occurred, which would then be appropriately mitigated to the extent practical and feasible. 

Allowing cross-country OHV use (more than 1,000 acres) on 1,403 miles of designated routes in areas 

where OHV use is limited to designated routes (528,000 acres, 95 percent) would result in the 

displacement of special status species through the human presence, noise, dust, and disruptive activities. 

Areas closed to OHV use (25,000 acres, 5 percent) or areas away from designated routes where OHV use 

is limited to designated routes would avoid impacts associated with disruption and preserve habitat 

characteristics. 

Vegetation treatments on an annual average of no more than 22,300 acres would result in temporary 

displacement of special status species wildlife during treatment. However, over the long term, the treated 

areas would provide improved forage conditions and reduced erosion, which would enhance special status 

species wildlife habitat and fisheries. 

Permitted activities (including mineral exploration and development, ROW and facility construction, and 

other activities subject to site-specific NEPA evaluation and monitoring) could result in displacement of 

special status species from noise and human presence associated with these activities. Construction and 

maintenance noise associated with mining, vehicular traffic, and other human activities could cause 

disturbances to species during sensitive periods, which could potentially cause special status species to 

abandon roosts or nest sites. BLM management of areas allowable for permitted activity and protection of 

special status species habitats could reduce any potential for cumulative habitat degradation, such as NSO 

and seasonal closures. NSO buffers for special status species and their habitats would afford direct 

protection to those species and refuge for special status species sensitive to activity that could occur 

within these areas. Seasonal closures of special status species habitats would provide direct protection 

from disruptive activity during sensitive periods. 

The possibility of increased human presence in SRMAs, concentrating around staging areas, trails, and 

other developed recreation sites, could displace wildlife species from habitat surrounding interpretive 

sites and result in trampling, collection, and other inadvertent removal of plant species, depending on the 

location and level of human presence associated with the site. Mitigation (e.g., timing, location, and group 

size limits) would be identified during site-specific NEPA analysis, thus reducing the potential for 

impacts. Increasing management presence in SRMAs (95,100 acres, 17 percent) would decrease impacts 

from dispersed recreation activities. Implementation plans for each SRMA could include mitigations to 

avoid special status plant species and minimize trampling of plant species. Management of recreation by 

allowing dispersed camping could result in trampling and removal of special status plant species and 

likely would result in minor localized harassment of special status species wildlife due to human presence 

and disruptive activities. 

Special status species habitat within the Alton coal field could be lost in the short and long term due to 

surface coal mining activities on and adjacent to these areas. Specifically, this would affect the southern-
 Special Status Species 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-35 

most population of the Greater sage-grouse. Although the federally administered coal resources do not 

coincide with the lek used by the local population, the development of the coal mine would eliminate 

habitat resources on brood-rearing habitat and habitat adjacent to the lek. Development of the coal mine, 

removal of the overburden, and surface mining operations would result in the long-term (life of the RMP) 

loss of habitat resources and displacement of individual birds. Although mitigation and reclamation could 

reduce the impacts, development of the coal mine could result in displacement or loss of the local 

population. 

Closing raptor areas (including those associated with special status species) to rock climbing could result 

in the elimination of long-term disruptive effects on nesting activities during sensitive periods, which 

could indirectly affect reproduction and cause species to not abandon areas. Limiting SRP groups to 12 

people per group within wetland or riparian zones, WSAs, and designated critical habitat for special status 

species and limiting SRP groups to 25 people per group in the remainder of the decision area could reduce 

the effects of displacement from large groups of people. 

Habitat Maintenance and/or Enhancement 

Implementing decisions to increase populations of special status species, developing and implementing 

monitoring and conservation measures for listed and sensitive species and their habitats, and working 

with the Utah Division of Wildlife Resources (UDWR) and other partners to implement the Utah 

Comprehensive Wildlife Conservation Strategy (UDWR 2005a) for preventing the need for further listing 

of species would protect and foster recovery of special status species and maintain habitat conditions. 

Impacts on special status species from applying Standards for Rangeland Health to all rangelands and 

Guidelines for Grazing Management for BLM Lands in Utah (BLM 1997a) for rehabilitation of 

rangelands would offer protection for special status species and assist in maintaining or improving the 

ecological health and condition of rangeland ecosystems over the long term, which could provide 

necessary habitat components for special status species. 

Focusing vegetation treatments on identified high-priority areas and increasing the potential treatment 

acres would target areas where habitat function could be most improved; site-specific impacts would be 

addressed prior to treatment. In addition, treatments associated with maintaining or restoring special 

status species habitat, including Greater sage-grouse, would improve overall habitat conditions for these 

species. This would result in an increase in habitat components, including increased forage and shelter. 

Vegetation treatments on an average of no more than 22,300 acres annually could maintain natural 

disturbance rates. 

General vegetation management of rehabilitation objectives, including managing for 51 percent or higher 

of PNC, would maintain available forage and maintain or enhance special status species habitat. 

Vegetation management in riparian areas would maintain or improve special status species habitat 

conditions, provide direct protection of special status species habitat, and retain adequate water supply to 

support fisheries. Protecting hanging gardens could have similar results in these areas. Restoring 

sagebrush steppe communities and old-growth forest and woodland stands would improve the long-term 

ecological health and habitat condition. Treatments for sagebrush steppe restoration could cause 

temporary disturbances to special status species occupying these areas. 

Management of noxious and invasive species would improve the ecological health and condition in 

treated areas over time, which may provide necessary habitat components for special status species, but 

could cause temporary disturbances to special status species occupying treated areas. Closing and 

reclaiming roads, facilities, or improvements that are no longer necessary could deter continued use of the 

area, resulting in reduced disturbance to special status species habitat. Reclaiming roads would enhance 

special status species wildlife habitat through removal of disturbed areas, increase in forage, and 
Special Status Species 

Chapter 4 Proposed RMP and Final EIS 

4-36 Kanab RMP 

reduction of habitat fragmentation. In addition, noise and disturbance associated with roads would be 

eliminated by reclaiming roads. 

Implementation of the Welsh’s milkweed and Siler’s pincushion cactus recovery plans would provide 

overall protection to maintain or improve habitat conditions for these species. In addition, prohibiting 

motorized use in and through islands of vegetation in designated critical habitat for Welsh’s milkweed 

(790 acres) would eliminate further potential disturbance to this species from these activities. 

Maintaining the overall stand health of pondersa pine, as opposed to just protecting trees under the current 

management situation, in addition to protecting bald eagle feeding and concentration areas, peregrine 

falcon use areas, and other raptor nest sites would provide direct protection to special status raptors and 

avoid and reduce habitat deterioration in areas occupied by special status species. These measures would 

also reduce or eliminate displacement of raptors from feeding and nesting areas, reducing or eliminating 

possible effects of increased stress and abandonment of the habitat. However, temporary disturbance from 

treatments to restore stand health would occur. Using Best Management Practices for Raptors and Their 

Associated Habitats (BLM 2006a) would provide for use of seasonal and spatial buffers, as well as 

mitigation, to maintain and enhance special status species raptor nesting and foraging habitat. 

The Proposed RMP would be more restrictive to surface disturbing activities than the current 

management situation. Areas that are closed to surface disturbing activities (23,800 acres, 4 percent), 

open to oil and gas leasing subject to major constraints (NSO), and closed to oil and gas leasing (162,400 

acres, 29 percent); areas withdrawn and recommended for withdrawal from minerals entry (24,591 acres, 

4 percent, and 9,500 acres, 2 percent, respectively); areas closed to mineral material disposals (105,000 

acres, 19 percent); ROW exclusion areas (75,700 acres, 14 percent) and ROW avoidance areas (106,670 

acres, 19 percent); and areas closed to OHV use (25,000 acres, 5 percent) would protect special status 

species habitat from such activities. These decisions include restrictions on uses of fish and wildlife 

habitat, special status species habitat, ACECs, SRMAs, WSAs, WSRs, and areas that are sensitive to 

disturbance (e.g., fragile soils and riparian/wetland areas). The reduction or elimination of development in 

these areas would limit surface disturbance, maintain special status species habitat quality, and reduce or 

eliminate the effects of displacement from human presence. Protection of fragile soil areas and 

implementation of erosion control measures would reduce erosion and surface runoff, which could 

enhance special status species habitat. Applying BMPs to avoid or reduce fragmenting habitat, and 

mitigating habitat losses for listed and sensitive species where appropriate, could avoid and reduce habitat 

fragmentation and losses for special status species. In addition, mitigation would be considered where 

appropriate, which could reduce habitat fragmentation and losses for special status species. 

Incorporating erosion control measures on slopes greater than 15 percent would further reduce erosion 

and surface runoff, which could enhance special status species habitat. In addition, cooperative 

implementation of the Upper Sevier Watershed Management Plan, managing the Sevier River in 

accordance with the total maximum daily load (TMDL), and avoiding or minimizing impacts on water 

quality could maintain or improve the conditions of fisheries. Managing the discharge of produced waters, 

including no surface discharge in the Colorado River Basin, would maintain special status species habitat 

by preventing possible degradation of water quality and fisheries. 

In general, management actions for bald eagles and Utah prairie dogs would provide direct protection to 

these species and associated habitats and avoid or reduce habitat deterioration in areas occupied by 

special status species. Management of the plague and other diseases in Utah prairie dog colonies could 

reduce the spread of plague in this species and others. 

Management actions for the Mexican spotted owl, such as permitting no surface activities or occupancy 

within 1⁄2 mile of Mexican spotted owl nests and no surface disturbing activities from March 1 to August 
 Special Status Species 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-37 

31 in protected activity centers (PACs), breeding habitats, or designated critical habitat, would provide 

direct protection and minimize disturbance to Mexican spotted owl nesting and fledgling habitat and 

minimize disturbance or harassment to Mexican spotted owl during the breeding season. These decisions 

would also provide habitat protection for other special status species that may also be sensitive to 

disruptive activities in these areas. Surveying would aid in identifying locations and distribution of 

Mexican spotted owl and other special status species and in protecting occurrences that are identified. 

Protective management measures for the Mexican spotted owl, including prohibiting new recreation 

facilities or trails within PACs, seasonal closures of existing facilities, and limiting SRP groups to 12 

persons per group or less would protect and enhance this species habitat and reduce human presence and 

disruptive activities. 

Management actions for the Western yellow-billed cuckoo and Southwestern willow flycatcher, such as 

monitoring and restricting authorized or casual use activities that may adversely impact Southwestern 

willow flycatchers or their habitats, would provide direct protection and minimize disturbance in Western 

yellow-billed cuckoo and Southwestern willow flycatcher habitats. These decisions would also provide 

habitat protection for other special status species that may be sensitive to disruptive activities. Surveying 

would aid in identifying locations and distribution of Western yellow-billed cuckoos and Southwestern 

willow flycatchers and other special status species and in protecting occurrences that are identified. 

Management actions associated with water quality and watershed health such as BMPs, protection of 

culinary water supplies, and water source protection zones could maintain or improve the conditions of 

riparian areas and water sources that may be occupied by special status species. Management of riparian 

areas through project design features or stipulations and water retention would maintain or improve 

special status species habitat conditions and retain adequate water supply for special status species. 

Permitting commercial timber harvest for the purpose of promoting forest health would improve the longterm health of forest habitats. However, this could cause temporary disturbances or displacement during 

project implementation. Site-specific impacts would be addressed prior to harvest. Management actions 

for woodland product harvest, such as closing WSAs to harvest except for incidental collection for onsite 

campfire use and administrative purposes, would provide a source of cover and habitat for prey species 

and ensure a prey base for raptors and other predators. Permitting woodland product harvesting in riparian 

areas in proper functioning condition (PFC) on a case-by-case basis for maintenance and/or improvement 

of riparian ecosystems could provide long-term habitat enhancement through overall forest health and 

habitat diversity. 

Management of ROWs and ROW corridors for the siting and construction of communication towers 

using measures to avoid and minimize impacts on migratory birds likely would minimize or eliminate 

loss of migratory birds from guy wires and other associated features of communication towers, enhancing 

overall habitat for migratory birds. Managing powerlines to reduce the risk of raptor electrocution or linestrike would reduce raptor injury and mortality. In addition, burying new and reconstructed utility lines 

could further reduce electrocution risks to raptors and collision potential for migratory birds. 

Implementing measures for protection and not allowing surface disturbing activities within 330 feet of 

riparian/wetland areas would minimize changes in stream characteristics, which could result in altered 

water chemistry (e.g., phosphorous loading), increased sediment loads, or elevated mineral concentrations 

(e.g., selenium). Reducing sediment loading in the decision area would protect important habitat 

characteristics of special status species fish in the decision area, and downstream in both the Virgin and 

Colorado River drainages. 

Restrictions on visually obtrusive developments on VRM Class I and Class II areas would limit 

development on approximately 170,400 acres, which would provide more protection to special status 

species and associated habitat from development activities within these areas. 
Special Status Species 

Chapter 4 Proposed RMP and Final EIS 

4-38 Kanab RMP 

Special designations (e.g., ACECs, WSAs, and WSRs) management could reduce or eliminate surface 

disturbance, thereby protecting special status species habitats. Management aimed at conserving 

vegetation and limitations on surface disturbing and other disruptive activities would maintain overall 

habitat conditions. Management of the Cottonwood Canyon ACEC would indirectly provide protection to 

special status species habitat characteristics from surface disturbances through stipulations on oil and gas 

leasing subject to major constraints (NSO), closures to mineral entry and disposal, and limiting OHV use 

to designated routes. Managing suitable river segments to protect their ORVs, free-flowing nature, and 

tentative classification would provide direct protection to wildlife ORVs within 3,770 acres of river 

corridors (21 miles). Management in WSAs consistent with BLM interim management policy would 

indirectly protect and enhance special status species habitat characteristics. 

Summary 

Habitat alteration, fragmentation, and/or loss occurs when habitat components needed for species survival 

(e.g., forage and cover) are removed or when contiguous habitat is broken up (fragmented) by surface 

disturbing activities. This results in a reduction in usable ranges and disruption of movements among 

habitats, transitional areas, and breeding areas (Harris 1991). 

Displacing activities may not directly affect components, but they force animals to move into less 

desirable habitat, increasing competition for available resources with other species and uses. Users could 

introduce noise or dust that could disturb species during sensitive periods, which could indirectly affect 

reproduction or cause species to abandon areas such as nest sites or areas that contain key habitat 

components such as important food sources. Stress inflicted on species could also deteriorate species’ 

health, which could affect survivability. Displaced wildlife incurs a physiological cost either through 

excitement (preparation for exertion) or through locomotion. 

Habitat maintenance and/or enhancement occur as a result of vegetation treatments to reduce soil loss, 

improve crucial big game habitat, restore ecological function, and increase forage production. In general, 

vegetation treatments would improve habitat conditions or provide missing habitat components, reduce 

sedimentation in water sources occupied by special status species, and improve wildlife habitat for special 

status species with similar forage requirements. These treatments could provide diverse habitats for 

various special status species. 

The Proposed RMP would provide protection for special status species and associated habitat. 

Management actions would prevent habitat alteration and surface disturbance in special status species 

habitat. The Proposed RMP would provide habitat maintenance and enhancement due to species-specific 

management (particularly for Greater sage-grouse), vegetation treatments that mimic natural processes, 

management of ACECs, and management of WSR-suitable segments. However, special status species 

habitat within the Alton coal field could be lost over the long term due to surface coal mining activities on 

and adjacent to these areas. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

Implementation of RMP management actions would result in surface disturbing activities, including 

dispersed recreation, OHV use, mineral and energy development, and ROW development, that could 

result in irreversible or irretrievable loss of wildlife habitat. Irreversible and irretrievable loss of wildlife 

habitat could reduce the amount of suitable special status species habitat that could be used for expansion. 

However, management prescriptions and mitigation prescribed under the alternatives are intended to 

reduce the magnitude of these impacts and restore some of the soil, vegetation, and habitat lost. 
 Special Status Species 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-39 

Laws protecting threatened and endangered species generally would provide for mitigation of irreversible 

and irretrievable impacts from permitted activities. Areas open to cross-country OHV use, specifically in 

designated critical or crucial habitat, could result in the loss of some resources, which would be 

individually irreversible. 

Short-term uses of BLM lands for some permitted activities could affect the long-term sustainability of 

some special status species habitat. Uses could affect species by displacing animals or removing plants 

from primary habitats and removing components of these habitats that may not be restored for more than 

20 years. For example, because translocation of Greater sage-grouse between populations has not proven 

successful, long-term loss of sage-grouse habitat due to oil and gas development and other mineral 

activity could result in the displacement and/or loss of localized sage-grouse populations. 

Unavoidable damage to special status species from permitted activities could occur if resources 

undetected during surveys were identified during ground disturbing activities. In such instances, activities 

would be halted upon discovery and mitigation would be implemented to minimize further damage to or 

loss of individuals. Unavoidable loss of species due to non-recognition, lack of information and 

documentation, and inadvertent damage or use could also occur.
Fish and Wildlife Habitat 

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4-40 Kanab RMP 

4.2.6 Impacts on Fish and Wildlife Habitat 

This section presents potential impacts on fish and wildlife habitat from implementing the Proposed 

RMP. Threatened and endangered species habitat impacts are addressed in the special status species 

section and in the BA. 

Wildlife populations fluctuate, sometimes widely, in response to natural factors such as wildfire, 

abundance or scarcity of forage or prey items, and climate extremes such as drought and severe winters. 

These factors make it difficult to discern potential impacts on wildlife resulting from specific 

management actions and from impacts caused by natural factors. Changes or stressors to habitat 

components (e.g., vegetation, water, soil, or air) are likely to cause direct and indirect effects on wildlife 

and fish. Therefore, potential effects on habitats are the principal focus of this assessment. 

Impacts on fish and wildlife include actions that result in habitat alteration, fragmentation, or loss; 

wildlife displacement; and habitat maintenance and enhancement. Habitat alteration occurs when 

activities alter the existing habitat character. Surface disturbing activities, such as energy developments, 

ROWs, road and trail construction, or other activities may reduce habitat quality or lead to habitat 

alteration, fragmentation, or loss. Habitat alteration, fragmentation, and loss affect the usable ranges and 

routes for wildlife movement. Wildlife displacement occurs when land use activities result in the 

movement of wildlife into other habitats, increasing stress on individual animals, and increasing 

competition for habitat resources. Impacts on fish and wildlife from displacement depend on the location, 

extent, timing, and/or the intensity of the disruptive activity or human presence. Occurrence of these 

disruptive activities over an extended period of time in areas on or adjacent to fish and wildlife habitat 

could cause either temporary or permanent displacement of wildlife. Impacts from displacement would be 

greater for those fish or wildlife species with limited existing habitat and/or a low tolerance for 

disturbance. Habitat maintenance or enhancement can maintain or improve vegetative conditions, reduce 

soil loss, improve soil water-holding capabilities, control the spread of invasive species, and restore 

ecological integrity. 

The following assumptions were used in the analysis: 

• If monitoring reveals that mitigation is unsuccessful in reducing or eliminating impacts, 

immediate measures to prevent further impacts would be implemented as appropriate to the 

species affected. 

• Impacts on big game populations that exceed the current population objective levels would not be 

considered significant if the impacts would not reduce the populations below the objective levels. 

• Sufficient habitat exists to maintain current fish and wildlife population objectives. 

• Disruptive activities would displace wildlife, although some wildlife adaptation would occur. 

Under the Proposed RMP, impacts on fish and wildlife are not anticipated as a result of implementing 

management actions for the following resources and designations: air quality and other designations. 

Proposed RMP 

Habitat Alteration, Fragmentation, and/or Loss 

Fire management activities have the potential to directly and indirectly affect fisheries and wildlife habitat 

throughout the decision area, depending on treatment timing, extent, location, elevation, duration, fuel, 

severity of fires, and habitat type or vegetation community and soil type of treated area. Effects on 

vegetation have the potential to directly or indirectly affect fish and wildlife species that inhabit them or 

areas adjacent to (or downstream from) them. 
Fish and Wildlife Habitat 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-41 

Resource protection measures would limit short-term and long-term impacts on fisheries and aquatic 

resources from wildland fire. Direct effects may result from the introduction of fire retardant aviation fuel 

or lubricants into streams and wetlands, erosion of exposed soils from fire line construction on steep 

slopes adjacent to streams, damaged riparian vegetation and soils (resulting in erosion) from the use of 

heavy equipment and establishment of fire camps, or reduced natural stream flow during water drafting 

and pumping. These impacts could degrade the water quality of fisheries. The collective short-term 

impacts of increased sedimentation (from erosion) could have watershed-wide adverse effects, including 

changes in temperature, turbidity, and water chemistry. Because actions to protect resources and projectspecific analyses would limit impacts of prescribed fire and would place constraints on non-fire fuel 

treatments in and adjacent to wetlands, riparian zones, and water habitats, short-term impacts from these 

fire management activities would be minimized or eliminated. Over the long term, wildland fire 

management actions would reduce the risk of severe wildland fire and associated suppression activities.

Wildland fire likely would affect suitable habitat used by raptors, migratory birds, small mammals, 

carnivores and predators, amphibians and reptiles, and a variety of habitats used by upland big game 

species. Resource protection measures would minimize short-term impacts on non-game and big game 

species (e.g., direct species mortality, habitat destruction, and habitat displacement). Direct effects from 

wildland fire suppression could include damaged vegetation (including forage resources) from the use of 

heavy equipment and establishment of fire camps, weed invasion, an increase in acres of undesirable 

habitat types, and a decrease in understory diversity and overall species richness (Adams and Simmons 

1999). These effects could cause species displacement and potential mortality. Indirect impacts could 

include changes in the survival or successful reproduction of aquatic prey species (e.g., for birds and 

carnivores) due to increased sedimentation and subsequent habitat modification as a result of upstream 

erosion. 

Resource protection measures would be considered and implemented, as appropriate, for wildland fire use 

and planned actions, and direct impacts on raptors and migratory birds would be limited to those 

associated with wildfire suppression activities. These include mortality, habitat destruction, and 

temporary displacement. Indirect impacts could include short-term reduction in available prey sources. 

Raptors and migratory birds found in desert and riparian/wetland habitats would be more likely to incur 

project-related impacts because these habitats are relatively far removed from their natural fire regimes.

Over the long term, mortality or long-term displacement of species likely would be reduced because 

wildland fire use and prescribed fire would not likely consist of large fires, and rehabilitation would be 

implemented as necessary and appropriate. Populations could be displaced for longer periods of time if 

management activities were implemented repeatedly within the same treatment area (e.g., mechanical 

treatment followed by prescribed fire followed by biological treatment). Long-term effects on habitat 

would include a gradual increase in species diversity that would more closely reflect conditions associated 

with a natural fire regime. 

Wildlife habitat contained within the Alton area could be lost due to surface coal mining activities on and 

adjacent to 3,600 acres. Reclamation activities, beginning within 3 years of initial disturbance, would 

begin to reestablish wildlife habitat in the disturbed areas. On average, 100 acres would be reclaimed per 

year. Sagebrush communities that are disturbed or removed take 20 to 100 years to reestablish; therefore, 

successful mitigation could result in the restoration of habitat values over the long term. 

Locating ROWs in common would result in concentrated surface disturbances and habitat deterioration or 

loss causing species to seek alternative habitats. Locating ROWs in common could actually increase 

habitat loss or fragmentation if improperly located through habitat. 
Fish and Wildlife Habitat 

Chapter 4 Proposed RMP and Final EIS 

4-42 Kanab RMP 

Authorized excavation of cultural sites, paleontological localities, or cultural inventories would have local 

and short-term impacts on wildlife and their habitats. The short- and long-term impacts associated with 

these actions would not be detrimental to wildlife and their associated habitat given the limited footprint 

of such actions on the landscape. 

Habitat fragmentation occurs when a contiguous habitat is broken up (fragmented) by surface disturbing 

activities. This may cause a reduction in usable ranges and disruption of movements among crucial 

habitats (Harris 1991). Under this alternative, more wildlife habitat would be protected by additional 

stipulations on oil and gas exploration and development. However, allowing oil and gas leasing subject to 

the standard terms and conditions on 95,400 acres could result in fragmentation through the reduction of 

usable habitat and disruption of movement among habitats, transitional areas, and parturition areas 

associated with the construction of access roads, facilities, and wells depending on the location and timing 

of development. Oil and gas exploration and development activities would disturb approximately 2,976 

acres over 20 years, which would constitute approximately 1 percent of the planning area. Approximately 

2,370 acres would be reclaimed within 20 years. Wildlife habitat not reclaimed (606 acres) in these areas 

would be lost due to oil and gas exploration and development. Overall, effects on fish and wildlife habitat 

would be relatively minor over the entire planning area. 

Forest and woodland product harvest, areas open to cross-country OHV use (1,000 acres, less than 1 

percent), road construction, facility construction, mineral development and construction of associated 

facilities, and ROW construction could reduce a source of cover for small mammals and reptiles, habitat 

for birds, and big game winter range and parturition areas. Concentrated cross-country OHV use could 

remove existing vegetation, which would result in increased runoff, thus reducing wildlife and fisheries 

habitat quality. Surface disturbing activities could increase sediment delivery to streams, which could 

interfere with the life history requisites of fish. Forest and woodland product harvest would be allowed on 

a case-by-case basis except in WSAs and non-WSA lands with wilderness characteristics, and crosscountry OHV use would be allowed in previously disturbed areas. The current and anticipated demand for 

forest and woodland products would not result in an increase in impacts. Although cross-country OHV 

use would be allowed on more than 1,000 acres (less than 1 percent), fish and wildlife habitat values 

would not be impacted because the areas being proposed for cross-country use have been subject to 

disturbance over the past several years, either through natural processes (e.g., sand dunes) or human use 

(e.g., sand dunes and topsoil pits). In these areas, continued disturbance of previously disturbed areas 

would not result in additional loss of habitat values. 

Management of locatable minerals and mineral materials would result in short-term and direct impacts on 

wildlife and associated habitat through surface disturbance and habitat loss; however, impacts would be 

minimal. Impacts from locatable mineral development would be minimal because a plan of operation, 

including a reclamation plan, is required for all mining claim disturbances. The development of locatable 

minerals and mineral materials would disturb approximately 1,050 acres over 20 years. The development 

of locatable minerals and mineral materials could cause localized impacts on wildlife through the 

disturbance of habitat. 

Designing road crossings to support fish passage in areas that support fish would allow for areas to be 

recolonized from a neighboring population and allow natural movement of fish populations in fisheries. 

This could also allow for more aggressive introduced species into native fish population habitat. 

Displacement 

Displacement from surface disturbance or disruptive activities moves animals into less desirable habitat 

and increases competition for available resources with other species and uses. Impacts of human activity 

on big game crucial winter range include habitat and forage loss caused by surface disturbing and other 

disruptive activities at any time of the year. Dispersed recreation activity, mineral exploration and 
Fish and Wildlife Habitat 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-43 

development, and ROW development could result in displacement and physiological stress to wildlife 

from human presence and activity during sensitive life stages. Under the Proposed RMP, seasonal 

restrictions on surface disturbing activities during sensitive life stages, including in lambing, breeding, 

and fawning seasons and in crucial deer and elk winter, migration, and transitional ranges, would decrease 

the possibility of displacement and physiological stress to wildlife from human presence and activity 

during these sensitive life stages. The possibility of increased human presence in SRMAs, concentrating 

around staging areas, trails, and other developed recreation sites, could displace wildlife species from 

habitat surrounding interpretive sites, depending on the location and level of human presence associated 

with the site. Increasing management presence in SRMAs (95,100 acres, 17 percent) would decrease the 

potential for these impacts from dispersed recreation activities. 

Allowing dispersed camping would result in minor localized harassment of wildlife due to human 

presence and disruptive activities. Dispersed recreation activities could impact fish and wildlife species by 

introducing noise that could disturb species during sensitive periods. This could indirectly affect 

reproduction or cause species to abandon areas such as nest sites or areas that contain key habitat 

components such as important food sources. Effects would be greater in areas that receive frequent and/or 

intense recreation use. Areas subject to more visitation would include easily accessible locations, such as 

along major roads, near communities, or in areas that offer attractive opportunities for recreation. 

Although damage to fish and wildlife habitats would continue to be monitored, detrimental effects from 

casual use would not be apparent until after the damage has occurred, which would then be appropriately 

mitigated to the extent practical and feasible. 

Oil and natural gas production could result in the use of pits to separate oil from produced water or to 

evaporate large volumes of water with high levels of total dissolved solids (TDS). Birds are attracted to 

these pits because they mistake them for natural bodies of water. The sticky oil then entraps the birds in 

the pits and they die from exposure and exhaustion. Birds that do manage to escape can die from 

starvation or experience impaired reproduction caused by the toxic effects of oil ingested during preening 

and loss of embryos from oil on feathers of adults incubating eggs. Scavengers and predators can also 

suffer adverse effects from consuming oiled birds. Pits or ponds containing hypersaline water can pose a 

mortality threat to migratory birds through ingestion of toxic brine, susceptibility to avian botulism, and 

sodium crystallization on feathers, which destroys thermoregulatory and buoyancy functions. It is BLM 

standard practice that pits containing harmful fluids be maintained in a manner that prevents migratory 

bird mortality, thus eliminating potential effects. 

Vegetation treatments on an annual average of no more than 22,300 acres would result in temporary 

displacement of wildlife that uses the treatment areas for a portion of their life cycle. Some species would 

recover quickly and would reoccupy the sites, although others may be displaced for longer, until the 

habitat conditions required by the species become reestablished. However, over the long term, the treated 

areas would provide improved habitat conditions and reduced erosion, which would enhance habitat for 

wildlife and fish. If less than an annual average of 4,650 acres were treated, shrublands generally would 

convert into woodlands and reduce understory vegetation. The loss of understory vegetation could, over 

the long term, decrease forage species, but increase habitat for species dependent on pinyon-juniper 

woodlands. 

The possibility of increased human presence in areas of additional interpretive sites for cultural resources 

and public education and developed recreation sites could displace wildlife species from habitat 

surrounding interpretive sites, depending on the location and level of human presence associated with the 

site. 

In general, travel management activities that result in increased human presence would have a localized 

impact on fish and wildlife species. Impacts could include increased displacement of wildlife, increased 
Fish and Wildlife Habitat 

Chapter 4 Proposed RMP and Final EIS 

4-44 Kanab RMP 

stress during critical time periods, and degradation of habitats. OHV use can alter the seasonal use 

patterns of many wildlife species. Of particular concern are raptor nesting sites, big game parturition 

areas, and winter habitats. Allowing cross-country OHV use on 1,000 acres and on 1,403 miles of 

designated routes in areas where OHV use is limited to designated routes (528,000 acres, 95 percent) 

would result in the displacement of wildlife through human presence and disruptive activities; however, 

severely reducing the area available for cross-country OHV use would reduce the overall effect on 

wildlife from OHV use. Areas closed to OHV use (25,000 acres, 5 percent) or away from designated 

routes where OHV use is limited to designated routes would avoid impacts associated with the disruption 

of wintering big game and preserve habitat characteristics. Seasonal restrictions on 2 miles of OHV routes 

in Pugh Canyon for raptor species would provide protection from disturbance and habitat degradation 

during the closure period from February 1 to August 31. 

Closing raptor areas to rock climbing could result in the elimination of long-term disruptive effects on 

nesting activities during sensitive periods, which could indirectly affect reproduction and cause species to 

not abandon areas. Limiting SRP groups to 12 people per group within wetland/riparian zones, WSAs, 

and designated critical habitat for special status species, and limiting SRP groups to 25 people per group 

in the remainder of the decision area could reduce wildlife displacement from large groups. 

Habitat Maintenance and/or Enhancement 

Applying Standards for Rangeland Health to all rangelands and Guidelines for Grazing Management for 

BLM Lands in Utah (BLM 1997a) for rehabilitation of rangelands would offer protection for fish and 

wildlife habitat by maintaining or improving the ecological health and condition of rangeland ecosystems. 

Using livestock grazing to enhance ecosystem health or mitigate resource problems (e.g., noxious/ 

invasive weed control and hazardous fuel reduction) where supported by site-specific environmental 

analysis could result in enhancement of overall wildlife habitat and over the long term could decrease 

invasive species. Continuing to implement noxious weed and invasive species control measures would 

maintain or improve fish and wildlife habitat, but could cause localized temporary disturbances during 

control measures. 

Focusing vegetation treatments in identified high-priority areas and increasing the potential treatment 

acres would target areas where habitat function could be most improved. This would result in an increase 

in habitat components, including increased forage and shelter. Vegetation treatments on an average of no 

more than 22,300 acres annually could maintain natural disturbance rates, providing for greater habitat 

diversity; however, if less than an annual average of 4,650 acres were treated, then habitat values, 

including forage and shelter, may not function within their natural disturbance regimes, altering the value 

of the habitat. In addition, treatments associated with maintaining or restoring special status species 

habitat could improve wildlife habitat in the same area. 

General vegetation management of rehabilitation objectives, including managing for 51 percent or higher 

of PNC, would maintain available forage and maintain or enhance wildlife habitat. Vegetation 

management in riparian areas and hanging gardens would maintain or improve fish and wildlife habitat 

conditions, provide direct protection of fish and wildlife habitat, and retain adequate water supply to 

support fisheries. Restoring sagebrush steppe communities and maintaining old-growth forest and 

woodland stands could improve the long-term ecological health and habitat condition and help support 

diverse wildlife and sagebrush-obligate species and their food sources. Treatments for sagebrush steppe 

restoration could cause temporary disturbances to wildlife occupying these areas. 

The Proposed RMP proposes more restrictions on surface disturbing activities than the current 

management situation. Areas that are closed to surface disturbing activities (23,800 acres, 4 percent), 

open to oil and gas leasing subject to major constraints (NSO) and closed to oil and gas leasing (162,400 

acres, 29 percent); areas withdrawn and recommended for withdrawal from minerals entry (24,591 acres, 
Fish and Wildlife Habitat 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-45 

4 percent, and 9,500 acres, 2 percent, respectively); closed to mineral material disposals (105,000 acres, 

19 percent); ROW exclusion areas (75,700 acres, 14 percent) and ROW avoidance areas (106,670 acres, 

19 percent); and areas closed to OHV use (25,000 acres, 5 percent) would protect fish and wildlife habitat 

from surface disturbance and disruptive activities. These decisions include restrictions on uses of fish and 

wildlife habitat, special status species habitat, ACECs, SRMAs, WSAs, WSRs, Wilderness, and areas that 

are sensitive to disturbance (e.g., fragile soils and riparian/wetland areas). The reduction or elimination of 

development in these areas would limit surface disturbance, maintain fish and wildlife habitat quality, and 

reduce or eliminate the effects of displacement from human presence. Areas open to oil and gas leasing 

subject to moderate constraints (timing limitations, CSU) (296,200 acres, 54 percent) would include 

stipulations to minimize impacts from oil and gas exploration and development on big game crucial 

winter, migration, and transitional ranges, on Desert bighorn sheep lambing and fawning seasons, and on 

seasonal buffers for raptor habitat. Protection of fragile soil areas and implementation of erosion control 

measures would reduce erosion and surface runoff, which could enhance fish and wildlife habitat. 

Applying BMPs to avoid or reduce fragmenting habitat and mitigating habitat losses for listed and 

sensitive species where appropriate could avoid and reduce habitat fragmentation and losses for fish and 

wildlife. In addition, mitigation would be considered where appropriate, which could reduce habitat 

fragmentation and losses. 

Closing and reclaiming roads, facilities, or improvements that are no longer necessary could deter 

continued use of the area, resulting in reduced disturbance to fish and wildlife habitat. Reclaiming roads 

would enhance wildlife habitat through removal of disturbed areas, increases in forage, and reduced 

habitat fragmentation. 

Incorporating erosion control measures on slopes greater than 15 percent would further reduce erosion 

and surface runoff, which could enhance fish and wildlife habitat. In addition, cooperative 

implementation of the Upper Sevier Watershed Management Plan, managing the Sevier River in 

accordance with the TMDL, and avoiding or minimizing impacts on water quality could maintain or 

improve the conditions of fisheries. Managing the discharge of produced waters, including no surface 

discharge in the Colorado River Basin, would maintain fish and wildlife habitat by preventing possible 

degradation of water quality and fisheries. 

Management actions associated with water quality and watershed health, soils, and fish and wildlife, 

including BMPs, protection of culinary water supplies, and water source protection zones, could maintain 

or improve riparian habitat conditions and fisheries. Management of riparian areas through project design 

features or stipulations and water retention would maintain or improve riparian habitat conditions and 

retain adequate water supply. Implementing BMPs designed to minimize detrimental impacts on soils for 

ground disturbing activities would reduce the potential for localized habitat deterioration that may occur. 

Management of the plague and other diseases in Utah prairie dog colonies could reduce the spread of 

plague in chipmunks and ground squirrels. Protective management measures for the Mexican spotted owl, 

including prohibiting new recreation facilities or trails within PACs, seasonal closures of existing 

facilities, and limiting SRP groups to 12 persons or fewer per group, would protect and enhance fish and 

wildlife habitat and reduce human presence and disruptive activities. 

Management actions for desired future conditions of important wildlife and fish habitat would improve 

habitat conditions, especially deer winter range and sagebrush habitats, by maintaining and prioritizing 

habitat vegetation treatments in areas of crucial deer and Greater sage-grouse winter range and sagegrouse brood-rearing habitat. Providing for fish passage on road crossings would minimize impacts on 

population function and interaction. 
Fish and Wildlife Habitat 

Chapter 4 Proposed RMP and Final EIS 

4-46 Kanab RMP 

Management of habitat to provide for wildlife management objectives, authorization of wildlife habitat 

improvement projects, and retaining crucial wildlife habitat in public ownership would protect or enhance 

fish and wildlife habitat and provide key habitat components. However, this could cause temporary 

disturbances during project construction. Fish and wildlife translocation, transplantation, augmentation, 

and reestablishment would allow for management flexibility to ensure healthy wildlife populations. 

Permitting commercial forest and woodland product harvest for the purpose of promoting forest health 

would improve the long-term health of forest habitats. However, this could cause temporary disturbances 

or displacement during project implementation. Management actions for woodland product harvest, such 

as closing WSAs and non-WSA lands with wilderness characteristics to harvest except for incidental 

collection for onsite campfire use and administrative purposes, would provide a source of cover and 

habitat for prey species and ensure a prey base for raptors and other predators. Permitting woodland 

product harvesting in riparian areas in PFC for maintenance and/or improvement of riparian ecosystems 

could provide long-term habitat enhancement through overall forest health and habitat diversity. 

Management of forage allocation by allocating 11,045 AUMs to wildlife throughout the decision area and 

closing 48 AUMs on the Water Canyon Allotment to livestock grazing would provide an increased 

amount of forage allotted to ungulate and other species in the Water Canyon Allotment. Management to 

mitigate conflicts between grazing and other uses could provide a mechanism to ensure that habitat 

deterioration would not occur due to overuse by multiple uses. 

Management of ROWs and ROW corridors for the siting and construction of communication towers with 

consideration of measures to avoid and minimize impacts on migratory birds likely would minimize or 

eliminate loss of migratory birds from guy wires and other associated features of communication towers. 

Managing powerlines to reduce the risk of raptor electrocution or line-strike would reduce raptor injury 

and mortality. In addition, burying new and reconstructed utility lines could further reduce electrocution 

risk to raptors and collision potential for migratory birds. 

Restrictions on visually obtrusive developments on VRM Class I and Class II areas would limit 

development on approximately 170,400 acres. 

Management prescriptions associated with ACECs would restrict surface uses that could otherwise result 

in loss and disturbance of habitat. Managing the Cottonwood Canyon ACEC (3,800 acres) as a VRM 

Class II area and requiring NSO stipulations on new leases would reduce the extent of surface disturbance 

in the ACEC in upland, riparian, and forest and woodlands habitat. 

Managing suitable river segments to protect their ORVs, free-flowing nature, and tentative classification 

would provide direct protection to wildlife ORVs within 3,770 acres of river corridors (21 miles). 

Management outlined in the Paria Canyon–Vermilion Cliffs Wilderness Plan and Interim Management 

Policy (IMP) (in WSAs) would indirectly protect and enhance habitat characteristics of species such as 

raptors, fish, and big game. 

Summary 

Habitat alteration, fragmentation, and/or loss occurs when habitat components needed for species survival 

(e.g., forage and cover) are removed or when contiguous habitat is broken up (fragmented) by surface 

disturbing activities. This results in a reduction in usable ranges and disruption of movements among 

habitats, transitional areas, and breeding areas (Harris 1991). 
Fish and Wildlife Habitat 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-47 

Displacing activities may not directly affect components, but they force animals to move into less 

desirable habitat, increasing competition for available resources with other species and uses. Users could 

introduce noise or dust that could disturb species during sensitive periods, which could indirectly affect 

reproduction or cause species to abandon areas such as nest sites or areas containing key habitat 

components such as important food sources. Stress inflicted on species could also deteriorate species 

health, which could affect survivability. A fleeing or displaced animal incurs additional costs through loss 

of food intake and potential displacement to poorer (lower) quality habitat. 

Habitat maintenance and/or enhancements occur as a result of vegetation treatments to reduce soil loss, 

improve crucial big game habitat, restore ecological function, and increase forage production. Vegetation 

treatments would result in short-term reduction of habitat values (e.g., forage and shelter) until vegetation 

communities are reestablished. However, over the long term the treated areas would provide improved 

forage conditions and reduced erosion, which would enhance wildlife habitat and fisheries. Vegetation 

treatments would improve the diversity of vegetation age classes and lead to greater herbaceous 

vegetation production and forage quantity and quality, improving palatability for some wildlife species. 

The Proposed RMP would restrict surface disturbing activities and disturbances, resulting in varying 

degrees of protection for fish and wildlife habitat. Management actions that would protect fish and 

wildlife habitat from surface disturbing and disruptive activities include ACEC designations, mineral 

exploration and development closures, and OHV use closures. Over the long term, vegetation treatments 

would also maintain or enhance habitat characteristics. Surface disturbing activities and disruptive 

activities, such as recreation, mineral exploration and development, OHV use, and vegetation treatments, 

would be the most common sources of displacement. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

Due to the limited extent of foreseeable development and the existing health of wildlife populations, there 

would be no irreversible or irretrievable impacts. 

Management actions could result in various short-term impacts on habitat, such as increased localized soil 

erosion and vegetation damage. Surface disturbing activities could result in the greatest potential for 

impacts on long-term productivity. Existing health of wildlife population, limited extent of foreseeable 

development, management actions, and application of BMPs would minimize the effect of short-term 

uses. 

Unavoidable damage to fish and wildlife from permitted activities could occur if resources undetected 

during surveys were identified during ground disturbing activities. Unavoidable loss of species due to 

lack of information, documentation, and inadvertent damage or use could also occur. 

Surface disturbing activities could result in unavoidable adverse impacts, although these impacts could be 

mitigated to the extent possible. Permanent conversion of areas to other uses such as transportation and 

mineral and energy development would decrease the relative abundance of species within portions of 

plant communities, reducing habitat values in these areas. Oil and gas wells and their associated 

infrastructure would be mitigated to the extent possible to minimize fragmentation and avoid the most 

significant wildlife habitat values. 
Wildland Fire Ecology 

Chapter 4 Proposed RMP and Final EIS 

4-48 Kanab RMP 

4.2.7 Impacts on Wildland Fire Ecology 

This analysis addresses the potential impacts on fire ecology from implementing the Proposed RMP. 

Impacts on resources, resource uses, and designations resulting from implementation of the fire 

management program are discussed in the resource sections in this chapter. This analysis focuses on the 

management alternatives or actions that affect fire intensity, frequency, and suppression efforts. 

Fire intensity could be affected by activities that decrease fuel loading, such as vegetation treatments and 

harvesting of forest and woodland products, and activities that alter the composition and structure of 

vegetation communities. High-intensity fires generally result in a greater loss of vegetation cover, 

changes to soil chemistry, damage to root structures, and a greater ability for non-native species to 

become established. Activities that could introduce ignition sources (e.g., recreation use and mineral 

exploration and development) would have the greatest effect on fire frequency. These additional ignition 

sources would increase the probability of wildland fire occurrence and increase the need for fire 

suppression activities. The ability to use certain fire suppression techniques could be affected by 

restrictions designed to protect sensitive resources from surface disturbing activities. Such restrictions are 

associated with the management of wilderness, WSAs, sensitive viewsheds, cultural and paleontological 

resources, and special status species. 

The analysis is based on the following assumptions: 

• Fire is an important functional, natural disturbance in many of the ecological systems found in the 

decision area. 

• A direct relationship exists between the density of human use within the decision area and the 

frequency of human-caused fires. 

• Fire size and intensity are more likely to increase as fuel loading increases. 

• Wildland fire use would be expected to not require rehabilitation. If unintentional resource 

damage does occur, rehabilitation will be applied. 

• Demand for fuels treatment will continue to increase over the life of the plan. 

• ATVs and off-road motorcycles have a reduced potential for ignition sources because they have 

raised exhaust systems and spark arresters. 

• Burned acres for wildfires would not exceed 87,100 acres for a 20-year cumulative maximum 

(BLM 2005c). If these acres are exceeded, it may require additional analysis. 

• Wildland fire use would not exceed 390 acres for a 20-year cumulative maximum (BLM 2005c). 

If these acres are exceeded, it may require additional analysis. 

• Prescribed fire acres would not exceed 103,000 acres for a 20-year cumulative maximum (BLM 

2005c). If these acres are exceeded, it may require additional analysis. 

• Non-fire fuels treatment acres would not exceed 117,500 acres for a 20-year cumulative 

maximum (BLM 2005c). If these acres are exceeded, it may require additional analysis. 

• ESR acres would not exceed 87,100 acres for a 20-year cumulative maximum (BLM 2005c). If 

these acres are exceeded, it may require additional analysis. 

In the absence of quantitative data, best professional judgment was used, and impacts are sometimes 

described using ranges of potential impacts or in qualitative terms, if appropriate. Under the Proposed 

RMP, impacts on fire ecology would not be anticipated as a result of implementing management actions 

for other designations. 
 Wildland Fire Ecology 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-49 

Proposed RMP 

Fire Ecology Management 

Activities associated with fire ecology management likely would have the greatest effect on the ability to 

control wildland fires. Using wildland fire and prescribed fire to protect, maintain, and enhance resources 

would reduce fuel loading and promote healthy, diverse vegetation communities, both of which would 

decrease the intensity of wildland fires and facilitate suppression efforts. Suppressing wildland fires in 

areas where fire is not desired (such as areas with high resource values, structures, cultural sites, and 

habitat for sensitive species) may in the short term reduce fire size and intensity in these areas and 

increase the ability to control fires and protect important resources from fire damage. This management 

action would also directly facilitate achievement of the goals of the fire program; however, implementing 

fire suppression would continue to limit and exclude fire from functioning in its natural role, resulting in 

further departure from the historic fire regime over the long term, and would indirectly result in a longer 

fire-return interval, the continued buildup of fuel loads, and the promotion of vegetation communities that 

would more likely fuel high-intensity fires. Fire-dependent plant communities could deteriorate over the 

long term if fire were prevented from occurring within these communities. 

Management Actions that Affect Fuel Loads 

Grazing by livestock and/or wildlife would reduce fire frequency by reducing fine fuels (e.g., grasses) that 

serve as ignition sources and allow low-intensity wildland fires to spread. Using livestock grazing to help 

accomplish resource objectives on allotments (e.g., hazardous fuel reduction) on a case-by-case basis 

would further reduce fuel loads. Although this could result in fewer fires in the decision area, decreasing 

the probability of ignition could also provide more time for the accumulation of larger fuel sources (e.g., 

shrub vegetation) between fires, which could increase the intensity of wildland fires over the long term. 

Applying the Standards for Rangeland Health to all rangelands would prevent severe removal of fine 

fuels by surface uses, which would help maintain fine fuel cover and the occurrence of low-intensity fires. 

The standards would also promote healthy, diverse vegetation communities that generally fuel lowintensity fires. 

Vegetation and weed treatments would decrease both standing and non-standing vegetation (fuel load) 

across the decision area, which would decrease the intensity of wildland fires and allow fires to be more 

easily controlled. These activities would also modify the composition and structure of vegetation 

communities by creating mosaic vegetation patterns and natural fuel breaks, and by promoting healthy, 

diverse vegetation communities that generally fuel low-intensity fires. Specifically, efforts to reduce 

incursion of non-native annual grasses (primarily cheatgrass), encroachment of shrubby vegetation, 

buildup of biomass in forested areas, and spread of noxious and invasive weeds would help to achieve this 

effect. Habitat improvements for special status species and fish and wildlife could also have similar 

impacts. Treating vegetation to improve resource conditions would continue to reduce the occurrence of 

uncharacteristic wildland fire, damage and catastrophic suppression, and rehabilitation costs. 

Conducting annual vegetation and land treatments (e.g., wildlife habitat treatments, watershed treatments, 

livestock rangeland treatments, fuels treatments, and stewardship contracting) on an annual average of no 

more than 22,300 acres (446,000 acres over the life of the plan) using the full range of vegetation 

treatment methods and tools (i.e., prescribed fire, mechanical, chemical, biological, woodland product 

removal, and wildland fire) would decrease fuel loading, which would decrease the intensity of wildland 

fires and allow fires to be more easily controlled. Vegetation and weed treatments would decrease both 

standing and non-standing vegetation (fuel load) across the decision area, which would decrease the 

intensity of wildland fires, and allow fires to be more easily controlled. These activities would also 

modify the composition and structure of vegetation communities by creating mosaic vegetation patterns 

and natural fuel breaks, and by promoting healthy, diverse vegetation communities that generally fuel 
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4-50 Kanab RMP 

low-intensity fires. Specifically, efforts to reduce incursion of non-native annual grasses (primarily 

cheatgrass), encroachment of shrubby vegetation, buildup of biomass in forested areas, and spread of 

noxious and invasive weeds would help to achieve this effect. Habitat improvements for special status 

species and fish and wildlife could also have similar impacts. Treating vegetation to improve resource 

conditions would continue to reduce the occurrence of uncharacteristic wildland fire, damage and 

catastrophic suppression, and rehabilitation costs. In addition, managing to achieve the 51 percent or 

higher of PNC could promote diverse vegetation communities that would burn with less intensity and be 

more easily controlled or could increase fire intensity. 

Under the Proposed RMP, treatments would be conducted in areas containing ponderosa pine for stand 

health, which would increase tree spacing, decrease fuel loading, and thereby decrease fire size/intensity. 

Fuels regimes would move toward Condition Class 1. Managing for old-growth forests and woodland 

stands would reduce the amount of dead and downed fuels attributed to insects, disease, and overgrowth. 

This would maintain old-growth stands, with sufficient surface cover and ladder fuels to ensure that 

wildland fires would be low-intensity, small, and easy to control. By managing for the desired condition 

these vegetation types would move toward fire regime Condition Class 1. 

The harvesting of forest and woodland products would reduce fuel accumulations in wooded areas and 

subsequently reduce wildland fire intensity. This activity would reduce overall canopy density, which 

would inhibit the movement of fire through the canopy. Harvest of woodland products would reduce the 

fuel load and help reduce the encroachment of pinyon-juniper woodlands into the sagebrush steppe. 

However, this impact would be localized because the demand is limited. Individual treatment areas could 

act as firebreaks, changing wildland fire behavior in these areas. In addition, permitting harvest of forest 

and woodland products to promote or sustain forest health on a case-by-case basis would further reduce 

loads and improve forest health and could move those areas harvested toward fire regime Condition 

Class 1. 

Management Actions that Affect Fire Suppression Activities 

Maintaining air quality standards within thresholds established by the State of Utah could result in fewer 

prescribed fires or more suppression efforts on wildland fires. If it were determined that air quality or 

Class I airsheds would be adversely impacted, wildland fire use and prescribed fires would be suspended. 

Consideration of regional haze could increase the restrictions on wildland fire use or prescribed fire. 

These restrictions would lead to increased fuel loads. 

The presence of significant cultural and paleontological resources would require suppression of wildfires 

threatening the sites. Their presence also would limit and/or restrict certain types of fire suppression 

methods and fuels treatments. This could affect the ability of firefighters to protect cultural sites and 

surrounding areas during wildland fire suppression activities. The need for suppression actions during 

wildland fire events would be reduced for cultural sites that received hazardous fuels treatments. This 

impact would occur in small, localized areas where such resources are known to exist. 

Areas where surface disturbing actions would be precluded would increase to 23,800 acres (4 percent). 

This would increase the area where fire suppression activities could be limited or restricted. 

Surface disturbance restrictions intended to protect natural values, including Wilderness, WSAs, WSRs, 

fish and wildlife, and special status species (e.g., prohibiting ground disturbing activities within 1⁄2 mile of 

bald eagle nests and Mexican spotted owl nests), could preclude certain types of fire suppression 

activities, which would limit the ability to control fires and to protect these sensitive resources. Seasonal 

restrictions could preclude certain types of fire suppression activities within the restricted time frame. 

Controlling surface disturbing and disruptive activities to minimize impacts on identified crucial habitat 

for sensitive species, applying BMPs to avoid or reduce habitat fragmentation, prohibiting surface 
 Wildland Fire Ecology 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-51 

disturbing activities within 1⁄2 mile of active or suitable Utah prairie dog habitat, and applying seasonal 

restrictions in big game habitats could restrict certain types of fire suppression activities, which could 

limit the ability to control fires and to protect these sensitive resources. 

Under the Proposed RMP, VRM Class I areas would increase to 76,000 acres (14 percent) and VRM 

Class II areas would increase to 94,400 acres (17 percent). This could limit mechanical land treatments, 

which could result in fuels buildup and increased risk of catastrophic wildfires in this area. 

Six eligible river segment corridors (5,530 acres) would be determined suitable and managed to protect 

their ORVs, free-flowing nature, and tentative classification. This would increase the area where fire 

suppression activities could be limited or restricted. Although management associated with the 

Cottonwood Canyon ACEC does not specifically address wildland fire management, fire suppression 

activities would have to consider its resources, which could affect some of the suppression tactics 

available. 

The full range of suppression activities are available within Wilderness areas and WSAs, although the 

suppression methods that result in the least long-term disturbance (i.e., use minimum tool standard in the 

Wilderness area and nonimpairment criteria for WSAs) while protecting human life and property would 

be preferred. In addition, wilderness policy and the IMP could affect fire suppression activities and 

equipment used in WSAs and in the Paria Canyon–Vermilion Cliffs Wilderness. This could affect fire 

suppression efforts and the ability to control large, intense wildland fires. Wilderness and WSA 

management would allow the use of chemical, biological, or mechanical treatments, which would help 

restore ecological functions. These areas would move toward fire regime Condition Class 1 as a result of 

the various forms of treatment. 

Aboveground ROWs and communication sites would require additional efforts by firefighters to protect 

these areas in wildland fire events. Underground ROWs would need to be avoided during suppression 

efforts such as the construction of fire lines. Development of ROWs would result in clearing vegetation to 

make way for linear features, such as roads, pipelines, and transmission lines. ROWs could provide fuel 

breaks, which could be effective in preventing the spread of wildland fires. Some ROWs could also 

provide firefighters with access routes to remote areas. The magnitude of impacts from ROWs would 

decrease because 75,700 acres (less than 14 percent) would be excluded from new ROWs. In addition, 

new ROWs would be avoided in 106,670 acres (19 percent) of the decision area. This could reduce the 

areas where ROWs would need to be protected. However, it would also reduce the fuel breaks and access 

routes associated with the ROWs. 

Management Actions that Affect Fire Frequency 

Recreational activities in the decision area could affect fire management. The recreational opportunities in 

the decision area attract increasing numbers of visitors, which increases the probability of unintentional 

fire starts and the need for fire suppression activities. Campfires and exhaust systems on motorized 

vehicles both can cause unintentional ignitions. Developed campsites would act as safety zones and fuel 

breaks, but would also require additional protection in wildland fire events. Ignition would be less likely 

in developed campsites (fire rings, safety) because of fire restrictions. 

Because OHV use allows visitors to access remote areas, human-caused fires (e.g., due to unattended 

campfires and vehicle sparks) could occur in areas that are difficult to access with fire suppression 

equipment. The routes that provide motorized access to public lands within the decision area facilitate 

travel, and increase the distribution of visitors throughout the decision area, thus increasing the extent of 

related effects. OHV use allows visitors to access even the most remote areas of the decision area, which 

can make access difficult for fire suppression equipment in wildland fire events. However, the routes 

would also provide access for suppression efforts and natural fuel breaks. Developing more recreation 
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4-52 Kanab RMP 

sites and facilities would concentrate ignition sources to areas of high use. In these areas, the lack of fuels 

would be less likely to result in ignitions. Additional restrictions on OHV use would decrease the 

potential for wildland fire occurrence. Decreasing the areas open to cross-country OHV use to 1,000 acres 

(less than 1 percent) and increasing the area limited to 1,403 miles of designated routes on 528,000 acres 

(95 percent) would decrease the potential for wildland fire occurrence because less area would be easily 

accessible to visitors. 

Activities associated with mineral exploration and development would increase human presence and the 

use of heavy equipment in the decision area, which would introduce additional ignition sources and 

increase the probability of wildland fire occurrence and the need for fire suppression activities. Related 

long-term disturbance of about 607 acres would result in degraded vegetation communities that could 

more likely fuel high-intensity fires; however, developed areas could provide increased accessibility to 

remote areas for fire suppression equipment, and provide fuel breaks in the case of wildland fire events. 

Surface disturbance caused by development activities could modify the composition and structure of 

vegetation communities, including the spread of noxious weeds. These disturbed areas could be more 

likely to fuel high-intensity fires. 

Summary 

Vegetation treatment and forest and woodland product harvest under the Proposed RMP would reduce 

fuel loading and the intensity of wildfire. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources. There are no short-term uses 

proposed that would affect the long-term productivity of wildland fire ecology because of the application 

of identified resource protection measures. Recreational activities, development of mineral resources, and 

general use of the decision area will continue to increase, introducing additional ignition sources and 

increasing the potential for wildland fires. Wildland fires from these ignition sources are not desired, and 

would increase the need for suppression activities. 
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4.2.8 Impacts on Cultural Resources 

The primary cultural resource impact is the disturbance of artifacts, sites, and features of sites that reduces 

their scientific integrity, alters their association with traditional values, reduces their public use values, 

and reduces the potential to provide significant data. This can occur from activities or processes that 

disturb the surface, remove vegetation, increase soil erosion, or otherwise lead to cultural artifacts being 

damaged or moved from their original positions (in situ) prior to scientific documentation. Cultural 

resource information and values can also be damaged or lost if the soil matrix at a site is lost or removed 

without the potential for scientific study. Although deterioration of cultural sites and their artifacts may be 

slowed or halted, physical damage to objects and sites cannot typically be reversed. Cultural values can 

also be affected if the physical setting associated with a site is altered in a way that changes the 

relationship between the site and its physical surroundings. Short-term impacts on these cultural resource 

values from visual or auditory disturbance generally affect public or traditional uses of cultural sites or 

areas. These impacts can diminish the site’s traditional use values, but can often be ameliorated or 

accommodated through activity planning. 

To preserve cultural resource values as a part of our national heritage, various laws, regulations, and 

policies require that cultural resources be considered in any agency decision that could affect cultural 

resources. Consideration usually includes inventory, evaluation, and mitigation of effects. Addressing 

effects on cultural sites includes either project relocation or redesign (avoidance), or scientific data 

recovery methods such as recordation, surface collection, subsurface testing, and excavation. 

Although information on locations of all cultural sites in the decision area is incomplete, the analysis 

considers the management alternatives and their potential to directly or indirectly affect cultural 

resources, as noted above. The number of sites that could be affected by various actions is directly 

correlated with the degree, nature, and quantity of surface disturbing activities in the decision area and 

whether the activity occurs in an area of high or low site density. Impacts are quantified where possible. 

In the absence of quantitative data, best professional judgment was used. Some of the decisions in this 

document are programmatic; others may be implemented immediately (e.g., route designation or oil and 

gas leasing stipulations). To ensure preservation of specific cultural resource sites, further analyses will be 

required at the implementation level following site-specific cultural resource inventories. 

The required consultations for Section 106 of the National Historic Preservation Act (NHPA) are in 

progress. The BLM has forwarded to the State Historic Preservation Office a determination that, although 

in some cases, management actions in this plan may have a potential to affect historic properties, there 

would be no adverse affect to these historic properties. Section 106 consultation will be completed prior 

to signature of the Record of Decision (ROD). 

The analysis is based on the following assumptions: 

• Cultural resources would continue to be discovered throughout the decision area. 

• As access to an area increases, incidental damage of cultural resources adjacent to the access 

routes would increase. Impacts from incidental damage would be reduced as distance from the 

access route increases. 

• The demand for use of cultural resources (e.g., public use, scientific use, and traditional use) will 

increase as access to and use of the planning area increases. 

• The number of sites that could be impacted by various actions would be directly correlated with 

the degree, nature, and quantity of surface disturbing activities within the decision area and 

whether the activity occurs in an area of high or low site density. 
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4-54 Kanab RMP 

Under the Proposed RMP impacts on cultural resources are not anticipated as a result of implementing 

management actions for the following resources and designations: air quality and other designations. 

Proposed RMP 

Cultural Resource Management Actions 

Cultural resources would be managed in compliance with laws, regulations, and bureau policy, addressing 

their management when a site is identified during inventory associated with a surface disturbing activity. 

Each alternative would comply with federal laws and agency guidelines governing the identification, 

evaluation, and protection of cultural resources and Native American sacred/traditional sites. Cultural 

resources would continue to be identified, evaluated, and considered in association with all federal 

undertakings. Impacts on known cultural resource sites from surface disturbing actions would be 

mitigated. Impact mitigation, such as the scientific excavation of identified sites, would minimize the 

potential for adverse effects to known cultural resource sites. Monitoring identified cultural sites that have 

known impacts and sites that are sensitive to incidental impacts would indicate if management actions are 

needed to protect the sites, decreasing the potential for losing cultural values as a result of deterioration 

and impact. 

Updating the Class I cultural resource inventory every 10 years would provide the landscape-level 

understanding of the cultural resources in the decision area. This would ensure that mandatory 

inventories, proactive inventories, and research designs would build on the cultural resource inventories 

and studies already completed. Associated with using proactive research, protection, and inventories 

involving universities, avocational and service groups, site stewards, tribes, and community outreach, the 

knowledge of, information about, and protection and preservation of cultural resources and the associated 

information they contain would be increased. Allocating cultural sites to use categories and managing 

them for their various uses would result in sites being proactively managed considering cultural resource 

sites’ varied values. Because most cultural sites would be managed for scientific use, no use would occur 

on the sites until scientific study could recover the information associated with the sites. Allowing 

changes to site use allocations would allow for site-specific characteristics and circumstances to be 

addressed as varying situations arise. 

Providing interpretive opportunities could provide more cultural resource sites for public use and 

education. This action would require inventories to recover scientifically important data prior to allowing 

public use of the sites. Increased interpretation opportunities would increase public appreciation for the 

decision area’s cultural values. Increased emotional linkages associated with appreciation could lead to 

increased user stewardship behavior (Sharpe and Ewert 2000). Major impacts associated with stewardship 

behavior include increased protection of cultural sites, decreased inadvertent damage to or disturbance of 

cultural sites, decreased vandalism and looting, and preservation of the integrity of cultural resources. 

The prioritization of areas for proactive cultural resource inventories would result in the identification of 

cultural resources and sites, increasing the database of known sites in areas where the potential for 

incidental impacts is greatest and areas where the potential to identify sites is greatest. This information 

would assist in National Register recommendations and would increase the knowledge base in this area 

while providing for improved management of these resources. 

Precluding surface disturbing activities within 1⁄4 mile or within the visual horizon, whichever is closer, of 

cultural landscapes eligible for the National Register generally would protect these areas from visual 

intrusions. However, there could be areas where cultural landscapes extend beyond the 1⁄4 mile where 

visual intrusions in the landscape could be allowed. In these areas, adherence to federal regulations would 

result in consideration and mitigation of these impacts. However, it would be easier to mitigate visual 

intrusions beyond the 1⁄4 mile due to the setback. 
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Kanab RMP 4-55 

Coordination with Native American Tribes to identify and manage traditional cultural properties could 

result in the identification of traditional cultural properties. If traditional cultural properties were 

identified, management of these sites for traditional use could result in avoidance of surface disturbing 

actions in and around the sites, either temporally or spatially. The cultural resource sites would be 

preserved in place, and Native American concerns taken into account.

OHV Access and Use (Cross-Country Use and Use on Designated Routes) 

Cross-country OHV use would be allowed on approximately 1,000 acres (less than 1 percent). However, 

there would be a very low potential for impacts on cultural resources in these areas because they have 

been subject to previous Section 106 (DD Topsoil Pit) or Section 110 (sand dunes) inventories that have 

not identified any cultural sites. 

Managing most of the decision area as closed to cross-country OHV use and limiting OHV use to 

designated routes on 528,000 acres (95 percent) would increase protection to cultural resources. Cultural 

resources away from designated routes would be protected from OHV impacts. Rather than the potential 

for increased disturbance and incidental damage associated with pioneered routes in areas open to crosscountry use, impacts on cultural resources from OHV use on designated routes would be limited to 1,403 

miles (95 percent) of designated routes. There would be no impacts from OHV use on 25,000 acres (5 

percent) closed to OHV use, in areas away from the designated routes, and on 75 miles (5 percent) of 

closed routes. 

Reducing temporary roads associated with temporary projects and reclaiming unnecessary facilities and 

improvements would maintain and/or improve the isolated nature of the cultural sites, protecting them 

from incidental damage. Limiting OHV use to designated routes in areas with fragile soils would 

eliminate impacts from cross-country OHV use and not increase erosion above natural rates in these 

areas. This would maintain existing levels of natural deterioration to cultural sites. 

Mineral Development 

Mineral development as a result of implementing the mineral decisions would involve direct and indirect 

impacts on cultural resources. Direct impacts are related to the level of surface disturbance assumed under 

the RFD scenario. Because the actual placement of each mineral development or associated feature is 

unknown at this level of planning, impacts on cultural resources are noted as potential impacts. Impacts 

also vary based on the type of mineral decision and areas available for development of the various 

minerals. 

Cultural resource values on 391,600 acres (71 percent) open to oil and gas leasing subject to the standard 

terms and conditions and open to oil and gas leasing subject to moderate constraints (timing limitations, 

CSU) could be impacted by oil and gas leasing. Although cultural site densities vary in different areas 

throughout the decision area (Chapter 3, Cultural Resources section), site densities are low enough to 

provide for the avoidance, following identification, of cultural sites when lease holders exercise initial 

development rights associated with oil and gas leases. Based on the RFD, oil and gas developments 

within these areas would impact 2,070 acres over the life of this plan (Appendix 15). Development on 

these acres would typically be subject to Class III cultural resource inventories and evaluation on a 

project-by-project basis prior to allowing disturbance. This likely would result in the identification of 

between 10 (low site density) and 226 (high site density) cultural sites in these areas. Site densities 

throughout the decision area generally would result in the identification and avoidance of cultural sites 

during development. However, development in areas of very high cultural site density could result in the 

identification of sites that are unavoidable to mineral development. Sites that are unavoidable would be 

physically altered or eliminated during mitigation activities such as data recovery or other onsite means, 

as determined through the Section 106 process. Although the physical site could be altered or eliminated, 
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4-56 Kanab RMP 

excavation would preserve the artifacts and information associated with the site, maintaining the cultural 

values. 

Managing 475,000 acres (86 percent) as open to oil and gas leasing (open to oil and gas leasing subject to 

the standard terms and conditions, open to oil and gas leasing subject to moderate constraints [timing 

limitations, CSU], and open to oil and gas leasing subject to major constraints [NSO]) could result in 906 

acres of surface disturbance from seismic operations supporting oil and gas leases. This likely would 

result in the identification of between 4 (low site density) and 99 (high site density) cultural sites in these 

areas. On identification, seismic operations likely would be able to avoid all the identified sites. 

Although more of the decision area is available for further coal leasing consideration, the RFD anticipates 

one surface mine would be developed in the Alton area, disturbing approximately 3,600 acres over the life 

of the plan (Appendix 15). Although the exact placement of the mine is not a proposed decision in this 

document, based on the density of cultural sites within the Alton area disturbance of this many acres 

would result in the identification of approximately 100 sites. Because the surface coal mine would result 

in the complete disturbance of surface resources, these sites would not be able to be avoided, resulting in 

mitigation through data recovery for many of these sites. This would increase the knowledge of the 

cultural resources in the area, but it would also eliminate these sites from future study and uses (e.g., 

public, traditional, and scientific). However, because of the large number of sites, it may not be feasible to 

mitigate all of the sites through data recovery. As a result, some National Register–eligible sites could be 

lost without any data recovery. Development of a scientific research design prior to development of the 

coal mine would result in mitigation of the sites with the greatest potential for data recovery and 

information, limiting the extent of this impact to the degree possible. 

Potential long-term impacts on cultural resources from mineral development include the identification of 

cultural resources during inventories preceding development activities. Identification of sites would 

increase the knowledge of the cultural resources in the areas. Most sites identified during these 

inventories would be avoided because of project relocation or redesign, which would protect the cultural 

resource site. When it is not possible to avoid sites, the archaeological sites would be physically altered or 

eliminated during mitigation activities, such as data recovery or other onsite means, as determined 

through the Section 106 process. Although the physical site could be altered or eliminated, excavation 

would preserve the artifacts and information associated with the site, maintaining the cultural values. 

During implementation of mineral development activities, there is also a potential for inadvertent damage 

to sites not identified during the inventories. 

Although cultural sites within the area of mineral development will have been identified and either 

avoided or mitigated as part of the specific mineral development projects, sites not located within the 

footprints of undertakings are also vulnerable to impacts because human traffic in the general area 

increases. Potential indirect effects on cultural resources include increased erosion on cultural resource 

sites located in the vicinity of mineral developments where vegetation cover has been reduced or 

eliminated, and the potential for inadvertent impacts associated with increased human activities in these 

areas. 

Because approval of mineral material sites is a discretionary decision, the inventories at the 

implementation level prior to development of approximately 650 acres (Appendix 15) likely would 

identify between 3 (low site density) and 70 (high site density) cultural sites. In addition, inventories prior 

to the development of locatable minerals on approximately 400 acres (Appendix 15) likely would identify 

between 2 (low site density) and 44 (high site density) cultural sites. These sites would be either avoided 

or mitigated through other means identified in the Section 106 consultation process. 
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Kanab RMP 4-57 

Other impacts from mineral exploration and development include short-term disruption from visual or 

auditory effects such as drilling and automobile traffic. These impacts usually affect cultural landscapes 

or traditional uses and would be mitigated or accommodated through measures identified in the Section 

106 consultation process. 

Planned (BLM) or Permitted (BLM-Approved) Surface Disturbing Actions 

Surface disturbing activities (e.g., mineral development activities, construction within ROWs, recreation 

site development, and construction of range improvements) could result in significant impacts on cultural 

resources in the absence of mitigation; however, these impacts would be mitigated through 

implementation of existing laws and policy, such as Section 106 of NHPA and FLPMA. Cultural values 

would be protected (i.e., data recovery or preserved in place) through compliance with these laws, 

regulations, and policies. Federal undertakings typically require cultural resource inventories that would 

result in the identification of cultural resource sites and determination of eligibility for the National 

Register of Historic Places (NRHP). The cultural resources data acquired through inventories and 

evaluations would increase knowledge of cultural resources in the region. Following site identification 

from site-specific inventories, mitigation measures would be prescribed as necessary for eligible 

properties. Using this process, significant impacts on cultural resources eligible for the NRHP would be 

avoided or mitigated. Avoidance is the BLM’s preferred measure to eliminate potential adverse effects on 

cultural resources. Avoidance preserves the cultural resource in place. If this is not possible under 

reasonable circumstances, data recovery is an alternative mitigation method. Data recovery preserves as 

much of the cultural record as possible through archaeological methods, documenting cultural resources 

by making archival records associated with collected artifacts. Although data recovery preserves as much 

data as possible, the property or the site is still lost or damaged. Most data recovery methods eliminate a 

site’s features through excavation. Removing cultural resources from a site using current scientific 

methods also reduces future scientific value if more accurate methods of analysis are developed. 

Mitigation through data recovery also reduces or eliminates other uses of cultural resources sites, such as 

traditional, public, conservation, or experimental use. Standard inventory and avoidance procedures 

conducted in conjunction with surface disturbing actions would protect most cultural resources from 

significant impacts. 

Despite the BLM’s best efforts to identify all eligible resources, there remains a potential for inadvertent 

impacts on previously undiscovered sites, especially buried sites with no surface indications. There is a 

set process, through Section 106, for identifying, evaluating, and treating the effects of inadvertent 

discoveries, reducing potential impacts from these discoveries. 

Management that Restricts Surface Disturbing Activities 

Management decisions that restrict surface disturbance in an area, such as controlling erosion in frail 

watersheds, implementing BMPs, limiting disturbance in special status species habitat, or managing areas 

for wilderness characteristics, would preserve cultural resources in place. Prohibiting or restricting surface 

disturbing activities or excluding areas from surface disturbance would result in fewer Section 106 

inventories, thus reducing the potential for incidental damage and the potential for site identification and 

recordation through data recovery associated with development. Controlling erosion in frail watersheds 

would ensure disturbance does not result in increased soil erosion in these areas. Erosion control measures 

would protect cultural resources in these areas from degradation associated with erosion above natural 

rates. 

Areas that are closed to surface disturbing activities (23,800 acres, 4 percent) would protect cultural 

resources from such activities. Such decisions include restrictions on cultural sites and uses of fish and 

wildlife and special status species habitat and riparian/wetland areas. The reduction or elimination of 

development in these areas would result in fewer Section 106 inventories, reducing the potential for site 
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4-58 Kanab RMP 

identification and recordation through data recovery associated with surface disturbing developments. In 

addition, such restrictions on surface disturbance could make cultural resource studies more difficult. 

However, inventories associated with other activities (e.g., vegetation treatments for soils, watersheds, 

habitat, livestock grazing, and fuels reduction) could still result in the identification of cultural sites, as 

noted in the impacts from those decisions throughout this analysis. 

Cultural resources on 162,400 acres (29 percent) open to oil and gas leasing subject to major constraints 

(NSO) and closed to oil and gas leasing would be preserved in place from oil and gas development. This 

would include areas of high cultural site density near water sources, reducing the potential to identify sites 

and the potential to have unavoidable sites that require data recovery. In these areas there would be a 

reduction in the potential for site identification and recordation associated with oil and gas development 

compared with areas open for oil and gas leasing subject to the standard terms and conditions and areas 

open to oil and gas leasing subject to moderate constraints (timing limitations, CSU). In addition, cultural 

resources in areas that would be closed to mineral materials activities (105,000 acres, 19 percent) or 

withdrawn and recommended for withdrawal from minerals entry (24,591 acres, 4 percent, and 9,500 

acres, 2 percent, respectively) would also be protected in place from extraction of those minerals. 

Recreation Use 

The identification of and management associated with six SRMAs on 95,100 acres (17 percent) would 

provide for management at popular dispersed use areas. This could result in some minor developments 

that would focus recreation use, minimizing long-term impacts. This would decrease the potential for 

inadvertent damage of cultural sites. In addition, allowing vehicle parking for dispersed camping within 

150 feet of designated routes could result in vehicles associated with dispersed camping generally 

impacting surface features, breaking artifacts, and otherwise disturbing cultural resources at the surface. 

Increased public awareness through educational opportunities would emphasize the importance of 

protecting cultural resources. Interpretive signs and markers identifying cultural resources would inform 

and educate the public, thereby increasing compliance with RMP actions and increasing preservation of 

cultural resources. In addition, providing interpretive opportunities could provide more cultural resource 

sites for public use and education. This may require inventories to recover scientifically important data 

prior to allowing public use of the sites. Increased interpretation opportunities would increase public 

appreciation for the decision area’s cultural values. Increased emotional linkages associated with public 

appreciation could lead to increased user stewardship behavior (Sharpe and Ewert 2000). Major impacts 

associated with stewardship behavior include increased protection of cultural sites, decreased inadvertent 

damage to or disturbance of cultural sites, decreased vandalism and looting, and preserving the integrity 

of cultural resources. 

Providing heritage tourism opportunities throughout the decision area could provide more cultural 

resource sites for public use and education. This may require inventories to recover scientifically 

important data prior to allowing public use of the sites. 

Requiring SRPs when sensitive cultural resources could be impacted by permitted recreation use would 

allow for potentially affected cultural resource sites to be avoided. Limiting rock climbing within 300 feet 

of cultural sites would protect cultural resource sites from inadvertent human disturbance. 

Livestock Grazing 

Implementing Standards for Rangeland Health would contribute to maintained or improved range 

conditions and soil and vegetation stability. This would reduce the potential for new or continued impacts 

on cultural resources from erosion and vegetation-related impacts related to livestock grazing. In addition, 

using livestock grazing to enhance ecosystem health could improve vegetation structure and maintain 
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Kanab RMP 4-59 

natural disturbance regimes (e.g., removing cheatgrass). Although there could be short-term impacts from 

livestock congregation and trampling cultural sites, over the long term improved ecosystem health would 

help treated areas avoid increased fire frequency, protecting cultural sites from impacts from fire. Sitespecific cultural reviews prior to implementation of such grazing use would eliminate the potential for 

unmitigated damage from livestock congregation. 

The dispersed nature of livestock grazing generally results in livestock on an allotment being scattered in 

very small groups of 2-5 animals over large areas. However, in areas where livestock tend to congregate 

and/or trail, that disturbance could be concentrated in small, localized areas. In these small, localized 

areas, cultural resource sites could possibly be impacted by short-term removal of protective vegetation 

cover and increased soil compaction. These types of impacts would be site-specific and localized. 

Adherence to the Standards and Guidelines would result in mitigation of these possible impacts and a 

decrease in potential erosion and trampling. Impacts on specific areas would be identified and mitigated 

through a number of different means related to the grazing permit administration process (e.g., moving 

salt blocks or water locations, fencing). With mitigation these impacts likely would be relatively minimal. 

Changes to grazing management could be subject to adherence of Section 106, which would mitigate 

impacts on cultural resources. In addition, reallocating forage from livestock on the Water Canyon 

Allotment would eliminate the potential for grazing-related impacts on cultural resources in this area. 

Wildland Fire 

Wildfire, wildfire suppression efforts (including ESR actions), wildland fire use, and prescribed fire could 

impact cultural resource sites throughout the decision area, including the eligibility characteristics of sites 

that are listed or eligible for listing on the NRHP. Because not all cultural resource sites are known, the 

potential for impacts on cultural resources exists where wildland fire occurs within the decision area. 

Impacts from wildland fire vary, depending on the temperature and duration of exposure to heat. 

Generally, higher temperatures and/or longer duration of exposure to heat increase the potential for 

damage to cultural resources. Prehistoric and historic resources potentially affected by wildfire may be 

inorganic (e.g., lithic/rock, ceramics, cans, glass, and rock art) or organic (e.g., basketry, wooden 

structures, and dendroglyphs). Generally, organic materials are more at risk because they tend to burn or 

to be altered at lower temperatures than inorganic items. Wildfire impacts on inorganic cultural resources 

include fracturing, shattering, and changes in color and internal luster, which might reduce an artifact’s 

ability to render information about the past. Hotter temperatures and longer exposure to fire are more 

likely to affect lithic materials. When these materials are likely to be present, it may be necessary to take 

protective measures. Wooden substructures, common in adobe structures, could be destroyed, possibly 

compromising the structure as a whole if exposed to fire. Historic earthworks such as trails, roads, 

irrigation ditches, and canals are less sensitive to fire. Wildfire could also impact rock art. Although there 

are no specific temperature guidelines for rock art, fire effects include soot smudging and discoloration 

from smoke, which obscure the rock art images; degradation of the rock surface from spalling, 

exfoliation, and increased weathering; changes in organic paints due to heat; and damage to rock varnish, 

which may destroy the potential to date the art (Tratebas 2004, Kelly and McCarthy 2001). Wildfire could 

also affect the dating potential of cultural data from both organic and inorganic material (Deal n.d., 

Buenger 2003, Loyd et al. 2002, Shackley et al. 2002, Solomon 2002). 

As a general rule, fire would not affect buried cultural materials. Studies show that even a few centimeters 

of soil cover (4 inches) are sufficient to protect cultural materials (Oster n.d.). Wildfires that burn hot and 

fast through a site may have less of an effect on certain types of cultural materials than fires that smolder 

in the duff or burn for a long time period, allowing heat from the fire to penetrate the surface. In addition, 

heat from wildland fires could change the physical nature of the ground, making it harder to identify 

cultural resources. 
Cultural Resources 

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4-60 Kanab RMP 

The temporary reduction in vegetation cover following wildland fires would enhance surface visibility in 

the short term, which could allow otherwise undetected cultural materials to be identified and recorded. 

Increased visibility could also increase incidental damage to cultural resources from public land users in 

the area before the vegetation provides surface cover. Loss of vegetation cover could also lead to a loss of 

cultural data through increased damage from increased soil erosion and alteration of soil characteristics, 

changes in drainage patterns, and flooding after a fire. 

Often, cultural resources are more at risk of impact due to fire suppression activities than from wildland 

fire. Suppression efforts, such as fire line construction (hand and bulldozer lines) and the establishment of 

helicopter bases, safety zones, and fire camps, could disturb the surface and potentially destroy artifacts 

and the integrity of cultural resource sites. Water, foam detergents, and fire retardants could damage 

artifacts and features by causing swelling and then contraction. Other potential impacts from the use of 

retardants would include rapid cooling and subsequent damage (e.g., breakage, spalling, corrosion, 

staining, and rusting) to archaeological materials. Discoloration or warping of metallic surfaces could also 

occur. Rock art is particularly sensitive to damage from retardants. Impacts from wildland fire would be 

limited to less than 190,490 acres (34 percent), which would include less than 87,100 acres of wildfire, 

less than 390 acres of wildland fire use, and less than 103,000 acres of prescribed fire fuel treatments. 

Mitigation of these impacts would be provided through adherence to resource protection measures. 

Consultation with a cultural resource specialist during suppression activities in areas containing sensitive 

cultural resources would help to minimize impacts. 

Following suppression, ESR actions on less than 87,100 acres (16 percent) are subject to NHPA Section 

106 requirements, as amended (36 CFR 800, consultation with the Utah State Historic Preservation 

Officer). The areas that would be subjected to surface disturbance are subject to Class III cultural resource 

inventory. Inventories would result in the identification of cultural sites and lower the potential for 

impacts on cultural resources. Many areas used traditionally for hunting would be expected to be 

revegetated following a wildfire event. For localities where food or medicinal or raw material plants are 

gathered, the threat of invasive species occupying those areas may be an issue.

Wildland fires and prescribed fires typically burn at a lower temperature and duration than large wildfire 

events, which means that potential impacts would be less severe than those of unmanaged wildland fire. 

Prescribed fire events are occasionally preceded by non-fire fuels reduction actions to obtain a smaller, 

more manageable, and less intense planned burn. The relatively small acreages available for wildland fire 

use, relative to other possible fire management actions, would minimize the potential for impacts from 

such use. The potential impacts from these methods would typically have less long-term impact than from 

an unmanaged wildland fire event. Although loss of or damage to cultural resources during all planned 

fuel treatments is possible, proper planning and consultation with a cultural resource specialist would 

reduce these impacts to a negligible level. Over the long term, managing areas to restore fire regimes 

would result in less intense wildland fires and greater protection of susceptible or sensitive cultural 

resources.

Management to decrease current fuel loads could result in short-term increases in acres burned, but it 

would also decrease the number of large severe fires over the long term, which would in turn result in a 

decrease in the level of suppression required on an average wildland fire. A decrease in impacts on 

cultural resources from ground disturbing and other suppression activities would be realized over the long 

term. Heat- and duration-related impacts would be similarly reduced over time. In addition, as the longterm fire regime condition class approaches more natural conditions that would not support undesirable 

fires, non-fire fuel treatments could be phased out as a prescribed fire pretreatment, reducing the potential 

impacts on sites.
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Kanab RMP 4-61 

Non-Fire Vegetation Treatments 

Vegetation treatments (e.g., wildlife habitat treatments, watershed treatments, livestock rangeland 

treatments, fuels treatments, and stewardship contracting) would not be allowed to exceed an annual 

average of 22,300 acres (446,000 acres over the life of the plan). This would ensure that vegetation 

manipulation and associated short-term increases in soil erosion do not exceed historic levels of 

disturbance. In addition, allowing use of the full range of upland vegetation treatment methods and tools 

(i.e., prescribed fire, mechanical, chemical, biological, woodland product removal, and wildland fire use) 

would provide for the most acres of vegetation to be treated. Over the long term, the increase in the 

opportunities for vegetation treatments also could reduce the potential for impacts from catastrophic 

wildfires and have the greatest long-term reduction in pinyon-juniper encroachment and the associated 

reduction in soil erosion. However, because no acres would be required to be treated, vegetation could 

continue to trend toward increased woodland cover, decreasing shrubs and grasses and therefore 

increasing erosion, and thus increasing deterioration of sites. 

Non-fire vegetation treatments and other planned actions with the potential to affect cultural resources are 

subject to the requirements of Section 106 of NHPA, as amended (36 CFR 800, consultation with the 

Utah State Historic Preservation Officer). Areas affected by surface disturbance would be subject to a 

cultural resource inventory. Inventories would result in the identification of more cultural sites and lower 

the potential for impacts on cultural resources. 

Non-fire vegetation treatments could directly impact cultural resources, depending on their location and 

type. Mechanical treatments (e.g., brush crunching and Dixie harrow) are more likely to impact cultural 

resources than are low-intensity treatments such as chemical treatments or hand lop-and-scatter. Some 

types of historic properties, such as historic mining-related features, could benefit from implementation of 

hazardous fuel reduction projects that would lessen the potential for severe, high-intensity wildland fires 

that could damage or destroy fire-susceptible sites. 

Non-fire vegetation treatments involving surface and shallow subsurface disturbance could introduce 

organic materials to lower soil layers, contaminating shallow subsurface cultural resource sites containing 

early historic or prehistoric datable organics, such as charcoal, wood, or preserved plant materials. Plant 

and pollen contamination would lead to incorrect or inaccurate analytical results by researchers studying 

such remains preserved at sites. Surface and shallow subsurface effects could also include horizontal and 

vertical displacement of the upper portion of soils in which cultural resources are contained, 

compromising depositional context and integrity and causing artifact damage or destruction. 

Other Management Actions 

Cultural resources (particularly archaeological sites and historic ranches) are often located adjacent to 

water resources and/or riparian/wetland areas. Managing riparian/wetland areas in PFC would reduce 

stream bank erosion from localized flooding events and other soil disturbing actions, which would 

preserve cultural resources in place in or directly adjacent to riparian areas. 

Cultural resource inventories and evaluations would be required before transferring lands from federal 

jurisdiction, ensuring that cultural resource sites are inventoried, documented, and mitigated before 

ownership changes. The BLM may retain or obtain lands containing important cultural and historic 

resources, providing protection under federal management policies. 

Cultural inventories and clearances prior to paleontological data recovery projects could identify cultural 

sites. In addition, paleontological resource assessments and inventories could result in the identification of 

cultural sites. 
Cultural Resources 

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4-62 Kanab RMP 

Management in the Paria Canyon–Vermilion Cliffs Wilderness Plan and IMPs (in WSAs) should provide 

long-term protection of cultural resources. 

Retaining crucial wildlife habitat and riparian areas in public ownership could also result in cultural sites 

being retained, ensuring that the sites are protected. 

Restrictions on visually obtrusive developments on VRM Class I and Class II areas would limit 

development on 174,000 acres (31 percent). Although not a restriction on surface disturbance, 

management to preserve and maintain the landscape could reduce disturbance that could impact cultural 

resources. This long-term impact generally would preserve cultural resources in place. 

Potential impacts from commercial live plant and seed collecting would be identified through the 

permitting process and mitigated prior to implementation. In areas proposed for harvest, an increased 

potential would exist for identifying cultural resource sites. Mitigation for impacts would usually be 

avoidance. 

Impacts on cultural resources from implementing silvicultural practices and Native American harvest 

activities would be identified through the permitting process and mitigated prior to implementation. In 

areas proposed for harvest or treatment, there would be an increased potential for identifying cultural 

resource sites. Mitigation for impacts would usually involve avoidance of any sites. Impacts from noncommercial harvest activities not required to obtain permits would be similar to the impacts from 

dispersed recreation. 

Summary 

The BLM would continue to mitigate impacts on cultural resources from authorized uses through project 

avoidance, redesign, and, if necessary, data recovery. However, cultural resources would continue to 

deteriorate through natural agents and inadvertent damage. 

Under the Proposed RMP, increased restrictions on areas of high cultural resource potential would 

decrease the number of sites that could be identified or affected by mineral development because such 

development would be occurring in areas of lower site density. Due to inventories associated with mineral 

development (mineral materials, locatable minerals, oil and gas, and coal), between 28 (low site density) 

and 658 (high site density) cultural sites would be identified over the life of the plan. Most identified sites 

would be avoided, although sites identified during development of the surface coal mine (between 9 and 

219 sites) likely would be eliminated following data recovery. 

Under the Proposed RMP cross-country OHV use would be limited to areas that have already been 

disturbed. In areas limited to designated routes, impacts from vehicle use off the route would be 

eliminated, but sites adjacent to routes could be damaged. These sites would be identified through 

inventories of routes on a case-by-case basis. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

Laws protecting cultural resources generally would provide for mitigation of irreversible and irretrievable 

impacts on cultural resources from permitted activity. However, development of a surface coal mine 

would impact a large number of sites (approximately 100). The large number of sites might make it not 

feasible to mitigate all of the National Register–eligible sites through data recovery. Loss of these sites 

without mitigation would result in an irretrievable loss of data. Development of a scientific research 

design prior to development of the coal mine would result in mitigation of those sites with the greatest 
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Kanab RMP 4-63 

potential for data recovery. Cultural sites that are wholly eliminated due to short-term uses such as 

scientific data recovery efforts and data recovery supporting surface disturbing activities would no longer 

be available for further study. Although data would be recovered through scientific means, the complete 

excavation of a site would result in an irreversible and irretrievable commitment of resources. 

Unavoidable damage to cultural resources from permitted activities could occur if resources that were not 

detected during surveys were identified during ground disturbing activities. In these instances, further 

impacts would be halted upon discovery and the resource would be mitigated to minimize data loss. 

Because areas open to cross-country OHV use in the Proposed RMP are not in areas of high cultural 

sensitivity, there would be a low potential for unavoidable impacts. Unavoidable loss of cultural resources 

due to non-recognition, lack of information and documentation, erosion, and inadvertent damage or use 

would also occur. Broad-scale sampling and classification of areas with a high likelihood of containing 

cultural resources would be expected to reduce the probability of unavoidable adverse impacts on the 

resource. 
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4-64 Kanab RMP 

4.2.9 Impacts on Paleontological Resources 

Impacts on paleontological resources occur from natural weathering and erosion, surface disturbing 

activities, excavation, and theft or vandalism. In general, fossil resources are physically destroyed through 

such agents or activities, or in the case of theft and vandalism important contextual data is also 

irretrievably lost. Unlike cultural resources, which exist largely at or near the land surface, 

paleontological resources are found both at the surface and throughout the subsurface environment. As a 

result, actions that may destroy a fossil presently at the surface (e.g., coal mining or road construction) 

may at the same time expose new resources that were deeply buried in rock strata. In this same manner, 

erosion is continually bringing new fossils to the surface even as it destroys what is presently exposed. 

For management purposes, impacts must be set against the context of the rarity of individual fossil 

specimens. As erosion brings a particular fossil specimen to the surface, if it is a relatively common and 

well understood fossil species or is a non-diagnostic portion of a potentially rare form, impacts on that 

resource up to and including its complete physical destruction are not significant. By definition, all 

vertebrate fossils are considered rare by the BLM, and impacts on these types of fossils are of greatest 

concern. 

BLM paleontological resource management policy is to identify, evaluate, and, where appropriate, protect 

scientifically significant paleontological resources, ensuring that proposed land uses, initiated or 

authorized by the BLM, do not inadvertently damage or destroy these resources (BLM Manual 8270, 

Paleontological Resource Management). BLM policy also requires the facilitation of appropriate 

scientific, educational, and recreational uses of paleontological resources, such as research and 

interpretation. Surface disturbing actions are required to mitigate damage to paleontological resources. 

Mitigation measures include project relocation or redesign (avoidance) and use of scientific data recovery 

methods. Avoidance is the BLM’s preferred mitigation measure for surface disturbing activities. Standard 

assessment/inventory and avoidance procedures conducted in conjunction with surface disturbing actions 

would protect most paleontological resources from significant impacts. In general, impacts on 

paleontological resources from ground disturbance are long term in nature. Although natural erosion, 

exposure, and deterioration of paleontological localities may be slowed or halted, damage to fossils and 

localities cannot typically be reversed. 

The impact analysis and conclusions are based on the BLM’s knowledge of resources and the project 

area, review of existing literature, spatial analysis, and information provided by other agencies. Impacts 

are quantified where possible. In the absence of quantitative data, qualitative impacts and the direction of 

impact were identified. The analysis is based on the following assumptions: 

• Paleontological resources will continue to be discovered throughout the decision area. 

• Recovery and curation in paleontological resources by permitted specialists results in resource 

protection and preservation of paleontological values and in educational opportunities. 

• Paleontological resources identified during assessments and inventories would be protected 

through data collection and mitigation. 

• The number of localities that could be impacted by various actions would be directly correlated 

with the degree, nature, and quantity of surface disturbing activities within the decision area. 

• Surface disturbing activities could expose, dislodge, or damage paleontological resources and 

features that were not visible prior to surface disturbance. 

Under the Proposed RMP, impacts on paleontological resources are not anticipated as a result of 

implementing management actions for the following resources, resource uses, and designations: air 

quality, cultural resources, livestock grazing, and other designations. 
 Paleontological Resources 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-65 

Proposed RMP 

Paleontological Resource Management 

Monitoring scientifically significant paleontological localities would document the rate of deterioration 

and provide baseline data for possible site protection, restoration, or data retrieval. 

Paleontological inventory data for the decision area is crucial for sound resource protection decisions. 

Annual compilations of all new paleontological localities should be updated and entered into a single 

comprehensive geographic information system (GIS) database that is accessible to local resource 

specialists. This would ultimately lead to better resource protection because decision-makers would be 

empowered with emerging patterns for the spatial and temporal distribution of paleontological resources. 

Providing interpretive opportunities could provide more paleontological resource sites for public use and 

education because inventories would be required to recover scientifically important data prior to allowing 

public use of the sites. Increased paleontological interpretation could also increase public appreciation for 

the decision area’s paleontological values. Increased public appreciation could lead to increased user 

stewardship. Impacts associated with stewardship attitudes include increased protection of paleontological 

sites, decreased inadvertent damage to or disturbance of paleontological sites, decreased vandalism and 

looting, and improved preservation of the integrity of paleontological resources. 

Paleontological Resource Assessments/Inventories 

Requiring on-the-ground paleontological inventories prior to permitting surface disturbing activities in 

areas with a high potential for paleontological resources would result in the identification, evaluation, and 

protection, where appropriate, of scientifically significant fossil resources. By focusing on areas with a 

high potential, the formation and facies most likely to contain scientifically significant fossils would be 

scrutinized. If fossil resources are identified, mitigation measures could be applied to protect the resource. 

Mitigation measures include project relocation or redesign (avoidance) and various scientific data 

recovery methods, such as recordation, surface collection, subsurface testing, or excavation. These 

mitigation actions would prevent significant impacts on paleontological resources and increase the 

knowledge and understanding of the area’s paleontological resources and of the history of life on Earth. 

In addition, projects such as development/construction within ROWs, recreation site development, or 

construction of range improvements would be studied prior to implementation. 

Requiring assessments in areas with a medium potential for paleontological resources would allow for 

mitigation needs to be identified and implemented in areas less likely to contain significant fossils. There 

is a potential for some localities in areas with a medium potential to be damaged after surface disturbance 

begins if a field inventory were not performed. Based on the findings of the assessment, mitigation would 

be implemented at all phases of development. 

As the number of paleontological inventories and assessments increases, knowledge of the area’s 

paleontological resources would increase. More paleontological localities would be identified and there 

would be an associated reduction in the number of localities that are damaged prior to surface disturbing 

activity. 

The prioritization of these areas for proactive inventories would identify paleontological resources and 

sites, increasing the database of resources. This would increase the knowledge base in this area while 

providing for improved management of these resources. 

Consulting and coordinating with other local, state, and federal land agency paleontological resource 

specialists (if available) before undertaking significant ground disturbing activities in areas with a high 
Paleontological Resources 

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4-66 Kanab RMP 

potential for paleontological resources would ensure that information gathered concerning similar 

geologic formations and facies is shared among agencies. This will ensure that similar resources are 

protected both within and outside the decision area. 

Other Paleontological Resource Management 

Allowing surface collection of common invertebrate and botanical paleontological resources throughout 

the decision area could result in the incidental collection of scientifically significant resources. However, 

identifying and closing to casual collection areas with rare and significant fossils could reduce impacts 

from incidental collection. 

Targeting fossil sites with high scientific value for excavation and curation would ensure that fossil sites 

with high scientific value are protected either through excavation and data recovery or through increased 

monitoring. In addition, monitoring high-significance (scientific or interpretive) sites with fossil resources 

that are not feasible or desirable to excavate or collect would ensure that fossil sites important to science 

and the public are protected from inadvertent damage or natural deterioration. 

Route Designation and Accessibility 

Although cross-country OHV use would be allowed on more than 1,000 acres (less than 1 percent), 

paleontological resources would not likely be damaged because the areas being proposed for crosscountry use have been subject to disturbance over the past several years, either through natural processes 

(e.g., sand dunes) or human use (e.g., sand dunes and topsoil pit). In these areas, continued disturbance of 

previously disturbed areas would not result in impacts on paleontological localities. 

Limiting OHV use to designated routes on 528,000 acres (95 percent) would provide increased protection 

to paleontological resources. The change from managing most of the decision area as open to crosscountry OHV use under the current management situation to limiting OHV use to designated routes 

would decrease impacts. Paleontological resources away from designated routes would be protected from 

OHV impacts. Rather than the potential for increased disturbance and incidental damage associated with 

pioneered routes in areas open to cross-country use, impacts on paleontological resources from OHV use 

on designated routes would be limited to 1,403 miles (95 percent) of designated routes. There would be 

no impacts from OHV use on 25,000 acres (5 percent) closed to OHV use, in areas away from the 

designated routes, and on 75 miles (5 percent) of closed routes. However, restricting motorized use to 

designated routes could also limit access for paleontological study and excavations. In addition, reducing 

temporary roads associated with temporary projects and reclaiming unnecessary facilities and 

improvements would further reduce access for paleontological resource study, increasing their isolated 

nature. Although such isolation provides indirect protection from inadvertent damage, it also increases the 

potential for a locality to be damaged through natural deterioration prior to being identified and 

recovered. 

Dispersed Recreation Activities 

Unlike permitted activities (e.g., mineral development or ROW development) that are subject to sitespecific evaluations and monitoring, dispersed recreation activities are not under the same degree of 

scrutiny prior to use. Because of their widespread occurrence and generally unsupervised nature, casual 

recreational use likely would result in unmitigated impacts on paleontological resources exposed at the 

surface. Most of this impact would result from unauthorized collecting and vandalism; however, 

unmitigated impacts could also result from any surface disturbing aspect of recreation. 

Mineral Development 

Areas would be open to oil and gas leasing subject to the standard terms and conditions and open to oil 

and gas leasing subject to moderate constraints (timing limitations, CSU) on approximately 343,000 acres 
 Paleontological Resources 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-67 

(62 percent) of areas with a high or medium potential for paleontological resources. Based on the RFD, 

oil and gas development within these areas could impact up to 2,070 acres over the life of this plan 

(Appendix 15). Required inventories for areas that have a high potential for paleontological resources 

would result in the identification of more paleontological localities. In these areas, impacts on 

paleontological resources would be limited to damage of subsurface fossils not identified in the inventory. 

Required assessments in areas with a medium potential for paleontological resources could also result in 

the identification of more paleontological resources. However, there would still be a potential for fossils 

in these areas to be damaged after surface disturbance begins. 

Managing 475,000 acres (86 percent) as open to oil and gas leasing (i.e., open to oil and gas leasing 

subject to the standard terms and conditions, open to oil and gas leasing subject to moderate constraints 

[timing limitations, CSU], and open to oil and gas leasing subject to major constraints [NSO]) could 

result in 906 acres of surface disturbance from seismic operations supporting oil and gas leases. If 

assessments were performed prior to these activities, paleontological localities could be identified. 

However, the potential for significant impacts would remain because of the lack of required inventories 

prior to surface disturbance. 

Based on the RFD, oil and gas development could impact up to 2,070 acres over the life of this plan 

(Appendix 15). Vertebrate or other scientifically significant fossils could be inadvertently damaged from 

disturbance if they were not identified and avoided. However, under the Proposed RMP, inventories 

would be required in areas with a high potential for paleontological resources and assessments would be 

required in areas with medium potential. Required inventories and assessments could identify more 

paleontological localities. However, the potential for impacts would remain in areas with a medium 

potential because of the lack of required inventories prior to surface disturbance. 

Surface disturbance associated with the development of mineral materials (650 acres) and locatable 

minerals (400 acres) could impact paleontological resources in a manner similar to the impacts noted for 

oil and gas development. Under the Proposed RMP, more localities could be identified prior to surface 

disturbance because of required inventories and assessments, which would result in avoidance and/or 

recovery of fossil resources. 

Management that Restricts Surface Disturbing Activities 

Areas that are closed to surface disturbing activities (23,800 acres, 4 percent) would protect 

paleontological resources from such activities. Such decisions include restrictions on uses of fish and 

wildlife and special status species habitat and areas that are sensitive to disturbance (e.g., fragile soils and 

riparian/wetland areas). The reduction or elimination of development in these areas would result in fewer 

paleontological inventories, reducing the potential for locality identification and recordation through data 

recovery associated with surface disturbing developments. In addition, such restrictions on surface 

disturbance could make paleontological resource studies more difficult. 

Paleontological resources on approximately 159,000 acres with a high or medium potential (29 percent of 

areas with high and medium paleontological resource potential) that are open to oil and gas leasing 

subject to major constraints (NSO) and closed to oil and gas leasing would be preserved in place from oil 

and gas development. In these areas there would be a reduction in the potential for identification and 

recordation of localities associated with oil and gas development, compared with areas open for oil and 

gas leasing subject to the standard terms and conditions and areas open to oil and gas leasing subject to 

moderate constraints (timing limitations, CSU). In addition, paleontological resources in areas that would 

be closed to mineral materials activities (105,000 acres, 19 percent) or withdrawn and recommended for 

withdrawal from minerals entry (24,591 acres, 4 percent, and 9,500 acres, 2 percent, respectively) would 

also be protected from potential impacts associated with the extraction of those minerals. There would be 
Paleontological Resources 

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4-68 Kanab RMP 

a reduction in the potential to identify localities associated with locatable mineral entry, compared with 

areas open to such location. 

Actions that Affect Vegetation Conditions 

Wildland fire suppression activities (e.g., construction of fire lines, bulldozing of access roads, and 

general movement of heavy equipment) could disturb the surface, creating impacts on mineral soils and 

bedrock. Fossils could be dislodged or damaged from such disturbance. 

The number of acres that could receive vegetation treatments (e.g., wildlife habitat treatments, watershed 

treatments, livestock rangeland treatments, fuels treatments, and stewardship contracting) could increase, 

potentially increasing the impacts on paleontological resources. Not allowing treatments to exceed an 

annual average of 22,300 acres (446,000 over the life of the plan) would ensure vegetation manipulation 

and associated short-term increases in soil erosion do not exceed historic levels of disturbance. In 

addition, allowing use of the full range of upland vegetation treatment methods and tools (i.e., prescribed 

fire, mechanical, chemical, biological, woodland product removal, and wildland fire use) would provide 

for the most acres of vegetation to be treated. This could result in the identification of more 

paleontological resource sites associated with more acres of vegetation treatment. Over the long term, 

opportunities for vegetation treatments could also reduce the potential for impacts from catastrophic 

wildfires and the potential for long-term reduction in pinyon-juniper encroachment and the associated 

reduction in soil erosion. However because no acres would be required to be treated, the potential for 

impacts on paleontological resources could be low. 

Planned (BLM) or Permitted (BLM-Approved) Surface Disturbing Actions 

Surface disturbing activities in an area where there are known or potential fossil resources could have 

significant impacts on those resources. Although in general the best places to see fossils exposed at the 

surface are where there is little to no vegetation, the spatial distribution of fossils is not controlled by soil 

or vegetative cover. Potential resource loss can occur even in soiled-over or heavily vegetated areas if the 

ground disturbance is deep enough to reach underlying bedrock. As a result the largest potential impacts 

on paleontological resources would occur where the largest surface disturbances occur in formations with 

high potential for paleontological resources. 

Development of a 3,600-acre mine in the Alton coal field would result in damage to or loss of subsurface 

paleontological resources. This area is overlain by Tropic shale, which has a high potential for 

paleontological resources. The process of stripping the overburden would fragment and displace fossil 

resources and remove them from their context. Monitoring the spoil heaps (stripped overburden) could 

result in the identification and recovery of some fossil resources, mitigating some of the loss. 

Other Management Actions 

Land exchanges, sales, or other disposals that remove public lands with fossil resources from federal 

ownership could create significant impacts on those resources by their irretrievable loss to the public. On 

the other hand, acquisition of fossil-rich lands through similar realty-related actions may actually benefit 

paleontological resources. Prior to any transferal of land from public ownership, paleontological resources 

must be inventoried, evaluated, and mitigated whenever necessary to ensure that lands with scientifically 

significant paleontological resources are retained or that the maximum benefit from known resources is 

obtained prior to disposal of such lands, in accordance with all existing federal policy. 

Granting of special ROWs that preclude access, or any activity or designation that prevents scientific 

inquiry or excavation, could ultimately make recovery and preservation of specific significant specimens 

extremely difficult or impossible. 
 Paleontological Resources 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-69 

Restrictions on visually obtrusive developments on VRM Class I and Class II areas would limit 

development on 174,000 acres (31 percent). Although not a restriction on surface disturbance, 

management to preserve and maintain the landscape could reduce disturbance that could impact 

paleontological resources. This long-term impact generally would protect paleontological resources. 

Impacts on paleontological resources from implementing silvicultural practices would be identified 

through the permitting process and mitigated prior to implementation. In areas proposed for harvest or 

treatment, an increased potential would exist for identifying paleontological resource sites. Mitigation for 

impacts would usually include avoidance. 

Summary 

Under the Proposed RMP, requiring paleontological assessments prior to permitting surface disturbing 

activities would provide a degree of protection to paleontological resources. The degree of damage from 

surface disturbing activities depends on many things, including paleontological potential in the area of 

proposed disturbance, the level of disturbance, and the type/level of assessment or inventory used to 

identify the paleontological resources. The Proposed RMP would require inventories in areas with a high 

potential, focusing on areas where damage would most likely occur. On identification, paleontological 

resources would be protected through project avoidance, redesign, abandonment, and data recovery 

investigations. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

Inventories completed prior to surface disturbing activities generally would provide for mitigation of 

irreversible and irretrievable impacts on identified surface paleontological resources from permitted 

activities. However, subsurface paleontological resources could be irreversibly and irretrievably damaged 

and lost from activities that go deep into bedrock. Damage and loss of these subsurface resources would 

constitute an unavoidable adverse impact. For example, development of the coal mine in the Alton area 

would result in these irreversible and irretrievable impacts and unavoidable adverse impacts. Areas open 

to cross-country OHV use, specifically areas of high potential for paleontological resources, could result 

in destruction of some resources, which would be irreversible and irretrievable. Land exchanges, sales, or 

other disposals that remove public lands with fossil resources from federal ownership could result in their 

irretrievable loss to the public. Short-term data recovery (collection) measures would result in long-term 

preservation of paleontological resources, limiting the loss of scientific values associated with the 

physical resources. 

Unavoidable damage to paleontological resources from permitted activities could occur if resources 

undetected during assessments were identified during ground disturbing activities. If paleontological 

resources are identified during ground disturbance, further disturbance would cease and mitigation would 

be implemented to minimize data loss. Unavoidable loss of paleontological resources due to nonrecognition, lack of information and documentation, erosion, and inadvertent damage or use would also 

occur. Broad-scale sampling and classification of areas with a high likelihood of containing 

paleontological resources would be expected to reduce the probability of unavoidable adverse impacts on 

the resource. 
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4-70 Kanab RMP 

4.2.10 Impacts on Visual Resources 

This section presents potential impacts on visual resources, specifically the potential for management 

decisions to create visual changes in or contrasts from the existing landscape, from implementing the 

Proposed RMP. Visual resources generally are impacted by activities that introduce new visual elements 

into the landscape, changing the features that characterize the existing landscape (e.g., the form, line, 

color, and/or texture of the landform, water, vegetation, or structures). Generally, the greater the surface 

disturbance the greater is the change to the landscape. This impact analysis and these conclusions are 

based on knowledge of resources and the decision area, review of existing literature, spatial and temporal 

analysis, and information provided by other agencies. Effects are quantified where possible. In the 

absence of quantitative data, professional judgment was used. Impacts are sometimes described using 

ranges of potential impacts or in qualitative terms, if appropriate. 

The analysis is based on the following assumptions: 

• VRM classes (objectives) are prescriptive for all resources and uses. Activities proposed that 

would not initially meet VRM objectives for the area would be mitigated to the extent needed to 

meet the objectives. Those activities proposed that could not be mitigated would not be 

authorized. 

• The visual resources “inventory classes represent the relative value of the visual resources” 

(BLM-H-8410 Visual Resource Inventory). 

• New surface disturbing activities proposed would be subject to NEPA analysis, including a VRM 

contrast rating. 

• Potential impacts on scenic quality were estimated by evaluating the potential for management 

actions to noticeably change existing landscapes. Current visual resource conditions, against 

which management impacts are compared, were identified through an inventory of visual 

resources. The scenic qualities of the landscape are measured comparatively by application of 

visual resources management classes (I, II, III, and IV) generated from the inventory (see VRM, 

Chapter 3). Impacts from actions proposed in Chapter 2, including alternative VRM objectives, 

are measured against the scenic quality of the existing landscape (as characterized by the 

inventory classes) identified in the inventory. Landscape modifications and impacts on visual 

resources would occur under any management objective (class). The degree of impact would 

depend on the visual objectives, the nature of the proposed project, and the observation point of 

the visitor. 

All surface disturbing activities, regardless of the alternative or management action, would be subject to 

the management objectives of the area within which the activity takes place. The visual resource contrast 

rating system is used to analyze the potential site-specific impacts of surface disturbance and the facility 

design and placement. Surface disturbing activities and facilities would be designed to mitigate their 

visual impacts and conform to the area’s designated VRM objective. Mitigation could include painting, 

facility design, and placement. 

Under the Proposed RMP, impacts on visual resources are not anticipated as a result of implementing 

management actions for the following resources, resource uses, and designations: air quality, cultural 

resources, and paleontological resources. 
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Proposed RMP 

Visual Resource Management Classes 

Management decisions that result in surface disturbance would have direct impacts on scenic quality by 

changing existing landscape characteristics. Similarly, decisions that reduce surface disturbance generally 

would decrease changes to the landscape or preserve scenic quality. The area of impact is not limited to 

the specific area of disturbance. Rather, the viewshed in which the disturbance occurs would be impacted. 

The severity of the impact, or the degree of change and contrast from the existing visual conditions, 

generally would decrease as distance from the disturbance increases. In addition, the larger the 

disturbance, the more visible it would be from foreground and middle ground viewpoints, and thus the 

greater the impact on visual quality.

Setting VRM objectives would impact visual quality. Objectives for VRM Classes I and II would provide 

for the least amount of landscape change and the highest level of visual resource protection, both short 

and long term. VRM Classes III and IV objectives are less protective and would allow for more surface 

disturbing impacts and landscape change. VRM Class I areas would provide the greatest protection to 

visual resources throughout the decision area by restricting surface disturbance and development. Surface 

disturbing activities would not be allowed unless impacts could be mitigated to meet Class I objectives. 

Class II objectives would provide protection of visual qualities, retaining the existing character of the 

landscape. Class III objectives would not emphasize protection of an unmodified landscape and visual 

resources. Class IV objectives allow for major modifications of the landscape. Activities that occur in 

these areas would result in greater change to the characteristic landscape, and may not protect scenic 

values. For more information on VRM class objectives, see the Visual Resources section in Chapter 3. 

Under the Proposed RMP, more than twice as many acres would be managed to preserve their existing 

landscape character (Class I management objectives) as were inventoried as Class I (Table 4-6). The acres 

that would be managed by Class I objectives generally were inventoried as Class II and were adjusted due 

to the presence of a WSA. There would also be a shift of Class IV inventory areas to Class III 

management objectives on approximately 24,600 acres. This change in management would require 

visually obtrusive activities to decrease their visual impact through mitigation measures. In addition, the 

portion of the decision area southwest of U.S. Highway 89 between Kanab and Mt. Carmel Junction 

would be managed as VRM Class III even though much of it was inventoried as VRM Class II. This will 

allow vegetation treatments to be implemented to a greater extent in this concentrated area of pinyonjuniper woodland encroachment. 

Table 4-6. Visual Resource Management Class Acreages—Differences from Inventory 

Class Acreages 

Class I Class II Class III Class IV 

Visual Resource Inventory Class Acres 21,400 165,900 169,200 197,500 

Proposed RMP 

Visual Resource Management Class Acres 76,000 94,400 210,700 172,900 

Acres Different from Inventory Class +54,600 –71,500 +41,500 –24,600 

Percent Change from Inventory Class +255% – 43% +25% –12% 

Wildland Fire 

Fire (wild and prescribed fire) and fire suppression have many effects on the landscape, and thus its visual 

values, in both the short and long term. Most noticeably, fire affects vegetation. But fire suppression also 
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4-72 Kanab RMP 

affects, to a lesser degree, landform. When fire burns, it consumes vegetation. Fire severity varies 

depending on the vegetation community. In the decision area, fire in sagebrush communities would 

remove shrubs and grasses and stimulate regrowth of new vigorous plants, maintaining the vegetative 

element of the landscape. Fire in these communities can also result in the invasion of exotic plants such as 

cheatgrass. In areas with the potential for invasion, fire would facilitate conversion of a landscape with 

some vegetative variety to a monoculture of grasses, and less visual interest and appeal. In pinyon-juniper 

woodlands, however, fire would help maintain openings in the woodland forest, more vegetation variety, 

and more visual appeal. In a coniferous forest, fire may contribute to the loss of trees and understory 

brush and grasses. The fire, however, would also create openings in forests, and stimulate regrowth of 

shrubs, forbs, and grasses, introducing new lines, colors, and textures to the vegetative component of the 

landscape. More variety often leads to more interest and more visual appeal to the visitor. Fire 

suppression would result in construction of fire lines (hand and bulldozer) that remove vegetation and 

expose the underlying soil. These actions would create noticeable lines in the vegetation and some 

disturbance to the landform. Soil disturbances would be rehabilitated at the end of the suppression effort, 

restoring the landform to a near natural condition. Linear vegetation removal, however, would take longer 

to recover, especially in forest and woodland environments. In the short term, burned vegetation would be 

unpleasant to view for many visitors. Over the long term, however, fire would often create variety in the 

vegetation of a landscape that is interesting and appealing to view, depending on vegetation type and size 

of the fire. 

The effects of fire suppression on visual resources would vary depending on the methods used for 

suppression and the landform and vegetation community in which the fire occurs. Construction of fire 

lines (hand or bull dozer), firebreaks, and access roads for the suppression effort would produce shortand long-term changes to the landscape and visual resources. Construction of firebreaks, fire lines, and 

temporary access roads would result in linear features in the vegetation community and landform. 

Depending on the vegetation community where the fire occurs, distance, and observation point, the 

contrast may be easily seen (e.g., in pinyon-juniper or coniferous forest communities) or less noticeable 

(e.g., in grassland or sage brush communities). Fire lines and access routes constructed by bulldozers 

would result in some leveling of landforms and exposure of soils, creating apparent lines in color, form, 

and texture of the landform. Effective rehabilitation would restore disturbed landforms in the short term, 

but disturbances in forest and woodland vegetation communities would remain for a much longer period 

of time. Access to areas in the vicinity of bulldozer lines and firebreaks would be restricted in the short 

term to speed vegetation recovery and soil stabilization, thus decreasing the duration of long-term visual 

contrasts in vegetation. Use of fire retardant would result in short-term impacts on the color of the 

vegetation. The characteristic red color of retardant would often be easily seen, but the color fades over 

time.

Planned (BLM) or Permitted (BLM-Approved) Surface Disturbing Actions 

Construction of recreation sites and facilities (e.g., campgrounds, signs, interpretive sites, trailheads, 

roads, and parking areas) and the associated landform and vegetation disturbances needed to 

accommodate the facilities would directly impact visual resources by adding unnatural features at the site 

of the facilities and to the surrounding landscape. These facilities would be designed and located to meet 

visual objectives for the given area, but the effects would remain localized and long term. The visual 

effect would be less noticeable on a larger, landscape scale. 

Development of coal and locatable and mineral materials (e.g., sand and gravel) would result in removal 

of vegetation, alteration of the landform, and placement of structures on the landscape. The construction 

of roads to the mine or materials site would create lines in the landscape through removal of vegetation 

and cutting and filling of soils for the roadbed. The type of vegetation and the slope of the landform 

would affect the degree of contrast created. Road construction on steep slopes would require more cutting 

and filling of soil than construction on shallower slopes. Placement of roads in dense vegetation would 
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Kanab RMP 4-73 

result in more evident lines through the vegetation. Roads on gentle terrain through sparse vegetation 

generally would result in less contrast on the landscape. Construction of mine pits, tunnels, and adits and 

the resultant waste piles would introduce horizontal lines and terraces, especially on steep or angular 

slopes. Removal of vegetation to accommodate these mine features would create changes in the line and 

texture of vegetation. Removal of mine ore or materials would result in pits, terraces, and stockpiles that 

would contrast with the existing form and line of the land. The exposure of soils likely would result in 

noticeable changes in the color of the landform. Mine equipment and buildings, and other support 

facilities would introduce human-made structures to an otherwise more natural landscape. The size and 

degree of these changes would vary with the size of the mining operation, topography (landform), soil 

type (color and texture), vegetation type, and position of the observer. Withdrawing areas from mineral 

entry and closure to mineral material disposal would maintain existing landscape and visual qualities of 

surrounding areas.

Although mineral development is projected to disturb 8,426 acres (Appendix 15), the broader, 

surrounding landscape on which this disturbance is located would be altered by changes in landform, 

vegetation removal, and placement of structures. Any areas within the viewshed of the disturbances 

would be affected, reducing visual quality over larger areas. The complete magnitude of this impact 

would vary depending on the topography, vegetation, size of disturbance, and any mitigation actions that 

could be applied to reduce visual impacts. 

Surface disturbances associated with the construction of pipelines, powerlines, and communication lines 

and towers would create both short- and long-term changes to the landscape. ROWs for these types of 

facilities are typically linear, and introduce strong lines to the landscape. Removal of vegetation 

(depending on the vegetation type) to facilitate construction and maintenance would create noticeable 

lines (edges) in the vegetation. Exposure of the underlying soil (depending on the color and texture) 

would also create strong lines in the landscape. Rehabilitation of the surface over buried facilities would 

reduce some of these impacts over the long term, but travel routes along the corridors to accommodate 

access for inspection and maintenance would maintain noticeable lines in the landscape. The placement of 

permanent facilities, such as towers, powerlines, and pipelines, would add noticeable linear horizontal and 

vertical structures to the landscape and would permanently alter viewsheds, particularly in undeveloped 

landscapes. ROW corridors would concentrate these facilities and reduce visual contrast throughout much 

of the rest of the decision area. Wind and solar energy development also would introduce highly visible 

structures, which would alter the existing character of the landscape. 

Visual resource values on 391,600 acres (71 percent) that would be open to oil and gas leasing subject to 

the standard terms and conditions or open to oil and gas leasing subject to moderate constraints (timing 

limitation, CSU) could be impacted by exploration and development where such activity occurs. The 

construction of well pads, access roads, pipelines, compressor stations, and other support facilities 

associated with oil and gas exploration and development would result in modification of the landscape on 

approximately 2,070 acres. Construction of these facilities would alter the landform, remove vegetation, 

and introduce human-made structures to the landscape. On steeper slopes, road and well pad construction 

would result in cutting and filling of soil to produce roadbeds and well pads. More soil disturbance would 

occur on steeper slopes than on gentler slopes. Vegetation removal and soil disturbance associated with 

roads and well pads would create lines and openings on the landscape because of vegetation removal and 

exposure of the underlying soil. Contrast would occur in the color, line, and texture of the vegetation 

community. Depending on the amount of cutting and filling for roads and well pads, changes to landform 

would also be observed (e.g., leveling of angular slopes). The degree of contrast would also be affected 

by the vegetation community (density and type of vegetation), soil type (color and texture), and 

observation point of the viewer. Installation of pipelines, compressor stations, and other support facilities 

would result in vegetation removal, soil disturbance, and placement of human-made structures on the 

landscape. The size of the facilities would dictate the degree of vegetation removal. The steepness of 
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4-74 Kanab RMP 

slope would affect the amount of soil disturbance and landform change. The design and location of 

facilities would impact their visibility on the land. When pipelines are buried and the soils and vegetation 

are rehabilitated, the changes to the landscape would be shorter term. Roads, well pads, wellheads, pump 

jacks, and aboveground facilities would affect the landscape, and thus its visual appeal, over the long 

term. The density of development (i.e., well spacing) would affect the overall degree of impact, which 

could be small and localized or evident at a broader landscape level. 

Generally, geophysical exploration would not result in changes to the landform or long-term placement of 

structures on the landscape. Geophysical exploration could result in short-term and site-specific impacts 

on vegetation on approximately 906 acres. The resultant impacts on visual resources would be small, 

localized, and temporary. 

Management that Restricts Surface Disturbing Activities 

Prohibiting surface disturbance in areas that contain special status species, as well as in WSAs and the 

Paria Canyon–Vermilion Cliffs Wilderness, would also prevent long-term changes to the character of the 

landscape and thus its visual values. Habitat restoration measures that include surface or vegetation 

disturbance, however, could create noticeable short-term changes in the landscape, as described in the 

effects of vegetation treatments. Protecting wildlife habitat through stipulations on other land uses (e.g., 

collocation of ROWs, utility corridors, and oil and gas wells and limiting motorized travel) would reduce 

surface disturbance and landscape change, indirectly protecting scenic quality over the long term. 

Areas that are closed to surface disturbing activities (23,800 acres, 4 percent) would protect the existing 

character of the landscape. Such decisions include restrictions on uses of fish and wildlife and special 

status species habitat, and areas that are sensitive to disturbance (e.g., fragile soils and riparian/wetland 

areas). On 162,400 acres (29 percent) open to oil and gas leasing subject to major constraints (NSO) and 

areas closed to oil and gas leasing, changes to the landscape would be prohibited by limitations on surface 

disturbance and occupancy. Visual resources values in areas closed to mineral materials activities 

(105,000 acres, 19 percent) or withdrawn and recommended for withdrawal from minerals entry (24,591 

acres, 4 percent, and 9,500 acres, 2 percent, respectively) would be protected from changes in the 

landscape created by development of these minerals. In addition, excluding ROW development on 75,700 

acres (14 percent) would eliminate the long-term changes to the character of the landscape, and thus its 

visual values from such development. 

OHV Use and Route Designations 

OHV routes create visible lines on the landscape. Depending on topography, the vegetation community, 

and the observation points, those lines would be visible to varying degrees. In addition, removal of 

vegetation would reveal the underlying soil, which often is a contrasting color and texture to the 

surrounding vegetation. This would further accentuate the change to the landscape. Implementing a 

recreational OHV system of designated routes throughout the decision area would limit landscape 

disturbance caused by OHVs. Designating small areas of previous disturbance as open to cross-country 

OHV use would not result in additional impacts from the removal of vegetation and exposure of soil. 

Areas where OHV use is limited to designated routes would limit impacts on the landscape to the existing 

transportation system, and eliminate the creation of new routes that would result in further changes to the 

landscape and visual quality. Impacts from OHV use on designated routes would occur on 1,403 miles of 

designated routes on 528,000 acres (95 percent). Limiting OHV use to designated routes under the 

Proposed RMP would decrease impacts from OHV use throughout most of the decision area. Scenic 

quality on 25,000 acres (5 percent) of the decision area closed to OHV use would be protected from the 

impacts of motorized use. Over the long term, routes closed to OHV use would become obscured as 

vegetation extends into the route. 
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Livestock Grazing 

Where livestock grazing continues to be authorized, the installation of livestock facilities (e.g., fences, 

cattle guards, water developments, and roads) and the landform and vegetation disturbances needed to 

accommodate the facilities would directly impact visual resources by adding features not found in the 

surrounding landscape. Such impacts would be localized and long term. Areas with Class I or II 

management objectives would be more sensitive to construction of new facilities. Incorporating rangeland 

management practices and visual mitigation measures would help reduce the extent of visual impacts on 

the landscape. 

Changes in Vegetation (Vegetation Restoration, Habitat Manipulation, Fuels Treatments) 

Pinyon-juniper woodlands are naturally interspersed with openings of shrubs and grasslands. Over time, 

pinyon and juniper trees invade these grasslands. Wildfire once maintained these natural openings. Using 

a variety of treatments to reduce this encroachment would create openings in large expanses of pinyonjuniper woodlands. Focusing on reducing the encroachment of pinyon-juniper woodlands would create 

natural openings in large expanses of pinyon-juniper woodlands. The treatments would create noticeable 

lines along edges, changes in color, and changes in texture between the woodlands and grasslands. These 

contrasts would create variety and interest in an otherwise monotonous landscape maintained under the 

current management conditions. 

Summary 

Decisions that result in surface disturbance would have direct impacts on scenic quality by changing 

existing landscape characteristics. Similarly, decisions that reduce surface disturbance generally would 

decrease changes to the landscape or preserve scenic quality. 

Under the Proposed RMP, development of all minerals is anticipated to disturb 8,426 acres (Appendix 

15). Any areas within the viewshed of the disturbances would be affected, reducing visual quality over 

larger areas. The complete magnitude of this impact would vary depending on the topography, vegetation, 

size of disturbance, and any mitigation actions that could be applied during site specific analysis and 

design to reduce visual impacts. 

Areas subject to vegetation treatments would add vegetation variety and contrast to the landscape, 

increasing interest and variety in form, line, color, and texture. In the short term, this would create direct 

visual changes to the landscape. Over the long term, restoration and vegetation treatments designed to 

improve ecological conditions would create a mosaic in vegetation pattern that would increase visual 

variety and interest and improve scenic quality. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources. Surface disturbing actions and 

those that affect vegetation would result in various short-term effects, such as decreased visual resource 

quality associated with development actions on the landscape. Surface disturbing activities, including 

mineral and energy development (e.g., coal, oil and gas, and hard rock), infrastructure development (e.g., 

livestock waters, wildlife guzzlers, recreation sites, powerlines, and communication sites), and human 

use, would have the greatest potential for short-term uses affecting the long-term landscape character. 

Construction of roads, well pads, and other transportation infrastructure improvements could impair 

important visual elements, particularly if these developments occurred in areas of high visual sensitivity 

(i.e., near communities or areas of high recreation use). Many of these visual intrusions likely would 

affect the visual resources over the life of this plan. 
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4.2.11 Impacts on Non-WSA Lands with Wilderness Characteristics 

The Proposed RMP provides management decisions to protect, preserve, and maintain wilderness 

characteristics on five non-WSA areas (27,770 acres) with wilderness characteristics. It does not provide 

any specific management decisions in order to protect, preserve or maintain wilderness characteristics for 

the other 62,010 acres of non-WSA lands found to have wilderness characteristics. This section addresses 

impacts on wilderness characteristics which include the appearance of naturalness and outstanding 

opportunities for primitive recreation or solitude. Impacts could include actions that maintain, protect, or 

improve wilderness characteristics or actions that result in the complete or partial loss of these 

characteristics. Within non-WSA areas, the magnitude and intensity of impacts to wilderness 

characteristics constitute a number of variables. These variables include the size and configuration of the 

area, topography, vegetation type, sequence of development, and reclamation time. 

Management actions that could impact an area’s natural appearance could include the presence or absence 

of roads and trails, use of motorized vehicles along those roads and trails, fences and other improvements, 

nature and extent of landscape modifications, presence or lack of native vegetation communities, 

connectivity of wildlife habitats, or other actions that result in or preclude surface disturbing activities. 

All these activities affect the presence or absence of human activity and, therefore, could affect an area’s 

natural appearance. 

Two other wilderness characteristics (i.e., outstanding opportunities for solitude or primitive, unconfined 

types of recreation) are related to the human experience in an area. Visitors may have outstanding 

opportunities for solitude or for primitive, unconfined recreation when the sights, sounds, and evidence of 

other people are rare or infrequent; where visitors can be isolated, alone, or secluded from others; where 

the use of the area is through non-motorized, non-mechanical means; and where no or minimal developed 

recreation facilities are encountered. Impacts are quantified where possible; however, the lack of project 

specific locations results in impacts often being identified qualitatively. In the absence of quantitative 

data, best professional judgment was used. 

The analysis is based on the following assumptions: 

• Surface disturbances related to mineral exploration and development identified in the RFD 

(Appendix 15) would occur within the decision area. 

• Seismic operations would occur uniformly throughout the decision area. 

• Because non-WSA lands with wilderness characteristics constitute approximately 16 percent of 

the decision area, approximately 16 percent of the 906 acres (150 acres) of disturbance associated 

with oil and gas exploration (Appendix 15) could occur on non-WSA lands with wilderness 

characteristics. Restrictions on oil and gas development from management actions in non-WSA 

lands with wilderness characteristics could change this acreage. 

• Exploration wells would be developed uniformly throughout the area with high oil and gas 

development potential. 

• Because non-WSA lands with wilderness characteristics constitute approximately 27 percent of 

areas with high oil and gas development potential, approximately 27 percent of the 32 exploration 

wells (approximately 9 wells) anticipated in areas with high oil and gas development potential 

would occur within non-WSA lands with wilderness characteristics. With approximately 23 acres 

of disturbance per well (Appendix 15), development of 9 exploration wells would result in 

disturbance of approximately 210 acres of non-WSA lands with wilderness characteristics. 

Restrictions on oil and gas development from management actions in non-WSA lands with 

wilderness characteristics could reduce this acreage. 
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Under the Proposed RMP, impacts on non-WSA lands with wilderness characteristics are not anticipated 

as a result of implementing management actions for the following resources and designations: air quality, 

wilderness, WSAs, and other designations. 

Proposed RMP 

Management that Restricts Surface Disturbing Activities 

Management prescriptions on approximately 31 percent (27,770 acres) of the inventoried non-WSA lands 

with wilderness characteristics would protect, preserve, and maintain the wilderness characteristics in five 

non-WSA lands with wilderness characteristics (Table 4-7). In addition, prescriptions from other 

resources or special designations could provide additional indirect protection to the wilderness 

characteristics of the non-WSA lands with wilderness characteristics in Table 4-7, as well as the 

remaining non-WSA lands with wilderness characteristics described in Chapter 3 (Table 3-22). 

Table 4-7. Proposed RMP Non-WSA Lands with Wilderness Characteristics Managed for 

their Wilderness Characteristics 

Name of Non-WSA Land with Wilderness Characteristics1 Acres Percent2

East of Bryce 850 99%

Moquith Mountain 9,600 88%

Orderville Canyon 2,700 100%

Parunuweap Canyon 120 2%

Upper Kanab Creek 14,500 33%

Total 27,770 44%

Notes: 

1 – Non-WSA lands with wilderness characteristics not noted in this table will have no acres managed specifically to protect, 

preserve, and maintain their wilderness characteristics. 

2 – Number shows the percent of the evaluated acres determined to have wilderness characteristics (Table 3-22) that will be 

managed specifically to protect, preserve, and maintain wilderness characteristics

Management decisions that restrict surface disturbance in non-WSA lands with wilderness characteristics 

would also indirectly protect those characteristics. Such decisions include restrictions on uses of fish and 

wildlife habitat, vegetation management, protection of wild and scenic rivers (WSR), and areas that are 

sensitive to disturbance (e.g., fragile soils, riparian/wetland areas, and incorporated municipalities). 

Approximately 320 acres of the Orderville Canyon area of non-WSA lands with wilderness 

characteristics overlap the corridors of two suitable WSR segments. Management that protects the 

tentative classification and ORVs within these corridors also would provide protection to the wilderness 

characteristics. 

Motorized Use of Routes 

Non-WSA Lands Managed for Protection of Wilderness Characteristics 

None of five areas comprising 27,770 acres of non-WSA areas would be open to cross-country OHV 

travel, thus protecting these areas from any long-term impacts from cross-country OHV use. All five 

areas would limit OHV use to designated roads and trails. There would be no routes designated with East 

of Bryce non-WSA area. There would be 0.3 miles of routes designated in Parunuweap Canyon, and 15.2 

miles of routes designated within Upper Kanab Creek. In the Moquith Mountain non-WSA area, 2.9 

miles of routes would be designated for OHV use, while 0.8 miles of routes would be closed to OHV use. 
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4-78 Kanab RMP 

In the Orderville Canyon non-WSA area being protected, preserved, and maintained for its wilderness 

characteristics, 8.2 miles of routes would be designated for OHV use, while 0.4 miles would be closed to 

OHV use. In all five areas, a total of 26.6 miles of routes would be designated for OHV use.

All of these areas were found to have wilderness characteristics with ongoing OHV use of the designated 

routes. Allowing motor vehicle use to continue along the designated routes within the non-WSA lands 

with wilderness characteristics could impact recreation users’ perception of opportunities for solitude and 

primitive recreation as a result of the occasional sound and presence of OHV users. When the OHV user 

passes beyond sight and hearing range, opportunities for solitude and primitive recreation would return 

and natural soundscapes would be restored. Limiting OHV recreation use to these designated routes 

would minimize disturbance of adjacent lands, protecting the natural character of areas adjacent to these 

routes. The appearance of naturalness would be temporarily reduced by any signs and barricades that may 

be needed to keep vehicles on existing routes. Such structures would be temporary, limited to the routes, 

and would not affect the whole non-WSA lands with wilderness characteristics. This use would not 

expand beyond these routes nor impact the long-term naturalness of the non-WSA lands with wilderness 

characteristics. Occasional use of the designated routes by OHV users would continue to provide 

management that allows for the protection, preservation, and maintenance of the wilderness 

characteristics in these areas. There are no inventoried routes in the 320 acres in the Orderville Canyon 

area of non-WSA lands that would be closed to OHV use because it also overlaps a suitable wild and 

scenic river with a “wild” classification. 

Non-WSA Lands Not Managed for Protection of Wilderness Characteristics 

Not designating any non-WSA lands with wilderness characteristics for cross-country OHV use would 

protect these areas from any long-term impacts from cross-country OHV use. Allowing motor vehicle use 

along the 91.4 miles of designated routes within 62,010 acres of non-WSA lands with wilderness 

characteristics limited to designated routes could impact recreation users’ perception of opportunities for 

solitude and primitive recreation. The appearance of naturalness would be temporarily reduced by any 

signs and barricades that may be needed to keep vehicles on existing routes. Such structures would be 

temporary, limited to the routes, and would not affect the whole non-WSA lands with wilderness 

characteristics. In addition, the sound and presence of an increasing number of OHV users would reduce 

non-motorized recreation users’ perception of opportunities for solitude and primitive recreation. When 

the OHV user passed beyond sight and hearing range, opportunities for solitude and primitive recreation 

would return and natural soundscapes would be restored. Limiting OHV recreation use to these 

designated routes would minimize disturbance of adjacent lands, protecting the natural character of areas 

adjacent to these routes. This use would not expand beyond these routes nor impact the long-term 

naturalness of the non-WSA lands with wilderness characteristics. Closing 3 miles of routes in the 

Vermilion Cliffs area of non-WSA lands with wilderness characteristics not managed to protect, preserve 

or maintain its wilderness characteristics would eliminate all OHV impacts on wilderness characteristics 

in this area. Approximately 9,600 acres of the Vermilion Cliffs area of non-WSA lands with wilderness 

characteristics overlap the Kanab Community SRMA. Prescriptions to management for non-motorized 

recreation in the Non-Motorized RMZ provide indirect protection for wilderness characteristics in this 

area.

Visual Resources Management 

Non-WSA Lands Managed for Protection of Wilderness Characteristics 

Approximately 320 acres of the Orderville Canyon area of non-WSA lands with wilderness 

characteristics managed to protect, preserve, and maintain its wilderness characteristics that also overlaps 

a wild and scenic river with a “wild” classification would be managed as VRM Class I (Table 4-8), which 

would preserve the naturalness and opportunity for solitude and primitive recreation. All of the other 
 Wilderness Characteristics 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-79 

lands being managed for their wilderness characteristics values (27,450 acres) would be managed under 

VRM Class II objectives. The naturalness of these areas would be protected because of restrictions that 

require development activities to retain the existing character of the landscape. 

Non-WSA Lands Not Managed for Protection of Wilderness Characteristics 

The level of landscape change would be low on 22,280 acres on all or portions of five non-WSA lands 

with wilderness characteristics managed as VRM Class II. This VRM objective class was attributed to 

these areas due to other resource considerations, not because of their wilderness characteristics. The 

naturalness of these areas would be protected because of restrictions that require development activities to 

retain the existing character of the landscape. Naturalness would not be protected if visually intrusive 

activities occurred on 39,410 acres (44 percent) on eight non- WSA lands with wilderness characteristics 

managed wholly or partially as VRM Class III and Class IV areas. Disturbances and/or developments in 

these areas could introduce unnatural-looking visual intrusions, reducing the naturalness at a site-specific 

and landscape level. 

Table 4-8. Proposed RMP VRM Class of Non-WSA Lands with Wilderness Characteristics 

VRM Class I VRM Class II VRM Class III VRM Class IV Non-WSA Lands 

with Wilderness 

Characteristics Acres %1 Acres %1 Acres %1 Acres %1

Canaan Mountain 0 0% 0 0% 3,800 54% 3,200 46%

Carcass Canyon 0 0% 0 0% 200 91% 20 9%

East of Bryce 2 0 0% 860 100% 0 0% 0 0%

Moquith Mountain 2 0 0% 10,810 99% 90 1% 0 0%

Orderville Canyon 2 320 12% 2,380 88% 0 0% 0 0%

Paria/Pine Hollow 0 0% 0 0% 0 0% 900 100%

Parunuweap Canyon 2 0 0% 1,100 19% 4,200 74% 400 7%

Upper Kanab Creek 2 0 0% 24,200 56% 13,900 32% 5,500 13% 

Vermilion Cliffs 0 0% 10,700 96% 400 4% 0 0%

Wide Hollow 0 0% 0 0% 6,800 100% 0 0%

Total 320 0% 50,050 56% 29,390 33% 10,020 11% 

Notes: 

1 – Percent of area of non-WSA lands with wilderness characteristics. 

2 – All or portions of this area would be managed to protect, preserve, and maintain their wilderness characteristics under the

Proposed RMP (see Table 4-7)

Recreation Use 

All Non-WSA Lands with Wilderness Characteristics 

High concentrations of recreation users (large group sizes and/or frequent group encounters) in non-WSA 

lands with wilderness characteristics could decrease outstanding opportunities for solitude. However, 

most of the non-WSA lands with wilderness characteristics would not receive consistent concentrated 

recreation use. Early research proposed that solitude is impacted mainly by increasing number of intergroup contacts and not by the number within a user’s own group (Watson et al. 1998). More recent 

research has shown that the loss of solitude is not explained by the mere presence of others, but by the 

behavior of other groups conflicting with expectations of user behavior (Watson 2001). For example, 

interaction between OHV users and hikers in a wilderness setting could create a greater loss of solitude 
Wilderness Characteristics 

Chapter 4 Proposed RMP and Final EIS 

4-80 Kanab RMP 

for the hikers due to expectations placed on what activities they anticipated seeing while hiking that day 

or for the uses they personally deem “appropriate” for that area. Likewise, the differences in general 

recreation goals between day-users (less concerned about solitude, more interested in scenic beauty) and 

multi-day users (more concerned with the “purer” wilderness experience) could create conflicts based on 

only the expectations being sought by the individual recreationists (Cole 2001). Concerns about solitude 

and the number of groups encountered appear to be more important in more lightly used portions of 

wilderness, but are less helpful for setting use limits where use is heavy (Cole 2001). In general, the loss 

of solitude has been associated more with the behavior of other wilderness users, whether actually 

witnessed by others or interpreted through evidence of natural impacts, and the degree to which that 

behavior is beyond that expected (Freimund and Cole 2001). 

Under the Proposed RMP, limiting group sizes associated with SRPs within riparian areas and designated 

critical habitat to 12 people would help protect opportunities for solitude and primitive unconfined 

recreation. These impacts would be most evident in the areas currently receiving high levels of use, such 

as the Orderville Canyon area of non-WSA lands with wilderness characteristics surrounding the North 

Fork Virgin River and Orderville Canyon WSAs. Throughout the remainder of the non-WSA lands with 

wilderness characteristics, generally in more open landscapes, limiting SRP group sizes to 25 would keep 

group sizes low while allowing users to be able to seek out opportunities for solitude. In addition to the 

reduction in the number of users, supporting education and outreach programs such as Tread Lightly and 

Leave No Trace would reduce impacts from increasing numbers of overnight users as campers recreate in 

a manner that leaves fewer impacts. 

Limiting OHV use to designated routes throughout the decision area could increase the use of wheeled 

game carriers away from the designated routes. However, the overall impact from OHVs driving crosscountry would be eliminated. 

Planned (BLM) or Permitted (BLM-Approved) Surface Disturbing Actions 

Non-WSA Lands Managed for Protection of Wilderness Characteristics 

The five non-WSA lands with wilderness characteristics managed for their wilderness characteristics 

(27,770 acres) would be protected from oil and gas development (full-field wells or wildcat 

well/exploratory wells) activities due to NSO stipulations from non-WSA lands with wilderness 

characteristics management or closure to leasing from other management decisions (850 acres in East of 

Bryce area for are closed due to municiple boundaries and 320 acres of Orderville Canyon area are closed 

due to wild and scenic suitable “wild” segment). There are no waivers, exceptions, or modifications to the 

NSO stipulation. Long-term naturalness and opportunities for solitude and primitive recreation would be 

protected from oil and gas development in these areas. However, NSO stipulations do not necessarily 

preclude oil and gas exploration activities, on lease or off-lease, that do not result in surface occupancy. 

As a result, oil and gas exploration activities could result in impacts to wilderness characteristics on an 

estimated 50 acres within the 26,600 acres of non-WSA lands with wilderness characteristics managed for 

their wilderness characteristics that are open to oil and gas leasing subject to major constraints (NSO). 

These 50 acres of impacts reduce the appearance of naturalness and eliminate opportunities for solitude 

within the sights and sounds of the exploration activities. Naturalness would be impacted by increases in 

visual intrusions and human activity associated with the exporation, as well as short-term disturbance of 

vegetation. Increased noise levels, visual impacts (e.g., presence of equipment), presence of other people, 

and associated vehicular travel would eliminate opportunities for solitude and primitive recreation near 

the activity. Depending on the location of the exploration activities, and the adjacent terrain, vegetation, 

and atmospheric conditions, impacts resulting from oil and gas exploration could result in a short-term 

reduction in opportunities for solitude and primitive recreation to less than outstanding on portions of the 

four of the non-WSA lands with wilderness characteristics managed for wilderness characteristics. When 

exploration activities are completed, opportunities for solitude and primitive recreation would return and 
 Wilderness Characteristics 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-81 

there would be no long-term effects. Impacts to naturalness would generally be rehabilitated and revegetated within one growing season, although the rate would depend greatly on the vegetation type, soil 

conditions, and precipitation. Site-specific soil types and climatic variations would be major determinants 

in the length of time and success of reclamation. 

Overlapping management stipulations from other resource decisions would close 1,170 acres of nonWSA lands with wilderness characteristics managed for their wilderness characteristics to oil and gas 

leasing (850 acres in East of Bryce area for are closed due to municiple boundaries and 320 acres of 

Orderville Canyon area are closed due to wild and scenic suitable “wild” segment). This would 

precluding any impacts from oil and gas exploration or development activities, protecting, preserving and 

maintaining wilderness characteristics in these areas. 

All 27,770 acres of the non-WSA lands with wilderness characteristics managed to protect, preserve, and 

maintain their wilderness characteristics in the Proposed RMP (Table 4-7) would be closed to mineral 

material disposal. Wilderness characteristics in these areas would be protected from the losses of 

naturalness, solitude and opportunities for primitive recreation that would accompany such development. 

Approximately 320 acres in the Orderville Canyon and 890 acres in the Upper Kanab Creek non-WSA 

lands with wilderness characteristics that are managed to protect, preserve, and maintain their wilderness 

characteristics would be recommended for withdrawal from mineral entry due to wild and scenic river, 

and relict vegetation management, respectively. This would eliminate the potential for impacts from 

locatable mineral exploration and development. The remainder of the non-WSA lands with wilderness 

characteristics would be open to locatable mineral entry and are not recommended for withdrawal from 

mineral location. If development were to occur within these areas, impacts would result in the loss of 

naturalness, solitude, and opportunities for primitive recreation. The development potential for these 

minerals is low in the five non-WSA lands with wilderness characteristics being managed for those value, 

thus, the potential for impact would be low. 

All 27,770 acres of non-WSA lands with wilderness characteristics managed to protect, preserve, and 

maintain their wilderness characteristics in the Proposed RMP (Table 4-7) would be managed as ROW 

avoidance areas. Any approved ROWs would need to comply with the VRM Class II objectives. This 

would help mitigate affects to naturalness. If construction activities were necessary, those activities may 

temporarily affect solitude experiences or primitive recreation opportunities. Although some of the nonWSA lands with wilderness characteristics managed to protect, preserve, and maintain with wilderness 

characteristics are remote and may have a low probability for ROW requests, the decision area has been 

one of the few areas in the region where ROWs can still be located. On 320 acres along the wild and 

scenic river segment of Orderville Canyon, a right-of-way exclusion zone would preclude rights-of-way 

authorizations. 

Non-WSA Lands Not Managed for Protection of Wilderness Characteristics 

Mineral leasing exploration and development occurring within the non-WSA lands with wilderness 

characteristics not managed to protect, preserve or maintain their characteristics could impact both the 

naturalness and opportunities for solitude and primitive recreation from surface disturbance associated 

with exploration and development. Naturalness would be impacted primarily from increases in visual 

intrusions, human activity, and modifications to the landscape. Increased noise levels, visual impacts, 

presence of other people, and associated vehicular travel would impact opportunities for solitude and 

primitive recreation. The noise, people, vehicles, and equipment present during exploration for and 

development of mineral resources would eliminate opportunities for solitude and primitive recreation near 

the activity. Depending on the location of the well pads and roads, the terrain, vegetation, and 

atmospheric conditions, impacts resulting from mineral exploration and development would reduce the 

opportunities for solitude and primitive recreation to less than outstanding in all or a substantial portion of 
Wilderness Characteristics 

Chapter 4 Proposed RMP and Final EIS 

4-82 Kanab RMP 

the various non-WSA lands with wilderness characteristics. Naturalness could also be lost indirectly 

throughout the non-WSA lands with wilderness characteristics open for oil and gas leasing (standard 

terms and conditions, moderate constraints, and major constaints), if direct impacts involve multiple road 

networks and wells. The quality of the opportunity for solitude and primitive recreation could also be 

compromised. When development is completed, opportunities for solitude and primitive recreation could 

return. However, productive wells would remain in place and would be substantially noticeable until the 

wells are decommissioned and disturbance is reclaimed, eliminating naturalness for the life of the well. 

Restoration activities would reduce the loss of naturalness from surface disturbing activities, especially on 

exploration wells that would be rehabilitated and re-vegetated within 2–5 years. Site-specific soil types 

and climatic variations would be major determinants in the length of time and success of reclamation. The 

magnitude of these impacts would vary based on the acres of oil and gas leasing stipulations by each area 

of non-WSA lands with wilderness characteristics (Table 4-9). 

Managing approximately 55 percent of the non-WSA lands with wilderness characteristics not manged 

for wilderness characteristics (49,280 acres) as open to leasing subject to standard, or moderate 

constraints could result in impacts to naturalness, solitude and primitive recreation opportunities. This 

activity could eliminate naturalness and opportunities for solitude on or within the sights and sounds of 

the activities, as described above. Although 55 percent of the non-WSA lands with wilderness 

characteristics would be open to mineral leasing subject to standard terms and conditions or subject to 

moderate constraints, the RFD and analysis assumptions project no more than 120 acres of direct 

disturbance due to exploration activities and 140 acres of direct disturbance due to development of 

exploration wells. An additional 460 acres could be disturbed if the one very small oil/gas field is 

developed on non-WSA lands with wilderness characteristics. Based on these exploration and 

development acres, wilderness characteristics could be directly eliminated on approximately one percent 

of non- WSA lands with wilderness characteristics that are not managed for those characteristics. 

However, naturalness and outstanding opportunities for solitude could be impacted beyond these 720 

acres, depending on topographic and vegetation characteristics surrounding the wells. Over the long term, 

because most of the wells (32 of 52 wells in high-potential areas) would be exploratory, continued loss of 

naturalness would not occur and reclamation would generally restore the natural-looking conditions. 

Overlapping management stipulations from other resource decisions, would protect wilderness 

characteristics from oil and gas development on 12,670 acres within the non-WSA lands not being carried 

forward for protective management of their wilderness characteristics by closing these areas to leasing or 

requiring leases to be subject to major constraints (NSO) (Table 4-9). 

Table 4-9. Proposed RMP Acres of Oil and Gas Leasing Stipulations Within Non-WSA 

Lands with Wilderness Characteristics 

Open, Subject to 

Standard Terms 

and Conditions

Open Subject 

to Moderate 

Constraints

Open Subject 

to Major 

Constraints 

Closed to Leasing 

Non-WSA Lands 

with Wilderness 

Characteristics 

Name Acres %1 Acres %1 Acres %1 Acres %1

Canaan Mountain 0 0% 7,000 100% 0 0% 0 0%

Carcass Canyon 220 100% 0 0% 0 0% 0 0%

East of Bryce 2 0 0% 0 0% 0 0% 860 100%

Moquith Mountain 2 0 0% 0 0% 10,900 100% 0 0%

Orderville Canyon 2 0 0% 0 0% 2,380 88% 320 12%

Paria/Pine Hollow 550 61% 350 39% 0 0% 0 0%

Parunuweap Canyon 2 0 0% 5,580 98% 120 2% 0 0%
 Wilderness Characteristics 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-83 

Open, Subject to 

Standard Terms 

and Conditions

Open Subject 

to Moderate 

Constraints

Open Subject 

to Major 

Constraints 

Closed to Leasing 

Non-WSA Lands 

with Wilderness 

Characteristics 

Name Acres %1 Acres %1 Acres %1 Acres %1

Upper Kanab Creek 2 7,700 18% 20,500 47% 14,800 34% 600 1% 

Vermilion Cliffs 0 0% 1,280 12% 9,800 88% 20 <1%

Wide Hollow 0 0% 6,100 90% 700 10% 0 0%

Total 8,470 9% 40,810 46% 38,700 43% 1,800 2% 

Notes: 

1 – Percent of area of non-WSA lands with wilderness characteristics. 

2 – All or portions of this area would be managed to protect, preserve, and maintain their wilderness characteristics under the

Proposed RMP (see Table 4-7) 

Management of the Cottonwood Canyon ACEC would provide protection from mineral material disposal 

on 1,200 acres not managed to protect, preserve, and maintain wilderness characteristics within the 

Moquith Mountain area of non-WSA lands with wilderness characteristics. This is because the ACEC 

would be closed to such activities. The remainder of the non-WSA lands with wilderness characteristics 

not managed for protection of wilderness characteristics would be open to mineral material disposal. 

Development of such resources could create a loss of naturalness, impact solitude and result in loss of 

primitive recreation opportunities due to surface disturbance, noise from heavy equipment operation, and 

associated traffic. 

Approximately 1,200 acres in the Moquith Mountain area would be recommended for withdrawal from 

mineral entry due to ACEC designation. This would eliminate the potential for impacts from locatable 

mineral exploration and development. The remainder of the non-WSA lands with wilderness 

characteristics not managed for protection of wilderness characteristics would not be recommended for 

withdrawal from mineral location. If development were to occur within these areas, impacts would be 

similar to those noted for oil and gas above, resulting in the loss of naturalness, solitude, and 

opportunities for primitive recreation. The development potential for these minerals is moderate or low in 

non-WSA lands with wilderness characteristics, and the potential for impact would be low. 

Development of ROWs in non-WSA lands with wilderness characteristics not managed for protection of 

their wilderness characteristics would remove opportunities for solitude and primitive recreation during 

construction. The surface disturbance associated with the development would eliminate naturalness in 

these areas. Following construction activities, naturalness would remain impacted for above-ground 

facilities, while reclamation of subsurface ROWs would reduce the loss of naturalness. 

Changes in Vegetation (Vegetation Restoration, Habitat Manipulation, Fuels Treatments) 

All Non-WSA Lands with Wilderness Characteristics 

One of the factors related to opportunities for solitude is the presence of vegetation to provide screening. 

Healthy upland and riparian/wetland areas provide vegetation screening, improving opportunities for 

solitude. Maintaining and/or restoring riparian areas protects naturalness in these areas and improves 

vegetation screening to protect site-specific opportunities for solitude. Decisions associated with soil, 

water, fish and wildlife, livestock grazing, vegetation, wildland fire ecology, and special status species 

alternatives that result in direct changes to vegetation—whether intended to enhance, protect, and restore 

habitat; reduce soil erosion; increase livestock forage; or restore ecological functions—could be 

implemented in all non-WSA lands with wilderness characteristics. Solitude and naturalness could 

experience short-term losses while work was being conducted due to the sights and sounds associated 
Wilderness Characteristics 

Chapter 4 Proposed RMP and Final EIS 

4-84 Kanab RMP 

with the vegetation treatments and from the evidence of other people assisting in management activities. 

Long-term impacts would depend on the size and scope of the project. Allowing up to 446,000 acres of 

treatment over the life of the plan would result in these impacts occurring within some of the non-WSA 

lands with wilderness characteristics. 

Most vegetation treatments likely would occur in areas with invaded pinyon-juniper woodlands. 

Vegetation treatments in these areas could result in stumps, evidence of disturbed vegetation, or 

unnatural-looking edge patterns, reducing the short-term appearance of naturalness. Over the long term, 

these impacts would be rehabilitated and become unnoticeable. In addition, the change of vegetation from 

woodland to shrubland would help restore these areas to a more pre-settlement condition. However, the 

change could also reduce tall vegetation that is conducive to screening, decreasing opportunities for 

solitude and primitive recreation. Over the long term, allowing high levels of vegetation treatment would 

help maintain and/or enhance naturalness by bringing the fire regime condition class to a point that would 

allow fire to play its natural role in the ecosystem. However, not requiring treatments could result in 

further expansion of pinyon-juniper woodlands, improving screening and associated opportunities for 

solitude, but decreasing naturalness because vegetation communities continue to be outside their natural 

disturbance regimes. 

The five non-WSA lands with wilderness characteristics that are being managed for their wilderness 

characteristics would be closed to harvesting of woodland products. This would prevent impacts to the 

naturalness of these areas and preclude temporary impacts to solitude and primitive recreation from noise 

and human disturbance associated with wood cutting. Allowing harvesting of woodland products in the 

remaining 62,010 acres could impact non-WSA lands with wilderness characteristics by detracting from 

the natural character of the area and impacting opportunities for solitude. Impacts on natural character 

would be similar to the impacts from vegetation treatments noted above. 

Wildland Fire and Suppression 

All Non-WSA Lands with Wilderness Characteristics 

Non-WSA lands with wilderness characteristics are affected by a variety of influences. Environmental 

actions, including changes to vegetation communities and the resulting modification of fire’s role and 

regime, have resulted in an existing environment much different from the historical condition. Likewise, a 

variety of political and regulatory management constraints associated with other resource needs and 

safety considerations affect how the role of fire or non-fire fuels management can be applied within these 

areas. 

The goals of the wildland fire ecology program would be to allow wildland fire to function in its natural 

ecological role, mirroring the historical fire return interval and severity. Recognizing that vegetation 

conditions and fuel loading within these lands are not in a historically natural condition, fire would still be 

considered a natural, but managed, component within these areas. Management of fire in its natural role 

within these areas would be implemented through a variety of control strategies associated with naturally 

ignited wildland fires and through planned prescribed fires. Planned projects would each undergo a site 

specific environmental evaluation to determine the potential impacts on the resource prior to being 

approved. 

The application of AMRs to naturally ignited wildland fires to accomplish specific resource management 

objectives may be identified in predefined designated portions of these areas. Full suppression of wildland 

fires in these areas may be implemented to control fire size and severity. Likewise, managing naturally 

ignited fires may occur as appropriate for letting fire play its natural role. Although minimized by 

following the resource protection measures, short-term impacts on naturalness resulting from 

management response to wildland fire efforts may still include ground disturbances associated with 
 Wilderness Characteristics 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-85 

suppression efforts. ESR actions may be prioritized within these areas to stabilize wildfire areas, 

minimize the threat of invasive and noxious weed species becoming established, and preserve the natural 

and unique values inherent to them. The use of prescribed fire and non-fire treatments as a method to 

manage hazardous fuels and undesired vegetation cover may also be implemented. Short-term impacts on 

naturalness would be similar to fire suppression and ESR actions. 

Opportunities for solitude and primitive and unconfined recreation may be restricted (e.g., access) or 

impaired (e.g., visibility) during all naturally ignited and planned fire events. However, these impacts on 

the quality of visitor experience would be limited to the fire area and duration, and likely would not affect 

overall use and wilderness characteristics outside of the fire area. 

Over the long term, the wildland fire ecology decisions would result in modification of the current 

condition to one that would be more representative of the pre-European settlement vegetation cover. 

Long-term effects associated with the application of AMRs to fires and planned actions (movement 

toward natural fire regime and reduced severity of fire events) would outweigh any short-term loss of 

naturalness, access, and quality of experience impacts associated with opportunities for solitude and 

primitive and unconfined recreation. By implementing the proposed fire management goals of reducing 

hazardous fuels to restore natural ecosystems and allowing fire to function in its natural ecological role, 

natural conditions and the array of supplemental values contained within these management areas would 

be enhanced and preserved. Likewise, visitor experience and opportunities for solitude and primitive and 

unconfined recreation may be enhanced by restoration of the historical natural condition. 

Land Tenure Adjustments 

All Non-WSA Lands with Wilderness Characteristics 

None of the lands within the five areas being managed for protecting, preserving, or maintaining their 

wilderness characteristics would be available for FLPMA Section 203 sales or for land exchanges. 

Maintaining the integrity of these lands in public ownership would continue to allow BLM to manage for 

their wilderness characteristics. 

Within the 62,010 acres of non-WSA lands found to have wilderness characteristics, there are 

approximately 220 acres identified as available for FLPMA Section 203 sale. Selling these lands could 

result in a loss of naturalness and opportunities for solitude and primitive recreation because BLM would 

no longer manage these lands. The proposed 220 acres is limited to the entire Carcass Canyon area of 

non-WSA lands with wilderness characteristics within the decision area, which is not being managed to 

protect, preserve, or maintain its wilderness characteristics. This area and the adjacent public lands that do 

not have wilderness characteristics are isolated from other public lands within the decision area; however, 

it is adjacent to the Carcass Canyon WSA managed by the Grand Staircase–Escalante National 

Monument (GSENM). While disposal could result in a loss of opportunities in this area, it would 

eliminate the need to manage these isolated tracts. 

Lands within the 62,010 acres not identified for management of their wilderness characteristics could also 

be available for land exchange if they meet the criteria for land exchange identified in Chapter 2. If 

exchanged, the BLM would no longer manage these lands and the wilderness characteristics may be lost 

due to private ownership actions and management. 

Livestock Grazing 

All Non-WSA Lands with Wilderness Characteristics 

Areas frequented by livestock, such as springs or water developments, could have an unnatural 

appearance to some wilderness users and reduce the quality of primitive recreation opportunities. It is 
Wilderness Characteristics 

Chapter 4 Proposed RMP and Final EIS 

4-86 Kanab RMP 

important to note that the steep canyon topography in some of the non-WSA lands with wilderness 

characteristics makes livestock access difficult. While recreational use is commonly concentrated in the 

canyons, livestock use is generally outside of these areas, reducing potential impacts. Forage allocations 

in the Water Canyon Allotment (0 AUMs for livestock grazing) would eliminate the potential for 

livestock grazing impacts in portions of the Moquith Mountain area of non-WSA lands with wilderness 

characteristics which is not being managed to protect, preserve, or maintain its wilderness characteristics. 

In addition, forage allocations in the Zion Park Allotment (0 AUMs for livestock grazing) would 

eliminate the potential for livestock grazing impacts on portions of the Orderville Canyon area of nonWSA lands with wilderness characteristics which is being managed to protect, preserve, and maintain its 

wilderness characteristics. Where grazing has been historically permitted and is an ongoing use, the nonWSA areas were still found to have wilderness characteristics. It is not expected that this continued use 

would create new impacts to the wilderness character to any of these areas. 

Maintenance and construction of range improvements could result in short-term loss of opportunities for 

solitude during implementation and a long-term decrease in naturalness; however, due to the small size 

and localized nature of most non-vegetation-manipulation range improvements, this would not eliminate 

naturalness throughout non-WSA lands with wilderness characteristics. Using livestock grazing to 

enhance the ecosystem health and/or help accomplish resource objectives, such as noxious and invasive 

weed control and hazardous fuel reduction, could impact the naturalness of these areas in the short term. 

Other Management Actions 

All Non-WSA Lands with Wilderness Characteristics 

Short-term impacts on non-WSA lands with wilderness characteristics could be associated with cultural 

and paleontological inventories. During the survey and/or inventory there would be a loss of solitude, and 

during and following excavation there would be a loss of naturalness due to excavation activities. 

However, the number and size of these activities and, therefore, the related impact would be very low. 

Extensive seed collection and use of vegetative materials on non-WSA lands with wilderness 

characteristics could also result in short-term impacts on naturalness from soil disturbance. This would 

result in the loss of opportunities for solitude during collection. 

Soil management actions that would result in reclaiming surface disturbances where appropriate, closing 

and reclaiming temporary roads associated with projects, and removing and reclaiming facilities or 

improvements no longer necessary would reduce the amount of disturbance within non-WSA lands with 

wilderness characteristics. This could help restore naturalness in these areas and improve opportunities for 

solitude and primitive recreation. 

Summary 

Approximately 31 percent of non-WSA lands with wilderness characteristics (27,770 acres), within five 

areas, would be managed to protect, preserve, and maintain their wilderness characteristics. In these areas, 

management prescriptions would protect naturalness and outstanding opportunities for primitive 

recreation and solitude from new surface disturbing activities. Limiting OHV use to 26.6 miles of 

designated routes in non-WSA lands with wilderness characteristics being managed for those values 

could result in short-term perceived loss of opportunities for solitude and primitive recreation, but would 

not preclude the preservation, protection, or maintenance of those wilderness characteristics in those 

areas. This is because these lands were found to have wilderness characteristics even with those routes 

and occasional use by OHVs. In addition, some of the routes are being closed in these areas. 
 Wilderness Characteristics 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-87 

There could be impacts from oil and gas exporation and development to wilderness characteristics on 

portions of the non-WSA lands with wilderness characteristics not managed to protect, preserve, or 

maintain their wilderness characteristics (62,010 acres). Under the Proposed RMP, approximately 260 

acres of non-WSA lands with wilderness characteristics that are not being managed to protect, preserve or 

maintain their wilderness characteristics could be directly disturbed through oil and gas exploration and 

development activities, with an additional 460 acres that could be impacted if the oil and gas field 

development were to occur in non-WSA lands with wilderness characteristics. While less than 1 percent 

of all non-WSA lands with wilderness characteristics (managed for protection or not) would be directly 

impacted, the number of acres affected by oil and gas development could increase depending on sitespecific topographical and vegetative conditions and the ability to see and hear the development and 

function of oil and gas wells, but other management would affect the visibility of these developments. 

The potential for impacts from mineral materials and locatable mineral development is low, due largely to 

low development potential in the non-WSA lands with wilderness characteristics. 

The Proposed RMP also provides protection to wilderness characteristics through adherence to VRM 

classes. More than 56 percent of the non-WSA lands with wilderness characteristics (50,370 acres) would 

be managed as either VRM Class I or Class II, preserving or retaining the existing character of the 

landscape in these areas. All projects implemented in these areas would be required to adhere to the VRM 

class, minimizing their visual impact on the non-WSA lands with wilderness characteristics and 

protecting naturalness and outstanding opportunities for solitude. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources. There could be a short-term 

loss of wilderness characteristics due to mineral development during the life of the plan. Beyond the life 

of this plan, however, naturalness and opportunities for primitive recreation and solitude could be restored 

in most cases. This impact indicates a trade-off between the potential short-term uses and long-term 

preservation of every acre that has been identified as an area of non-WSA lands with wilderness 

characteristics. Generational uses of public lands have demonstrated that opportunities for solitude, 

primitive recreation, and, over time, the naturalness of these lands might be restored. For example, the 

enjoyment of wilderness characteristics is now available in places elsewhere in the western United States 

where uranium mines were predominant during the Cold War era of the 20th century. Time, reclamation, 

and the absence of human activities have restored and can continue to restore these attributes, although 

generally beyond the period this plan will be in effect. 

There is a potential for unavoidable adverse impacts and subsequent loss of one or all of the wilderness 

characteristics on some non-WSA lands with wilderness characteristics from mineral development. Due 

to the location of the non-WSA lands with wilderness characteristics and the development potential for 

minerals, the magnitude of acres affected would be small if development occurs on these lands. Managing 

45 percent of the non-WSA lands with wilderness characteristics as closed to leasing or open to leasing 

subject to major constraints would protect wilderness characteristics from this impact. None of the lands 

being managed for these values (27,770 acres) would be affected by fluid mineral development because 

these lands would be managed under a no surface occupancy stipulation with no waivers, exceptions, or 

modifications or be closed to leasing. 
Forestry and Woodland Products 

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4-88 Kanab RMP 

4.3 RESOURCE USES 

4.3.1 Impacts on Forestry and Woodland Products 

This analysis addresses potential impacts on forest and woodland products harvest from implementing the 

Proposed RMP. This analysis focuses on those management alternatives or actions that place limitations 

and/or affect the quantity or quality of products on the approximately 478,000 acres available for forest 

and woodland product harvest in the decision area, as discussed in Chapter 3. In the absence of 

quantitative data, best professional judgment was used, and impacts are sometimes described using ranges 

of potential impacts or in qualitative terms, if appropriate. 

The analysis is based on the following assumptions: 

• Several traditional woodland products (e.g., Christmas trees, posts, and poles) may be harvested 

from tree species growing on sites not classified as forest or woodland. 

• Demand for forest and woodland products is not anticipated to grow substantially over the 

planning period; however, biomass utilization may increase in the future. 

• Supply of forestry and woodland products would continue to substantially exceed demand. 

Under the Proposed RMP, impacts on forest and woodland products harvest would not be anticipated as a 

result of implementing management actions for the following resources and designations: air quality, 

livestock grazing, energy and minerals, recreation management, and lands and realty. 

Proposed RMP 

Forest and Woodland Harvest Management 

Implementing a management plan for woodland and/or forest products would result in long-term 

increases in sustainability of forest and woodland product harvest. 

Permitting commercial forest and woodland product harvest for the purposes of promoting or sustaining 

forest health on a case-by-case basis would allow harvests to occur, but would limit the potential for 

commercial harvest because it would be used only for the purpose of promoting or sustaining forest 

health. 

Permitting commercial and non-commercial harvest of green or dead pinyon and juniper woodland 

products (e.g., cedar posts, Christmas trees, fuelwood, and biomass utilization) areawide unless otherwise 

designated or stipulated and other woodland species on a case-by-case basis would facilitate woodland 

products harvest. Permitting harvest of woodland products in riparian areas in PFC on a case-by-case 

basis for the maintenance and/or improvement of riparian ecosystems would facilitate woodland products 

harvest. 

Closing WSAs (53,900 acres) and non-WSA lands with wilderness characteristics (27,770 acres) to 

woodland product harvest, except for incidental collection for onsite campfire use and administrative 

purposes, would preclude woodland products harvest in these areas. 

Limits or Restrictions on Harvest 

Implementing BMPs to minimize detrimental impacts on soils and water quality from ground disturbing 

activities and maintaining and/or enhancing riparian areas through project design features and/or 

stipulations would place limitations on harvest and could possibly prevent harvest in these locations. 
Forestry and Woodland Products 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-89 

Additional restrictions would be applied to surface disturbing activities, which would reduce the areas 

available for harvest. No surface disturbing action would be allowed on 23,800 acres (4 percent), 

increasing the area not allowed for harvest. The no surface disturbance restriction would be applied to 

areas within 1⁄4 mile or the visual horizon of cultural sites; within 1⁄2 mile of active bald eagle nest sites and 

Mexican spotted owl nests; within 1⁄2 mile of active, suitable, or potential reintroduction Utah prairie dog 

habitat/sites; and within 330 feet of riparian areas. 

Controlling surface disturbing and disruptive activities to minimize impacts on identified crucial habitat 

for sensitive species, applying BMPs to avoid or reduce habitat fragmentation, and prohibiting surface 

disturbing activities within 1⁄2 mile of active or suitable prairie dog habitat would restrict the location, 

extent, or method of opportunities for product harvest in these areas. 

VRM Class I areas would be 76,000 acres (14 percent) and VRM Class II areas would be 94,400 acres 

(17 percent). This would alter the location, extent, or method of forest and woodland harvest and restrict 

harvest opportunities. Alterations would be dependent on site-specific conditions and VRM class 

objectives following a visual contrast rating analysis and other environmental review. 

Management prescriptions associated with non-WSA lands with wilderness characteristics would restrict 

use of forest and woodland product harvest on 27,770 acres managed to protect, preserve, and maintain 

their wilderness characteristics. ACEC management could also restrict surface uses, including harvests. 

Under the Proposed RMP, the area of ACECs managed as VRM Class II would be increased to 3,800 

acres with the designation of the Cottonwood Canyon ACEC. These management prescriptions would 

further restrict surface forest and woodland uses, including harvests. 

Managing river segments as suitable for inclusion in the National Wild and Scenic Rivers System 

(NWSRS) could alter the location where forest and woodland product harvest can occur. Under the 

Proposed RMP, only six eligible river segments and corridors (5,530 acres) would be determined suitable 

and managed to protect their ORVs, free-flowing nature, and tentative classification. 

Restrictions on surface disturbing activities near cultural and paleontological sites could prevent or 

restrict harvest of forest and woodland products. 

Vegetation Management and Habitat Manipulation 

Vegetation treatments (e.g., wildlife habitat treatments, watershed treatments, livestock rangeland 

treatments, fuels treatments, and stewardship contracting) on an annual average of no more than 22,300 

acres (446,000 acres over the life of the plan) using the full range of vegetation treatment methods and 

tools (i.e., prescribed fire, mechanical, chemical, biological, woodland product removal, and wildland fire 

use) could reduce the extent of pinyon-juniper within the sagebrush steppe communities by converting 

treated areas to a grass/shrub-dominated community. Over the long term, treatments likely would 

decrease pinyon-juniper cover, but improve the productivity and health of existing stands and could 

increase the quantity and quality of products available for harvest. Over the long term, improving the 

ecological health of vegetation could increase the quality of forest products (Sonne and Briggs 2001, 

Prestemon et al. 2005). Based on recent woodland product demand, decreases in woodland cover would 

not affect the availability of woodland products. 

Vegetation resources would be managed to achieve 51 percent or higher of PNC, which would create a 

target for rehabilitation efforts that could increase the extent of successfully rehabilitated areas. 

Treatments would be allowed in areas containing ponderosa pine trees, which would improve the quantity 

and quality of harvest in these areas by reducing fuel loads and the potential for larger crown fires that 

lead to a loss of forest stands. Restoring forest and woodland old-growth stands to a pre-fire-suppression 
Forestry and Woodland Products 

Chapter 4 Proposed RMP and Final EIS 

4-90 Kanab RMP 

condition could increase tree spacing and encourage understory vegetation in these areas. This likely 

would increase the quantity and quality of forest and woodland products available for harvest. 

Wildland Fire 

Using wildland fire and prescribed fire to protect, maintain, and enhance resources would decrease the 

acres of woodlands available for harvest; however, rangeland health would be improved. Depending on 

the degree of severity, burned wood may or may not be useful. Suppressing wildland fires in areas where 

fire is not desired could increase the quantity of forest and woodland products. Fire suppression usually 

results in denser forest stands, increasing the risk of uncharacteristically larger or intense wildfires and 

mortality from insect pests and disease. 

Summary 

The Proposed RMP would allow harvest to continue; however, forest and woodland product harvest 

would be limited to only those areas that promote or sustain forest health. Vegetation treatment 

management actions under the Proposed RMP would provide additional measures to manage and improve 

vegetation, which maintain or improve the quantity and quality of forest and woodland products available 

for harvest. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources and no unavoidable adverse 

impacts. Based on historic and anticipated demand, short-term uses of forest and woodland products 

under each of the alternatives would not result in a loss of the long-term productivity of the forests and 

woodlands. 
 Livestock Grazing 

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Kanab RMP 4-91 

4.3.2 Impacts on Livestock Grazing 

This section describes potential impacts on livestock grazing from implementing the Proposed RMP. 

Impacts on resources and resource uses resulting from implementation of the livestock grazing program 

are discussed in those particular resource sections of this chapter. Impacts on livestock grazing activities 

are generally the result of activities that affect forage levels, land use restrictions that affect the ability to 

construct range improvements, and human disturbance/harassment of livestock within grazing allotments. 

Conducting vegetation treatments likely would have the greatest effect on livestock grazing because such 

treatments could increase vegetation production and forage available for livestock. Activities that result in 

surface disturbance (e.g., mineral development, ROW construction, and recreation) or management of 

resources that results in limiting surface disturbance (e.g., fish and wildlife, vegetation, water resources, 

soil resources, and visual resources) also would impact livestock grazing by affecting forage levels. 

Management of fire and forest and woodland products would affect livestock grazing by either preserving 

or increasing available forage for livestock over the long term. 

Impact analyses and conclusions are based on interdisciplinary team knowledge of resources and the 

project area, review of existing literature, and information provided by BLM resource specialists. Effects 

are quantified where possible or are described in qualitative terms in the absence of quantitative data. 

The analysis is based on the following assumptions: 

• Livestock grazing will be managed in accordance with the Standards for Rangeland Health and 

Guidelines for Grazing Management for BLM Lands in Utah. 

• Livestock grazing will occur throughout the majority of the decision area. 

• In the short term, actual forage use in the decision area may increase from current levels due to 

improving range condition and range recovery from recent drought. Over the long term, forage 

demand may continue at historic levels. 

Under the Proposed RMP, impacts on livestock grazing would not be anticipated as a result of 

implementing management actions for the following resources and designations: air quality, wilderness, 

WSAs, and other designations. 

Proposed RMP 

Livestock Grazing Management 

Impacts resulting from livestock grazing would primarily be related to forage removal by grazing 

livestock. Managing livestock grazing according to the Guidelines for Grazing Management for BLM 

Lands in Utah would improve livestock dispersal throughout pastures; control the season, duration, and 

intensity of grazing; and achieve range condition objectives. The intent of any applied practices and 

projects would be to improve the condition of the forage, thereby improving grazing management 

opportunities. Closing the Water Canyon Allotment (48 AUMs) to livestock grazing for the life of the 

plan would eliminate the opportunity to graze livestock in this allotment. 

Using livestock grazing to enhance ecosystem health and/or to help accomplish resource objectives on a 

case-by-case basis could provide for short-term, non-renewable increases in forage for livestock grazing. 

These increases would not be added to the existing grazing permit, so permittees would not be able to 

regularly plan on incorporating such forage use in seasonal grazing patterns. 
Livestock Grazing 

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4-92 Kanab RMP 

Actions that Directly Affect Vegetation Conditions 

Management of vegetation resources would generally enhance vegetative conditions and indirectly affect 

livestock grazing by increasing forage production and stabilizing livestock grazing. Applying the 

Standards for Rangeland Health under the vegetation management program would help to manage 

surface uses and thereby enhance rangeland conditions, increase long-term forage production, and 

stabilize livestock grazing. However, managing rangelands according to the Standards for Rangeland 

Health could also affect livestock operators on those allotments not meeting Standards for Rangeland 

Health for reasons attributed to grazing. Such adjustments could include season-of-use changes, forage 

allocation adjustments, implementation of grazing management practices (e.g., growing season 

deferment, riparian pastures, or exclosures), forage utilization limits, or conversions in kind or type of 

livestock. Management changes such as these could result in increased operating costs to the livestock 

operator. Over the long term, achieving the standards would result in maintained/increased water 

availability and forage production, which would benefit livestock through improved animal distribution, 

increased weight gain, and improved animal health. 

Conducting vegetation treatments on an annual average of up to 22,300 acres, particularly livestock 

rangeland treatments, would enhance vegetation conditions and indirectly affect livestock grazing by 

increasing forage production. These treatments would have a short-term effect on livestock grazing 

through forage removal and by excluding livestock use for two growing seasons on treated areas, but 

enhanced rangeland conditions would be realized over the long term. Increasing the acres of vegetation 

treated would increase the short-term displacement of livestock following the treatments, but over the 

long term increasing treatments would increase and improve vegetation types valuable for livestock 

grazing. However, because there is no requirement to treat a set acreage, there could be no short-term 

decreases in forage. If few or no vegetation treatments were implemented, the existing active use AUMs 

likely would decrease as pinyon-juniper woodlands continue to expand, invading sagebrush steppe 

vegetation types and reducing understory forage species. 

Treatment of invasive species and noxious weeds would serve to control and contain weed species 

infestations, thereby maintaining forage production, diversity, and vigor. These actions could temporarily 

displace livestock and reduce available forage. Guidelines for livestock grazing would be implemented to 

discourage the introduction and spread of weeds. Vegetation treatments would be prioritized to restore 

areas functioning at less than 51 percent of PNC, restore areas with noxious weed and/or non-native 

invasive plants, maintain previously treated areas, and achieve other objectives identified in the RMP. 

This would result in a systematic approach to treating vegetation communities, which likely would 

improve vegetation conditions and increase forage production. Treatments could be conducted in areas 

containing ponderosa pine trees, which likely would increase tree spacing and encourage forage 

production. 

Surface Disturbing Activities 

Surface disturbing activities associated with the development of minerals could disturb soils, remove 

vegetation, and increase the potential for the introduction and spread of noxious weeds. This would cause 

a loss of livestock forage and associated AUMs on 2,976 acres over the short term. Reclamation of 2,370 

acres would result in 606 acres of long-term surface disturbance. Mineral development activities could 

increase the potential for livestock harassment and livestock loss from vehicle collisions. However, the 

improvement of roads associated with mineral development could facilitate livestock management 

operations by improving access to remote locations within allotments. Given that livestock grazing occurs 

across most of the decision area, long-term disturbance would result in relatively minor impacts on 

livestock grazing. 
 Livestock Grazing 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-93 

The development of coal resources would be anticipated to result in the initial disturbance of 3,600 acres 

over the 20-year planning horizon, which would result in a loss of livestock forage in these areas. 

Reclamation is estimated to begin within 3 years of mining, and an average of 100 acres of disturbance 

per year would be reclaimed over the long term. Given that livestock grazing occurs across most of the 

decision area, the long-term disturbance would result in relatively minor impacts on livestock grazing. 

Construction activities related to the development of ROWs would remove a small amount of vegetation 

over the short term and increase the potential for the introduction and spread of noxious weeds, thereby 

causing a possible loss of livestock forage and associated AUMs. Increased vehicle travel on new roads 

also would increase the potential for the spread of weeds, animal harassment or injury, or interference 

with livestock grazing management. However, an increase in improved roads could facilitate livestock 

management operations by increasing access to remote locations within allotments. Under the Proposed 

RMP, 75,700 acres would be excluded from ROW development. This could decrease the extent of related 

forage removal, but also decrease opportunities for access to remote locations within allotments. 

Controlling Surface Uses and Surface Disturbance 

Implementing BMPs to minimize detrimental impacts on soils from ground disturbing activities and 

maintaining and/or enhancing riparian areas (Utah Riparian Management Policy [UT 2005-091]) through 

project design features and/or stipulations would help to reduce soil erosion, surface runoff, and 

sedimentation of streams. This would help to maintain and enhance vegetation and water quality and 

increase channel stability, which would indirectly provide forage and water for livestock. 

Activities associated with the management of cultural and paleontological resources would affect 

relatively small, localized areas and would not have measurable effects on livestock forage. Mitigating 

adverse impacts on cultural and paleontological resources and allowing for preservation and interpretation 

of such resources could include excavation of known sites, which would result in soil disturbances and 

forage removal. However, restrictions on surface disturbing activities near cultural and paleontological 

sites could prevent the removal of forage in these areas, but also could result in the modification or 

relocation of range improvements. 

Management actions to enhance wildlife habitat could affect livestock grazing by improving vegetation 

conditions and indirectly maintaining and/or increasing forage production. However, implementing 

decisions to increase populations of special status species, implementing conservation measures for listed 

and sensitive species, and prohibiting ground disturbing activities within 1⁄2 mile of bald eagle nests and 

Mexican spotted owl nests could also restrict opportunities for range improvements and other grazing 

management actions. 

Management of special status species could affect livestock grazing though habitat improvements and 

land use restrictions. Controlling surface disturbing and disruptive activities to minimize impacts on 

identified crucial habitat for sensitive species, applying BMPs to avoid or reduce habitat fragmentation, 

prohibiting surface disturbing activities within 1⁄2 mile of active or suitable prairie dog habitat, applying a 

CSU stipulation to avoid placing oil and gas wells in federally listed and candidate plant species occupied 

and suitable habitat, and applying an NSO stipulation within 1⁄2 mile of Greater sage-grouse leks could 

help to improve vegetation conditions and thereby improve forage production. However, these actions 

could also constrain rangeland improvement options by limiting the location of the proposed 

improvement. Maintaining or improving stream habitat in special status fish habitat would help to 

improve riparian vegetation and overall stream health, which could increase forage production and 

enhance water sources used by livestock. 

The management actions for soil resources would preclude cross-country OHV use in fragile soil areas 

and include additional efforts to reclaim surface disturbances and temporary roads. This could further 
Livestock Grazing 

Chapter 4 Proposed RMP and Final EIS 

4-94 Kanab RMP 

reduce soil erosion and improve vegetation conditions, which would indirectly increase forage for 

livestock. 

Implementing mitigation measures to minimize impacts on water quality and prohibiting surface 

discharge of produced water in the Colorado River Basin would reduce soil and salt loads to water 

sources and help maintain appropriate stream discharge rates. This would in turn maintain and enhance 

riparian vegetation and water quality, which would indirectly provide forage and water for livestock. 

Implementing additional measures to manage and improve vegetation could increase livestock forage. 

Vegetation resources would be managed to achieve 51 percent or higher of PNC, which would create a 

target for rehabilitation efforts that could increase the extent of successfully rehabilitated areas. Restoring 

forest and woodland old-growth stands to a pre-fire-suppression condition could increase tree spacing and 

encourage understory forage production in these areas. 

The effects from management of visual resources would be affected by the increase of VRM Class I areas 

(76,000 acres). This would further reduce the extent of surface disturbance and thereby indirectly reduce 

related forage removal due to surface disturbing activities. Managing visual resources could also limit the 

location of rangeland improvements. 

Wildland Fire 

Using wildland fire to protect, maintain, and enhance resources could help to improve vegetation 

conditions and increase forage production and availability for livestock. However, a short-term loss of 

forage may occur following a fire event. Suppressing wildfires in concert with increased fuels treatments 

could reduce the occurrence of catastrophic fires and thereby help to maintain vegetation cover and 

conserve livestock forage. Although suppression actions can create surface disturbances and result in the 

removal of forage through use of heavy equipment, implementing emergency stabilization and 

rehabilitation actions after suppression activities would help to mitigate these impacts. 

Recreation Use 

Recreational activities could impact livestock grazing through direct human disturbance. These impacts 

could include animal displacement, harassment, or injury or interference with livestock grazing 

management. In addition, concentrated recreation use, especially OHV use, could result in loss of 

vegetation. However, reducing cross-country OHV use to 1,000 acres would eliminate the impacts on 

livestock forage because the areas remaining open for cross-country OHV use are not conducive to 

livestock grazing. The remaining impacts on vegetation of OHV use along 1,403 miles of designated 

routes would be minimal. 

Management of the Kanab Community SRMA, Paria SRMA, Moquith Mountain SRMA, Orderville 

SRMA, North Fork Virgin River SRMA, and Escalante SRMA (95,100 total acres) would further 

emphasize the recreational opportunities available in the decision area and consequently increase the 

potential for livestock displacement, harassment, or injury or interference with livestock grazing 

management. However, implementing surface use restrictions within the SRMAs would help to reduce 

the degree of impact from recreational and other uses. Encouraging primitive types of recreation and 

prohibiting surface disturbance from oil and gas development in the Kanab Community SRMA (NonMotorized RMZ), Paria SRMA, Orderville Canyon SRMA, and North Fork Virgin River SRMA would 

help to reduce effects related to recreational use. 

Special Designations 

Management prescriptions associated with ACECs would affect livestock grazing management by 

restricting land uses that could result in livestock harassment and forage losses. Managing the 
 Livestock Grazing 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-95 

Cottonwood Canyon ACEC (3,800 acres) as a VRM Class II area and requiring NSO stipulations on new 

leases would reduce the extent of surface disturbance in the ACEC and thereby reduce related forage 

removal and damage. In addition, closing the Water Canyon Allotment to livestock grazing for the life of 

the plan would eliminate the opportunity to graze livestock in this allotment. 

Management of river segments to protect their ORVs, free-flowing nature, and tentative classification 

would include surface use restrictions. Such restrictions would minimize surface disturbance and related 

vegetation removal, which could help to maintain forage for livestock. Under the Proposed RMP, only six 

eligible river segments (5,530 acres) would be determined suitable and managed to protect their ORVs, 

free-flowing nature, and tentative classification. 

Commercial Forest and Woodland Product Harvest 

The commercial harvest of forest and woodland products and associated surface disturbances could result 

in a short-term loss of livestock forage. Over the long term, such activities would increase light 

penetration to understory vegetation communities (i.e., grasses and forbs) and thereby increase forage 

production. Forest and woodland product harvest activities could also temporarily displace livestock. 

Summary 

Under the Proposed RMP, adherence to the Standards for Rangeland Health and Guidelines for Grazing 

Management for BLM Lands in Utah would improve the long-term condition of the range and the orderly 

use of the range. While surface disturbing activities, recreational activities, and general human 

disturbance could lead to site-specific loss of forage, spread of noxious weeds, and displacement of 

livestock, vegetation treatments would help to offset forage losses by increasing forage production in 

treatment areas. Management of SRMAs (95,100 total acres) would reduce the impacts of increased 

recreation use within the decision area. While increased use could increase the degree of forage removal 

and disturbance to livestock, managing these areas as SRMAs would provide for increased management 

attention to resource conflicts. 

Under the Proposed RMP, vegetation treatments would be prioritized to restore areas functioning at less 

than 51 percent of PNC, restore areas with noxious weed and/or non-native invasive plants, and maintain 

previously treated areas to achieve other objectives identified in the RMP. This likely would improve 

vegetation conditions and increase forage production. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

Vegetation treatments and wildland fires that modify range conditions would temporarily reduce forage 

and would require restricting livestock from treated areas until vegetation becomes sufficiently 

established to withstand grazing (generally two growing seasons as per Utah Grazing Guidelines). 

However, this short-term impact would be reversible, and over the long term the treated/restored area 

would provide improved forage for livestock. 

Management actions could result in various short-term impacts on habitat, such as increased localized soil 

erosion, vegetation damage, and decreased visual resource quality. Surface disturbing activities could 

result in the greatest potential for impacts on long-term productivity. The limited extent of foreseeable 

development, mitigating management actions, and application of BMPs would minimize decreases in 

long-term productivity from short-term uses. There should not be any loss of long-term productivity for 

livestock grazing because grasses and other forage species could be reclaimed within 2 to 5 years. 
Livestock Grazing 

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4-96 Kanab RMP 

Wildland fires and surface disturbing activities could result in unavoidable adverse impacts, although 

these impacts could be mitigated to the extent possible. Permanent conversion of areas to other uses such 

as transportation and mineral and energy development would decrease vegetated areas. Applying BMPs, 

site-specific mitigation efforts, and restoration would decrease these impacts to the degree possible. 

Permanent mineral developments and their associated infrastructure would be mitigated to the extent 

possible to minimize loss of range resources. 
 Recreation 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-97 

4.3.3 Impacts on Recreation 

This section presents potential impacts on recreation resources, opportunities, and experiences from 

implementing the Proposed RMP. Recreation uses within the decision area include backpacking, 

recreational OHV use, hiking, camping, sightseeing/viewing nature, hunting, fishing, mountain biking, 

rock climbing, and horseback riding. Impacts on recreation primarily occur from management actions 

related to other resources or resource uses that result in long-term elimination or reduction of recreation 

opportunities or degradation of the recreation setting and experience (e.g., limited access, development 

activities, and the presence of man-made facilities). 

Impact analysis and conclusions are based on interdisciplinary team knowledge of resources and the 

decision area, review of existing literature, and information from other agencies. Effects are quantified 

where possible. In the absence of quantitative data, best professional judgment was used. Impacts are 

sometimes described using ranges of potential impacts or in qualitative terms if appropriate. 

The analysis is based on the following assumptions: 

• Recreation use within the planning area will continue to increase during the life of the RMP. 

• The incidence of resource damage and conflicts between recreationists involved in motorized and 

non-motorized activities will increase with increasing use of public lands. 

• The existing transportation network will be sufficient to meet the demand of recreational OHV 

opportunities. 

• There will be sufficient opportunities to meet the demand of non-motorized recreation (e.g., 

hiking, mountain biking, and equestrian). 

Under the Proposed RMP, impacts on recreation would not be anticipated as a result of implementing 

management actions for the following resources and designations: air quality and other designations. 

Proposed RMP 

Recreation Management Areas 

Management of the Kanab Community SRMA (33,100 acres) would provide motorized and nonmotorized recreation opportunities in close proximity to the town of Kanab. SRMA management would 

address user and resource conflicts that occur in the area between these two user groups and would 

protect and improve the recreation experience for both groups in both SRMA zones. 

Management of the Moquith Mountain SRMA (15,000 acres) would provide intensive recreation 

management for motorized recreation in sand dune areas (open to OHV use) and wooded environments 

(scenic trail use). Management of the SRMA would address user and resource conflicts while providing 

for a quality, motorized experience for different types of users. Identification of the Kanab Community 

and Moquith Mountain SRMAs would allow for focused recreation management in these areas and would 

diversify recreation opportunities in the area. 

Identifying the Paria Canyon area as a SRMA (21,200 acres) and managing the area as closed to OHV use 

and as a VRM Class I area would protect primitive recreation values and the opportunity for solitude and 

primitive/unconfined recreation. 

Management of the Orderville Canyon SRMA (1,950) and North Fork Virgin River SRMA (1,050 acres) 

would provide for primitive riparian canyon recreational opportunities; however, OHV use would be 

allowed on designated routes. This would provide opportunities for motorized recreation in an area with 
Recreation 

Chapter 4 Proposed RMP and Final EIS 

4-98 Kanab RMP 

high scenic quality, but could also increase the potential for user conflicts and displacement of users 

seeking solitude. 

Management of the Escalante SRMA (22,800 acres) would allow for motorized and non-motorized 

recreation opportunities in close proximity to the town of Escalante. A trail network would provide for 

hiking, equestrian, and scenery and wildlife viewing opportunities. Because of its proximity to town and 

allowed OHV use, the SRMA would not provide opportunities and experiences associated with solitude 

and primitive/unconfined recreation, but would provide for non-motorized uses in an outdoor naturallooking setting. 

Off-Highway Vehicle Use 

Opportunities for unrestricted, cross-country OHV use would be restricted to 1,000 acres. Most of the 

decision area would be limited to designated routes under the Proposed RMP. In these areas use would be 

limited to 1,403 miles of routes open year-round and 2 miles of routes closed seasonally. Closing 75 miles 

of routes to OHV use would eliminate opportunities for OHV use in these areas, but these areas would 

remain open for non-motorized recreation opportunities. In addition, the extent of areas closed to OHV 

use would be 25,000 acres, which would reduce opportunities for OHV travel and camping in remote 

areas. However, this increase in the level of restriction on OHV use would reduce conflicts between 

motorized and non-motorized users, increase public safety, and enhance the recreational experience 

associated with non-motorized recreation activities. 

Approximately 450 miles of new roads would be developed to support exploration and development of oil 

and gas, but roads associated with non-producing wells would be reclaimed within the life of the plan and 

would not be open for motorized use. Approximately 100 miles of new roads developed to access 

producing oil and gas wells would remain open for the life of the plan, but these would be open to 

recreation use on a case-by-case basis. 

Mineral Development 

Areas open to oil and gas leasing subject to standard terms and conditions would be 95,400 acres. These 

areas would generally be managed as open to oil and gas leasing subject to moderate constraints (296,200 

acres) or major constraints (83,400 acres). While the acres of surface disturbance associated with oil and 

gas exploration and development would not change (Appendix 15), increasing the acres with the various 

stipulations would result in more and larger areas where surface disturbance associated with mineral 

development would not be encountered. This would reduce the potential for conflict between mineral 

developments and recreation opportunities and experiences for recreationists seeking natural landscapes. 

Areas closed to leasing would be 79,000 acres, but would be in areas associated with primitive recreation 

opportunities, protecting the experiences of those recreationists. 

Areas open to locatable mineral development and mineral material sales could allow surface disturbance 

that could impact the desirability of these areas for recreation use. Recreation opportunities for 

recreationists seeking natural landscapes would be reduced in these areas. Closing 105,000 acres to 

mineral material sales would reduce related surface disturbance and help protect recreation opportunities 

and experiences in these areas. 

Recommending an additional 9,500 acres for withdrawal from locatable mineral entry would reduce the 

area in which locatable mineral development activities could occur. This would protect opportunities for 

primitive/unconfined recreation activities and enhance the experience of users seeking this type of 

recreation opportunity. 
 Recreation 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-99 

The development of coal resources would be anticipated to result in the initial disturbance of 3,600 acres 

over the 20-year planning horizon, which could reduce the quality of recreational experiences such as 

hunting, displace recreationists to other less-developed areas, and eliminate some recreation opportunities. 

Reclamation is estimated to occur within 3 years of mining, with the disturbed area being reclaimed over 

the long term. The reclamation would be concurrent/phased as the mining proceeds. 

Opportunities for recreational rock-hounding would decrease due to restrictions on collection of natural 

resources associated with SRPs, unless authorized. This stipulation would ensure natural resources in 

popular areas for SRP tours are managed in a sustainable manner, protecting the recreational setting that 

draws the tours. Collection would still be allowed upon authorization, so the opportunity for such use 

would not be eliminated, but the collection of natural resources (including rock-hounding) can be 

spontaneous. Requiring authorization could reduce the experience of some recreationists associated with 

SRPs. 

Controlling Surface Disturbance and Improving Habitat 

Management of VRM Class I areas (76,000 acres, 258 percent increase) would protect scenic quality by 

restricting landscape change, which would maintain and enhance the recreation experience for users 

seeking the opportunity for solitude and primitive/unconfined recreation. Application of VRM Class II 

designations (94,400 acres, 6 percent decrease) would retain the existing character of the landscape and 

would maintain scenic quality, which would enhance the recreation experience throughout these areas. 

Management of VRM Class III areas (210,700 acres, 207 percent increase) would generally not limit the 

type or amount of recreation use that would occur in these areas. Management of VRM Class IV areas 

(172,900 acres, 46 percent decrease) would allow for major modifications to the landscape, which would 

diminish scenic quality to a degree that would detract from recreation experiences for recreationists 

seeking natural landscapes. 

Management of soils to reduce soil loss on identified areas through land treatments and reseeding actions 

would protect the quality of the recreational experience in areas where surface occupancy would be 

allowed and reduce conflicts between recreationists and development activities, thus maintaining 

recreation opportunities and improving the recreation experience for recreationists seeking natural 

landscapes. Short-term impacts could occur due to temporary displacement of users during treatment 

activities. In addition, cross-country OHV use would be precluded in fragile soil areas and additional 

efforts would be conducted to reclaim surface disturbances and temporary roads. This would further 

reduce soil erosion and improve vegetation conditions, which would indirectly improve the general 

recreation experience for consumptive and non-consumptive users by enhancing the setting in which 

recreation activities take place. 

Implementing additional measures to manage and improve vegetation could enhance the recreation setting 

and experience for recreationists seeking natural landscapes. Vegetation treatments would be prioritized 

to restore areas functioning at less than 51 percent of PNC, restore areas with noxious weed and/or nonnative invasive plants, maintain previously treated areas, and achieve other objectives identified in this 

RMP. Treatments would be conducted in areas containing ponderosa pine trees, which likely would 

increase tree spacing and encourage forage production. This would further improve vegetation conditions 

and improve the long-term aesthetics of the area, which would indirectly enhance the recreation 

experience and setting for recreationists seeking natural landscapes. 

Management of special status species could affect recreation through habitat improvements and land use 

restrictions. Controlling surface disturbing and disruptive activities to minimize impacts on identified 

crucial habitat for sensitive species, applying BMPs to avoid or reduce habitat fragmentation, prohibiting 

surface disturbing activities within 1⁄2 mile of active or suitable prairie dog habitat, applying a CSU 

stipulation to relocate well placement in federally listed and candidate plant species occupied and suitable 
Recreation 

Chapter 4 Proposed RMP and Final EIS 

4-100 Kanab RMP 

habitat, and applying an NSO stipulation within 1⁄2 mile of Greater sage-grouse leks would all help to 

improve ecosystem conditions and the aesthetic value of these areas. This would indirectly enhance the 

recreation experience by improving the setting in which these activities take place. However, these 

actions could also constrain the development of recreation facilities and OHV use. Maintaining or 

improving stream habitat in special status fish habitat would help to improve riparian conditions, which 

could enhance the recreation setting and experience in these areas for recreationists seeking natural 

landscapes. 

Prohibiting surface disturbing activities on a seasonal basis in mule deer and elk crucial winter range, 

crucial Desert bighorn sheep habitat, and crucial pronghorn habitat and precluding oil and gas 

development and ROW construction in big game migration and transitional ranges would improve 

opportunities and experience associated with hunting and wildlife observation. These restrictions would 

affect opportunities and experiences associated with hunting and wildlife observation. 

Lands and Realty Actions 

Managing areas as ROW exclusion (75,700 acres) and avoidance (106,670 acres) areas would affect 

recreation opportunities, setting, and experience. ROWs would be prohibited in exclusion areas or 

mitigated in avoidance areas to reduce their impact on the natural environment. Reducing overall 

development in these areas could increase opportunities for primitive/unconfined recreation activities and 

enhance the experience of users seeking this type of recreation opportunity. 

Wildland Fire 

Short-term closures of recreation areas and facilities could occur in fire areas during fire suppression 

activities and through the use of prescribed fire, limiting recreation opportunities in these areas. However, 

managing the decision area for suppression in areas with high resource values and recreation facilities 

would help maintain and protect recreation facilities and opportunities. In addition, wildland fire could 

affect other recreation opportunities. Wildland fire could improve wildlife habitat and hunting and 

viewing opportunities over the long term. 

Vegetation Improvement 

Implementing BMPs to minimize detrimental impacts on soils from ground disturbing activities and 

maintaining and/or enhancing riparian areas (Utah Riparian Management Policy [UT 2005-091]) through 

project design features and/or stipulations would help to reduce soil erosion, surface runoff, and 

sedimentation of streams. This would help to maintain and enhance vegetation and water quality and 

increase channel stability, which would indirectly improve the general recreation experience for 

consumptive and non-consumptive users by enhancing the riparian setting in which recreation activities, 

such as hiking, picnicking, camping, and fishing, take place. 

Management of vegetation resources and implementing actions to enhance wildlife habitat through active 

treatments could affect recreation by improving ecosystem health and scenic quality. This would 

indirectly improve the general recreation experience for consumptive and non-consumptive users by 

enhancing the setting in which recreation activities take place. However, implementing decisions to 

increase populations of special status species and implementing conservation measures for listed and 

sensitive species could also restrict opportunities for certain types of recreation opportunities, such as 

OHV use. 

Special Designations 

Managing the Cottonwood Canyon ACEC (3,800 acres) would maintain primitive recreation 

opportunities and recreational experiences in the area by protecting natural resources important to 

recreationists. The boundary of this ACEC would increase from the existing 220-acre Water 
 Recreation 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-101 

Canyon/South Fork Indian Canyon ACEC to include considerably more land that would receive 

protective management. In addition, OHV use would be allowed on designated routes, which would 

provide for more OHV opportunities, but could also increase the potential for conflicts between 

motorized and non-motorized users. 

Outstanding river-related recreation opportunities would benefit from protection of recreation values. 

Under the Proposed RMP, only six eligible river segments (5,530 acres) would be determined suitable 

and managed to protect their ORVs, free-flowing nature, and tentative classification. 

Interpretive Opportunities 

Providing information regarding interpretation of natural and human history and conducting outreach 

programs through organizations, schools, and partnerships would help to build emotional, intellectual, 

and recreational ties with the cultural and natural resources within the decision area. In addition, 

coordinating with local communities and other groups to foster heritage tourism in the decision area 

would increase such recreation opportunities and enhance associated experiences. 

Protecting Specific Recreation Opportunities 

Areas that are specifically managed for protection of wilderness characteristics are frequent destinations 

for users seeking solitude and primitive/unconfined recreation opportunities. Maintaining the Paria 

Canyon–Vermilion Cliffs Wilderness (21,200 acres), five WSAs (53,900 acres) and managing 27,770 

acres of non-WSA lands with wilderness characteristics to protect, preserve and maintain those 

characteristics would protect the opportunities for non-motorized wilderness recreation experiences, while 

excluding activities that cause conflicts or diminished recreation experiences. 

The viewing of cultural resources and collection of some paleontological resources (invertebrate and 

botanical) are recreational activities that occur within the decision area. Protecting and mitigating impacts 

on cultural and paleontological resources would help to protect and preserve such resources and thereby 

maintain these recreation opportunities and related experiences. 

Summary 

Development activities that create surface disturbances could displace recreationists, reduce opportunities 

for primitive/unconfined recreation, and degrade the recreation setting and experience of other recreation 

activities that use natural settings as a component of their activity (e.g., hunting, driving for pleasure, 

wildlife watching, OHV riding, picnicking). Impacts also would occur in the form of conflicts among 

recreation users. Motorized recreation use would conflict with non-motorized recreation when they occur 

in close proximity, and would result in degradation of the setting and experience associated with nonmotorized recreation activities. 

Land use restrictions would help to reduce these impacts by enhancing the setting in which recreation 

activities take place and precluding certain activities in areas of user conflict. However, some restrictions 

could limit opportunities for motorized and hunting activities. In other areas, management decisions 

would manage for motorized activities, reducing the experience of non-motorized activities that occur in 

those areas. Under the Proposed RMP, increased land use restrictions to mitigate impacts from mineral 

development and to protect vegetation and biological resources would be implemented. This would help 

to maintain recreation opportunities and enhance the recreation setting and experience for recreationists 

who seek a natural setting in which to recreate (e.g., hunting, driving for pleasure, wildlife watching, 

OHV riding, picnicking). 
Recreation 

Chapter 4 Proposed RMP and Final EIS 

4-102 Kanab RMP 

Management associated with the SRMAs would focus on preservation of scenic, cultural, and biological 

resources and on allocating lands to different types of recreation uses. Under the Proposed RMP, portions 

of the SRMAs would be managed for motorized and non-motorized uses. In addition to reducing user 

conflicts, this would enhance the recreation setting and experience. 

Under the Proposed RMP, opportunities for cross-country OHV use would be considerably reduced 

because open OHV areas would be reduced by 99 percent. However, trail-based OHV opportunities 

would remain over most of the decision area, and opportunities for cross-country use would remain at 

Coral Pink Sand Dunes and a few other small locations. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There could be short-term impacts if recreation users are displaced or their experiences or desired 

outcomes are substantially interfered with by another activity or land use. However, these impacts would 

not be irreversible. Recreationists will individually implement coping techniques when confronted with 

undesirable situations while recreating. In addition, the levels of recreation use throughout most of the 

decision area are low enough that extended periods of interaction between recreation groups are rare. 

Long-term disturbance of areas for mineral development (approximately 600 acres) could affect the longterm use of some lands for certain recreation users seeking natural recreation settings. Some mineral 

development activities associated with the management actions of the alternatives would have 

unavoidable, adverse impacts on recreation opportunities and experiences. Exploration and development 

could fragment hunting areas and impact dispersed recreation. 
 Transportation 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-103 

4.3.4 Impacts on Transportation 

This section describes potential impacts on transportation and access from implementing the Proposed 

RMP. Impacts on resources and resource uses resulting from implementation of the transportation 

program are discussed in those particular resource sections of this chapter. 

The transportation program provides for ingress, egress, and access in the decision area. The following 

discussion of the effects on transportation and access focuses on management actions that restrict or 

facilitate transportation and access opportunities. Impacts on opportunities for OHV use are addressed in 

the recreation impact analysis. 

This analysis describes the degree of access and the extent of usable transportation systems within the 

decision area. This includes actions that would limit the degree of travel opportunities and the ability to 

access certain portions of the decision area. The majority of motorized access issues are related to OHV 

use; this form of transportation provides a major source of travel opportunities. 

Impacts on transportation and access as defined above (i.e., via local roads, state-maintained highways, 

and BLM-maintained system roads) would be anticipated primarily from route designations and the 

implementation of management actions that consolidate public land through purchases, exchanges, and 

disposal of isolated tracts. 

The analysis was based on the following assumptions: 

• The existing transportation network will remain in place throughout the life of this plan except as 

noted in the alternatives. 

• Revised Statute (RS) 2477 assertions may be evaluated by the BLM’s administrative review 

procedures, adjudicated by court decision, or other legal means. 

Impacts on transportation and access would not be anticipated from implementing management actions 

for the following resources: air quality, water, vegetation, wildland fire ecology, cultural resources, 

paleontological resources, visual resources, forestry and woodland products, livestock grazing, minerals 

and energy, and other designations. 

Proposed RMP 

Transportation Management 

Limiting OHV use to designated routes on 528,000 acres (95 percent) would reduce the ability to gain 

motorized access to every acre in the decision area because access would be restricted to designated 

routes (Map 9). Motorized access in these areas would be allowed on 1,403 miles of routes. The 

designated routes in these areas would provide for motorized access to most of the decision area, where 

non-motorized access could be obtained in the areas beyond the designated routes. The 75 miles of routes 

closed to use would not eliminate access to any portion of the decision area, although in some areas 

motorized access would require travel on more miles of routes to access the same area. Closing 25,000 

acres (5 percent) to OHV use would limit access in these areas to non-motorized means. Allowing crosscountry OHV use on 1,000 acres (less than 1 percent) would provide unlimited motorized access to only a 

limited portion of the decision area. 

Lands and Realty 

Allowing land tenure adjustments based on the criteria in the lands and realty management actions in the 

Proposed RMP would ensure accessibility to public lands where access is needed and could not be 
Transportation 

Chapter 4 Proposed RMP and Final EIS 

4-104 Kanab RMP 

otherwise obtained and would consolidate public lands, which could potentially contribute to a more 

cohesive transportation system. This could improve access to public lands and facilitate travel across the 

decision area. However, disposal actions would remove lands from federal ownership, which could also 

eliminate public access to those disposed parcels. Conversely, land acquisitions would allow for access to 

newly acquired lands and facilitate access to adjacent public lands through the creation of a more 

contiguous decision area. In addition, pursuing easements for access to public lands could provide access 

as needed and improve motorized OHV opportunities. 

Under the lands and realty program, the disposal (via Section 203 sales) of scattered tracts of public land 

(6,400 total acres) could improve access to private and public land parcels and facilitate travel across the 

decision area. Approximately 9,500 acres would be considered for withdrawal from public land laws, 

which would preclude future disposal actions in these areas. 

Other Management Actions 

Special status species and fish and wildlife actions that limit or prohibit disruptive activities within 

habitats would limit or eliminate access to some areas, depending on the magnitude and type of use along 

designated routes. However, roads developed to facilitate mineral exploration and development would 

increase access to portions of the decision area, if they are available for public use. Based on the RFD 

scenario (Appendix 15) an average of 5 miles of new road would be constructed for each well. Assuming 

that 20 of the 90 wells would be new production wells, there could be up to 100 miles of new roads 

associated with oil and gas development. These additional 100 miles of roads would augment the 

transportation network and improve access. 

Coordinating transportation planning with Kane and Garfield counties would provide for cooperative 

management of transportation systems. This would reduce access issues and management conflicts, 

improve the safety and convenience of the traveling public, and provide for more efficient use of 

resources. 

Summary 

The Proposed RMP would allow cross-country OHV use on 1,000 acres (less than 1 percent), which 

would provide unlimited motorized access to only a limited portion of the decision area. Under the 

Proposed RMP, approximately 95 percent of the decision area would be limited to designated routes, 

which would reduce the ability to access any area using motorized means. However, designated routes in 

the majority of the planning area would provide for motorized access to most of the decision area, where 

non-motorized access could be obtained in the areas beyond the designated routes. 

Land tenure adjustments could increase opportunities to consolidate public lands, improve access, and 

facilitate travel in portions of the decision area. Disposals would remove lands from federal ownership, 

which could eliminate public access. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources. Limiting use in most of the 

area to designated routes in the action alternatives would result in a perceived short-term loss of access, 

but long-term access on designated routes would be maintained due to decreases in impacts on other 

resource values. Unavoidable adverse impacts also would occur on motorized access. OHV area 

designations would limit motorized access to designated routes, preclude cross-country travel in the 

majority of the decision area, and preclude motorized access in the rest of the decision area. 
Lands and Realty 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-105 

4.3.5 Impacts on Lands and Realty 

Lands and realty is a resource use rather than an environmental component. Consequently, impacts on 

lands and realty are a direct result of the emphasis of other resource programs. The discussion of the 

effects on lands will be limited to the effects on permitted or authorized uses and land tenure adjustments. 

The analysis is based on the following assumptions: 

• Existing ROWs may be modified or amended if the action is consistent with the RMP. 

• ROW holders may renew their ROWs within the terms of the original ROW grant. 

• The BLM would continue to process land tenure adjustments consistent with RMP goals and 

decisions. 

• Lands identified for FLPMA Section 203 sale may be sold or otherwise disposed of within the 

life of the plan. 

• The demand for communication sites and ROW corridors would increase within the life of this 

plan. 

• Lands and interests in lands could be acquired from willing landowners by purchase consistent 

with RMP goals and decisions. 

Under the Proposed RMP, impacts on lands and realty are not anticipated as a result of implementing 

management actions for the following resources and resource uses: air quality, paleontological resources, 

forestry and woodland products, livestock grazing, transportation, minerals and energy, and wildland fire 

ecology. 

Proposed RMP 

ROWs, Leases, and Permits 

ROWs would be excluded on 75,700 acres (14 percent) (Map 11). ROW exclusion areas include WSAs, 

wilderness areas, and suitable WSR corridors with a tentative classification of “wild” or “scenic.” ROWs 

would be avoided on 106,670 acres (19 percent). ROW avoidance areas include the areas managed for 

wilderness characteristics, Greater sage-grouse habitat, and Utah prairie dog colonies. In VRM Class I 

areas (76,000 acres) and Class II areas (94,400 acres), stipulations to meet VRM objectives could be 

applied to lands and realty actions. These designations and VRM classes could require design and siting 

requirements and affect associated costs on new ROWs or amended ROWs. Such requirements may 

restrict placement and could limit future access, delay availability of energy supply (by restricting 

pipelines, transmission lines, and wind and solar projects), and create dead zones or delay availability of 

communications service. Such requirements could also require utility corridors and communication sites 

to be installed in less desirable locations or areas with more restrictions on accessibility or construction. 

ROW stipulations could require design and siting requirements and affect associated costs on new or 

amended ROWs. Restrictions may limit placement of future ROWs. Such requirements could also require 

utility corridors and communication sites to be installed in less desirable locations or areas with more 

restrictions on accessibility or construction. These restrictions include restricting disturbance in Utah 

prairie dog and Mexican spotted owl habitats. Seasonal limitations within 1 mile of bald eagle nest sites, 

within 1⁄2 mile of bald eagle winter concentration areas, and year-round restrictions on ground disturbing 

activities within 1⁄2 mile of bald eagle nest sites could limit access and delay project construction of new 

ROWs. Where seasonal restrictions limit the time available to complete activities, relocation of surface 

facilities could be required; however, allowing case-by-case exceptions could minimize the potential to 

affect placement and costs for new ROWs or amended ROWs. 
Lands and Realty 

Chapter 4 Proposed RMP and Final EIS 

4-106 Kanab RMP 

Not allowing surface disturbing actions on 23,800 acres (4 percent) would apply to all ground disturbing 

activities including lands and realty actions (Map 19). Some of these areas coincide with ROW exclusion 

and ROW avoidance areas. These stipulations would restrict ROW facilities and communication sites 

from being sited in these areas. 

Designating 15,200 acres (3 percent) as ROW seasonal restriction areas (Map 11) and 407,500 acres (74 

percent) as seasonal limitations on surface disturbing actions could limit the time available to complete 

activities and require relocation of surface facilities (Map 19). The ROW seasonal exclusion areas occur 

around a portion of U.S. Highway 89 between Mt. Carmel Junction and Kanab and a portion of State 

Route (SR) 9. However, allowing case-by-case exceptions could minimize the potential to affect 

placement and costs for ROWs. 

Allowing filming permits throughout the decision area following site-specific NEPA analysis could lead 

to site-specific restrictions applied to the permit. The restrictions could include design and siting 

requirements, which could affect the filming location and increase costs to conduct filming activities. 

Areas available for ROW development (including powerlines, pipelines, wind and solar projects, and 

communication sites) would accommodate desired placement of facilities, accommodate access and 

efficient energy supply (by allowing pipelines and transmission lines), and minimize additional costs. 

Land Tenure Adjustments 

Allowing land tenure adjustments that meet the criteria identified under the lands and realty management 

actions and considering land acquisitions to preserve cultural resources would facilitate access, improve 

management ability, and reduce conflicts between private landowners and uses within the planning area. 

Allowing land tenure adjustments, including FLPMA Section 203 disposals (6,400 acres, 1 percent), also 

would accommodate resource management needs within the decision area and adjacent communities 

(Map 13). 

Retaining public lands that contain riparian areas, crucial wildlife habitat, Cottonwood Canyon ACEC, 

sensitive cultural sites, and the Old Spanish National Historic Trail (Highway 89/20 segment in Garfield 

County) in the public ownership would protect natural resources in these areas. In addition, retaining 

Cottonwood Canyon ACEC would maintain the current watershed conditions of this culinary water 

source. 

Summary 

The Proposed RMP would allow for use of the Western Utility Group corridors. The Proposed RMP 

would designate approximately 185,000 acres as ROW exclusion or avoidance areas. The Proposed RMP 

would allow FLPMA Section 203 sales of 6,400 acres while retaining public lands that contain riparian 

areas, crucial wildlife habitat, and sensitive cultural sites. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources, no loss of long-term 

productivity from short-term uses, and no unavoidable adverse impacts. 
Minerals and Energy 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-107 

4.3.6 Impacts on Minerals and Energy 

This section presents potential impacts on energy minerals and non-energy minerals from implementing 

the Proposed RMP. Energy minerals include oil, gas, and coal. Non-energy minerals include locatable 

minerals, such as gypsum and limestone, and salable minerals, such as sand, gravel, and stone. 

The analysis is based on the following assumptions: 

• Valid existing leases would be managed under the stipulations in effect when the leases were 

issued, and new stipulations proposed under this RMP would apply if leases are renewed. 

• Leasing and drilling could occur throughout the entire decision area, except where restricted by 

management actions in the Proposed RMP. 

• A total of 90 wells (70 exploration and 20 new production wells) could be drilled during the next 

20 years, which could result in a future surface disturbance of 2,070 acres and 906 acres of 

disturbance from seismic operations. Approximately 2,370 acres of the total 2,976 acres would be 

reclaimed (Appendix 15). 

• The RFD for 90 oil and gas wells would not vary by alternative due to the low level of 

development anticipated, acres open for leasing (subject to standard, moderate, or major 

constraints) under each alternative, and the historic levels of development. 

• The estimated total surface disturbance from coal mining of federal coal in the decision area 

could entail about 3,600 acres including haul roads and surface facilities. The average annual 

surface disturbance would be approximately 100 acres, and reclamation would follow shortly 

behind mining. 

• The estimated total surface disturbance from locatable minerals would be from septarian and 

gypsum (alabaster). Septarian concretions and gypsum mining likely would disturb about 1 acre 

per year, resulting in a total 20-year surface disturbance of 20 acres. 

• The estimated total surface disturbance from salable minerals would be from sand and gravel, 

stone, and clay operations. Sand and gravel development would result in a total 20-year surface 

disturbance of 625 acres, with approximately 70 percent on BLM lands. Stone developments 

likely would be about 20 acres disturbed per year for stone, resulting in a total 20-year surface 

disturbance of 400 acres. About 70 percent of the disturbance is expected to be on BLM land. 

Clay exploration or development is expected to result in a surface disturbance of 5 acres. 

• As population growth and the demand for energy increase, so will the demand for leasable 

minerals, mineral materials, and other energy sources. 

Under the Proposed RMP, impacts on minerals and energy resources are not anticipated as a result of 

implementing management actions for the following resources, resource uses, and designations: air 

quality, wildland fire ecology, paleontological resources, forestry and woodland products, livestock 

grazing, transportation, and other designations. 

Proposed RMP 

Oil and Gas Leasing 

Approximately 79,000 acres would be closed to oil and gas leasing, which would preclude new oil and 

gas development. However, the impacts from closed areas on oil and gas exploration and development 

would be relatively minor because only 3,800 acres closed to leasing (less than 1 percent) are within areas 

of high development potential. The remaining areas closed to oil and gas leasing are in areas with low 

potential for oil and gas development. 
Minerals and Energy 

Chapter 4 Proposed RMP and Final EIS 

4-108 Kanab RMP 

Areas open to leasing subject to major constraints (NSO) (83,400 acres) could require directional drilling 

or other extraction methods to access resources. This management action could result in the relocation of 

facilities, increased extraction costs, and the possible loss of energy resources that cannot be reached by 

current or future drilling technologies or where directional drilling is not a viable option. Approximately 

76 percent of these areas (63,200 acres) occurs within areas of high potential for oil and gas, 5 percent 

coincides within areas of moderate potential, and 19 percent within low potential areas. However, impacts 

on oil and gas leasing would be relatively minor because the major constraints would apply to only 15 

percent of the decision area. 

Areas open to leasing subject to moderate constraints (CSU and timing limitation stipulations) (296,200 

acres) could in some cases result in the relocation of mineral facilities, including oil and gas facilities, or 

restrict the time available to complete exploration and development activities. CSU stipulations could 

require construction and installation of facilities in areas that are more difficult to develop or reclaim, or 

that are located farther from the mineral resource, which would potentially increase operating expenses. 

Timing limitation stipulations could defer oil and gas development activities and could require 

adjustments in drilling or exploration. Where seasonal restrictions severely limit the time available to 

complete activities, relocation of surface facilities may be required. Approximately 64 percent of this area 

(188,450 acres) occurs within areas of high potential for oil and gas, 5 percent coincides within areas of 

moderate potential, and 31 percent within low potential areas. The majority of the areas with moderate 

constraints are within areas with high potential, which could impact oil and gas exploration and 

development. However, exceptions to seasonal restrictions would in some cases allow development 

activities to occur. 

Areas open to leasing subject to standard terms and conditions (95,400 acres) would allow for oil and gas 

operations with the least number of restrictions. Approximately 82 percent of this area (78,200 acres) 

occurs within areas of high potential for oil and gas, 3 percent coincides with areas of moderate potential, 

and 15 percent with low potential areas. The majority of the oil and gas exploration and development 

activities likely would occur in these areas. 

An analysis of the oil and gas leasing stipulations based on the Energy Policy and Conservation Act 

(EPCA) report (U.S. Department of the Interior [USDOI] et al. 2006) reveals the effect of cumulative 

timing stipulations from the Proposed RMP on oil and gas exploration and development and on areas 

open to leasing subject to standard terms and conditions, areas open to leasing subject to moderate 

constraints (timing limitations, CSU), areas open to leasing subject to major constraints (NSO), and areas 

closed to leasing (Table 4-10). Cumulative timing limitations are divided into periods of less than 3 

months, 3 to 6 months, 6 to 9 months, and more than 9 months. Approximately 75,100 acres of the areas 

closed to leasing are WSAs. 

Table 4-10. Proposed RMP Oil and Gas Leasing Restrictions and Cumulative Timing 

Limitations 

Oil and Gas Potential 

Oil and Gas Leasing High 

Development 

Potential 

(acres) 

Moderate 

Development 

Potential 

(acres) 

Low 

Development 

Potential 

(includes 

restricted 

lands) 

(acres) 

Total Acres 

Open to leasing subject to the standard 

terms and conditions on the lease form 78,200 2,600 14,600 95,400 
Minerals and Energy 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-109 

Oil and Gas Potential 

Oil and Gas Leasing High 

Development 

Potential 

(acres) 

Moderate 

Development 

Potential 

(acres) 

Low 

Development 

Potential 

(includes 

restricted 

lands) 

(acres) 

Total Acres 

Open to leasing subject to moderate 

constraints (timing limitation <3 months) 400 0 10 410 

Open to leasing subject to moderate 

constraints (timing limitation 3 to 6 months) 153,300 11,600 83,700 248,600 

Open to leasing subject to moderate 

constraints (timing limitation 6 to 9 months) 50 2,800 3,200 6,050 

Open to leasing subject to moderate 

constraints (timing limitation >9 months) 24,000 340 6,100 30,440 

Open to leasing subject to moderate 

constraints (CSU) 10,700 0 0 10,700 

Open to leasing subject to major 

constraints (NSO) 63,200 4,000 16,200 83,400 

Closed to leasing 3,800 0 75,200 79,000 

The EPCA report (USDOI et al. 2006) estimated the oil and gas reserves in the western United States. 

Data from the report was used to approximate the number of barrels of oil and cubic feet of gas under 

areas closed to leasing and areas open to leasing subject to major constraints (NSO). Based on 

information from the EPCA report, approximately 29 thousands of barrels of oil and 3 million cubic feet 

of gas would be in non-recoverable areas open to leasing subject to major constraints (NSO). In addition, 

approximately 151 thousands of barrels of oil and 15 million cubic feet of gas would be in areas closed to 

leasing and would not be available for development within the decision area (Table 4-11). 

Table 4-11. Proposed RMP EPCA Analysis 

Total Liquids* Total Natural Gas** 

Proposed RMP Acres (Thousands of 

Barrels)*** 

(Millions of Cubic 

Feet)*** 

Proved Reserves and Undiscovered Technically Recoverable Resources 

Open to leasing subject to major constraints 

(NSO beyond 1⁄2 mile) 15,300 29 3 

Closed to leasing 79,000 151 15 

* Comprising oil, natural gas liquids, and liquids associated with natural gas reservoirs 

**Comprising associated dissolved and non-associated natural gas 

*** Estimate based on data from the Scientific Inventory of Onshore Federal Lands' Oil and Gas Resources and Reserves and 

the Extent and Nature of Restrictions or Impediments to Their Development, January 2006 (USDOI et al. 2006). 

Restrictions on surface disturbing activities near bald eagle nests and winter concentration areas; in 

Mexican spotted owl breeding habitat, designated critical habitat, or identified PACs; and in Western 

yellow-billed cuckoo and Southwestern willow flycatcher potentially suitable habitat would allow for oil 

and gas leasing subject to moderate constraints and major constraints. The moderate constraints could 
Minerals and Energy 

Chapter 4 Proposed RMP and Final EIS 

4-110 Kanab RMP 

result in the relocation of mineral facilities, including oil and gas facilities, or restrict the time available to 

complete exploration and development activities. The major constraints could require directional drilling 

or other extraction methods to access resources. Exceptions to moderate constraints (Appendix 3) could in 

some cases allow for exploration and development activities to occur. 

Locatable Minerals and Mineral Materials 

Approximately 9,500 acres (2 percent) would be recommended for withdrawal from locatable mineral 

entry, which would not affect gypsum and septarian prospects. Only very small-scale gypsum and 

exploration and development activity is expected in the decision area over the next 20 years (Appendix 

15). The majority of these areas recommended for withdrawal do not coincide with gypsum/septarian 

concretions development potential areas. 

Approximately 105,000 acres (19 percent) would be closed to mineral material sales, which would not 

affect sand and gravel and clay disposals. The majority of these areas closed to mineral material sales do 

not coincide with sand and gravel high development potential areas. 

Coal 

Coal management actions would allow for the leasing and development of coal resources on lands 

identified as suitable (Appendix 6). The RFD scenario for coal (Appendix 15) anticipates a coal mine in 

the Alton area of the Alton coal field. This area has a high development potential for coal. Based on the 

coal unsuitability criteria, approximately 113,629 acres would be suitable for further leasing consideration 

(Map 15). Prior to leasing federal coal lands and permitting a coal mine, further NEPA consideration to 

address conflicts between multiple uses would be required. 

Summary 

Oil and Gas Leasing 

Closing areas to oil and gas leasing or applying major or moderate constraints to leases directly impacts 

oil and gas exploration and development. Areas closed to oil and gas leasing would preclude new oil and 

gas development. Areas open to leasing subject to major constraints could require direction drilling or 

other extraction methods to access resources. Areas open to leasing subject to moderate constraints could 

in some cases result in the relocation of mineral facilities or restrict the time available to complete the 

exploration and development activities. Under the Proposed RMP, 14 percent of the decision area would 

be closed to leasing. Oil and gas exploration and development could occur on the remaining 86 percent of 

the decision area. 

Locatable Minerals and Mineral Materials 

In addition to the 24,591 acres currently withdrawn from locatable mineral entry, recommending 

withdrawing areas from locatable mineral entry would directly impact locatable mineral exploration and 

development activities. The Proposed RMP would recommend 94 percent of the decision area would be 

open to locatable mineral development. The areas recommended for withdrawal would not affect gypsum 

exploration and development activities. 

Closing areas to mineral material disposals would directly impact mineral material exploration and 

development activities. The majority of the areas closed to mineral material disposals would not close 

areas with high potential for sand and gravel and stone development. 
Minerals and Energy 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-111 

Coal 

Coal management actions would allow for the leasing and development of coal resources on lands 

identified as suitable (Appendix 6). The anticipated coal mine in the Alton area of the Alton coal field 

could be considered for further leasing under each alternative. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

An irreversible commitment of oil and gas, coal, and locatable minerals and mineral materials would 

occur from development over the next 20 years. There are no impacts on long-term productivity from 

short-term uses or unavoidable impacts on minerals exploration and development activities. 
Areas of Critical Environmental Concern 

Chapter 4 Proposed RMP and Final EIS 

4-112 Kanab RMP 

4.4 SPECIAL DESIGNATIONS

4.4.1 Impacts on Areas of Critical Environmental Concern 

There is one existing and five potential ACECs discussed in Chapter 3. The existing ACEC is contained 

wholly within the boundaries of the potential Cottonwood Canyon ACEC. Of the six potential ACECs 

discussed in the Draft RMP/EIS, all include scenic R&I values, four include cultural values and wildlife 

resources, and five include botanical resources. Other R&I values, resources, systems or processes, and 

hazards/safety/public welfare issues addressed during this analysis include geologic features, special 

status species, and human safety. Appendix 14 contains documentation of the process to evaluate 

nominations for ACECs and the R&I values for each ACEC. 

An ACEC is administratively designated by the BLM for “areas within the public lands where special 

management attention is required.” FLPMA defines an ACEC as an area: 

“within the public lands where special management attention is required (when such 

areas are developed or used, or where no development is required) to protect and 

prevent irreparable damage to important historic, cultural, or scenic values, fish and 

wildlife resources or other natural systems or processes, or to protect life and safety from 

natural hazards” (FLPMA Section 103(a)). 

This analysis identifies effects of the Proposed RMP on the BLM’s ability to protect against and prevent 

irreparable damage to the R&I values associated with each potential ACEC across the alternatives. This 

analysis addresses impacts on R&I values, which were confirmed by the interdisciplinary team. 

Protection of R&I values can occur as a result of management associated with designating ACECs, 

management associated with other special designations (e.g., WSAs and WSRs), general management of 

public lands (VRM classes, SRMAs, restrictions on wildlife habitat, special status species management 

alternatives), or through geographic or topographic characteristics. The most restrictive management that 

protects an area with R&I values will be the focus of the analysis. Analysis of less restrictive management 

that would not provide additional protection to an R&I value will not be addressed. For example, if part of 

an ACEC with scenic R&I values threatened by oil and gas development overlaps a WSA, the WSA 

management would eliminate the threat of irreparable damage. Therefore, the analysis would not address 

the impacts of ACEC management for those portions of the ACEC within the WSA, but would analyze 

the impacts from the WSA. 

In concert with BLM guidelines, the impact analysis considers management actions that “defend or guard 

against damage or loss” to the R&I values. This includes damaged values that can be restored over time 

and those that are irreparable. The management actions associated with the alternatives could either 

degrade or protect the R&I values and either cause or prevent irreparable damage to such values. 

This section is organized by ACEC in the order they appear in Chapter 3. 

Under the Proposed RMP, impacts on identified R&I values are not anticipated as a result of 

implementing management actions for the following resources, resource uses, and designations: air 

quality, soil resources, water resources, vegetation, wildland fire ecology, paleontological resources, 

forestry and woodland products, livestock grazing, lands and realty, WSRs, wilderness, and other 

designations. 
Areas of Critical Environmental Concern 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-113 

Water Canyon/South Fork Indian Canyon ACEC 

Impacts on the existing Water Canyon/South Fork Indian Canyon ACEC could occur if there were a 

threat of irreparable damage to scenic values and botanical and biological natural systems or processes. 

Potential threats include oil and gas development, OHV use, and locatable mineral exploration and 

development. 

Proposed RMP 

The existing ACEC would be included in the potential Cottonwood Canyon ACEC. See that section 

below for a discussion of impacts. 

Cottonwood Canyon ACEC 

Impacts on the potential Cottonwood Canyon ACEC could occur if there were a threat of irreparable 

damage to scenic and cultural values, wildlife resources, botanical and geologic systems or processes, or 

hazards/safety/public welfare. Potential threats include mineral development, unregulated OHV use, rock 

climbing, and general surface disturbance. 

Proposed RMP 

The ACEC designation and proposed management direction would be sufficient to protect R&I values 

from potential threats. Allowing oil and gas leasing subject to major constraints (NSO) would eliminate 

visual intrusions from surface occupancy. In addition, closing the area to mineral materials and locatable 

mineral entry would eliminate the potential for development of these minerals to potentially contaminate 

the Town of Fredonia’s water source and would protect scenic values and wildlife resources. Allowing 

OHV use limited to one 4-mile identified route would eliminate the potential for degradation from 

unregulated OHV use. Recreation management would regulate or limit rock climbing near cultural sites 

and important raptor habitat. This management would protect cultural values and wildlife resources from 

harm associated with rock climbing. 

Approximately 2,400 acres (63 percent of potential ACEC) would be within the Moquith Mountain WSA. 

Managing the area under the IMP would protect and prevent irreparable damage to the R&I values from 

surface disturbing activities, including mineral development. 

Welsh’s Milkweed ACEC 

Impacts on the potential Welsh’s Milkweed ACEC could occur if there were a threat of irreparable 

damage to scenic, geologic, or special status species (Coral Pink Sand Dunes tiger beetle and Welsh’s 

milkweed) values. Potential threats to these values include visual intrusions, surface disturbance, removal 

of vegetation, and OHV use. 

Proposed RMP 

Although the potential ACEC would not be designated, 1,250 acres (96 percent of the potential ACEC) 

would be within the Moquith Mountain WSA. Managing the area under the IMP would protect and 

prevent irreparable damage to the R&I scenic values and geologic processes from surface disturbing 

activities, including mineral development. In addition, harvest of woodland products would not be 

allowed in the WSA, eliminating the potential for disturbance of Welsh’s milkweed habitat. Managing the 

50 acres outside the WSA (4 percent of the potential ACEC) as VRM Class II would generally maintain 
Areas of Critical Environmental Concern 

Chapter 4 Proposed RMP and Final EIS 

4-114 Kanab RMP 

the existing character of the landscape, reducing the level of change on the landscape and protecting the 

scenic R&I values. 

Special status species management would prohibit motorized use in and through vegetation in designated 

critical habitat for Welsh’s milkweed, protecting this value from irreparable damage associated with OHV 

disturbance. Similarly, implementing conservation actions identified in the Conservation Agreement and 

Strategy for the Coral Pink Sand Dunes tiger beetle, including maintaining the established 370-acre 

conservation area, would protect this R&I resource from irreparable damage. 

Vermilion Cliffs ACEC 

Impacts on the potential Vermilion Cliffs ACEC could occur if there were a threat of irreparable damage 

to scenic and cultural values, wildlife resources, and botanical and geologic systems or processes. 

Potential threats include visual intrusions, mineral development, and OHV use. 

Proposed RMP 

The potential Vermilion Cliffs ACEC is not designated under the Proposed RMP. Managing 13,000 acres 

(56 percent) of the potential ACEC as VRM Class II would protect much of the R&I scenic and cultural 

values from irreparable damage. Managing 9,200 acres (39 percent) of the potential ACEC as VRM Class 

III would allow for some degree of change to the landscape, allowing for the introduction of visual 

intrusions into the area. ROWs would be allowed in VRM Class III and IV areas (10,400 acres), which 

could lead to surface disturbance in localized areas over the short term. Collocating ROWs would reduce 

these impacts. 

Management associated with the Kanab Community SRMA would result in 18,800 acres (80 percent) of 

the potential ACEC being open for oil and gas leasing subject to major constraints (NSO). This would 

eliminate the potential for visual intrusions from oil and gas development and for disturbance to the R&I 

wildlife (raptor) resources. Fish and wildlife and special status species management in the Proposed RMP 

prohibits disruptive activities within established buffers and seasons to protect raptor species. These 

restrictions would allow impacts from discretionary activities such as mineral material disposal to be 

eliminated, protecting the R&I wildlife (raptor) resources from irreparable damage. In addition, 

management of special status species in the Proposed RMP allows for surface disturbing and disruptive 

activities to be controlled or regulated to minimize impacts on identified crucial habitat for sensitive 

species. This would protect the R&I botanical natural processes or systems (special status plants) from 

irreparable damage associated with surface disturbing activities. 

OHV use throughout the potential ACEC would be limited to 63 miles of designated routes that already 

exist, with use being closed seasonally on 14 miles to protect raptor species. Limiting OHV use to these 

existing designated routes where disturbance has already occurred would protect the R&I cultural values 

and natural process (special status species plants) from irreparable damage associated with OHV use. 

White Cliffs ACEC 

Impacts on the potential White Cliffs ACEC could occur if there were a threat of irreparable damage to 

scenic and cultural values, wildlife resources, and botanical natural systems or processes. Potential threats 

include visual intrusions, mineral development, and OHV use. 
Areas of Critical Environmental Concern 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-115 

Proposed RMP 

Although the potential ACEC would not be designated, managing 22,400 acres (86 percent) of the 

potential ACEC as VRM Class II would protect much of the R&I scenic and cultural values from 

irreparable damage. Managing 3,600 acres (14 percent) of the potential ACEC as VRM Class III would 

allow for some degree of change to the landscape, allowing for the introduction of visual intrusions into 

portions of the area. The Class III areas are gentle sloping areas covered in pinyon-juniper woodlands, 

away from the Class A scenery that qualified as the R&I value. 

The R&I values in the potential ACEC would receive protection from oil and gas development impacts 

through management prescriptions from visual resource management, non-WSA lands with wilderness 

characteristics management, and other sensitive areas (e.g., special status species habitat, riparian areas, 

and incorporated municipalities). While 11,470 acres (44 percent) of the potential ACEC is open to oil 

and gas leasing subject to the standard terms of the lease form or subject to moderate constraints, 

management of the fish and wildlife and special status species in the Proposed RMP prohibits disruptive 

activities within established buffers and seasons to protect raptor species. These restrictions would reduce 

impacts from disruptive activities such as oil and gas, mineral material, and locatable mineral exploration 

and development, protecting the R&I wildlife (raptor) resources from irreparable damage. In addition, 

special status species management in the Proposed RMP allows for surface disturbing and disruptive 

activities to be controlled or regulated to minimize impacts on identified crucial habitat for sensitive 

species. This would protect special status species plants from irreparable damage associated with surface 

disturbing activities. Additionally, oil and gas developments in this area would also be required to meet 

the VRM Class II standards, which would provide protection to the scenic values and indirect protection 

to the other R&I values. Managing 14,530 acres (56 percent) of the potential ACEC as open to leasing 

subject to major constraints (NSO) or closed to leasing due to managing the area for its wilderness 

characteristics would eliminate the potential for threats from mineral development in these areas. 

OHV use throughout the potential ACEC would be limited to 35 miles of designated routes that already 

exist. Limiting OHV use to these existing designated routes where disturbance has already occurred 

would protect the cultural sites and special status species plants from irreparable damage associated with 

OHV use. 

Managing 14,130 acres (54 percent) of the potential ACEC for wilderness character (Upper Kanab Creek) 

would provide further protection from surface disturbing activities and would further protect the R&I 

values from irreparable damage. 

Parunuweap Canyon ACEC 

Impacts on the potential Parunuweap Canyon ACEC could occur if there were a threat of irreparable 

damage to scenic and cultural values and wildlife resources. Potential threats to these values include rock 

climbing, camping on cultural sites, visual intrusions, mineral development, and OHV use. 

Proposed RMP 

Although the potential Parunuweap Canyon ACEC would not be designated under the Proposed RMP, 

6,100 acres (100 percent) of the potential ACEC would be within the Parunuweap Canyon WSA. 

Managing the area under the IMP would protect and prevent irreparable damage to the R&I scenic and 

cultural values from surface disturbing activities and visual intrusions, including mineral development. 

Recreation management decisions from the Proposed RMP would provide avenues to eliminate the threat 

of irreparable damage to R&I cultural values from inadvertent camping on cultural sites. Using 

environmental education and interpretation and signage to control unauthorized use could educate 
Areas of Critical Environmental Concern 

Chapter 4 Proposed RMP and Final EIS 

4-116 Kanab RMP 

dispersed users concerning safe locations in which to camp. In addition, issuing SRPs following 

evaluation of factors, including specific resources that could be impacted such as cultural values and 

wildlife resources, would provide for education and implementation-specific decisions concerning 

campsites to eliminate this impact. Due to these recreation decisions, there would be no threat of 

irreparable damage to R&I cultural values from camping. 

Summary 

Under the Proposed RMP, only the Cottonwood Canyon ACEC would be designated, with management 

prescriptions that would protect the R&I values, resources, processes, systems, or hazards/safety/public 

welfare. Management associated with other resource program decisions would protect the R&I values, 

resources, processes, or systems in the other potential ACECs from threat of irreparable damage. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources within potential ACECs under 

the Proposed RMP. The Proposed RMP includes management actions to eliminate threats of irreparable 

damage to all R&I values associated with all potential ACECs. Through this management, the R&I values 

would be protected from short-term uses over the life of the plan. Therefore, there are no unavoidable 

adverse impacts that would result in the irreparable damage to R&I values associated with potential 

ACECs. 
Wild and Scenic Rivers 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-117 

4.4.2 Impacts on Wild and Scenic Rivers 

This section discusses impacts on eligible WSR segments that would occur from implementing the 

Proposed RMP. Analysis of impacts on WSRs is limited to the river segment corridor, which includes the 

viewshed within 1⁄4 mile on each side of a river’s high-water mark. In many cases the corridor would be 

limited to the canyon in which the river segment is located. 

The analysis of impacts on WSRs includes an evaluation of where management actions may be 

inconsistent with the tentative classification given to all eligible or suitable segments and of potential 

impacts on the ORVs of any eligible or suitable segment. Impacts on the tentative classification of the 

segments for each alternative will be discussed first, followed by impacts associated with the segment’s 

ORVs. No impacts on WSRs are expected to occur under any alternatives from management actions 

associated with air quality and other designations. For a more detailed explanation of ORVs, the criteria 

associated with each ORV, river classifications, and what is allowed within the corridor of each 

classification, see Appendix 13. 

Proposed RMP 

Under the Proposed RMP, six segments, totaling 5,530 acres/30 miles, would be determined as suitable 

for inclusion in the National Wild and Scenic Rivers System (NWSRS) and would be managed to protect 

their free-flowing nature, ORVs, and tentative classification. Tentative classification of the six segments 

is as follows: five segments (4,570 acres/25 miles) are “wild” and 1 segment (960 acres/5 miles) is 

“scenic” (Map 18). By determining nine of the eligible segments to be not suitable for inclusion in the 

NWSRS, BLM would no longer provide any direct protections of these segments’ ORVs or tentative 

classifications. Any protections afforded these values would occur indirectly from management actions 

associated with other resources. Because no direct protections would be afforded to the eligible segments, 

there is a potential that impacts on the ORVs could occur that could be severe enough to preclude them 

from future WSR consideration. 

Soil, Water, and Vegetation 

Soil, water, and vegetation management actions would not allow new surface disturbance within 330 feet 

of riparian/wetland areas, which would provide greater indirect protections to WSRs. This would protect 

the tentative classification of both “wild” and “scenic” segments by providing additional protections to 

maintain the integrity of the area. These stipulations also would provide indirect protections to many of 

the segments’ ORVs, such as scenic, fish, wildlife or ecologic ORVs, precluding disturbing activities that 

may effect the condition or presence of the values. 

Special Status Species and Fish and Wildlife 

Management of special status species and migratory bird decisions in fish and wildlife would include 

additional protective stipulations under the Proposed RMP to eliminate or reduce surface disturbing and 

disruptive activities, maintaining the various tentative classifications and protecting fish and wildlife 

ORVs of eligible and suitable segments. Mitigation to restore habitat loss and prioritize habitat vegetation 

treatments, various surface disturbance timing stipulations, group size limits, monitoring efforts, and 

efforts to reestablish native and naturalized fish and wildlife species would provide additional protections 

to wildlife and fish ORVs. Impacts from such actions would be site-specific and short-term and over the 

long term likely would provide additional protections to the fish and wildlife ORVs. 

Wildland Fire Ecology 

During and immediately after fire events, access to suitable segments for enjoyment of the opportunities 

associated with them may be restricted or impaired. Full suppression of wildland fires in these areas may 
Wild and Scenic Rivers 

Chapter 4 Proposed RMP and Final EIS 

4-118 Kanab RMP 

be implemented to control fire size and severity, thus protecting the ORVs within the segment corridors. 

Short-term impacts could include disturbance to soils, surfaces and groundwater, watershed functions, 

vegetation conditions, and habitats for special status species and fish and wildlife. Impacts would be 

minimized by post-fire rehabilitation efforts. Appropriate management response may include limiting the 

use of mechanical suppression activities or other techniques for reducing impacts on tentative 

classifications and ORVs. Suppression may be prioritized to protect the unique values threatened by 

wildfire. To minimize the impairment of the ORVs, Resource Protection Measures have been developed 

(Appendix 8). It is BLM policy to protect suitable rivers being studied in conjunction with Section 5(d)(1) 

of the Wild and Scenic Rivers Act. ESR actions would be implemented to stabilize wildfire areas and to 

minimize the threat of invasive and noxious weed species becoming established.

Cultural and Paleontology 

Law and policy guiding cultural and paleontological resources management would provide indirect 

protection to six segments (two suitable and four eligible) that contain cultural or historic ORVs by 

placing restrictions on surface disturbance activities and avoiding disturbance of the various cultural and 

historical sites. Cultural restrictions could occur on segments containing scenic, recreational, fish, 

wildlife, and ecologic ORVs, providing indirect protections of these values as well. Precluding surface 

disturbing activities within 1⁄4 mile or within the visual horizon (whichever is closer) for cultural sites 

where landscape association contributes to the eligibility on the NRHP could provide protections to the 

“wild” and “scenic” tentative classification of two suitable segments of the East Fork Virgin River 

containing cultural ORVs and to the cultural ORVs themselves. 

Visual Resource Management 

VRM management would help protect the six suitable segments because they would be either managed as 

VRM Class I (“wild” segments) or wholly contained within a WSA, which are managed as VRM Class I. 

Restrictions associated with VRM Class I would preserve the natural appearance of the area, providing 

protections to the tentative classifications and scenic and other ORVs of the segments by restricting 

visually impairing actions that could potentially cause impacts on the segments and values. The eligible 

segments not found suitable could receive protection due to VRM classifications associated with WSAs, 

ACECs, or non-WSA lands with wilderness characteristics managed to protect, preserve, and maintain 

their wilderness characteristics. 

Forestry and Woodlands Products 

All or portions of the six suitable segments are inside WSAs where forest and woodland product harvest 

would be prohibited. This would further protect the scenic ORVs. The eligible segments not found 

suitable could receive protection due to forestry and woodland product harvest management actions 

associated with WSAs, ACECs, or non-WSA lands with wilderness characteristics managed to protect, 

preserve, and maintain their wilderness characteristics. 

Livestock Grazing 

Livestock grazing management prescriptions would be compatible with the tentative classification of the 

one segment tentatively classified as “scenic”; however, there is a potential that certain rangeland 

improvements (e.g., fencing and water crossings) could be incompatible in some of the suitable and 

eligible segments tentatively classified as “wild” because of visual intrusions to the natural character of 

the area. In general, management actions of livestock grazing, which are subject to Standards for 

Rangeland Health, would be compatible with protective management of the segments’ ORVs. 
Wild and Scenic Rivers 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-119 

Recreation 

Under the Proposed RMP, suitable WSRs would receive indirect protection from more detailed recreation 

management associated with the establishment of SRMAs. Three of the six suitable segments (North Fork 

Virgin River, Orderville Gulch, and Paria River) listed in Table 4-12 are located within three of the 

SRMAs identified under the Proposed RMP. All of these areas are also with either WSAs or designated 

wilderness, which would generally be more restrictive than the SRMA management. However, 

management associated with the SRMAs would provide for protection to the recreational ORVs of the 

suitable segments. Six eligible segments in the Cottonwood Canyon area (Table 4-13) are located within 

the Moquith Mountain SRMA which is identified under the Proposed RMP. Management associated with 

the SRMA would provide indirect protection to the tentative classifications and ORVs of these eligible 

segments. 

Transportation 

Limiting OHV use to designated routes along the East Fork Virgin River segment tentatively classified as 

“scenic” would be compatible with the classification. Less than 1 mile of route would be designated on 

the east end of the scenic segment and the remainder of the viewshed would have no designated routes. 

No impacts would occur from OHV designation to the suitable segments with a tentative classification as 

“wild” because the five segments would be closed to OHV use. Restrictions on OHV use within the 

suitable segments would provide indirect protections to the segments’ ORVs, particularly scenic and 

wildlife, by restricting use that may reduce the natural character of the area or cause displacement of 

wildlife. Seven of the nine eligible segments are located in the Parunuweap and Moquith Mountain WSAs 

(Table 4-13). Managing for the IMP in these WSAs would be limited to designated routes. This would 

provide protection to the segments’ scenic and wildlife ORVs as only one route (way) accesses these 

segments. No routes are designated in the Deep Creek eligible segment, and the designated routes in the 

Three Mile Creek eligible segment would not eliminate the fish ORV associated with it. 

Lands and Realty 

Under the Proposed RMP, lands and realty management actions would exclude new ROWs from suitable 

segment corridors with a tentative classification of “wild” or “scenic.” This would preclude these surface 

disturbing and potentially visually obtrusive activities that could potentially impact the segment’s ORVs. 

Seven eligible segments are located in the Parunuweap and Moquith Mountain WSAs (Table 4-13). 

Managing for the IMP in these WSAs would exclude new ROWs and protect the segments’ scenic ORVs. 

Minerals and Energy 

No impacts on the tentative classification or ORVs of the six suitable segments would occur because there 

are no existing leases located within the segment corridors and because all segments are closed to mineral 

development. Seven of the nine eligible segments (Table 4-13) are located within WSAs or an ACEC 

which are closed to leasing and open to leasing subject to major constraints (NSO) respectively. This 

would indirectly protect the scenic, recreational, wildlife, and cultural ORVs. For those eligible segments 

or portions of segments outside the ACEC and WSAs, there could be impacts from mineral development, 

although management from other resources, such as VRM, special status species, or non-WSA lands with 

wilderness characteristics, would provide indirect protection to mitigate impacts on the eligible tentative 

classifications and ORVs. 

ACECs, WSAs, Wilderness 

Management associated with ACECs, WSAs, and wilderness would be compatible with the tentative 

classification of the suitable and eligible segments that are entirely or partially located within these areas 

and would provide additional protections to the segments’ ORVs. This would particularly be true for 

segments located within WSAs and wilderness because of restrictions placed on surface disturbance, 
Wild and Scenic Rivers 

Chapter 4 Proposed RMP and Final EIS 

4-120 Kanab RMP 

OHV use, and from managing the wilderness and WSAs as VRM Class I, protecting scenic ORVs and 

indirectly protecting other ORVs. In addition, WSAs and wilderness management actions would limit 

SRP group sizes to 12 or less. This would provide protection to recreational and wildlife ORVs, reducing 

the number of encounters, maintaining the primitive feel of the areas, and reducing wildlife displacement 

by recreationists. Table 4-12 and Table 4-13 indicate which suitable and eligible segments, respectively, 

would be located within one of these areas. Under the Proposed RMP no indirect protections would be 

afforded suitable segments from ACECs management because no segments would be located within 

designated ACECs. 

Table 4-12. Proposed RMP Suitable Segments Coinciding with WSAs or Wilderness Area 

Suitable Segment Acres Within WSA Acres Within Wilderness 

North Fork Virgin River North Fork Virgin River 

(200 acres, 46% of corridor) - 

East Fork Virgin River 

(Segment 37-40a) 

Parunuweap 

(960 acres, 100% of corridor) - 

East Fork Virgin River 

(Segment 40a-41) 

Parunuweap 

(770 acres, 100% of corridor) - 

Orderville Gulch Orderville Canyon 

(500 acres, 84% of corridor) - 

Meadow Creek/Mineral Gulch Parunuweap 

(1,570 acres, 89% of corridor) - 

Paria River - Paria–Vermilion 

(1,020 acres, 100% of corridor) 

Table 4-13. Proposed RMP Eligible Segments Coinciding with ACECs or WSAs 

 Eligible Segment Acres Within ACEC Acres Within WSA 

East Fork Virgin River 

(Segment 36-37) - Parunuweap 

(750 acres, 100% of corridor) 

Deep Creek - - 

Cottonwood Creek Cottonwood Canyon 

(280 acres 100% of corridor) 

Moquith Mountain 

(20 acres, 9% of corridor) 

Indian Canyon Cottonwood Canyon 

(20 acres, 14% of corridor) 

Moquith Mountain 

(20 acres, 17% of corridor) 

South Fork Indian Canyon Cottonwood Canyon 

(130 acres, 29% of corridor) 

Moquith Mountain 

(450 acres, 100% of corridor) 

North Branch of South Fork 

Indian Canyon 

Cottonwood Canyon 

(40 acres, 48% of corridor) 

Moquith Mountain 

(90 acres, 100% of corridor) 

Water Canyon Cottonwood Canyon 

(600 acres, 84% of corridor) 

Moquith Mountain 

(710 acres, 100% of corridor) 

Hell Dive Canyon Cottonwood Canyon 

(175 acres, 50% of corridor) 

Moquith Mountain 

(310 acres, 88% of corridor) 

Three Mile Creek - - 
Wild and Scenic Rivers 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-121 

Wild and Scenic Rivers 

Management of suitable WSRs would protect the tentative classifications and ORVs, through protective 

management allocations on other resources and uses (e.g., oil and gas leasing stipulations, VRM 

classifications, OHV area and route designations). Overall, these management actions would provide 

more protection for suitable segments, but non-suitable segments would be vulnerable to change. 

Under the Proposed RMP, nine of the eligible river segments (15.9 miles and 3,700 acres) would not be 

managed as suitable for inclusion in the NWSRS. Therefore, the BLM would no longer provide any direct 

protections to the segments’ ORVs or tentative classifications. Any protections afforded these values 

would occur indirectly from management actions associated with other resources. Examples of such 

indirect protections could include management associated with WSAs, ACECs, or various forms of 

restrictions placed on surface disturbance activities associated with resource management. Because no 

direct protections would be afforded to non-suitable segments, there is a potential that impacts could 

occur on the ORVs (impacts on each ORV are presented under their respective resources) and tentative 

classifications that could be severe enough to preclude them from future WSR consideration. 

Summary 

Impacts on the tentative classification of eligible and suitable segments would primarily occur to “wild” 

segments from increased access to river corridors associated with OHV designations. However, under the 

Proposed RMP the majority of the segments would be located within WSAs, and OHV restrictions are in 

place. Impacts on eligible and suitable segments’ ORVs would primarily occur from surface disturbing 

activities that would impact the scenic quality of the area and in some instance cause impacts on fish, 

wildlife, and recreational values. However, under the Proposed RMP the potential for impacts would 

decrease because of indirect protections from management of other resources (e.g., soil, water, fish and 

wildlife, and special status species), WSAs and wilderness. Additional protections also would be afforded 

to the ORVs of some segments from SRMA management. 

Under the Proposed RMP, by not managing all eligible segments in a protective manner there is a 

potential that impacts could occur to the ORVs and tentative classifications that could be severe enough to 

preclude them from future opportunities for WSR consideration. Any protections for these values would 

be an indirect result of management of other resources, such as WSAs. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

Based on their location and management of other resources, uses, and designations, impacts on WSRs are 

not irreversible or irretrievable. There will be no loss of long-term productivity due to short-term uses 

proposed in the alternatives. None of the activities proposed in this Proposed RMP/Final EIS will produce 

unavoidable adverse impacts on WSRs. 
Wilderness 

Chapter 4 Proposed RMP and Final EIS 

4-122 Kanab RMP 

4.4.3 Impacts on Wilderness 

This section discusses potential impacts on the portions of the Paria Canyon–Vermilion Cliffs Wilderness 

within the decision area from implementing the Proposed RMP. Wilderness areas are managed according 

to the Wilderness Act to preserve their wilderness characteristics (i.e., solitude, naturalness, and 

primitive/unconfined recreation). As such, the BLM cannot allow activities to occur within wilderness 

areas that would affect their wilderness characteristics. This section focuses on impacts on wilderness 

characteristics within the designated wilderness area. Because there are no existing mineral leases located 

within the wilderness area and Congress has closed wilderness areas to mineral development, wilderness 

characteristics are primarily influenced by the volume and density of recreational users and range and 

wildlife management projects. These impacts normally come from vegetation treatments, and the 

installation, maintenance, and use of range/wildlife improvements allowed under the Wilderness Act and 

Congressional Wilderness Grazing Guidelines. 

The analysis is based on the following assumptions: 

• Any new surface disturbing activities proposed would be subject to NEPA analysis and the 

minimum tool requirement. 

• Activities proposed that would not initially meet wilderness objectives for the area would be 

mitigated to the extent possible to meet the objectives. Activities that could not be mitigated may 

not be authorized. 

• Some proactive restoration of areas that do not meet desired wilderness objectives may be 

completed each year. 

Under the Proposed RMP, impacts on wilderness are not anticipated as a result of implementing 

management actions for the following resources, resource uses, and designations: air quality, soil 

resources, water resources, cultural resources, paleontological resources, forestry and woodland products, 

lands and realty, minerals and energy, ACECs, WSRs, WSAs, and other designations. 

Proposed RMP 

Minimizing change on the landscape would preserve the characteristic landscape; be in compliance with 

the Wilderness Act; and continue to maintain naturalness, solitude, and opportunities for primitive 

recreation while implementing other management actions. In addition, consideration of soundscapes 

would protect the perception of solitude, maintaining or restoring the natural quiet of the area. 

Recreation Management 

Implementing adaptive management principles to regulate group size based on the monitoring of the 

wilderness area resources and social conditions would mitigate impacts on solitude associated with 

increased recreation use. Indirect impacts on the wilderness area also would occur from establishing the 

Paria Canyon SRMA, which would implement management consistent with wilderness policy. In 

addition, supporting Tread Lightly and Leave No Trace programs throughout the decision area would 

reduce impacts on designated wilderness as recreation users recreate in a manner that leaves fewer longterm impacts. 

Vegetation Manipulation 

Vegetation manipulation projects, whether to restore ecological function, reduce hazardous fuels, improve 

habitat, or reduce invasive species, would be under the minimum tool requirement, and direct impacts 

likely would be localized and short term. Allowing the full suite of restoration tools (chemical, biological, 

mechanical, fire, natural processes) would allow the broadest approach to controlling invasive species and 
 Wilderness 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-123 

restoring ecological function. Solitude experienced by recreational users could be reduced in the short 

term while the treatment is implemented. Over the long term, naturalness would remain unchanged; the 

magnitude of this restoration would depend on the type and scope of vegetation restoration. All impacts 

would be localized, and over the long term naturalness would be enhanced by restoring natural vegetation 

structures and patterns. While allowing the broadest range of treatment methods could increase short-term 

impacts, the long-term restoration of natural function could occur in more areas and in a shorter time 

period. 

Wilderness Management 

Managing the Paria Canyon–Vermilion Cliffs Wilderness to protect wilderness characteristics would 

protect wilderness values through application of the minimum tool analysis for all surface disturbing 

activities. Implementation of the Wilderness Management Plan allows for periodic adjustments to sitespecific management in order to ensure wilderness characteristics are preserved. 

Visitors may have outstanding opportunities for solitude or primitive and unconfined recreation when the 

sights, sounds, and evidence of other people are rare or infrequent and where visitors can be isolated and 

alone or secluded from others. High concentrations of recreation users (large group sizes and/or frequent 

group encounters) would decrease outstanding opportunities for solitude in wilderness. Continuing the 

current group size and visitor use limits required for use in the Paria Canyon, subject to adaptive 

management decisions deemed necessary through monitoring and evaluation of resources and social 

conditions, would preserve opportunities for solitude. 

Continuing to manage the wilderness area as VRM Class I and closed to OHV use and all motorized and 

mechanized vehicles, with no designated routes, would preserve wilderness character from these 

potentially intrusive activities. In accordance with Wilderness Act Section 4(d), exceptions to exclusions 

on motorized and mechanized vehicles could result in a short-term detraction from the natural character 

of the area. In addition, there is a potential for a short-term elimination of solitude and naturalness from 

increased sights and sounds associated with the use of equipment and mechanical transport. These 

impacts would be uncommon and short term in nature, if they do occur. 

Wildland Fire Suppression 

Wildland fire suppression tactics and ESR activities following fire events could result in a short-term loss 

of solitude related to the presence of personnel to implement the activity; however, over the long term 

vegetation in the area would appear natural, providing a diverse and desirable vegetative cover. These 

activities would take into account factors including existing wilderness characteristics of the area, need to 

prevent impairing actions, historic fire occurrence, natural role of fire, proposed degree of suppression, 

smoke management, use of natural firebreaks, and adequate buffer zones. Adherence to resource 

protection measures while implementing wildland fire activities would limit intrusion on wilderness 

characteristics to the extent possible while protecting human life. The vegetation in the wilderness area is 

not adapted to frequent wildland fires; the potential for impacts from wildland fire activities would be 

low. 

Livestock Grazing 

Livestock grazing could have a perceived impact on wilderness character. Primitive recreational 

experiences could be impacted by the presence of livestock in a wilderness setting. Areas frequented by 

livestock, such as springs or water developments, could have a perceived unnatural appearance to some 

wilderness users. It should be noted that livestock seen in Paria Canyon generate some visitor comments 

on the trailhead comment form. Maintenance of range improvements allowed by the Wilderness Act and 

Congressional Wilderness Grazing Guidelines could result in short-term impacts on solitude and 

naturalness. 
Wilderness 

Chapter 4 Proposed RMP and Final EIS 

4-124 Kanab RMP 

Summary 

Wilderness characteristics in the Paria Canyon–Vermilion Cliffs Wilderness would generally be protected 

due to management associated with the wilderness alternatives. The Proposed RMP could result in shortterm loss of solitude during vegetation treatments, but over the long term naturalness would be restored. 

There also could be some loss of naturalness from the presence of livestock grazing as allowed by the 

Wilderness Act and Congressional Wilderness Grazing Guidelines; however, the level of impact would be 

based on individual perception. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources. No short-term uses would be 

permitted if they resulted in the long-term impairment of wilderness characteristics. Due to application of 

the minimum tool requirements, there would be no unavoidable adverse impacts. 
Wilderness Study Areas 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-125 

4.4.4 Impacts on Wilderness Study Areas 

Under BLM policy, WSAs are managed according to the IMP (H-8550-1) to protect the area’s identified 

wilderness characteristics until such time that Congress acts on BLM 1992 recommendations. The IMP 

provides direction for managing other resource uses within WSAs. Any management schemes considered 

in this RMP must be within the parameters provided by the IMP. 

WSAs will continue to be managed to the non-impairment standard, and as such the BLM cannot allow 

activities to occur within WSAs that would impair their suitability for preservation as wilderness. 

Therefore, significant impacts on WSAs (i.e., impairment) would not occur under any of the alternatives. 

Although impacts on natural resources within WSAs would occur from a variety of uses, they would be 

non-impairing and therefore would not result in long-term impacts on the wilderness characteristics of the 

WSAs. Some uses that may be impairing to wilderness characteristics in a WSA may be permitted under 

IMP because they are only temporary uses that do not create substantial surface disturbance. 

The analysis is based on the following assumptions: 

• Managing WSAs according to the IMP will protect the wilderness characteristics of WSAs in a 

manner that will not “impair the suitability of such areas for preservation as wilderness” (FLPMA 

Section 603(c)). 

• Management actions that enhance biological or environmental characteristics would improve the 

wilderness quality and suitability of the WSAs. 

Under the Proposed RMP, impacts on WSAs are not anticipated as a result of implementing management 

actions for the following resources, resource uses, and designations: air quality, cultural resources, 

paleontological resources, forestry and woodland products, lands and realty, minerals and energy, 

ACECs, WSRs, wilderness, and other designations. 

Proposed RMP 

Motorized Use of Routes (Inventoried Ways) 

Impacts from allowing motor vehicle use along designated routes (inventoried ways) within the 

Parunuweap Canyon, Orderville Canyon, and Moquith Mountain WSAs would decrease because 7.6 

miles of routes (inventoried ways) in these areas would be closed to motorized use. The short-term 

impacts from OHV use on opportunities for solitude and primitive recreation would be eliminated along 

and adjacent to these routes (inventoried ways). OHV use along the remaining 25.0 miles of designated 

routes (inventoried ways) could could impact recreation users’ perception of opportunities for solitude 

and primitive recreation. The appearance of naturalness within WSAs would be temporarily reduced by 

any signs and barricades that may be needed to keep vehicles on existing routes (inventoried ways). Such 

structures would be temporary, limited to the routes (inventoried ways), and would not affect the WSA as 

a whole. In addition, the sound and presence of OHV users would reduce non-motorized recreation users’ 

perception of opportunities for solitude and primitive recreation. When the OHV user passed beyond sight 

and hearing range, opportunities for solitude and primitive recreation would return and natural 

soundscapes would be restored. 

Limiting OHV recreation use to these designated routes (inventoried ways) could minimize disturbance of 

adjacent lands, protecting the natural character of areas adjacent to these routes. However, with vehicle 

use of inventoried routes (inventoried ways) continuing in the WSAs, there is greater risk that users will 

inappropriately leave the routes and form new trails, which could impair wilderness suitability. Therefore, 

under this alternative, motorized use would be actively monitored by the BLM, and any traces resulting 
Wilderness Study Areas 

Chapter 4 Proposed RMP and Final EIS 

4-126 Kanab RMP 

from inappropriate vehicle use off of existing routes (inventoried ways) would be immediately removed 

so that new OHV trails do not form. OHV use would be conditional and would not be allowed to expand 

beyond these routes (inventoried ways) or further impact the natural character of the WSAs. Because 

impacts would be short term and localized, no lands within these WSAs would be disqualified from 

consideration as wilderness by Congress. 

Recreation 

The intensity of impacts from recreation use within WSAs would decrease due to limiting group sizes 

associated with SRPs within WSAs to 12 people, protecting opportunities for solitude and primitive 

unconfined recreation. These impacts would be most evident in the areas currently receiving high levels 

of use, such as the North Fork Virgin River, Orderville Canyon, and Parunuweap Canyon WSAs. 

However, reducing group sizes in the face of increases in the number of groups could result in a 

continuation of the existing levels of impact. In addition to the reduction in the number of users, 

supporting education and outreach programs such as Tread Lightly and Leave No Trace would reduce 

impacts from increasing numbers of overnight users as campers recreate in a manner that leaves fewer 

impacts. 

Visual Resources Management 

VRM Class I objectives would support the IMP guidelines to not impair the natural character of the 

existing landscape. The objective of VRM Class I is to preserve the existing character of the landscape. 

While the VRM objective provides for natural ecological changes, level of change to the landscape should 

be very low and must not attract attention. The IMP prevents the impairment of wilderness values, but 

allows some modifications to the natural character of the area if modifications are found not to impair or 

because of valid rights, grandfathered activities, safety considerations, or other reasons. In such cases, 

managing the WSAs as VRM Class I complements the IMP by providing techniques to ensure that 

potential changes are designed not to attract attention, protecting naturalness, opportunities for solitude, 

and primitive recreation. 

Wildland Fire and Suppression 

During and immediately after fire events, access to WSA areas and enjoyment of opportunities for 

primitive recreation associated with them may be restricted or impaired. Full suppression of wildland fires 

in these areas may be implemented to control fire size and severity, protecting these opportunities.

Wildfire suppression activities could result in short-term impacts, including disturbance to soils, surfaces 

and groundwater, watershed functions, and vegetation conditions. Impacts would be minimized by postfire rehabilitation efforts. Appropriate management response within WSAs could limit the use of 

mechanical suppression activities or other techniques for reducing these impacts. Temporary disturbances 

may occur to resources and values; however, these effects would be short term while wilderness values 

are assessed on a long-term scale. 

Long-term impacts associated with the use of an appropriate management response to wildfire 

suppression, wildland fire use, and the planned actions of prescribed fire and non-fire fuel treatments on 

WSAs are the decreased risk of large severe wildfire events. With the removal of hazardous fuels, a trend 

increasing the preservation of naturalness and opportunities for primitive recreation would be in place. 

Because fire is a part of the natural environment, the WSAs’ natural character would not only be 

protected, but also likely enhanced.

Livestock Grazing 

Livestock grazing could have a perceived impact on wilderness character. Primitive recreational 

experiences could be impacted by the presence of livestock in a wilderness setting. Areas frequented by 
Wilderness Study Areas 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-127 

livestock, such as springs or water developments, could have a perceived unnatural appearance to some 

wilderness users. It is important to note that the steep canyon topography in many of the WSAs makes 

livestock access difficult in some areas. While recreational use is commonly concentrated in the canyons, 

livestock use is generally outside these areas, reducing potential impacts. 

Maintenance of range improvements allowed by the IMP could result in short-term impacts on solitude 

and naturalness; however, long-term impacts would not meet the non-impairment criteria. Using livestock 

grazing to enhance the ecosystem health and/or help accomplish resource objectives, such as noxious and 

invasive weed control and hazardous fuels reduction, could beneficially impact the naturalness of the 

wilderness area by reducing opportunities for noxious and invasive weed infestation and limiting the 

potential for severe fire damage. 

Changes in Vegetation (Vegetation Restoration, Habitat Manipulation, Fuels Treatments) 

Decisions associated with soil, water, fish and wildlife, livestock grazing, vegetation, wildland fire 

ecology, and special status species alternatives that result in direct changes to vegetation—whether 

intended to reduce soil erosion or restore ecological functions—may be implemented in WSAs, but could 

be limited to protect the wilderness characteristics. Site-specific treatment actions would go through 

environmental planning and review to analyze potential impacts on naturalness and opportunities for 

primitive recreation and solitude. There could be impacts on solitude from increased sights and sounds 

associated with the vegetation treatments and from the evidence of other people assisting in management 

activities. Depending on the magnitude and duration of the task, there could also be impacts on the natural 

character of the area associated with habitat management. Over the long term, vegetation and fuels 

treatments would help maintain the naturalness of WSAs by bringing the fire regime condition class to a 

point allowing fire to play its natural role in the ecosystem. Any proposals would be considered on a caseby-case basis and must enhance wilderness characteristics in order to be permitted. 

Summary 

Wilderness characteristics within WSAs would be protected under the Proposed RMP. There could be 

short-term loss of perceived naturalness and opportunities for primitive recreation due to OHV use along 

designated routes (inventoried ways) and in the Moquith Mountain sand dunes area, but there would be 

no long-term impacts. 

Under the Proposed RMP, there could be short-term impacts on opportunities for solitude from the 

increasing presence and numbers of encounters with other visitors to the WSAs, specifically those that 

border Zion National Park. There could also be long-term impacts from increasing non-motorized 

recreation use associated with camping in these areas. Under the Proposed RMP, these impacts would 

decrease due to limitations on group size associated with SRPs permitted in these areas, although 

increases in the number of groups could result in a continuation of the existing levels of impact. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources. No short-term uses would be 

permitted if they resulted in the long-term impairment of wilderness characteristics. Due to application of 

the non-impairment standard, there would be no unavoidable adverse impacts. 
Other Designations 

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4-128 Kanab RMP 

4.4.5 Impacts on Other Designations 

This section addresses impacts on other designations, including National and State Scenic Byways and 

Backways and the Old Spanish National Historic Trail. The Proposed RMP does not include a proposal 

for a BLM Backcountry Byway, which is the only byway or backway designation administered and 

managed by the BLM. Therefore, the only impact on byways and backways is associated with the BLM’s 

responsibility to coordinate with the various state and national organizations that designate and administer 

the byways and backways. The impacts of the decisions related to these byways and backways will be 

addressed in the cumulative impact analysis. 

The analysis is based on the following assumptions: 

• Existing development along the two segments of the Old Spanish National Historic Trail within 

the decision area has removed actual trail tread or associated sites. 

• Mineral development in the Old Spanish National Historic Trail corridor would be limited to 

mineral material sites (sand or gravel) or minor hard rock development. 

Under the Proposed RMP, impacts on other designations are not anticipated as a result of implementing 

management actions for the following resources, resource uses, and designations: air quality, soil 

resources, water resources, vegetation, special status species, fish and wildlife, wildland fire ecology, 

cultural resources, paleontological resources, forestry and woodland products, livestock grazing, 

recreation, lands and realty, ACECs, WSRs, wilderness, and WSAs. 

Proposed RMP 

Old Spanish National Historic Trail Management 

Due to the degree of existing development along the Highway 89/20-Garfield County segment (e.g., U.S. 

Highway 89, SR 20, private farms, and utility ROWs) and the lack of identified trail tread, impacts would 

largely be associated with highly visible developments within the corridor and viewshed beyond the 

current extent. Managing for VRM objectives would help to maintain the landscape associated with the 

Old Spanish Trial. 

Providing interpretive opportunities for both segments of the Old Spanish National Historic Trail would 

increase public appreciation for the trail’s values and significance in the region and in the Nation’s 

history. Increased public appreciation could lead to increased user stewardship, appreciation, and 

protection of the corridor. 

Coordinating management of the Old Spanish National Historic Trail with the National Park Service 

(NPS) and other BLM offices would assist in providing consistent management throughout its extent, 

preserving the values for which it was designated. 

Actions that Result in Visible Changes to the Trail Corridor 

Managing northern portions of the Highway 89/20-Garfield County segment as VRM Class II would 

maintain the existing landscape with minimal changes. While existing development has changed the 

landscape from its condition at the time of trail use, this management would maintain the portions of the 

corridor most similar to the historical conditions. Managing the visual resources in the southern portions 

of this segment’s corridor, which have been more altered by existing development and landscape 

alteration, as VRM Class III and IV would allow for continued changes to the landscape. Over the long 

term, this could affect the landscape associated with this portion of the trail. 
 Other Designations 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-129 

Managing the few parcels of public land along the Highway 89-Kane County segment as VRM Class IV 

could allow changes to the landscape. The level of current visual changes to this portion of the trail is 

consistent with this designation. 

Route designations surrounding both segments would maintain the existing character of the landscape 

without allowing extensive new routes. This would maintain the existing character of the landscape in 

these areas. 

VRM stipulations on the northern portion of the Highway 89/20-Garfield County segment in the decision 

area (VRM II) would reduce the potential impacts to the the existing character of the landscape. 

Summary 

Under the Proposed RMP, management would provide for consideration of the historic values present 

along the corridor and the subsequent developments that have occurred. In addition, the management 

actions provide for coordination and interpretative efforts to increase public appreciation for the trail’s 

values and significance in the region and Nation’s history. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There would be no irreversible and irretrievable commitment of resources associated with other 

designations. There will be no loss of long-term productivity or condition of other designations due to 

short-term uses proposed in the alternatives. None of the activities in this Proposed RMP/Final EIS will 

produce unavoidable adverse impacts on the other designations. 
Social and Economic 

Chapter 4 Proposed RMP and Final EIS 

4-130 Kanab RMP 

4.5 SOCIAL AND ECONOMIC

This section is subdivided into three general areas: 

• Impacts on social and economic conditions 

• Impacts on tribal interests 

• Impacts on public safety. 

4.5.1 Impacts on Social and Economic Conditions 

This section describes potential social and economic impacts from implementing the Proposed RMP. 

Such impacts may result from specific individual management actions, but also often reflect the collective 

effect of a number of actions under a particular alternative. Thus, this section presents impacts from the 

specific management actions of various resource programs and alternatives on the local economy, 

population, community services, public finance, and social customs and culture. Environmental justice, a 

BLM critical element, is also addressed. 

Potential economic impacts include changes in employment, income, business costs, and tax revenue to 

local, state and Federal Government entities. Changes in employment and income can then cause indirect 

socioeconomic impacts, such as changes in population, which can lead to community impacts on housing, 

infrastructure, and other government services. These economic impacts may then produce social impacts, 

such as changes in community structure as new people move in to take new jobs. Management of 

resources can have direct social impacts on residents and visitors, affecting livelihoods, lifestyles, 

attitudes, opinions, quality of life, and social structures. 

The socioeconomic impact analysis and conclusions are based on BLM knowledge of resource uses in the 

project area; review of existing literature; and information provided by BLM specialists, local and state 

cooperating entities, and industry contacts. Impacts are quantified where possible and described in 

qualitative terms in the absence of reliable quantitative data. The analysis of socioeconomic impacts is 

intended to capture the most notable, overall socioeconomic impacts under each alternative, and cannot 

address all potential impacts. 

Economic Impact Analysis Approach and Quantitative Results 

Economic impacts can be described qualitatively, and in certain cases where adequate data exists they can 

be quantified. Qualitative impact analysis involves identifying the most likely direction of change in 

economic conditions resulting from a particular management action or a set of management actions 

expected to have similar effects. For example, based on the type of action, a likely increase or decrease in 

production values or costs for certain producers may be identified, or an increase or decrease in tourist 

expenditures in the planning area may be deemed likely. These determinations are based on experience in 

the local area or other, similar areas and professional judgment. The results of all qualitative impact 

analyses are presented below for each alternative. 

Quantitative economic impact analysis requires that sufficient information exists to quantify current 

conditions or a change in the value of production or in costs or expenditures resulting from a specific 

management action or set of actions. Where sufficient data exists, these changes in value or costs can then 

be analyzed with an economic model to estimate likely changes in employment and income. In other 

cases, employment and income effects cannot be quantified, but the basic data on costs and values can be 

presented. 
Social and Economic 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-131 

This section details the approach used for each quantitative economic impact analysis. Descriptions of the 

approach and relevant data are presented first for each sector for which quantification of employment and 

income impacts was possible. Next, the approach for additional sectors for which a simple cost and value 

analysis was possible is presented. Then the quantitative results are presented. It is most efficient to 

present the quantitative results together with the methodology discussion and to provide tables showing 

quantitative results in one section so that differences between the alternatives can easily be seen. 

Employment and income impacts are estimated in this study with the IMPLAN computer model 

(IMPLAN version 2.0.1025). IMPLAN is a regional economic impact model that provides a mathematical 

accounting of the flow of dollars and commodities through a region’s economy. The region, or 

socioeconomic study area, for economic impacts in this study is Garfield and Kane counties. 

The IMPLAN model requires inputs of impacts on an industry or industries in the study area in terms of 

changes in the value of production or expenditures. These changes in value or cost require data and 

assumptions specific to the study area. Information from various sources regarding current management 

strategies and uses and how these uses may change under each alternative provides physical, quantitative 

measures of impacts (e.g., tons of coal produced, number of gas wells drilled and completed, and AUMs). 

Information from various other sources provides unit values and unit costs. Table 4-14 summarizes the 

primary data and sources used to estimate value and cost inputs for the IMPLAN model for those resource 

uses for which quantification of employment and income impacts is possible. 

Table 4-14. Data Types and Sources for Sectors for Which Quantification of Employment 

and Income Impacts Is Possible 

Resource Use Required Data Data Sources 

Oil and Gas Drilling and 

Production 

• Number of wells to be drilled 

• Success ratios 

• Drilling and completion costs 

• Production costs 

• Expected proportion of costs incurred 

locally 

• Utah Geological Survey 

• U.S. Department of Energy 

• Interviews with Utah oil and 

gas companies 

• BLM, including RFD scenario 

• Kanab Draft RMP/EIS 

Alternatives 

Coal • Historical and forecasted prices 

• Projected tonnage per year 

• Utah Geological Survey 

• U.S. Department of Energy 

• Interviews with Utah coal 

companies 

• BLM, including RFD scenario 

• Kanab Draft RMP/EIS 

alternatives 

Grazing 

• Historical allocated AUMs for livestock 

within the decision area 

• Historical livestock prices 

• Allocated AUMs under each Draft 

RMP/EIS alternative 

• BLM 

• Utah agriculture statistics 

• Kanab Draft RMP/EIS 

alternatives 

For each resource use, future economic activity is dependent on a variety of factors beyond the control of 

the BLM. For instance, the extent, pace, and timing of energy development activities depend on national 

and international energy demand and prices, production factors within each industry, and business 

strategies of operators. Because the pace of energy development in the planning area is unknown, a 

constant rate of production is assumed in this analysis for coal production and oil and gas drilling and 
Social and Economic 

Chapter 4 Proposed RMP and Final EIS 

4-132 Kanab RMP 

production. Likewise, use of livestock AUMs is assumed to be constant throughout the study period based 

on the AUM allocations for each alternative. Actual economic impacts may vary if the rate of production 

in any of these industries changes over the study period. 

The specific approach to use of the data outlined in Table 4-14 is detailed below. This data is used to 

determine primary impacts, in terms of changes in the value of production or in expenditures. These 

primary impacts serve as the inputs into the IMPLAN model to analyze the total economic impact of each 

alternative. The total economic impact includes the following changes in income and employment: 

• Direct impacts are the employment and income directly supported by the industry in question 

(e.g., coal). 

• Indirect impacts are the employment and income generated by industries (e.g., trucking) that 

support the subject industry (e.g., coal). 

• Induced impacts are the employment and income generated as a result of household expenditures 

supported by income from the industry in question (e.g., spending of labor income from the coal 

industry). 

Employment figures in the results below represent total employment. IMPLAN does not distinguish 

between full-time and part-time jobs. 

Coal Production Economic Impact Analysis Methodology 

Based on the RFD, the production of coal is expected to commence within the life of the RMP. A coal 

company is taking necessary actions to begin coal mining activity on the Alton coal field. Once initiated, 

coal mining is expected to continue for many years in the future. The Alton coal field falls partially within 

the RMP/EIS decision area and is addressed in Chapter 2 and in the unsuitability report (Appendix 6). 

According to the RFD, coal production is expected to begin on private mineral-owned lands and then 

transition to the adjacent decision area lands. 

According to the RFD, a coal company plans to mine at least 40 million tons of coal. For the purposes of 

the economic impact analysis, it was assumed that this amount will be mined over 20 years, at a constant 

rate of 2.0 million tons per year, beginning in 2010. Based on the private-to-federal landownership ratio 

for the mine stated in the RFD (570 acres and 1,430 acres, respectively), it was assumed that mining from 

the decision area federal mineral estate will begin in 2010, with 1.43 million tons mined from the decision 

area annually. The economic impact of additional coal production from private land, 0.57 million tons per 

year, is addressed in the cumulative impacts section. 

The value of coal production within the decision area was estimated by applying an annual price forecast 

per short ton to the annual production rates stated above. The average forecasted price was obtained from 

the U.S. Energy Information Administration (2006) and represents the average forecasted minemouth 

price for the United States over the period 2003 through 2030. Table 4-15 summarizes the production and 

price assumptions for coal mining over the 20-year time period. The economic contribution of this 

activity in terms of jobs and earnings was estimated by running the forecasted value of coal production 

through IMPLAN Sector 20, Coal Mining for Garfield and Kane counties, which constitute the 

socioeconomic study area.1 An economic profile of this sector based on IMPLAN data for Emery and 

 

1 IMPLAN allows impacts on be estimated in two ways. First, if the total value of output is known or estimated, this value can 

be run through IMPLAN in the specific industry being evaluated. For instance, the economic contribution of the coal 

industry to Garfield and Kane counties can be estimated by running the total value of production through IMPLAN Sector 

20, Coal Mining. Economic contributions can also be estimated using IMPLAN by examining the direct expenditures needed 

to produce a good or service. This approach is used to estimate impacts of oil and gas development on Garfield and Kane 

counties. 
Social and Economic 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-133 

Carbon counties was used as a proxy for the socioeconomic study area’s coal mining industry because the 

industry does not yet exist within this area. 

BLM management decisions under each alternative are not expected to alter potential coal production 

levels. Thus, the expected socioeconomic impacts associated with coal production are expected to be the 

same under each alternative as described below. 

Table 4-15. Annual Coal Mining Value of Production from Federal Mineral Estate 

Year 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 

Federal 

Production 

(1,000 

Short 

Tons) 

1,430 1,430 1,430 1,430 1,430 1,430 1,430 1,430 1,430 1,430 

Average 

Minemouth 

Price 

(2006$s) 

20.84 20.63 20.42 20.37 20.34 20.44 20.83 21.19 22.41 22.89 

Value of 

Production 

(1,000$) 

$29,807 $29,508 $29,195 $29,126 $29,086 $29,229 $29,792 $30,300 $32,044 $32,727 

Year 2020 2021 2022 2023 2024 2025 2026 2027 2028 2029 

Federal 

Production 

(1,000 

Short 

Tons) 

1,430 1,430 1,430 1,430 1,430 1,430 1,430 1,430 1,430 1,430 

Average 

Minemouth 

Price 

(2006$s) 

23.89 24.08 24.72 25.71 26.39 27.65 28.31 28.88 29.37 29.61 

Value of 

Production 

(1,000$) 

$34,167 $34,430 $35,353 $36,771 $37,733 $39,537 $40,488 $41,291 $41,993 $42,349 

Oil and Gas Drilling and Production Economic Impact Analysis Methodology 

The economic impact of oil and gas operations was analyzed in two phases: 

• Phase I: Exploration and Development 

• Phase II: Production. 

Phase I considered how many exploratory and development wells would be drilled in the decision area 

and how many would be completed as producing wells. The average number of wells expected to be 

drilled within the decision area was taken from the RFD. While the RFD figure encompasses the entire 

planning area, insufficient information exists to allocate the RFD wells to planning area lands versus other 

lands. It was assumed that all wells predicted in the RFD are on decision area land. This assumption is 

consistent with RMP/EIS oil and gas assumptions for other resources and resource uses. This is an 

appropriate approach when the level of activity in a sector is relatively small. This assumption results in 

an analysis that indicates the maximum potential economic contribution to the local economy of oil and 
Social and Economic 

Chapter 4 Proposed RMP and Final EIS 

4-134 Kanab RMP 

gas activity on decision area lands. This maximum contribution can then be compared to the contribution 

of other sectors to assist in understanding the relative impacts. A number of additional assumptions were 

necessary for this analysis; they are summarized in Table 4-16. 

Table 4-16. Assumptions for Fluid Minerals Economic Impact Analysis (in 2005 Dollars) 

Item Assumption/Estimate Source 

Number of wells drilled 

per year 

4.5 Appendix 15, RFD Table 15-1 figures of 90 total wells 

divided by 20-year period 

Number of wells entering 

production per year* 1 Appendix 15, RFD Table 15-1 figures of 20 production wells divided by 20-year period 

Type of wells: 

 Oil 

 Conventional Gas 

Not germane 

A breakdown by type of well is not necessary because 

the costs of drilling and completion for both types are 

estimated to be the same. 

Average cost of drilling 

and completion to 

producing well: 

 Oil 

 Conventional Gas 

$2.25 million 

$2.25 million 

BLM State Office mineral staff, based on costs in recent 

“Paying Well Determination” submittals for wells similar 

to those expected in the Kanab RMP/EIS decision area. 

Average cost of drilling 

and completion to dry 

hole: 

 Oil 

 Conventional Gas 

$1.35 million 

$1.35 million 

BLM State Office mineral staff professional judgment. 

Average annual 

operating costs: 

 Oil 

 Conventional Gas 

$60,000 

$60,000 

BLM State Office mineral staff, based on costs in recent 

“Paying Well Determination” submittals for wells similar 

to those expected in the decision area. 

Note: * Development of the 20 expected production wells likely would occur in a single field, developed within a few-year span.

However, there is no way of knowing when and where the oil and gas development will happen. For analysis purposes 

the development is spread out annually, at one well per year, to estimate economic impacts. 

With regard to Phase I, the assumptions result in figures of $6.975 million for annual oil and gas well 

drilling and completion costs. Not all of these expenditures benefit the socioeconomic study area because 

the oil and gas industry within the socioeconomic study area is quite small due to the low level of 

development that has occurred in this area. It was therefore assumed for this analysis that all the drilling 

operators would originate from areas outside the study area. Investment in oil and gas drilling would have 

less of an economic impact on the area because most of the direct expenditures (labor costs in particular) 

would not be recirculated back into the local economy. However, some businesses that would support 

drilling activities indirectly are located in the study area; for example, water hauling is used by the drilling 

crews. A study of impacts of gas drilling in Carbon and Emery counties concluded that only 40 percent of 

the direct expenditures for new wells would occur locally (Utah Department of Natural Resources 1995). 

The same assumption was used for oil and gas exploration and development activities in the decision 

area. Therefore, 40 percent of the drilling and completion costs were run through IMPLAN Sector 28, 

Support for Oil and Gas Activities, to estimate employment and income impacts of this potential activity. 

An economic profile of this sector based on IMPLAN data for Emery and Carbon counties was used as a 

proxy for the socioeconomic study area’s oil and gas support activities industry because the drilling 

industry has not been active in the area since before the data for the IMPLAN model was compiled. 

The impacts associated with oil and gas production were estimated under Phase II. Here, the annual direct 

expenditures needed to operate each completed oil and gas well, as summarized in Table 4-16, were used 
Social and Economic 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-135 

to estimate employment and income impacts. These expenditures were assumed to be 100 percent local. 

This assumption would overestimate the impacts associated with oil and gas production if some of these 

expenditures are actually made outside of the local planning area. The annual economic contribution of 

this activity was estimated by running the annual direct expenditures for well operations through 

IMPLAN Sector 19, Oil and Gas Extraction, for counties within the socioeconomic study area. The 

annual amount and impact of these expenditures would grow throughout the planning period as more and 

more successful wells come into production each year. 

Insufficient information exists in the Draft RMP/EIS alternatives to quantitatively differentiate drilling 

and production levels by alternative. 

Livestock Grazing Economic Impact Analysis Methodology 

Historical data on domestic livestock forage active use (see Chapter 3) and varying management policies 

by alternative were used to estimate future livestock use under each alternative, as summarized in Table 

4-17. The estimates summarized in this table represent two approaches to projecting the AUMs that 

would be used by permittees on an annual basis. Permitted use under the Proposed RMP would be greater 

than 18,000 AUMs. However, in recent years the active use (paid for in each year) of grazing allocations 

has been considerably less than permitted use. In the 2000 to 2006 period, on average 7,731 AUMs were 

active of 18,241 permitted, or 42.4 percent. This active use of 42.4 percent is due to a severe drought 

during 1999–2004. This rate of active use is likely to be lower than future active use as the region comes 

out of the drought—and active use in 2005 and 2006 did show an upward trend. Evaluating average active 

use and total permitted use, which is the maximum use under current permitted AUMs, provides a range 

that brackets likely future use. Thus the estimated future active use under each alternative is assumed to 

be between the average active use (42.4 percent) and the total permitted use. Given that grazing of sheep 

and horses is currently minimal in the planning area and that use is not expected to change over the next 

20 years, economic impacts from these activities were not quantified. 

Table 4-17. Livestock Use per Alternative (AUMs) 

Proposed RMP 

Total Permitted Use 18,193 

Conversion Factor to Current Active Use 42.4% 

Current Active Use 7,710 

Over the past 10 years, less than 2 percent of active AUMs have been used for sheep and horses (Table 3-

25). For the purposes of this analysis, it is assumed that all AUMs would be used for cattle grazing, which 

produces higher value per AUM than sheep grazing. 

The value of cattle grazing per AUM was estimated as summarized in Table 4-18. Data was obtained 

from the Utah Agricultural Statistical Service, as shown in columns 2 and 3, and includes the value of 

cattle sold in Utah from 2000 through 2004. Total cattle sales were divided by the number of cows that 

had calved, which provided a value per cow sold, as summarized in column 4. The value per cow was 

then divided by an AUM conversion factor, resulting in an estimated value per AUM in nominal dollars. 

An inflation factor was used to convert nominal dollars to real dollars (2006) as summarized in column 7. 

Using this method, the average value of cattle AUMs in Utah from 2000 through 2004 was estimated to 

be $48.82. 
Social and Economic 

Chapter 4 Proposed RMP and Final EIS 

4-136 Kanab RMP 

Table 4-18. Estimated Value of Cattle AUMs 

Year 

Value of 

Production 

(1,000$s)a

Cows That 

Have Calved 

(1,000 Head)a

Value Per 

Cow 

Conversion to 

AUMs 

(AUMs/Cow)b

Value of 

Production 

per AUM 

Nominal $s 

Value of 

Production 

per AUM 

Real 2006$s 

2000 $296,585 450 $659.08 16 $41.19 $47.27 

2001 $314,868 450 $699.71 16 $43.73 $49.03 

2002 $284,580 450 $632.40 16 $39.53 $43.48 

2003 $323,040 430 $751.26 16 $46.95 $50.65 

2004 $358,715 440 $815.26 16 $50.95 $53.68 

5-year average $48.82 

Notes: 

a

 Utah Agricultural Statistics 

b (Workman 1986) 

The total estimated range of values of livestock production for each alternative was then estimated by 

multiplying the average value per AUM by the estimated number of total permitted AUMS and current 

active AUMs to get the range of total current value of production from grazing allocations on BLM lands 

within the planning area. The results are summarized in Table 4-19. 

Table 4-19. Estimated Value of Livestock Production per Year 

Proposed RMP 

Value of Total Permitted Use $888,161

Value of Current Active Use $376,404

The economic contribution of this activity in terms of jobs and income was estimated by running the 

value of grazing activities—under current active use and total permitted use scenarios—through IMPLAN 

Sector 11, Cattle Ranching and Farming, for Garfield and Kane counties. 

Other Sectors 

Some sectors have sufficient data to allow quantification of basic costs and market values, but insufficient 

data to allow quantification of employment and income impacts. These sectors are: 

• Vegetation—plants and seeds. Insufficient data (e.g., species and size) is available for plants, but 

costs and values of seeds can be calculated. 

• Woodland products—fuelwood, posts, and Christmas trees. 

For these sectors, basic data was collected on quantities harvested, costs charged by the BLM, and 

approximate values in the local market. This data allowed calculation of (a) total costs paid to the BLM, 

(b) total value in the local market, and (c) total savings, defined as total market value minus total cost. 

Employment and income impacts could not be calculated because IMPLAN does not have economic 

sectors that are specific enough to these products. However, given the relatively small values shown 

below, employment and income generated by these harvests are small compared to the other sectors 

discussed above. 
Social and Economic 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-137 

There were sectors for which quantification of economic impacts might be expected but was not possible. 

For these sectors (Table 4-20), qualitative description of economic impacts is provided under each 

alternative if there are any economically discernable differences in the alternatives. 

Table 4-20. Sectors for Which Quantification of Economic Impacts Is Not Possible 

Use Reason(s) Impacts Cannot Be Quantified 

Locatable minerals; 

specifically, septarian 

concretions and 

gypsum 

The RFD indicates limited development will occur. However, there is insufficient 

information on quantities expected to be mined. 

Salable minerals; 

specifically, sand and 

gravel, stone, and clay 

The RFD indicates sand and gravel and stone development is expected, and limited 

clay development will occur. However, there is insufficient information on quantities 

expected to be mined. 

All other minerals According to the RFD, no exploration or development of other minerals is expected. 

Lands and realty 

There is insufficient information on actions that would occur or would be precluded to 

allow quantification of economic impacts. Parcel-specific information, including 

projected sales prices and rental rates, would be required. 

Recreation; 

transportation (OHV 

use) 

Recreation Management Information System (RMIS) data from Chapter 3 is not 

considered accurate enough to allow for credible estimates of economic impacts. In 

other cases (e.g., OHV registrations), there is insufficient information to attribute use 

specifically to decision area lands, or insufficient information (e.g., recreation permit 

data) on expenditures of recreators for specific uses in the decision area or similar 

areas. 

Fiscal impacts are a separate category of impacts from those addressed by the IMPLAN model. Fiscal 

impact analysis is highly data intensive and depends on very specific assumptions. Currently, there is 

insufficient data to accomplish quantitative fiscal impact analysis of the alternatives. However, some 

qualitative comments on fiscal impacts are possible and are included by alternative below. 

Results: Impacts on Regional Employment and Income 

The total economic impacts from coal mining, oil and gas drilling and production, and livestock grazing 

from activities directly attributable to decision area lands were estimated using IMPLAN and the total 

value of expenditures or production developed from the data and assumptions discussed above. Table 

4-21 provides the results for employment (full- and part-time jobs) and labor income on an annual basis. 

The coal mining, oil and gas production, and livestock production figures are given as ranges. For coal, 

this is because the forecasted selling price rises each year. For oil and gas production, operating 

expenditures will increase as more wells come online over the 20-year RFD planning period. For 

livestock production, the range indicates the economic impacts under recent rates of active AUM use and 

the impacts if full permitted AUM use should occur. In the case of oil and gas exploration and 

development, due to the conservative assumptions of the analysis, the figures in Table 4-21 are the 

maximum potential economic benefits; the benefits specifically attributable to decision area lands could 

be less. 

For all resource uses in Table 4-21 except livestock grazing, the IMPLAN analysis was based on the 

current management situation because insufficient information is available to allow quantification of 

economic differences between the alternatives. In the case of livestock grazing, the alternatives include 

differences in the number of AUMs allocated to livestock. However, the resulting differences in the value 

of production, when run through the IMPLAN model, produced differences for employment of less than 
Social and Economic 

Chapter 4 Proposed RMP and Final EIS 

4-138 Kanab RMP 

one job and differences in labor income of only a few hundred dollars for current active AUMs and total 

permitted AUMs—in both cases within the margin of error of any economic model and within the 

rounding margin for reporting of results. Therefore, the quantifiable economic impacts of the grazing 

alternatives are deemed identical. 

The lack of quantifiable differences in economic impacts in Table 4-21 does not mean that differences 

would not occur. Some differences are simply not quantifiable given the available data. The most 

important potential variations in economic activity between the alternatives are noted in the narratives 

below for each alternative. 

It is very important to note that BLM public lands generate additional jobs and income that is not shown 

in Table 4-21. The economic contributions of a number of uses of BLM lands could not be quantified. In 

particular, recreational activities (including OHV-based recreation) no doubt generate substantial 

employment and income. The other activities discussed in Table 4-20 make smaller, but important, 

economic contributions. 

Employment and income generated by activities associated with the BLM lands in this Proposed 

RMP/Final EIS are a small percentage of total employment and personal income in the two-county 

socioeconomic study area. IMPLAN reports that total employment in the study area exceeded 7,300 while 

income topped $239 million in 2003. 

Table 4-21. Annual Employment and Income (in 2006 Dollars) Generated in the 

Socioeconomic Study Area from Use of BLM Lands Under RMP/EIS Alternatives 

Average Annual Employment Average Annual 

Labor Income Sector 

Direct Indirect/ 

Induced Direct Indirect/ Induced 

Coal Mining* 125 to 178 42 to 59 $9,483,000 to 

$13,473,000 

$1,389,000 to 

$1,973,000 

Oil and Gas Drilling* 9 3 $774,000 $85,000 

Oil and Gas Production* <1 to 6 <1 to 1 $9,000 to $173,000 $2,000 to $38,000 

Livestock Production** 8 to 18 3 to 8 $19,000 to $44,000 $37,000 to 

$88,000 

Notes: 

*Estimates are based on the current management situation. Insufficient information is available to quantify differences between

the current management situation and the Proposed RMP. Ranges in the values for coal mining reflect increases in the 

value (price) of coal over the study period, and the ranges for oil and gas production reflect more production wells coming 

online during the study period. 

**Differences in AUMs and resulting value of production by alternative were calculated; however, the resulting differences in 

employment and income were not significant and were within the rounding margin. The range in employment and income 

reflects current active use (low value) and full permitted use (high value). 

Source: IMPLAN model, based on data and assumptions for production from BLM lands as detailed in the text. 

Results: Basic Cost and Value Analysis 

Table 3-7 of the Draft RMP/EIS provides quantities of seeds collected from decision area lands. Table 3-

23 of the Draft RMP/EIS provides quantities of fuelwood, posts, and Christmas trees collected. This data 

allows a basic analysis of costs and values, as shown in Table 4-22. 
Social and Economic 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-139 

Table 4-22. Costs and Values of Harvests from BLM Public Lands 

Product 

Average 

Harvest, 

2001–

2006a

BLM 

Charge 

per Unitb

Market 

Value per 

Unitc

Total Cost 

to 

Harvester/ 

Revenue 

to BLM 

Total 

Market 

Value 

Total 

Savings 

to 

Harvester 

Total 

Savings 

at Highest 

Harvestd

Sagebrush 

seeds 

(pounds) 

200 $0.34 $4 $67 $800 $733 $733 

Four-wing 

Saltbush 

seeds 

(pounds) 

300 $0.15 $4 $45 $1,200 $1,155 $1,155 

Winterfat 

seeds 

(pounds) 

10 $0.30 $8 $3 $80 $77 $77 

Fuelwood 

(cords) 501 $5.00 $100 $2,504 $50,083 $47,579 $56,810 

Posts 

(number) 3,527 $0.40 $5 $1,411 $17,636 $16,225 $22,563 

Christmas 

trees 

(number) 

119 $5.00 $40 $597 $4,773 $4,177 $5,215 

a

 Seed figures were available only for 2006. b

 Seed charges are from BLM Utah State Office IM No. UT 2003-080, Seed Collection Policy and Pricing, July 31, 2003. Other 

charges are from Kanab Field Office personnel. c

 Market values for seeds are typical “dirt weight” prices paid to harvesters (not retail prices) from Granite Seed Company, Lehi, 

Utah, per April 2007 interview. Other values are from Kanab Field Office personnel. d

 Values in this column are based on the highest harvest level in the available data. 

The figures in Table 4-22 for the total savings to the harvester represent different types of value, 

depending on the product and the harvester. In the case of seeds, which are largely harvested for resale to 

retail seed companies, the total savings represents the revenue from which a commercial seed harvester 

can pay wages and other costs and take profits. For fuelwood, posts, and Christmas trees, the total savings 

represent either the same type of revenue pool, such as for commercial operators who resell the products, 

or, for individuals and families who harvest these products for their own use, represent money they save 

by harvesting from BLM public lands. These savings allow them to spend this portion of their income on 

other needs. 

Social Impact Analysis Approach 

Along with fish, wildlife, vegetation, and the physical environment, people are an integral part of 

ecosystems. Livelihoods, lifestyles, attitudes, beliefs, values, social structure, culture, and population 

characteristics affect and are affected by management actions such as those made by the BLM. In 

addition, BLM lands and BLM management of these lands have emotional meanings to many people. 

As discussed in the socioeconomic conditions section in Chapter 3, there are a number of broad but 

distinct types of use of and interests in BLM land. These categories reflect the different linkages people 

have to the land. They are characterized by distinct sets of values, opinions, and perceptions about BLM 

lands and the effects of various land management policies and actions. The interest categories, as defined 

in Section 3.5.1, are: 
Social and Economic 

Chapter 4 Proposed RMP and Final EIS 

4-140 Kanab RMP 

• Local traditional use 

• Motorized recreation 

• Non-motorized recreation 

• Outfitter-based recreation 

• Livestock grazing 

• Natural resource development 

• Preservation. 

The social impact analysis in this Proposed RMP/Final EIS uses these categories of interest to 

differentiate impacts of management actions under each alternative. The analysis is written in terms of 

impacts on individuals or groups that have interests in each specific category. This is not meant to imply 

that all individuals and social groups fit neatly into a single category; many specific individuals or 

organizations may have multiple interests and would see themselves reflected in more than one category. 

Nonetheless, these categories provide a useful way of organizing the discussion of social impacts. The 

social impact analysis is qualitative and based on knowledge of resource uses and social patterns and 

conditions in the socioeconomic study area. 

Proposed RMP 

Economic Impacts 

Certain activities within the planning area are now occurring, or are expected to commence, and are 

expected to continue in the future. The activities that are expected to have the greatest impacts on the 

regional economy include coal production, oil and gas exploration and production, livestock grazing, and 

recreation and tourism. The economic impacts that are expected from the Proposed RMP are as follows: 

• Direct economic benefits to the socioeconomic study area would accrue from BLM-influenced 

activities such as coal production, oil and gas development, livestock grazing, and recreation and 

tourism. 

• Various industries in the regional economy would continue to be indirectly affected by activities 

within the planning area, including retail establishments and services that benefit from 

expenditures of labor income generated by resource uses on BLM public lands. 

• Tax and other revenues derived from activities on BLM-administered lands would continue to 

have fiscal implications for the Federal Government, the State of Utah, and communities near the 

planning area. 

• BLM KFO budgets will provide inputs to the local economy. Payroll for field office employees 

and material purchases and contracts for restoration and rehabilitation of public lands (e.g., 

vegetation treatments to achieve vegetation and range management goals and Desired Wildland 

Fire Conditions) represent inflows of money to the socioeconomic study area. 

• Economic benefits from development of locatable minerals are expected to be low. Excepting 

septarian nodules and alabaster, there is low potential for locatable minerals in the decision area, 

and the Proposed RMP is not expected to affect development. 

• Economic benefits from sand and gravel and stone development are expected to increase over the 

planning period. Exclusions from mineral material disposal will have little impact on these 

economic contributions because ample sites for development are available under the Proposed 

RMP. Economic benefits will include jobs and income from production and sale of mineral 

materials, and cost savings to local governments and other entities resulting from avoidance of 

transport or purchase of mineral materials from more distant locations. 

• Commercial timber harvesting has not occurred in recent years on decision area lands and is not 

expected to occur under any of the alternatives. 
Social and Economic 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-141 

• Population growth would continue regardless of BLM management actions, and this growth, not 

activities on BLM lands, would drive most of the economic changes expected to occur in the 

socioeconomic study area over the planning period. 

• Designations of ACECs, wilderness areas, WSRs, and other designations would produce 

“designation effects” that draw non-local visitors to the socioeconomic study area, resulting in 

monetary inflows to the area through expenditures in local establishments. The economic impacts 

due to these effects are encompassed within the discussions below related to specific resource 

uses. 

Impacts on Population 

Any population change that could be associated with implementation of the Proposed RMP in the 

Proposed RMP/Final EIS likely would be linked to employment changes. The most notable employment 

change expected under the Proposed RMP/Final EIS would derive from the initiation of coal mining in 

the decision area. Coal development could produce approximately 237 new jobs in the planning area by 

the end of the planning period. This is a large amount of jobs compared to the population base of the area 

near the proposed mine. It is unlikely these jobs would all be absorbed by the existing population of the 

nearest communities—Census 2000 total populations were 134 in Alton, 355 in Glendale, 596 in 

Orderville, and 127 in Hatch—or by the population growth through the planning period that would be 

expected in these communities without the mine. Some of the jobs might be also be absorbed by the 

existing and growing—but more distant—populations of Kanab and Panguitch (3,596 and 1,623 in 2000, 

respectively). Nonetheless, it appears likely that the proposed mine would result in some population 

growth above and beyond the growth expected in the socioeconomic study area without the mine, 

particularly in the communities closest to the proposed mine. Detailed characterization of possible 

population changes is beyond the scope of the Proposed RMP/Final EIS, but would be addressed in an 

EIS that would be required for the proposed coal mine. 

Other employment changes due to Proposed RMP/Final EIS decisions would not result in notable 

population changes. New oil and gas development and production expected under the Proposed RMP 

would produce at most 19 jobs. Some differences between the alternatives in management actions with 

respect to recreation, transportation (OHV use), and grazing could result in variations in employment. 

These variations cannot be quantified given available information. However, these variations would be 

small in relation to the overall employment supported by these resource uses under the Proposed RMP 

because substantial recreation, OHV, and grazing activity would occur. 

Impacts on Community Services 

The Proposed RMP decisions could cause impacts on local government services in various ways. For 

example, changes in demand for local government services could vary with changes in population tied to 

management actions. As discussed above, with the exception of coal development, notable population 

changes are not expected. The level of coal development and production expected under the Proposed 

RMP would lead to an increase in employment that would probably result in population increases. These 

increases could be locally significant, resulting in new demands on community services. For example, 

demands on schools and utilities in the communities closest to the proposed coal mine could increase. It is 

not clear whether existing infrastructure in these communities could absorb these increased demands. 

Management actions could also affect local government services directly. For example, the proposed coal 

mine would increase road maintenance and traffic control requirements on nearby roads and highways 

due to increased employee and heavy truck traffic. Detailed characterization of possible direct and 

indirect community services impacts is beyond the scope of the RMP, but would be addressed in an EIS 
Social and Economic 

Chapter 4 Proposed RMP and Final EIS 

4-142 Kanab RMP 

that would be required for the proposed coal mine. Specific actions to mitigate community service 

impacts of the coal mine would be determined in the coal mine EIS. 

Other activities supported by the Proposed RMP management decisions have implications for community 

services. For example, increased recreational use of decision area lands (including OHV use), which is 

likely to occur due to regional and national trends, would increase the demand for local government 

services associated with safety, emergency services, and police protection. While local search and rescue 

operations use volunteers, there would be a growing need for training, equipment, and resources. In 

addition, these operations must be supported by the Sheriff’s Office in each county. Road maintenance 

and traffic control requirements might also increase with the increased recreational demand expected. The 

types of community service impacts noted here could be mitigated through cooperation between the 

BLM, other local federal and state agencies, and local governments to establish efficient means for 

providing the necessary services. 

Increased government services also may be needed to support oil and gas development and production. 

This could include emergency and safety services and road maintenance. However, oil and gas 

development is very limited compared to major oil and gas producing areas in other parts of the western 

United States. Any community service impacts would be limited and could be mitigated through 

cooperation between the BLM and local governments to efficiently provide necessary services. 

Impacts on Public Finance 

Management decisions under the Proposed RMP could affect various revenues collected by the federal, 

state, and various local governments. The Socioeconomic Baseline Report (BLM 2005b) details a variety 

of revenue sources that are tied to or related to natural resource management on BLM lands. 

The largest revenue changes expected under the RMP would stem from new coal mining activity. The 

Federal Government would collect substantial new mineral rents, royalties, and possibly bonuses from the 

coal mine operator. Fifty percent of these revenues would be retained by the Federal Government, and 50 

percent forwarded to the State of Utah. The state would provide some of these revenues to local 

governments through a variety of funds, only one of which is directly proportional to the mineral 

revenues produced by each county. The state would probably obtain some new income tax revenue from 

the coal mine operator. The state has no severance tax on coal. Local governments likely would obtain 

some new natural resource property tax revenues from the coal mine. They cannot be quantified given 

currently available information, and it cannot currently be determined if new state and local government 

revenues would offset the financial requirements of any increased demands on community services. Such 

fiscal impacts should be examined in an EIS that would be required for the proposed coal mine. 

Oil and gas production expected under the Proposed RMP would produce some new federal and state 

mineral revenues, and the state would in turn provide some oil and gas revenues to the counties of origin. 

The state also would obtain new revenues from its oil and gas severance tax, oil and gas conservation fee, 

and income taxes. Local governments would obtain new revenues from associated natural resource 

property taxes. Because the amount of oil production is unknown these impacts cannot be quantified. 

Under the Proposed RMP, the BLM would collect revenues through ROW rents, recreation fees, grazing 

fees, mineral material fees, and other permit fees. Some of these fees would be forwarded to the federal 

treasury; others would be returned to state and local governments and local grazing boards or retained and 

used by the KFO. 

The Proposed RMP management actions are expected to continue to generate local sales and lodging tax 

revenues through expenditures of visitors in local establishments. These revenues would increase through 
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Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-143 

the planning period as visitation increases due to regional and national trends and management actions 

that increase the attractiveness of the decision area to non-local visitors. 

Land tenure adjustments under the BLM lands and realty program could potentially impact local 

government finances. Disposal of BLM lands to private ownership may reduce Payments in Lieu of Taxes 

(PILT) by the Federal Government to local government, but also would result in payments of property 

taxes to local government by the new private property owners. Land exchanges to other governments may 

also impact PILT payments. Acquisition of private land by the BLM would reduce property taxes paid to 

local government but would increase PILT payments. 

Social Impacts 

A number of social impacts could occur: 

• Activities and resources available in and around the planning area would continue to be important 

to the quality of life of current and future residents and visitors. 

• Management of BLM lands within the decision area has and will continue to have important 

social implications for many individuals and groups. This includes local residents that depend on 

development activities on BLM lands as a source of employment, income, or subsistence. Others 

are tied to the public lands for natural beauty, open space, recreational activities, and general 

ecosystem health. 

• Livestock grazing tied to the planning area would continue to have social and cultural importance 

in the study area. Challenges to continuation of these traditions would continue regardless of 

BLM management decisions, due to broader trends in the economics of grazing, intergenerational transfer of grazing operations, and other considerations. 

• Conflicts between resource users would continue. 

• The Proposed RMP would not significantly impact local residents’ “Sunday drive” enjoyment of 

BLM lands or other casual, dispersed uses not involving OHVs or harvesting of products off of 

BLM land. 

• The population increases resulting from a new coal mining operation are likely to result in social 

changes as people move to the socioeconomic study area to take some of the coal mine and 

supporting jobs. Some of these new residents likely would have values and preferences that differ 

from existing residents. The number of new jobs and new residents due to the coal mine is fairly 

small compared to overall socioeconomic study area figures, but could be locally significant. 

• WSAs would continue to be managed for potential designation under the Proposed RMP, thus 

maintaining values in these areas related to resource preservation and possibly foregoing values 

related to resource development until specific wilderness status decisions are made by Congress. 

Environmental Justice 

No environmental justice populations exist in the socioeconomic study area, based on federal criteria and 

the analysis in the Socioeconomic Baseline Report (BLM 2005b). Although not in the socioeconomic 

study area of Kane and Garfield counties, Utah, the Kaibab-Paiute Tribe reservation is adjacent to the 

planning area along the Utah-Arizona border. While the Kaibab-Paiute Tribe qualifies as an 

environmental justice population, no disproportionate adverse impacts to this area of higher density 

minority populations would occur from implementation of any of the management actions, resource 

programs, or objectives proposed under any of the alternatives. 
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Economic Impacts 

Vegetation—Plant and Seed Collection 

Continuation of plant and seed collection is permitted and likely under the Proposed RMP. Table 4-22 

shows the value of these practices to the BLM, in terms of the revenues received from fees charged to 

collectors, and to the collectors, in terms of the value they receive from seed companies that purchase the 

seeds. As shown in the table, these values are relatively small, totaling $115 in revenue to the BLM in 

2006 and $2,080 in market value or $1,965 in net value to the collectors. 

Coal Production 

Coal production on BLM-administered lands is considered likely under the Proposed RMP. Coal mining 

would directly support 125 jobs, increasing to 178 jobs in the local economy by the end of the planning 

period. Spending of income from these jobs is expected to generate additional economic activity in the 

local economy that would support, on average, 42 indirect and induced jobs, increasing to 59 indirect and 

induced jobs. Therefore, coal production on BLM-administered lands is expected to support up to 237 

total jobs. Coal production is also expected to generate more than $15.446 million in total annual earnings 

by the end of the planning period. Because changes in management described under each alternative are 

not expected to impact coal production (but may impact operational costs), the economic contributions 

estimated for coal are not expected to differ under any of the alternatives. 

Oil and Gas Drilling and Production 

Historically, the planning area has seen limited oil and gas exploration and very little development. 

Interest has recently increased with increased oil and gas prices. The RFD predicts 90 wells will be drilled 

in the planning area over the 20-year planning period. This is an average rate of about 4.5 wells per year. 

Using the data and assumptions outlined above, annual expenditures for oil and gas drilling attributable to 

decision area lands are expected to support at most nine direct jobs, three indirect and induced jobs, and 

$859,000 in labor income in the two-county socioeconomic study area. Additional, unquantifiable but 

very small numbers of jobs and income would be supported by geophysical survey activity. Expenditures 

on oil and gas production would support less than one job and $11,000 in labor income in the first year of 

the planning period, increasing to seven jobs and $211,000 in labor income in the last year. 

Although the total number of acres closed to fluid mineral leasing (79,000 acres) or open to leasing with 

major constraints (NSO) (83,400 acres) is greater than the current management situation, this likely would 

not have substantial effects on oil and gas development and production activity and resulting jobs and 

income because substantial high-potential areas would remain open with standard stipulations or 

moderate constraints such as seasonal limitations. Thus, the level of oil and gas development estimated in 

the RFD scenario would be achieved. Increased areas open to oil and gas leasing subject to moderate and 

major constraints under the Proposed RMP could increase the costs of oil and gas development 

somewhat. 

Livestock Grazing 

Grazing use of BLM lands would continue to provide jobs and income in the socioeconomic study area. 

Levels of grazing likely would be between current active use (which reflects recent drought conditions) 

and total permitted use. Based on the annual value of production from current active use of BLM grazing 

AUMs and the IMPLAN model, employment directly supported by livestock grazing on BLM lands for 

current active use is estimated to be eight full- or part-time jobs, with another three jobs from indirect and 

induced effects in the local economy. Employment directly supported by livestock grazing on BLM lands 

for total permitted use is estimated to be 18 full- or part-time jobs, with another eight jobs from indirect 

and induced effects in the local economy. Livestock production attributable to BLM land from current 

active use would result in $19,000 in direct labor income per year and another $37,000 in indirect and 
Social and Economic 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-145 

induced income, while livestock production attributable to BLM land from total permitted use would 

result in $44,000 in direct labor income per year and another $88,000 in indirect and induced income. 

Under the Proposed RMP, livestock grazing could be discontinued after voluntary relinquishment of all or 

part of a grazing preference. This could result in some foregone opportunities for other ranchers and a 

small decrease in jobs and income due to discontinuation of grazing on the specific relinquished 

preference. However, the economics of grazing may be improved and sustained, because grazing systems 

and range improvements would be designed to achieve and maintain healthy rangelands. Land treatments 

could lead to increased active use and increased livestock production, but the amount of any increase 

cannot be determined. 

Recreation 

Identification and management of SRMAs under the Proposed RMP would result in reduced conflicts 

between uses and improved recreational experiences. These results could lead to increased draw for 

recreationists from outside the two-county socioeconomic study area, resulting in monetary inflows and 

increased economic activity. A variety of general recreation management actions, including improved 

interpretation, environmental education, heritage tourism activities, and recreation management actions 

attendant on SRPs, likely would contribute to increased attractiveness of the decision area to nonresidents for commercial and private recreational uses, also leading to increased economic activity. 

Transportation 

Changes in OHV management actions under the Proposed RMP could affect the beneficial economic 

impacts from OHV use, in particular the draw for OHV users from outside the socioeconomic study area, 

which would affect monetary inflows. Very little of the decision area would remain open to cross-country 

OHV use. However, 528,000 acres would be available for use on designated routes, and 25,000 acres 

would be closed to OHV use. Under the Proposed RMP, 75 miles of the OHV routes would be closed. It 

is unlikely that increased management of OHV access under this scenario would lead to decreased draw 

of OHV riders from beyond the socioeconomic study area. It is more likely that an increased emphasis on 

designated routes, coupled with other trends in OHV use regionally, would lead to increased visibility to 

and visitation by non-local OHV riders, resulting in increased monetary inflows and benefits to the local 

economy. The supporting trends include increasing participation by local and non-local (e.g., from the 

Wasatch Front) OHV groups in signage and maintenance of routes in the region. Improvement of routes 

within and outside the decision area would contribute to the overall attractiveness of the socioeconomic 

study area for OHV use by non-local OHV riders. However, closing 7.5 miles of routes within the WSAs 

would reduce the opportunities for income associated with motorized-dependent SRPs and general OHV 

recreationists accessing these remote and scenic areas. 

Forestry and Woodland Products 

Domestic and limited commercial harvesting of woodland products (e.g., cedar posts, Christmas trees, 

and fuelwood) is expected to continue under this alternative, and biomass utilization could occur. These 

harvests provide small amounts of income to some local residents and help reduce household expenses for 

others. As shown in Table 4-22, on average the savings to households, compared to purchases at market 

rates, amount to $47,500 for fuelwood, $16,200 for cedar posts, and $4,200 for Christmas trees. 

Consolidation and simplification of permitting practices for woodland products under the Proposed RMP 

would not dramatically open up new areas for woodland product harvests or alter demand, and therefore 

would have little or no effect on the economic value of such harvests. 
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4-146 Kanab RMP 

Lands and Realty Program 

Requests for ROWs, permits, leases, withdrawals, and land tenure adjustments from other RMP programs 

or outside entities are expected to increase as neighboring communities grow and the demand for use of 

public lands increases. The Proposed RMP specifies a specific acreage (6,400 acres) of public land that 

would be available for FLPMA Section 203 sales with NEPA compliance and consistent with other 

decisions in this RMP. Disposal of BLM lands to local governments or private parties may further 

economic development within the socioeconomic study area or serve other important social purposes such 

as provision of special recreational areas. Exclusions and constraints on ROWs under the Proposed RMP 

are not expected to substantially constrain local economic development. Neither the increased economic 

activity nor other social benefits or costs can be quantified within the framework of the Draft RMP/EIS 

process because these impacts depend on the location and timing of the specific land tenure adjustments. 

Analysis of these impacts would properly occur at the implementation level. Withdrawal of certain areas 

from mineral entry under the Proposed RMP is not expected to reduce the economic contributions of 

mineral and energy utilization due to the limited extent of withdrawals relative to the total lands available 

for mineral entry. 

Social Impacts 

The Proposed RMP is expected to result in social impacts as described for the following interests: 

• Local traditional use. Under the Proposed RMP, utilization of woodland products could continue 

much as at present; the Proposed RMP decisions do not substantially change the availability of 

BLM land for these harvests. However, some local residents would have their access to woodland 

products complicated by closure of most of the decision area to cross-country OHV use. Closing 

7.5 miles of inventoried ways in WSAs could result in a loss of opportunity to access areas 

traditionally used for uses such as family gatherings, hunting, and dispersed recreation. 

• Motorized recreation. Individuals and groups with a strong preference for cross-country OHV use 

would lose many opportunities for this type of use under the Proposed RMP. However, because 

95 percent of existing OHV routes would remain available, most OHV users would be able to 

find satisfactory experiences. In addition, the Proposed RMP includes provision of increased 

facilities and other improvements that likely would improve the recreational experience for many 

OHV riders. Also, emphasis on designated routes likely would reduce some conflicts with nonmotorized recreationists because both groups’ expectations of where OHV use would and would 

not occur would be clarified. However, closing 7.5 miles of inventoried ways in WSAs would 

result in a loss of opportunity to access remote, scenic areas by OHV. 

• Non-motorized recreation. Recreational experiences of persons interested in non-motorized 

recreation would improve for several reasons. Areas and trails for motorized and non-motorized 

uses would be clarified. Identification and management of a number of SRMAs would clarify 

uses, provide facilities, and result in other improvements that enhance recreational experiences. A 

variety of general recreation management policies and practices, and increased interpretive and 

environmental education activities, also would enhance recreational experiences for motorized 

and non-motorized recreationists. In addition, closing 7.5 miles of inventoried ways in WSAs 

would eliminate interactions with OHV users and increase opportunities for solitude and 

naturalness on and adjacent to these ways. 

• Outfitter-based recreation. The Proposed RMP likely would have little social impact on persons 

interested in this type of recreational experience throughout most of the decision area. However, 

closing 7.5 miles of inventoried ways in WSAs would reduce the opportunity for OHV tours into 

remote, scenic areas. A number of decisions related to SRPs would place some limitations on 
Social and Economic 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-147 

permitting and practices of outfitters, but many of these same decisions, such as limitations on 

group size, may also enhance the recreation experiences of persons who use outfitters. 

• Livestock grazing. Impacts on livestock grazing custom and culture would be limited. There is 

little difference in the initial allocation of AUMs, and the Proposed RMP would include land 

treatments that could increase availability of forage for livestock. Potentially there could be some 

social impacts resulting from the Proposed RMP decision that AUMs voluntarily relinquished by 

a grazing preference holder could be reallocated to other uses, such as wildlife forage. This could 

result in some foregone opportunities to maintain local grazing custom and culture by allowing 

other ranchers to obtain the allotments. 

• Natural resource development. Persons and groups interested in natural resource development 

would experience few impacts from the Proposed RMP. Commercial timber harvesting would 

still be permitted on a case-by-case basis. The total acreage closed to oil and gas leasing or open 

with major constraints (NSO) would increase somewhat, and the acreage open to leasing with 

moderate constraints such as seasonal limitations would increase substantially. Nonetheless, 

significant opportunities for oil and gas development would remain. These decisions could 

increase costs for operators, but would not result in less than full achievement of the RFD oil and 

gas development projections. The Proposed RMP provides more defined policies for granting of 

ROWs for various economic activities, but would not substantially limit these uses of BLM lands. 

• Preservation. The Proposed RMP would satisfy many individuals and groups with preservation 

interests by substantially reducing cross-country OHV use. Increased constraints on or closures to 

oil and gas development would increase protection of habitat, ecosystem, visual, and other values 

held by persons and groups interested in preservation. Some who have this interest in 

preservation may consider the decision to find only 6 of 15 river segments suitable for WSR 

status a loss of value compared to continued management of all segments as eligible. In addition, 

closing 7.5 miles of inventoried ways in WSAs would satisfy individuals and groups with 

preservation interests by increasing restrictions on uses that may result in impacts on WSAs. 

Summary 

The Proposed RMP would allow the reasonably foreseeable coal mine near Alton to continue on a path 

toward development. This coal mine would provide by far the largest new economic stimulus to the 

socioeconomic study area of all activities contemplated in the Proposed RMP. However, the population 

growth associated with the coal mine may lead to new demands and impacts on community services. 

Most employment and income-generating activity would find ample opportunities under the Proposed 

RMP. 

The Proposed RMP would provide improved management approaches to use of resources that would 

address many potential resource use conflicts. The closure of almost all land to cross-country OHV use 

would produce some impacts on local custom and culture such as some woodland product harvest 

practices, and would restrict some motorized recreation users of BLM lands. At the same time, 

preservation of 95 percent of existing OHV routes and provision of increased facilities and other 

improvements would improve the recreational experience for many motorized recreation users and would 

reduce some conflicts with non-motorized users. The Proposed RMP would include land treatments to 

increase livestock forage availability that would be welcomed by livestock grazing interests. Preservation 

interests would welcome the increased constraints on natural resource development. At the same time, 

natural resource development interests would still find substantial development opportunities available 

under the Proposed RMP. 
Social and Economic 

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4-148 Kanab RMP 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

There are no irreversible or irretrievable commitment of resources associated with socioeconomics. 
 Tribal Interests 

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Kanab RMP 4-149 

4.5.2 Impacts on Tribal Interests 

There are two main types of impacts on Native American tribal interests: (1) damage to or loss of 

religiously/spiritually significant sites, and (2) actions that affect tribal treaty rights or the ability to access 

areas/resources for traditional/ceremonial purposes. The BLM coordinates and officially consults 

regularly with various Native American tribes/groups to identify and consider their concerns in BLM land 

use planning and decision-making. Further consultation (as part of this planning effort and during 

implementation of the RMP) will continue to identify specific sites or areas. 

The Proposed RMP has measures to protect cultural resource sites, including those related to traditional 

uses and practices. Impacts from the alternative decisions to cultural resource sites are discussed and 

analyzed in the Cultural Resources section. Physical impacts on religiously/spiritually significant sites 

would not be different than those noted in the cultural resources impact analysis and therefore will not be 

repeated here. However, religiously/spiritually significant sites differ from more typical archaeological 

and historical sites because of their sacredness to Native Americans and because the loss of information 

and damage on the site cannot be mitigated by recovery of scientific information. Federal mandates 

encourage the BLM to protect these places and to make accommodations to allow their traditional and/or 

religious use by Native American people to the extent possible within the bounds of other appropriate 

regulations. Therefore, in addition to the impacts on the physical site noted in the Cultural Resources 

section, impacts from surface disturbing activities could include a disruption from visual or auditory 

effects of such actions (e.g., drilling, earth-moving equipment, and automobile traffic). The duration of 

these impacts are directly related to the duration of the disruptive activity. For example, disruptions from 

an exploratory oil and gas well would be eliminated upon reclamation (3 to 5 years), while disruptions 

associated with a surface coal mine would extend over the life of the mine. The spiritual/religious 

significance and the experience of people on sites at or adjacent to these disturbances would be reduced or 

lost due to the intrusions. Mitigation identified in the tribal and Section 106 consultation processes would 

identify measures to reduce impacts to the extent possible. Through the process of mineral development, 

most of these impacts would be avoidable. However, development of a coal mine in the Alton area could 

result in the elimination of sites that could be religiously/spiritually significant. 

Because no tribal treaty rights or trust responsibilities are known within the Kanab Field Office, 

management actions on the part of the BLM will have no impact on such rights. The remainder of this 

section will address impacts on the ability to access areas/resources for traditional/ceremonial purposes.

Under the Proposed RMP, impacts on tribal interests other than those identified in the cultural section and 

described above are not anticipated as a result of implementing management actions for the following 

resources, resource uses, and designations: air quality, soil resources, special status species, fish and 

wildlife, paleontological resources, livestock grazing, recreation, transportation, minerals and energy, 

ACECs, WSRs, wilderness, WSAs, and other designations. 

Proposed RMP 

Identification and Protection of Religiously/Spiritually Significant Sites 

Based on the American Indian Religious Freedom Act Amendments of 1994, the BLM will “protect and 

preserve for American Indians their inherent right of freedom to believe, express, and exercise the 

traditional religions...including but not limited to access to sites...and the freedom to worship through 

ceremonials and traditional rites.” In addition, EO 13007 directs federal land management agencies to 

accommodate access to and ceremonial use of Indian sacred sites by Indian religious practitioners and 

avoid adversely affecting the physical integrity of such sacred sites, to the extent practicable, permitted by 

law, and not clearly inconsistent with essential agency functions. Sacred sites would be identified on a 
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4-150 Kanab RMP 

case-by-case basis through consultation efforts with Native American tribes. As these sacred sites are 

identified, the BLM would protect them and the access to them through site-specific means identified on a 

case-by-case basis. 

Tribal knowledge contributes to the management of cultural resources and traditional use areas or sacred 

sites. Working with Native American Tribes to protect their rights to practice their religions could result 

in the identification and management of cultural resource sites and areas for traditional and 

religious/spiritual uses. Maintaining current agreements and establishing new agreements with Native 

American Tribes could allow areas of religious concern to be identified and protected for traditional, 

spiritual, or other uses prior to permitting other activities that could affect these areas. In addition, these 

agreements could improve communication concerning the consultation process and the specific land 

management projects in which the various tribes are most interested. This type of proactive coordination 

with interested tribes could result in the identification and management of traditional use areas and Native 

American religious sites prior to disruptive projects being proposed. 

Condition and Accessibility of Resources for Traditional Uses 

Native American traditional use of vegetation, forest, and woodland resources would be allowed through 

permits. While requiring a permit would result in the identification of areas and species on a case-by-case 

basis, the Proposed RMP management decisions would ensure that opportunities for such uses are 

allowed. 

Implementing up to 22,300 acres of annual vegetation treatments would increase beyond just acres for 

wildland fires or fuels treatments. These treatments could result in a short-term loss of traditional use 

opportunities, but in the long term vegetation conditions would move toward a pre-European settlement 

state, improving the condition of traditionally used species. 

Not allowing surface disturbing activities within 330 feet of riparian areas would protect these areas and 

their associated water sources. In addition, implementing no surface disturbance at hanging gardens, 

which are usually associated with springs, would protect these areas that have been noted as 

ethnographically sensitive. 

Land Tenure Adjustments 

While 6,400 acres would be available for potential FLPMA Section 203 sale, none of these areas are 

located adjacent to the Kaibab-Paiute Reservation. The nearest parcels available for sale are three parcels 

southeast of the town of Kanab. In addition, these acres do not include any of the areas that the KaibabPaiute Tribe requested be made available for disposal. 

Summary 

The Proposed RMP would result in the consideration and/or protection of religiously/spiritually 

significant sites due to adherence to existing laws and policies. Proactive coordination with interested 

tribes could result in the identification and management of traditional use areas and Native American 

religious sites and improve avoidance and other mitigations to these sites prior to disruptive projects 

being proposed. 

Identification of areas and species for traditional use, and access to these areas, would require permits 

under the Proposed RMP. While requiring a permit would result in the identification of areas and species 

on a case-by-case basis, the management decisions in these alternatives would ensure that opportunities 

for such uses are allowed. 
 Tribal Interests 

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Kanab RMP 4-151 

Each alternative will manage vegetation communities to restore vegetation to pre-European settlement 

conditions. However, the Proposed RMP would move vegetation to this condition at a faster rate through 

a full range of vegetation treatment techniques. Treatments would result in a short-term loss of traditional 

use opportunities, but in the long term vegetation conditions would move toward a pre-European 

settlement state, improving the condition of traditionally used species. Management actions under the 

Proposed RMP would provide protection to springs and riparian areas. 

The Proposed RMP would provide lands available for FLPMA Section 203 sale and provide the 

opportunities to purchase lands, including lands near the reservation. 

Irreversible and Irretrievable/Short-Term Uses Versus Long-Term Productivity/Unavoidable 

Adverse Impacts 

Laws protecting Native American religious/spiritual sites would generally provide for mitigation of 

irreversible and irretrievable impacts from permitted activities. Cultural sites that are wholly eliminated 

due to short-term uses such as scientific data recovery efforts and data recovery supporting surface 

disturbing activities would no longer be available for traditional use of the resources at the site. As such, 

complete excavation of a site would result in an irreversible and irretrievable commitment of resources. In 

addition, it may not be feasible to mitigate all of the sites associated with development of a surface coal 

mine. As a result, some religiously/spiritually significant sites could be lost. 

Due to the sacred nature of some traditional uses, areas, and sites, these areas/sites are generally not 

known or discussed outside of the affected community. There is a potential unavoidable loss of these 

resources, areas, and sites due to non-recognition or lack of information and documentation. Under the 

Proposed RMP, proactive consultation efforts would improve the potential for these sites to be identified, 

improving the potential for mitigation of surface disturbing activities. 
Public Safety 

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4.5.3 Impacts on Public Safety 

Proposed RMP 

The potential for impacts from hazardous material and waste would be low because hazardous waste sites 

do not currently exist within the decision area. Impacts would be further limited through federal 

regulation of hazardous materials, substances, and waste; national contingency plans; BLM policy on 

hazardous waste disposal; and continued coordination with federal and state partners regarding hazardous 

materials and waste issues (e.g., abandoned mine lands [AML]). BLM-administered public land sites 

contaminated with hazardous wastes would be reported, secured, and remediated according to applicable 

federal and state regulations and contingency plans. Such efforts would be costly and likely involve 

several regulatory agencies and other entities or individuals. If remediation of a large hazardous waste site 

was necessary, considerable funding would be required for the public health and safety program, which 

could result in significant impacts. Because hazardous waste sites do not currently exist within the 

decision area, the potential for this to occur would be low. 

The BLM would work with the state AML program to identify and close/render these sites safe and to 

help ensure program funds are made available. On sites where the BLM shares ownership with other 

entities, cooperative efforts with the State of Utah to address remediation needs would be required. 

Evaluating all AML sites to determine effective methods for remediation would require substantial effort 

and funding over the 20-year planning period. Conducting actual remediation efforts would greatly 

increase costs associated with managing the public health and safety program. 
 Cumulative Impacts 

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Kanab RMP 4-153 

4.6 CUMULATIVE IMPACTS

Cumulative impacts are the effects on the environment that result from the impact of implementing any 

one of the alternatives of the Draft RMP/EIS in combination with other actions outside the scope of this 

plan, either within the planning area or outside it. The CEQ regulations for implementing NEPA define 

cumulative impacts as: 

“...the impact on the environment which results from the incremental impact of the 

action when added to other past, present, or reasonably foreseeable future actions 

regardless of what agency (federal or non-federal) or person undertakes such actions. 

Cumulative impacts can result from individually minor but collectively significant actions 

taking place over a period of time.” (40 CFR 1500–1508) 

Cumulative impact analysis is required to evaluate the environmental conditions that result from many 

different actions that act together. The real effect of any single action cannot be determined by 

considering that action in isolation but must be determined by considering the likely result of that action 

when acting in conjunction with many others. Management decisions may well be influenced by activities 

and conditions on intermingled non-public lands and on adjacent lands beyond the planning area 

boundary. Therefore, assessment data and information may span multiple scales, land ownerships, and 

jurisdictions. These involve determinations that are often complex and to some degree subjective. 

The analysis of cumulative impacts serves to place the projected incremental impacts from the RMP 

alternatives in the context of past, present, and future impacts. Combining the projected impacts of RMP 

alternatives with past, present, and future impacts necessarily involves projections and limited analyses, to 

the extent possible. Analyses are limited and qualitative in nature due to the inability to isolate the 

specific contribution of all past and present impacts from non-federal lands ; challenges of predicting 

potential impacts for reasonably foreseeable future actions; the broad programmatic and strategic nature 

of RMP alternatives; unknown nature and pace of resource uses and technological changes that could 

occur; and changing circumstances related to agency priorities, policies, and the economy. It is neither 

practical nor required to exhaustively analyze all possible cumulative impacts. Instead, CEQ indicates the 

cumulative impact analysis should focus on meaningful impacts due to the nature of the RMP decisions 

4.6.1 Cumulative Analysis Methodology 

The cumulative impacts discussion that follows considers the Proposed RMP in the context of the broader 

human environment and specifically actions that occur outside the scope and geographic area covered by 

the RMP. Because of the programmatic, broad-scale nature of this RMP, this assessment is broad and 

generalized to address potential effects that could occur from a hypothetical management scenario when 

combined with other activities or projects. This assessment is primarily qualitative for many resources 

because of the lack of detailed information that would result from project-level decisions, site-specific 

resource conditions, and other activities or projects. 

Cumulative impact analysis is limited to important issues of national, regional, or local significance. 

Therefore, not all issues identified for direct or indirect impact assessment in this EIS are analyzed for 

cumulative effects. Because of the wide geographic scope of a cumulative impact assessment and the 

variety of activities assessed, cumulative impacts are commonly examined at a more qualitative and less 

detailed level than are the direct and indirect impacts presented previously in this chapter. This analysis 

includes discussion of factors that have created the current environment that is described in Chapter 3, 

Affected Environment. These past actions are considered cumulatively with the alternatives of this RMP. 

Factors that could be expected to influence that environment in the future are also considered. 
Cumulative Impacts 

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4-154 Kanab RMP 

The spatial boundaries of each resource cumulative analysis, known as the cumulative impact analysis 

area, vary by resource and are larger for resources that are mobile or migrate compared to resources that 

are stationary. In some cases, spatial boundaries may be contained within the planning area or an area of 

the planning area. Evaluation of potential impacts considers incremental impacts that may occur resulting 

from the proposed project, while also considering impacts from past, present, and reasonably foreseeable 

future actions. Reasonably foreseeable future actions are those future action activities that have been 

committed to or that are known proposals that could take place within the 20-year planning period. 

Reasonably foreseeable future action scenarios are projections made only for the prediction of future 

impacts; they are not actual planning decisions or resource commitments. 

Projections, which have been developed for analytical purposes only, are based on current conditions and 

trends and represent a best professional estimate. Unforeseen changes in such factors as economics; 

demand; and federal, state, and local laws and policies could result in different outcomes than those 

projected for this analysis. 

The following factors were considered in this cumulative impact assessment: 

• Federal, non-federal, and private actions 

• The potential for synergistic effects or synergistic interaction among or between effects 

• The potential for effects to cross political and administrative boundaries 

• Other spatial and temporal characteristics of each affected resource 

• The comparative scale of cumulative impacts across alternatives. 

4.6.2 Past, Present, and Reasonably Foreseeable Future Actions 

Projects and activities were identified through review of available information. The following general 

types of projects were identified as having the greatest likelihood of generating potential cumulative 

impacts: 

• Regional minerals and energy projects 

• Water projects 

• Road improvement projects 

• Neighboring land use planning and development. 

Other potential future actions have been considered and eliminated from further analysis because there is 

only a small likelihood of these actions being pursued and implemented within the life of the plan or 

because there is so little known about the potential action that formulating an analysis of impacts would 

be premature. In addition, potential future actions that protect the environment (such as new, potentially 

threatened, or endangered species listings or regulations related to fugitive dust emissions) are unlikely to 

create significant environmental effects alone or in combination with this planning effort. Federal actions 

such as species listings would require the BLM to reconsider the decisions created from this plan because 

the consultations and relative impacts may no longer be appropriate. These potential future actions may 

have greater capacity to affect the resource uses within the decision area. However, until more 

information is developed, no reasonable estimate of impacts can be developed. 

Continued surface disturbing activities are foreseeable actions anticipated in the decision area. Some 

management actions related to these uses have been considered within the range of the Draft RMP/EIS 

alternatives, but the continued existence of these activities is driven by the multiple-use mandate and will 

occur unless another legislative action intercedes. The potential cumulative impacts of these land uses are 

then inherent and are not clearly identifiable because these uses are historically connected to the condition 

of the land. 
 Cumulative Impacts 

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Kanab RMP 4-155 

Data on the precise locations and overall extent of the resources within the decision area varies according 

to resource type and locale. Further, the understanding of the impacts on and the interplay among these 

resources is evolving. As knowledge improves, management measures (adaptive or otherwise) would be 

considered to reduce potential cumulative impacts. 

Regional Minerals and Energy Projects 

West-Wide Energy Corridor Programmatic EIS 

The West-Wide Energy Corridor Draft Programmatic EIS (PEIS) was released to the public in October 

2007. The Draft PEIS analyzes the environmental impacts of designating more than 6,000 miles of energy 

corridors on federal land in 11 western states and incorporating those designations into relevant land use 

and resource management plans. The Draft PEIS analyzes a No Action Alternative and a Proposed 

Action. Under the No Action Alternative, federal energy corridors would not be designated on federal 

lands in the 11 western states; the siting and development of energy transport projects would continue 

under current agency procedures for granting ROWs. Under the Proposed Action, the agencies would 

designate and incorporate through relevant land use and resource management plans certain federal 

energy corridors that would consist of existing, locally designated federal energy corridors together with 

additional, newly designated energy corridors located on federal land. The Energy Policy Act of 2005, 

Section 368, Energy Right-of-Way Corridors on Federal Land, required agencies to designate energy 

corridors, taking into account the need for upgraded and new electricity transmission and distribution 

facilities in order to improve reliability, relieve congestion, and enhance the capability of the national grid 

to deliver electricity. 

The project requires federal agencies to cooperate using their respective authorities to (1) designate 

corridors for oil, gas, and hydrogen pipelines and electricity transmission and distribution facilities on 

federal land in the 11 contiguous western states; (2) perform any environmental reviews that may be 

required to complete the designations of such corridors; and (3) incorporate the designated corridors into 

the relevant agency land use and resource management plans or equivalent plans. The one corridor that 

crosses the decision area has been incorporated into the Proposed RMP. 

BLM Wind Energy Development PEIS and Wind Energy Development Program 

A December 2005 ROD on the PEIS for wind energy development where appropriate on BLMadministered public lands in the western states amended several land use plans (LUP). Although the EIS 

identifies areas where development would be incompatible (wilderness, critical habitats, etc.), it 

prescribes BMPs for wind energy development projects on the public lands. The PEIS is intended to 

facilitate this form of renewable energy development on suitable areas of the public lands. 

Coal Mine Development of Private Coal Resources in the Alton Area 

The State of Utah is considering an application to surface mine privately owned coal resources associated 

with the Alton Coal Lease Tract in Kane County. The privately owned tracts are adjacent to federally 

administered coal resources that BLM is considering for competitive leasing, as described in Chapter 3 

and the RFD Scenario (Appendix 15). The tract is proposed for development by surface mining methods 

to ensure maximum economic recovery of the resource. 

The development of private coal resources (fee coal) would occur as part of development of the federal 

coal resources administered by the BLM. Preliminary plans would be to mine the coal from private 

surface/federal subsurface (approximately 1,300 acres) first and then expand onto adjacent federal 

surface/federal subsurface (approximately 2,300 acres). In addition to the mining of federal coal, 
Cumulative Impacts 

Chapter 4 Proposed RMP and Final EIS 

4-156 Kanab RMP 

preliminary plans would be to mine coal from private surface/fee coal (approximately 800 acres) for a 

total cumulative surface disturbance of 4,400 acres in the planning area. The average annual total surface 

disturbance would be approximately 220 acres. 

Tropic to Hatch Transmission Line 

Garkane Energy Cooperative proposes to construct, operate, and maintain a 138 kilovolt (kV) electric 

transmission line requiring a Special Use Authorization, Grant of ROW, and/or Special Use Permit for an 

ROW. The proposed project will include the construction of a 138kV transmission line, associated 

substations, access roads, and the removal and reclamation of a portion of the existing transmission line. 

The proposed action would cross private lands and lands administered by the U.S. Forest Service (USFS), 

BLM, and the State of Utah. 

The proposed corridor originates on private land at the proposed East Valley Substation and extends 

northeast following East Valley Road to an existing Rocky Mountain Power 230kV transmission line 

corridor. The project route then parallels the south side of the Rocky Mountain Power 230kV 

Transmission Line to the northwest through Cedar Fork Canyon. As the project route exits the Canyon on 

the Paunsaugunt Plateau, it diverges from the Rocky Mountain Power 230kV Transmission Line corridor 

and extends east across John’s Valley for approximately 7 miles. At this point, the corridor turns south for 

approximately 2 miles, crossing SR 12 near the Bryce Canyon Pines Motel. The route then extends west 

through Johnson Bench until it intersects Forest Service Road 1150, and then parallels Forest Service 

Road 1150 to the head of the Hillsdale Canyon. The project route continues through a designated utility 

corridor west down the canyon to Forest Road 223 and turns north for approximately 0.5 mile. At this 

point, the project route leaves the road and extends due west across Long Valley paralleling section lines, 

and eventually crossing U.S. Route 89 where it then turns to the southwest for approximately 2 miles to 

the Hatch Substation. The proposed line would cross approximately 15 miles of National Forest; 3.67 

miles of GSENM; and 3.53 miles of BLM KFO, 7.27 miles of state, and 1.76 miles of private lands. 

Water Projects 

Lake Powell Pipeline 

The State of Utah Board of Water Resources and Washington, Kane, and Iron counties are pursuing the 

construction of a pipeline that would run from Lake Powell to Sand Hollow Reservoir. The pipeline 

would originate at Lake Powell near the Glen Canyon Dam, and would deliver water to Sand Hollow 

Reservoir, located approximately 10 miles east of St. George. The Lake Powell pipeline would consist of 

roughly 120 miles of estimated 66-inch pipe from Lake Powell to Sand Hollow Reservoir and 38 miles of 

30-inch pipe from Sand Hollow to Cedar City. The corridor is anticipated to be 3,000 feet wide. As part 

of the initial feasibility studies, various alternative alignments are being investigated in an effort to 

identify the least costly alignment that would have minimal impact on the environment. 

The pipeline is being proposed in order to meet the water demands of the growing population in southern 

Utah. The 158 miles of pipeline would bring 70,000 acre-feet of water to Washington County, 10,000 

acre-feet to Kane County, and 20,000 acre-feet to Iron County. The pipeline would probably exceed $494 

million in current dollars. The Lake Powell pipeline would allow Utah to tap into the Upper Colorado 

River water. 

The pipeline is most likely a project that is several years in the making. Prior to construction of the 

pipeline, additional engineering and financial feasibility studies must be completed and ROWs and 

various permits and agreements obtained. An extensive environmental review of the proposal to build the 
 Cumulative Impacts 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-157 

pipeline will be conducted, and stakeholder and public input will take place. The actual construction of 

the pipeline is estimated to last 3 years. 

Jackson Flat Reservoir–Kane County Water Conservancy District 

The Jackson Flat Reservoir is proposed on approximately 200 acres of non-BLM-administered lands 

within Kanab city limits. The reservoir would store 3,900 acre-feet of water. The reservoir could change 

flow regimes and water quality parameters south of Kanab (Kanab Creek fifth-level Hydrologic Unit 

Code [HUC]). In addition, the construction of the reservoir could increase the demand for mineral 

materials. A draft environmental assessment was released in fall 2007. 

Road Improvement Projects 

Expansion of U.S. Highway 89 

U.S. Highway 89 is anticipated to be widened over the next 20 years. The widening of the highway would 

allow for an increase in traffic volume. In addition, portions of the highway would be developed into a 

four-lane divided highway. 

Neighboring Land Use Planning and Development 

Conversion of Land Use 

Conversion of agricultural lands to residential and commercial uses would increase the demand for 

groundwater sources to support these additional uses. The conversion of these lands would make 

remaining undeveloped lands more important for wildlife habitat and other resource uses. 

Management of Adjacent Lands 

Activities on adjacent lands could affect public land in the decision area, general public land management 

on adjacent lands, and management of private and state lands. There are no major projects identified on 

these lands, but there are differences or similarities in management. 

Areas managed by federal land management agencies include: 

• St. George BLM Field Office 

• Richfield BLM Field Office 

• Arizona Strip BLM Field Office 

• Grand Staircase-Escalante National Monument 

• Dixie National Forest 

• Fishlake National Forest 

• Glen Canyon National Recreation Area 

• Bryce Canyon National Park 

• Zion National Park. 

Each of these areas has a LUP to guide the management of federal lands in these areas. 
Cumulative Impacts 

Chapter 4 Proposed RMP and Final EIS 

4-158 Kanab RMP 

4.6.3 Cumulative Impacts by Resource 

Air Quality 

Dispersed recreation, prescribed burning activities, and mineral and energy development cause emissions 

of PM, CO, NOx, SO2, and VOC emissions currently below regulatory thresholds. In the future, these 

emissions could impact ambient air quality, visibility, and atmospheric deposition. The cumulative impact 

analysis of air quality within and near the planning area includes major sources such as coal-fired power 

plants and cogeneration facilities. 

Data provided by KFO staff was used to determine the base year conditions after the development of 

proposed energy resources was complete. In addition, emissions data was gathered for the area. The most 

recent Utah Division of Air Quality (UDAQ) Statewide Emissions Inventory Report shows the primary 

air pollutants in Garfield and Kane counties are VOCs, followed by CO, PM10, NOx, SOx, and PM2.5. 

Table 4-23 shows the criteria pollutant levels in tons per year from the Statewide Emissions Inventory. 

The 2002 emissions from the sources in Kane and Garfield counties are 182,641 tons per year (UDAQ 

2002). The emissions from future BLM activities for the Proposed RMP are 3,554 tons per year. 

Emissions from proposed actions from BLM activities in the decision area will contribute approximately 

one-tenth of a percent of the emissions of the State of Utah and 2 percent of the sum of emissions from 

Garfield and Kane counties. 

Table 4-23. 2002 Criteria Pollutant Inventory (tons per year) 

Area PM10 PM2.5 SOx NOx VOC CO Total 

Garfield 5,155 4,024 95 1,638 51,387 57,471 115,746 

Kane 750 205 89 564 48,948 16,544 66,895 

Utah Total 82,439 23,288 49,090 205,313 911,310 1,314,041 2,562,193 

Utah Average 3,053 1,208 1,818 7,604 33,752 48,668 94,895 

Sources: (UDAQ 2002) and (UDAQ 2003) 

Considering that the permitted sources do not calculate emissions from some of the oil and gas sources 

and that the permitted emissions come from single point sources, the future anticipated emissions from 

BLM activities will be low in comparison to existing sources and would not cause exceedance of State or 

federal ambient air quality standards. 

Soil Resources 

The cumulative impact analysis boundary for soil resources is the planning area and the fifth order 

watersheds that intersect the planning area boundary. BLM management actions combined with the 

proposed construction and development of the Lake Powell pipeline, coal development activities, 

development of the West-wide energy corridor, and construction of the Jackson Flat Reservoir could 

increase localized erosion and decrease soil productivity, which could degrade downstream water quality. 

However, these permitted activities would comply with authorizing permit stipulations and apply BMPs 

that would minimize overall soil erosion and loss of soil productivity resulting in limited incremental 

impacts from BLM actions. 
 Cumulative Impacts 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-159 

Water Resources 

The cumulative impact analysis boundary for water resources is the planning area and the fifth order 

watersheds that intersect the planning area boundary. BLM management actions combined with the 

proposed construction and development of the Lake Powell pipeline, coal development activities, 

development of the West-wide energy corridor, and construction of the Jackson Flat Reservoir could 

increase incremental impacts associated with localized erosion and sediment loading, which could 

degrade downstream water quality. However, BLM-permitted activities would comply with authorizing 

permit stipulations that would minimize soil erosion and degradation of water quality and are not 

expected to contribute to the overall cumulative effect to water quantity and quality from past, present, 

and reasonably foreseeable actions. In addition, fire use and vegetation treatments proposed by BLM 

under the Proposed RMP would incrementally improve watershed health, which could increase the ability 

of the watershed to retain moisture. This could increase the volume of water within the watershed. 

Vegetation 

The cumulative impact analysis boundary for vegetation includes the entire decision area. Potential 

cumulative impacts on vegetation would occur from a combination of activities and land uses occurring 

within the analysis boundary. Such incremental impacts would result primarily from vegetation 

treatments, surface disturbing activities, and general human disturbance. 

Loss of vegetation from activities on BLM-administered lands could result from surface uses and 

disturbances such as minerals development, ROW development, and open OHV use, which could alter 

the composition and structure of vegetation communities; increase the potential for the introduction and 

establishment of noxious weeds; and reduce species diversity, primary production, and the recruitment of 

new plants. Surface disturbance in riparian/wetland areas under the Proposed RMP could decrease 

riparian/wetland functioning conditions. 

Past fire suppression has contributed to increasing pinyon-juniper encroachment in the decision area and 

to a concurrent decrease in aspen and ponderosa pine communities. Fire use and vegetation treatments 

under the Proposed RMP would generally maintain or improve vegetation communities by removing 

undesired species, increase species diversity and age class, improve vegetation composition and structure, 

and increase vegetation cover. In addition, vegetation treatments and range improvements on lands 

adjacent to the decision area (public and private) would increase available forage and water for wildlife 

populations and livestock (for use by private operators) in these areas. This also would improve 

distribution of livestock and wildlife, improving vegetation condition. These incremental impacts would 

result in healthier vegetation communities that are more capable of retaining moisture and nutrients and 

resisting disease, non-native species invasion, drought, and other natural disturbances and stressors. 

Special Status Species (Threatened, Endangered, and Sensitive) 

The cumulative impact analysis boundary for effects on special status species is the planning area and the 

watershed boundaries that intersect the planning area. The development of the Lake Powell pipeline, 

highway construction, and ROW corridors proposed under the West-wide energy corridor project would 

result in a loss of habitat for special status species wildlife and plants and could temporarily displace 

special status species wildlife from these areas. The conversion of land use from agricultural lands to 

residential and commercial uses would increase the habitat values of undeveloped land. The change in 

land use could result in the loss of foraging and nesting habitat for some special status species. 

Management of adjacent lands would affect habitat conditions and special status species populations. 

Because the majority of adjacent lands are federally managed, special status species habitat values must 

be considered through federal landscape and activity planning. The surface development of private coal 
Cumulative Impacts 

Chapter 4 Proposed RMP and Final EIS 

4-160 Kanab RMP 

resources in the Alton area (approximately 800 acres) (Appendix 15) would impact the southern-most lek 

of the Greater sage-grouse. Combined with mining operations on adjacent lands with federally 

administered coal resources (approximately 3,600 acres), this could result in the long-term loss of the 

local sage-grouse habitat and displacement of individuals. Presently there is an EIS underway as part of a 

coal leasing application in the Alton Amphitheater. High interest habitats will be addressed in that EIS. 

The anticipated incremental impact from the Proposed RMP on special status species would be minor 

when compared to the overall cumulative effect on special status species. 

Fish and Wildlife 

The cumulative impact analysis boundary for effects on fish and wildlife is the planning area and the 

watershed boundaries that intersect the planning area. The development of the Lake Powell pipeline, 

highway construction, and the ROW corridors proposed under the West-wide energy corridor project 

would result in a loss of habitat and could temporarily displace wildlife from these areas. The conversion 

of land use from agricultural lands to residential and commercial uses would increase the habitat values of 

the remaining undeveloped land. The change in land use could result in the loss of habitat for some 

wildlife species. Management of adjacent lands would affect habitat conditions and wildlife populations. 

Because the majority of adjacent lands are federally managed, fish and wildlife habitat values must be 

considered through their landscape and activity planning. In addition, UDWR management of herd levels, 

including herd objectives and herd harvest levels, would directly affect wildlife populations and 

associated levels of habitat use. Vegetation treatments and range improvements on lands adjacent to the 

decision area (public and private) would increase available forage and water for wildlife populations and 

livestock (for use by private operators) in these areas. This also would improve distribution of livestock 

and wildlife, improving vegetation condition. The Proposed RMP management actions would increase 

vegetation treatments and range improvements that would incrementally improve the quality of the 

wildlife habitat. 

Wildland Fire Ecology 

Effects on fire frequency, intensity, and suppression activities resulting from BLM actions within the 

decision area would combine with similar effects caused by activities sponsored by other groups and 

private interests to create cumulative impacts on fire management within the analysis boundary. As 

development, recreational activities, and general use of the area increased, so would the number of 

potential ignition sources and consequently the probability of wildland fire occurrence, which would 

increase the need for federal, state, and local agencies to suppress wildland fires to protect life, property, 

and sensitive resources. Development of the area also would increase the amount of Wildland-Urban 

Interface (WUI) areas, which would put additional pressure on fire suppression efforts because these are 

high-priority areas for fire suppression. Suppression activities within WUI areas could be more 

dangerous, time-consuming, and expensive than suppression in undeveloped areas. In addition, activities 

associated with fire suppression, recreation, development, and general land use would cumulatively 

contribute to the modification of the composition and structure of vegetation communities and increase 

the spread of noxious and invasive weeds. Such effects would in turn alter the decision area’s fire regime, 

potentially increasing the frequency, size, and intensity of wildland fires. Developed areas and associated 

roads and ROW corridors could also provide increased accessibility to remote areas for fire suppression 

equipment and provide fuel breaks in the case of wildland fire events. The Proposed RMP would 

incrementally modify and improve the composition and structure of vegetation communities and move 

the decision area’s fire regime towards condition class 1. 
 Cumulative Impacts 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-161 

Cultural Resources and Tribal Interests 

Impacts associated with resource decisions from this RMP, combined with other past, present, and 

reasonably foreseeable actions, could produce cumulative impacts on cultural resources and resources of 

religious or traditional importance to Native American tribes associated with the decision area. The 

cumulative impact analysis area for cultural resources includes the planning area and neighboring lands 

with connected cultural resources, including parts of the GSENM, Iron and Piute counties, and the 

Kaibab-Paiute Reservation lands.

Land management of adjacent federal lands would provide protection for cultural resources throughout 

the region. Required inventories prior to surface disturbance would increase the number of identified sites 

and decrease the potential for damage from surface disturbing activities. Similar management direction 

and resource uses occur in these planning areas. In addition, any surface disturbance associated with 

water projects, regional minerals, or energy projects would require adherence to cultural resource laws 

and regulations, resulting in the inventory and identification of cultural sites and in some cases data 

recovery. 

Under the Proposed RMP, cultural resources would be managed in compliance with federal law, 

regulation, and policies that require the preservation of cultural resources either in place or through data 

recovery, which would result in minor incremental impacts to cultural resources. Management from other 

resource programs (non-WSA lands with wilderness characteristics, special status species, riparian, fish 

and wildlife, SRMAs, and ACECs) would also provide protection from surface disturbing activities that 

could damage cultural resource sites.

Potential congressional designation of WSR segments would require a Class III cultural resource survey 

to identify and monitor cultural resources. Some cultural resources would require additional mitigation as 

a result of public interaction with the resource. 

Paleontological Resources 

The cumulative impact analysis boundary for paleontological resources includes the decision area and 

neighboring lands with connected paleontological resources. Management activities on adjacent federal 

lands would provide protection for paleontological resources throughout the region. Inventories prior to 

surface disturbance would increase the number of identified localities and decrease the potential for 

damage from surface disturbing activities. These inventories also would increase the knowledge of the 

region’s paleontological resources. 

The cumulative effects of surface disturbing activities within paleontological Class I areas, especially 

mineral development in the region, have the potential to damage this fragile, non-renewable resource. 

However, existing laws, regulations, and policies provide for mitigation of effects through avoidance or 

data recovery efforts. Although it is expected that some fossils would be destroyed in the course of 

legitimate uses of public lands, mitigation measures likely would bring paleontologists to areas where 

fossils had not been previously studied. Thus, fossils that would otherwise have disintegrated over time 

due to weathering and erosion would be collected, placed in repositories, and protected in perpetuity. 

Beyond mineral development, cumulative impacts on paleontological resources could occur through 

incremental degradation of the resource base from a variety of sources, reducing the information and 

interpretive potential of the paleontological resource values. Mineral development on lands that are not 

protected by federal laws or policies protecting paleontological resources could decrease the regional 

resource base, increasing the scientific value of the paleontological resources within the decision area. 

This combined with the actions on BLM-administered lands could result in minor incremental impacts to 

paleontological resources. 
Cumulative Impacts 

Chapter 4 Proposed RMP and Final EIS 

4-162 Kanab RMP 

Visual Resources 

The cumulative impact analysis boundary for visual resources includes the decision area and neighboring 

lands within the viewshed that overlap the decision area.

Development actions within and outside the decision area could produce long-term cumulative impacts on 

visual resources. Reasonably foreseeable future actions, including planning efforts to locate and develop 

mineral and hydrocarbon resources and establish ROW corridors, would have impacts on visual 

resources. Impacts would be caused by surface disturbance from production, exploration, and 

construction of drilling and mining facilities and development within ROWs. However, these projects 

would be required to conform to an area’s VRM class objectives. Projects in VRM Class I and II areas 

could be required to conform to these VRM class objectives through design, camouflage, and/or 

topographic screening, which would prevent their cumulative impacts on visual resources from becoming 

dominant features on the landscape in sensitive VRM class designations. Cumulatively, the Proposed 

RMP would provide protections for visual resources because the 170,400 acres (31 percent) of VRM 

Class I and II would be in addition to restrictions on development on adjacent National Parks, National 

Monuments, Glen Canyon National Recreation Area, and wilderness areas. VRM Class III and IV area 

objectives in the decision area would not emphasize protection of an unmodified landscape and visual 

resources and would allow for major modifications to the landscape. Activities that occur in these areas 

could result in changes to the characteristic landscape and may not protect scenic values. 

Continued recreational OHV use also would maintain the 1,403 routes on BLM land in addition to routes 

on private and state lands. These routes would result in cumulative impacts from the landscape contrast 

associated with linear route disturbances.

The growing need to decrease the potential for catastrophic fire in the region through mechanical 

treatments aimed at reducing fuel loads would gradually alter landscapes where treatments are conducted. 

Vegetation treatments would change the vegetation component of the landscape, and thus its visual 

character. The degree of change would vary depending on the vegetation type, size of the treatment area, 

and treatment method. For example, vegetation treatments in pinyon and juniper vegetation communities 

would be more visually apparent than vegetation treatments in sagebrush communities. Smoke from 

prescribed fires used for the same purpose would sporadically affect the quality of viewsheds and 

interfere with the public’s viewing of scenery. 

The overall contribution of the Proposed RMP to the cumulative impact on visual resources is expected to 

be a minor incremental increase to the visual disturbances as a result of mineral resource development, 

transportation, and vegetation treatments. Additionally, there would be incremental increases in the areas 

managed to protect visual resources. 

Areas with Wilderness Characteristics (Wilderness, WSAs, and Non-WSA Lands 

with Wilderness Characteristics) 

The cumulative impact analysis boundary for areas with wilderness characteristics (designated 

wilderness, WSAs, and non-WSA lands with wilderness characteristics) includes areas within the 

planning area with identified wilderness characteristics and the full extent of those areas that overlap 

outside the planning area. In addition, areas with wilderness characteristics of adjacent land management 

agencies were considered as cumulative management of adjacent lands described above (Table 4-24). 
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Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-163 

Table 4-24. Acres of Areas with Wilderness Characteristics in the Cumulative Impact 

Analysis Boundary 

Area Name Designated 

Wildernessa

WSAs 

(BLM)/Forwarded 

to Congress 

(NPS)a

Non-WSA Lands 

with Wilderness 

Characteristics 

(BLM)/ Potential & 

Proposed for 

Wilderness (NPS)a

Total Areas with 

Wilderness 

Characteristicsa

Kanab Field Office 21,200 53,900 27,770b 102,870 

Dixie National Forest1 25,600 0 0 25,600 

Arizona Strip Field 

Office2 80,765 0 34,942b 115,707 

St. George Field 

Office3 2,690 94,916 0 97,606 

Grand Staircase–

Escalante NM4 0 881,997 457,049 1,339,046 

Vermilion NM2 89,825 0 37,566b 127,391 

Grand Canyon/ 

Parashant NM2 95,150 0 215,345b 310,495 

Zion NP5 0 120,620 11,995 132,615 

Bryce Canyon NP6 0 20,810 0 20,810 

Glen Canyon 

National Recreation 

Area6 0 0 637,250 637,250 

Cedar Breaks NM6 0 4,830 0 4,830 

Capitol Reef NP6 0 179,815 4,050 183,865 

Grand Canyon NP6 0 0 1,111,902 1,111,902 

Lake Mead National 

Recreation Area6 0 0 561,300 561,300 

Totals 315,230 1,356,888 3,099,169 4,771,287 

Notes: 

a - All figures are shown in acreages. 

b - Not total acres of non-WSA lands with wilderness characteristics, but total acres of non-WSA lands with wilderness 

characteristics proposed to be managed to maintain wilderness characteristics in the Proposed RMP/Final EIS. 

Sources: 1 - USFS 2006, 2 - BLM 2007, 3 - BLM 1999b, 4 - BLM 2000, 5 - NPS 2001b, 6 - NPS 2003 

As a result of implementing the management prescriptions under the Proposed RMP, wilderness 

characteristics on approximately 27,770 acres of areas with wilderness characteristics would be managed 

to protect, preserve and maintain those characteristics within the decision area. Because of BLM WSA 

management, management of existing wilderness by the BLM and USFS, and management of lands 

administratively endorsed for wilderness by the NPS, the cumulative effect would be the protection of 
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4-164 Kanab RMP 

wilderness characteristics on 4,314,238 acres throughout the region (all areas except non-WSA lands with 

wilderness characteristics within GSENM, which are not specifically managed to protect their wilderness 

characteristics). Not managing 62,010 acres of non-WSA lands with wilderness characteristics within the 

Kanab Field Office would contribute to a loss of areas with wilderness characteristics in the region. 

However, cumulatively the number of acres being protected for their wilderness characteristics in the 

region is much larger. In this context, the loss of wilderness characteristics on less than 1 percent of the 

non-WSA lands with wilderness characteristics in the decision area would not result in a significant 

incremental loss of these resources in the region. 

Under the Proposed RMP, designation of a West-wide energy corridor, as proposed in the West-Wide 

Energy Corridor PEIS, would result in a 3,500-foot-wide ROW corridor being established through 1,580 

acres of the Upper Kanab Creek area of non-WSA lands with wilderness characteristics and across 400 

acres of the eastern portions of the Vermilion Cliffs area of non-WSA lands with wilderness 

characteristics. The portions of the Upper Kanab Creek area of non-WSA lands with wilderness 

characteristics east of the proposed energy corridor (9,690 acres) would remain at more than 5,000 acres 

and would retain its wilderness characteristics, as would the Vermilion Cliffs area of non-WSA lands with 

wilderness characteristics. Development of ROWs within the corridor would remove opportunities for 

solitude and primitive recreation during construction. The surface disturbance associated with the 

development would eliminate naturalness in these portions of the Upper Kanab Creek and Vermilion 

Cliffs areas of non-WSA lands with wilderness characteristics. Following construction activities, 

naturalness would remain impacted for above-ground facilities, while reclamation of subsurface ROWs 

would reduce the loss of naturalness. 

Use and/or development of non-federal land inholdings within the Moquith Mountain and Parunuweap 

WSAs and the Paria Canyon–Vermilion Cliffs Wilderness could result in the loss of wilderness 

characteristics in portions of these areas. Based on the “Cotter Decision” (State of Utah v. Andrus, 1979), 

“BLM is obligated to provide reasonable access to State sections.” The decision notes that the BLM can 

regulate the method and route of access to State of Utah School and Institutional Trust Lands 

Administration (SITLA) lands encircled by federal land; however, the regulation may not prevent the 

State or its lessee from gaining access to its land, nor may it be so prohibitively restrictive as to render the 

land incapable of full economic development. While there has been no current demand for access to these 

sections, such actions could occur within the planning window. Providing access could diminish or 

eliminate wilderness characteristics in the areas adjacent to the access routes. The magnitude and duration 

of the impact would depend on the location of the route, type of access, and type of development being 

supported by the access. Because designated wilderness and WSAs (Congressionally mandated) would be 

managed to maintain their wilderness characteristics, impacts would be mitigated and likely would result 

in only localized and short-term disturbance. 

Forestry and Woodland Products 

The cumulative impact analysis boundary for forest and woodland products is the planning area and 

watersheds that intersect the planning area. The availability of other forest and woodland products on 

adjacent lands could reduce the demand for these products within the decision area. The Proposed RMP 

management actions on the harvest of forest and woodland products would have a negligible incremental 

impact to the overall cumulative impact on the resource in the planning area. 

Livestock Grazing 

The cumulative impact analysis boundary used to analyze cumulative impacts on livestock grazing 

includes all grazing allotments within the planning area. Potential, cumulative impacts on livestock 

grazing operations could occur from a combination of activities and land uses occurring within the 
 Cumulative Impacts 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-165 

analysis boundary. Such impacts could result primarily from vegetation treatments, surface disturbing 

activities, the presence of grazing wildlife, and general human disturbance. Vegetation treatments and 

range improvements on lands adjacent to the decision area (public and private) would increase available 

forage and water for wildlife populations and livestock (for use by private operators) in these areas. This 

also would improve distribution of livestock and wildlife, improving rangeland conditions. In addition, 

vegetation treatments designed to enhance rangeland conditions would generally result in long-term 

increases in forage production. This could also result in short-term forage loss and livestock displacement 

directly in the areas of treatment. 

Existing and future surface disturbing activities, recreation use, and big game populations located within 

the analysis boundary could incrementally reduce forage available for livestock and cause a incremental 

increase in soil disturbance, vegetation removal, spread of noxious weeds, and livestock displacement. 

Impacts would generally be greater in areas with large populations of big game and in areas of intense 

surface disturbance. These impacts could result in changes in rangeland health and jeopardize compliance 

with the Standards for Rangeland Health on some allotments. If livestock grazing is considered to be a 

factor in violating the Standards for Rangeland Health, the responsible livestock operator could be 

required to make adjustments to grazing practices. 

Surface disturbing activities, including coal development activities and related construction of roads and 

infrastructure, could be a primary cause of site-specific loss of forage and the spread of noxious weeds. 

The implementation of BLM’s mitigation guidelines, restrictions on surface use, Standards for Rangeland 

Health, vegetation treatments, and monitoring efforts would all provide measures of protection for forage 

resources on federal lands, which would help to incrementally reduce overall effects on livestock grazing 

operations. 

Recreation 

The cumulative impact analysis boundary used to analyze cumulative impacts on recreation resources 

includes the planning area and all big game herd units that intersect the planning area. Because hunting is 

a major recreation activity within the planning area, any activities that affect game populations would in 

turn impact recreation opportunities and experience. 

Cumulative impacts on recreation would potentially occur from a combination of land uses that result in 

conflicts for unconfined and primitive recreation opportunities. Such impacts are a result of increased 

recreational activity occurring within and outside of the planning area and other conflicts generated from 

permitted actions. Conflicts among recreationists would result in a major impact on the recreation setting 

and experience. Motorized recreation use would conflict with primitive/unconfined recreation when they 

occur in close proximity and would result in degradation of the setting and experience associated with 

primitive/unconfined recreation activities. There would be a negligible incremental impact to recreational 

opportunities and experiences from the Proposed RMP management actions. 

Transportation 

The cumulative impact analysis boundary includes the planning area and immediately adjacent segments 

of state and local road networks including portions of Zion National Park, Capital Reef National Park, 

Glen Canyon National Recreation Area, GSENM, Arizona Strip Field Office, Richfield Field Office, St. 

George Field Office, Cedar City Field Office, Dixie National Forest, and regional State Trust Lands. 

These road networks include routes shared with the BLM and other federal agencies and routes shared 

with the GSENM. Cumulative impacts on transportation and access would primarily occur from actions 

that facilitate, restrict, or preclude motorized access. Management actions that restrict OHV use would 

limit the degree of travel opportunities and the ability to access certain portions of the planning area. The 
Cumulative Impacts 

Chapter 4 Proposed RMP and Final EIS 

4-166 Kanab RMP 

Proposed RMP would provide for motorized access to most of the decision area, where non-motorized 

access could be obtained in the areas beyond the designated routes. Closures would not eliminate access 

to any portion of the decision area, although in some areas motorized access would require travel on more 

miles of routes to access the same area. The continued maintenance of federal and state highways would 

provide arterial connections to BLM system roads. County-maintained routes that connect federal and 

state highways to BLM system routes would maintain and improve access to the decision area’s 

resources. The Proposed RMP management actions to close 99 percent of the decision area to crosscountry OHV travel in combination with similar management actions of adjacent field offices and 

agencies would incrementally reduce opportunities for cross-country OHV travel. 

Lands and Realty 

The cumulative impact analysis boundary for lands and realty include the planning area and segments of 

ROW corridors that intersect its boundaries. The ROWs and ROW segments are maintained by state or 

local agencies, adjacent BLM field offices, and other federal agencies. The Tropic to Hatch transmission 

line, Lake Powell pipeline, West-wide energy corridor, expansion of U.S. Highway 89, and development 

along U.S. Highway 89 and SR 12 could affect the lands and realty program. These projects and 

developments would require approval of ROWs that cross the decision area. Under the Proposed RMP, 

restrictions on ROWs in the decision area, combined with restrictions from other management plans in the 

planning area, would have a minor incremental effect by limiting the location of ROWs. 

Minerals and Energy 

The cumulative impact analysis boundary for minerals and energy resources varies by the type of mineral 

resource. The cumulative impact analysis boundary for oil and gas is the planning area and contiguous 

geological structures and oil and gas fields that intersect the planning area. The cumulative impact 

analysis boundary for coal is the planning area and the boundaries of adjacent coal fields (Alton, 

Kaiparowits, and Kolob). The cumulative impact analysis boundary for locatable minerals is the planning 

area. The cumulative impact analysis boundary for mineral materials is the planning area and adjacent 

mineral material sources. The development of the West-wide energy corridor project could lead to an 

increased interest in oil and gas activities. Stipulations on oil and gas leasing in the decision area would 

have a minor effect on the ability to develop oil and gas resources. The expansion of U.S. Highway 89 

and continued development along U.S. Highway 89 and SR 12 and in local communities could increase 

the demand for mineral materials. The mineral material closures in the decision area would have a minor 

incremental effect on the ability to develop mineral materials. 

Areas of Critical Environmental Concern 

The cumulative impact analysis boundary for ACECs is the potential ACEC boundaries. Cumulative 

impacts from the implementation of other resource decisions within and outside of the decision area on 

currently designated and potential ACECs would be minimal, with the exception of mineral and OHV 

decisions. The nature of the R&I values associated with the potential ACECs tends to result in impacts 

that occur quickly but recover slowly, if at all in the case of some visual impacts and impacts on cultural 

sites. As such, any impact would result in an incremental increase in the potential for irreparable damage 

to R&I values. Under the Proposed RMP, only the Cottonwood Canyon ACEC would be designated; 

management associated with other resource program decisions would protect the R&I values, resources, 

processes, or systems in the other potential ACECs. Management of adjacent lands would incrementally 

protect the R&I values from irreparable damage. 
 Cumulative Impacts 

Proposed RMP and Final EIS Chapter 4 

Kanab RMP 4-167 

Wild and Scenic Rivers 

Impacts to WSRs would result from the river being managed to maintain its classification, free-flowing 

nature, and ORVs. Incremental impacts likely would not occur because eligible rivers are reviewed during 

the suitability process, and suitability is based on the environmental and economic consequences that 

would result from designation. In addition, the suitable segments are within existing WSA boundaries and 

would be protected from potential impacts. Because the BLM has no control over potential modification 

to a river’s shoreline or any other form of development on non-public lands, minor incremental impacts 

could occur in these areas. Management actions to pursue land acquisitions of non-BLM lands to 

accomplish resource management goals would provide opportunities to manage ORVs and to mitigate 

any efforts that could impact the river’s tentative classification or free-flowing nature. 

Other Designations 

The cumulative impact analysis boundary for the Old Spanish National Historic Trail is the extent of the 

Old Spanish National Historic Trail. Adjacent federal land management agencies would be required to 

provide protection to this national designation. However, development on state and private land through 

scattered BLM land associated with both segments could incrementally decrease the historic character of 

the landscapes. In addition, road improvement projects and water projects could result in additional 

development within the segments of the Old Spanish National Historic Trail. These could incrementally 

reduce the historic character of the landscapes associated with both segments. The Proposed RMP 

management actions would maintain some of the character of the Highway 89/20-Garfield County 

segment, especially on the northern portions of that segment, regardless of cumulative actions. The 

Proposed RMP management actions would protect the historic nature of the Old Spanish National 

Historic Trail. 

The cumulative impact analysis area for byways and backways is the extent of the ways. Cooperating 

with the managing authorities of the byways and backways to protect and preserve the associated 

landscape values would maintain and enhance these values and provide for heritage tourism opportunities. 

This cooperation could be accomplished through implementation-level planning and site developments 

that could interpret these resources and provide expanded visitor services in the area. 

Social and Economic Conditions 

The cumulative impact analysis boundary for social and economic conditions is the socioeconomic study 

area, which includes the entirety of Garfield and Kane counties. Such impacts would include economic 

and social impacts related to short-term economic stimuli and possible short-term local community 

service impacts related to major construction projects and resource extraction activities in the 

socioeconomic study area. In addition to the coal mine on decision area lands, such major projects also 

would include the following, if and when they occur: the Lake Powell pipeline, construction of a divided 

highway parallel to U.S. Highway 89, an energy pipeline through the area, Jackson Flat Reservoir 

(proposed by the Kane County Water Conservancy District), and development of tar sands in Glen 

Canyon. The Proposed RMP management actions would allow for the increased demand for mineral 

materials (sand and gravel) to complete these major projects. The completion of these projects would 

indirectly allow for economic and population growth and the expansion of communities. Conversion of 

private agricultural lands to residential and other uses as the area grows would increase the importance of 

BLM public lands to the maintenance of the economy and culture of livestock grazing. The importance of 

BLM public lands to maintenance of other local livelihoods, customs, and culture also would depend on 

cumulative decisions regarding management of other lands in the area, including NPS, USFS, BLM, 

GSENM, and state and private lands. 
Cumulative Impacts 

Chapter 4 Proposed RMP and Final EIS 

4-168 Kanab RMP 

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Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-1 

CHAPTER 5—CONSULTATION AND COORDINATION 

This chapter describes the efforts undertaken by the Bureau of Land Management (BLM) throughout the 

process of developing the Proposed Resource Management Plan (RMP)/Final Environmental Impact 

Statement (EIS) to ensure the process remained open and inclusive to the extent possible. This chapter 

also describes efforts to comply with legal requirements to consult and coordinate with various 

government agencies. These efforts include public scoping; designating cooperating agencies; receiving 

and responding to public comments; consulting with state, local, and tribal governments; and determining 

whether the Proposed RMP/Final EIS is consistent with tribal, state, local, and county plans. 

BLM land use planning activities are conducted in accordance with National Environmental Policy Act of 

1969 (NEPA) requirements, Council on Environmental Quality (CEQ) regulations, and U.S. Department 

of the Interior (USDOI) and BLM policies and procedures implementing NEPA. NEPA and the 

associated laws, regulations, and policies require the BLM to seek public involvement early and 

throughout the planning process in order to develop a reasonable range of alternatives of proposed actions 

and to prepare environmental documents that disclose the potential impacts of proposed actions and 

alternatives. In addition, Title II, Section 202 of the Federal Land Policy and Management Act (FLPMA) 

directs the BLM to coordinate planning efforts with Native American Indian tribes, other federal 

departments, and agencies of state and local governments as part of its land use planning process. 

Specifically, FLPMA Section 202(b)(9) directs that BLM “land use plans ... shall be consistent with State 

and local plans to the maximum extent [those plans are] consistent with federal law and the purposes of 

this Act.” This chapter documents this consultation and coordination. 

5.1 COLLABORATIVE MANAGEMENT

The USDOI is committed to a collaborative approach to public land management. The more that people 

can be empowered as stewards of the land, the more effective the implementation of the Department’s 

conservation mission will be. To improve stewardship at all levels of government and “to foster a Nation 

of citizen stewards,” the Secretary of the Interior has advanced a four C’s philosophy: conservation 

through communication, consultation, and cooperation (USDOI 2006). 

The BLM has sought for public communication by providing information to the public and extending 

several requests for information throughout the planning process. This has provided a valuable exchange 

of ideas with interested organizations and publics. The process of this outreach is described below in the 

public participation section. 

Federal regulation directs the BLM to invite eligible federal agencies, state and local governments, and 

federally recognized Indian tribes to participate as cooperating agencies when developing or revising 

resource management plans (43 Code of Federal Regulations [CFR] 1610.3-1(b)). These agencies are 

invited to participate because they have jurisdiction by law or can offer special expertise. Cooperating 

agency status provides a formal framework for these governmental units to engage in active collaboration 

with a lead federal agency in the planning process. 

Following publication of the Notice of Intent (NOI) to prepare the Draft EIS, Kanab Field Office (KFO) 

representatives met with representatives from Kane and Garfield counties, Utah. As a result of these 

meetings, the BLM entered into a memorandum of agreement (MOA) with each county, formalizing the 

counties as cooperating agencies in the RMP revision. In addition, there is a statewide agreement between 

the BLM and the State of Utah (including departments and divisions, such as the Division of Wildlife 

Resources [UDWR] and Division of Parks and Recreation) to be included as cooperating agencies in 
Chapter 5 Proposed RMP and Final EIS 

5-2 Kanab RMP 

BLM RMP revisions. The BLM also provided opportunities for interested Native American tribes to 

become cooperating agencies. Only the Kaibab-Paiute Tribe requested cooperating agency status, and the 

BLM entered into an MOA formalizing the Tribe’s status as a cooperating agency. 

As directed by 43 CFR 1610.4, the BLM has collaborated with the cooperating agencies during data 

inventory and information collection, analysis of the management situation, formulation of alternatives, 

analysis of effects of alternatives, and selection of the preferred alternative, although the decision to select 

a preferred alternative remained the exclusive responsibility of the BLM (43 CFR 1610.4-7). Throughout 

the planning process the BLM invited the cooperating agencies to provide planning information on 

various planning topics, including geographic information system (GIS) data layers and other county- or 

state-level information. The BLM invited designated representatives from the cooperating agencies to 

attend each interdisciplinary team (ID team) meeting. Representatives from the agencies were also invited 

to several sub-ID team meetings that specifically addressed resources within the agencies’ area of special 

expertise and/or resources for which they have jurisdiction by law. 

The BLM sought further input from all cooperating agencies by affording them the opportunity to review 

and provide comments on planning documents (i.e., Scoping Report, Socioeconomic Baseline Profile, 

Analysis of the Management Situation, Alternatives, Preliminary Draft EIS, Draft RMP/EIS, and the 

Preliminary Proposed RMP/Final EIS). Throughout the planning process, the cooperating agencies 

worked with the BLM and provided verbal and/or written comments that helped to develop this Proposed 

RMP/Final EIS. 

5.2 NATIVE AMERICAN CONSULTATION

In accordance with the National Historic Preservation Act (NHPA) and several other legal authorities (see 

BLM Manual 8120), and in recognition of the government-to-government relationship between tribes and 

the Federal Government, the BLM has initiated Native American consultation efforts related to 

preparation of the Kanab RMP. In December 2004, the BLM provided official notification of the land use 

plan (LUP) revision to 21 tribes/groups through certified mail with return receipt requested. The BLM 

mailed notification requests to the following tribes/groups: 

• Kaibab-Paiute Tribe 

• Cedar Band of Paiutes 

• Indian Peak Band of Paiutes 

• Kanosh Band of Paiutes 

• Koosharem Band of Paiutes 

• Shivwits Band of Paiutes 

• San Juan Southern Paiute 

• Navajo Nation Historic Preservation Department 

• Navajo Nation—Coppermine Chapter Coordinator 

• Navajo Nation—Navajo Mountain Chapter 

• Navajo Nation—Cameron Chapter 

• Navajo Nation—Kaibeto Chapter 

• Navajo Nation—Tuba City Chapter Coordinator 

• Navajo Nation—Bodaway/Gap Chapter 

• Navajo Nation—Olijato Chapter 

• Navajo Nation—Coalmine Canyon Chapter Coordinator 

• Navajo Nation—Lechee Chapter 

• Hopi Tribe 

• Hopi Tribe—Hopi Cultural Preservation Office 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-3 

• Ute Cultural Rights and Preservation 

• Pueblo of Zuni 

The notification letter invited tribal governments to become involved in the planning process and outlined 

potential consultation opportunities throughout the planning process. The letter also requested input on 

issues and concerns to be considered during the planning process and initiated efforts to identify areas of 

traditional cultural concern. As of July 2005 the Kaibab-Paiute Tribe has officially responded to initial 

consultation requests and has signed an MOA formalizing cooperating agency status. The Navajo Tribe 

did not request cooperating agency status, but has requested periodic updates by remaining on the RMP 

mailing list and receiving planning bulletins. No other tribes replied to the notification letter. 

Copies of the Draft RMP/EIS have been sent to all tribes noted in the above list for review and comment. 

Consultation will continue throughout the planning process and in preparing the Proposed RMP/Final 

EIS. 

In this planning effort the BLM is not acting as the agent of Indian trust assets, and there are no trust 

assets involved. Although public land resources in the decision area are not Indian trust assets, the BLM 

must make an affirmative effort to consult with Native American tribes and must consider their input 

fairly. However, public land decisions are based on multiple-use principles and a complex framework of 

legal responsibilities, not on property principles associated with Indian trust assets. 

5.3 INTERGOVERNMENTAL CONSULTATION AND COORDINATION

FLPMA Section 202(b)(9) directs that the BLM shall consider those “State, local, and tribal plans that are 

[relevant] in the development of land use plans for public lands; assist in resolving, to the extent practical, 

inconsistencies between Federal and non-Federal Government plans, and shall provide for meaningful 

public involvement of State and local government officials ... in the development of land use decisions 

for public lands.” The BLM identified the following state and local plans as relevant to this planning 

process: 

• Kane County General Plan, 1998 

• Kane County General Plan, as amended in 2007 

• Garfield County General Plan, as amended in 1998 

• Garfield County General Management Plan, Resource Management Amendment, 2007 

• Garfield County Economic Development Plan, 2007 

• State Comprehensive Outdoor Recreation Plan, 2003 

• Utah Comprehensive Wildlife Conservation Strategy, 2005 

• Scenic Byway 12 Corridor Management Plan, 2001 

• Coral Pink Sand Dunes State Park General Management Plan, 2004. 

As noted in Section 5.1, Collaborative Management, Kane and Garfield counties and the State of Utah are 

cooperating agencies and were provided opportunities to provide input throughout the planning processes. 

Consistency with agency and local and state government plans was primarily accomplished through 

frequent communications and cooperative efforts (meetings and communications) between the BLM ID 

team and these cooperating agencies. This regular communication has ensured that potentially 

inconsistent decisions could be identified early and resolved to the extent possible. Appendix 16, County 

General Plan Public Land Decisions Summary, contains decisions from the Garfield and Kane counties 

General Plans that apply to public land management. Combining communication with cooperating 

agencies, ID team review of Appendix 16, reviews of the plan consistency section in the Analysis of the 
Chapter 5 Proposed RMP and Final EIS 

5-4 Kanab RMP 

Management Situation, and review of other statewide plans ensured that the Proposed RMP is consistent 

with state and local plans to the extent possible.

The BLM cultural resource management program operates in accordance with 36 CFR 800, which 

provides specific procedures for consultation between the BLM and the State Historic Preservation 

Officer (SHPO). The SHPO has been included as a cooperating agency within the MOA with the State of 

Utah. The BLM has coordinated with the SHPO during the development of the Draft RMP/EIS, 

specifically addressing how cultural resources may be affected. A copy of the Draft RMP/EIS was sent to 

the SHPO for review and comment. 

During the preparation of the Coal Unsuitability Report, the BLM coordinated with the State of Utah 

(Governor’s Office and UDWR) and U.S. Fish and Wildlife Service (USFWS). The BLM held several 

meetings with the State of Utah and USFWS to coordinate information about species in the Kanab 

planning area. The BLM and the State of Utah, in coordination with USFWS, jointly identified federal 

lands with habitat for species of high interest including elk, mule deer, and Greater sage-grouse. 

5.4 CONSULTATION AND COORDINATION WITH OTHER FEDERAL 

AGENCIES

In developing the Proposed RMP/Final EIS, the BLM coordinated with numerous other federal agencies. 

There are some legal statutes requiring official consultation with some federal agencies. Coordination and 

consultation (as necessary) efforts are described below. 

5.4.1 U.S. Fish and Wildlife Service 

Consultation with USFWS is required under Section 7(c) of the Endangered Species Act of 1973 (ESA) 

prior to initiation of any project by the BLM that may affect any federally listed or endangered species or 

its habitat. This RMP revision is considered to be a major project and the Final EIS defines potential 

impacts on threatened and endangered species as a result of management actions proposed in the 

alternatives. USFWS staff participated in ID team meetings and was provided drafts of alternative 

decisions for discussion and input. 

The BLM requested a list of federally listed threatened or endangered plant and animal species present in 

the decision area on December 13, 2004; USFWS responded to this request by providing the list of 

species to be considered in the planning process on December 15, 2004. Due to the length of the planning 

process, the BLM requested USFWS to confirm the list of species prior to impact analysis in early April 

2006; USFWS responded in mid-April 2006, providing a reference to the USFWS Mountain-Prairie 

Region website listing of Utah Endangered Species by county. The KFO used this list throughout 

preparation of the Final EIS. 

During the preparation of the Coal Unsuitability Report, the BLM coordinated with USFWS to evaluate 

the coal unsuitability criteria defined in 43 CFR 3461.5. The BLM informally consulted with USFWS to 

identify habitat designated or proposed as critical and determined by both agencies to be of essential 

value. In addition, the BLM coordinated with USFWS to identify federal lands with high-priority habitats 

for migratory bird species. 

As part of the formal consultation with the USFWS on this Proposed RMP/Final EIS, a Biological 

Assessment (BA) has been provided to the USFWS for review and comment. The BLM determined that 

the implementation of the Proposed RMP/Final EIS “may affect” the species on which this consultation 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-5 

occurred. The USFWS may concur with BLM’s determination via memorandum or prepare a biological 

opinion. 

5.4.2 National Park Service 

Contacts were made early in the planning process with Zion National Park, Bryce Canyon National Park, 

and Glen Canyon National Recreation Area (NRA), the three national park units that share boundaries 

with the Kanab planning area. BLM representatives met with National Park Service (NPS) representatives 

during scoping and discussed issues of concern. Zion and Bryce Canyon National Parks provided 

comments during the scoping period, and representatives from the NPS attended public scoping meetings. 

Issues raised by the NPS were specifically addressed during alternative development. All three NPS units 

were provided copies of the Draft RMP/EIS for review and comment. 

5.4.3 U.S. Forest Service 

The KFO shares common boundaries with the Dixie National Forest. USFS is engaged in revising its 

LUP at the same time that BLM is revising its plan. As well as sharing boundaries, the two agencies share 

some common issues. BLM communication with the Dixie National Forest regarding the planning 

process has been largely informal, addressing those boundary issues that the two agencies share such as 

Wild and Scenic River (WSR) suitability. The Dixie National Forest was provided a copy of the Draft 

RMP/EIS for review and comment. 

5.4.4 Environmental Protection Agency 

NEPA regulations require that EISs be filed with the Environmental Protection Agency (EPA) for review 

and comment (40 CFR 1506.9). The Kanab Draft RMP/EIS was submitted to the EPA for review as 

required by CEQ regulations. 

5.5 CONSISTENCY WITH OTHER PLANS

This Proposed RMP/Final EIS has been prepared by the KFO with assistance from the BLM Utah State 

Office and the cooperating agencies. This is the second in a series of three NEPA documents released to 

the public during the federal land use planning process. The Draft RMP (the first NEPA document) was 

sent to the public on October 12, 2007 with an associated 90-day comment period until January 10, 2008. 

The BLM planning regulations require that RMPs be “consistent with officially approved or adopted 

resource-related plans, and the policies and procedures contained therein, of other Federal agencies, State 

and local governments, and Indian Tribes, so long as the guidance and RMPs also are consistent with the 

purposes, policies and programs of Federal laws and regulations applicable to public lands” (43 CFR 

1610.3-2(a)). To ensure such consistency, finalized plans were received from federal, state, and local 

agencies as well as tribal governments. These same agencies received copies of the Draft RMP/EIS for 

review and comment, and will receive copies of this Proposed RMP/Final EIS. As stated previously, 

FLPMA Section 202 requires the BLM to coordinate land use planning activities with other federal 

agencies, state and local governments, and Indian tribes. FLPMA also requires BLM to ensure that 

consideration is given to non-BLM plans that are pertinent to the development of the RMP, assist in 

resolving inconsistencies between Federal and non-Federal Government plans, and provide for 

meaningful public involvement of other federal agencies, state and local government officials, and Indian 

tribes in the development of the RMP. 
Chapter 5 Proposed RMP and Final EIS 

5-6 Kanab RMP 

The BLM is aware that there are specific county and state plan decisions relevant to aspects of public land 

management that are discrete from and independent of federal law. FLPMA requires that the development 

of an RMP for public lands must be coordinated and consistent with county plans to the extent possible 

by law and inconsistencies between Federal and non-Federal Government plans be resolved to the extent 

practical (FLPMA, Title II, Section 202 (c)(9)). However, the BLM is bound by federal law. As a 

consequence, there will be an inconsistency that cannot be resolved or reconciled where state and local 

plans conflict with federal law. 

Thus, while county and federal planning processes under FLPMA are required to be as integrated and 

consistent as practical, the federal agency planning process is not bound by or subject to county plans, 

planning processes, or planning stipulations. In addition, the relevant goals, objectives, or policies of a 

county are often equivalent to an activity or implementation-level decision and not an LUP decision. The 

very specific county goals would be addressed in any subsequent BLM activity or implementation-level 

decision. 

Table 5-1, Table 5-2, Table 5-3, Table 5-4, and Table 5-5 outline the planning consistency of the 

Proposed RMP with the approved management plans, LUPs, and controls of other agencies with 

jurisdiction in or adjacent to the planning area. With few exceptions, the Proposed RMP/Final EIS is 

consistent with the Kane and Garfield counties’ plans. The authorized officer will continue to collaborate 

with federal agencies, state and local governments, and Indian tribes on implementation of the RMP and 

on pursuing consistency with other plans and will move toward integration of such plans to the extent that 

they are consistent with federal laws, regulations, and policy directives. 

Table 5-1. Garfield County General Plan (January 1998) 

Resource Garfield County General Plan Decision Consistent

Solid Waste 

The county will develop a policy regarding the amount of solid waste it 

will accept from public lands and develop a fee schedule for public lands 

solid waste management. 

N/A 

Air Quality The preservation of clean air is one of the county’s goals. Most areas 

are Class 2 and development is permitted. Yes 

Water Quality 

The county supports using unused water resources, using existing 

sources in the most efficient manner, eliminating existing pollution, and 

preventing new pollution. 

Yes 

Economic 

The county supports aggressively pursuing coal and other mineral 

resource development, exploring tourism and recreational opportunities, 

retaining and expanding existing agricultural/timber-related businesses, 

increasing Payments in Lieu of Taxes (PILT), and creating new 

attractions and recreational facilities. BLM and U.S. Forest Service 

(USFS) land management practices should encourage economic 

ecological sustainability. 

Yes 

Land/Realty 

State school land exchanges should consider future impacts on the 

growth of county communities. 

State school land/federal land exchanges should increase “in county” 

state land acreage totals or county benefiting economic value. 

Existing public access to public lands should be preserved and 

enhanced, and all Revised Statute (RS) 2477 rights-of-way (ROW) 

should be preserved. 

Transfers of private lands to federal/state ownership should not result in 

a net “private land” acreage loss, unless they result in long-term, 

ongoing economic benefit to the county. 

Yes 

Safety The county reserves the right to establish user fees for search and N/A 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-7 

Resource Garfield County General Plan Decision Consistent

rescue activities, based on a user pay concept. 

Wildlife 

Wildlife numbers should be established for designated areas. The 

introduction of any exotic plant or animal species into the county should 

not take place without formal concurrence by the County Commission 

and public hearings should be held. Watchable wildlife areas should be 

developed. 

Yes 

Grazing The number of animal unit months (AUM) allocated should be expanded 

to the full carrying capacity of the forage resource. Yes 

Timber 

Partnerships should be created and should promote long-term timber 

industry development in order to stabilize, maintain, and expand the 

industry through the combined efforts of business and the public. 

The county wants to ensure that forests are maintained as a healthy 

renewable resource. 

Yes 

Wild and Scenic 

Rivers 

The county will comment on and may develop and submit designation 

proposals to the appropriate federal agencies. Yes 

Table 5-2. Garfield County General Management Plan Resource 

Management Amendment (December 2007) 

Resource Garfield County Resource Management Amendment Consistent

Air Quality 

Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Yes 

Geology, 

Topography, and 

Climate 

Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Yes 

Soil Resources 

Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Yes 

Water Resources 

Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Yes 

Vegetation 

Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Yes 

Noxious/Invasive 

Weeds 

Large infestations of Tamarisk and Russian Olive have impacted many 

of the streams, riparian areas, and groundwater resources of the county. 

Continued efforts are needed to completely eradicate the species and 

protect the area from recurrent infestations. 

Yes 

Special Status 

Species (Threatened, 

Endangered, and 

Sensitive) 

Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Yes 

Fish and Wildlife Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

Yes 
Chapter 5 Proposed RMP and Final EIS 

5-8 Kanab RMP 

Resource Garfield County Resource Management Amendment Consistent

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Forage 

It is the county’s position that forage allocations be balanced between 

competing users based on fair and equitable assumptions and 

considering local goals and desires. Perhaps the greatest concern is that 

there needs to be a clear understanding of much how forage is available 

to be allocated between livestock and wildlife, and how much of that 

forage goes to each. 

Yes 

Wildland Fire 

Ecology 

Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Yes 

Cultural Resource 

Management 

The county identifies several desired conditions and policies related to 

improving inventory, completing compliance in a timely manner, 

retaining existing resources, constructing a curation facility, capitalizing 

on economic opportunities associated with research and identification 

(etc.), and issuing permits. 

Yes 

Paleontological 

Resources 

The county identifies several desired conditions and policies related to 

improving inventory, completing compliance in a timely manner, 

retaining existing resources, constructing a curation facility, capitalizing 

on economic opportunities associated with research and identification 

(etc.), and issuing permits. 

Yes 

Visual Resources 

Each federal agency has its own system for classifying visual resources 

and for scenery management. No two agencies are completely 

consistent with the county’s planning efforts or expressed desires. 

Generally, Visual Classification Areas are more restrictive than needed 

outside National Parks and Designated Wilderness. 

No 

Forestry and 

Woodland Products 

Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Yes 

Transportation 

County-desired conditions and policies include resolving issues in a 

timely manner; preserving access to public and private lands; 

recognizing the transportation network; resolving RS 2477 issues; 

incorporating sufficient scope to reduce additional analysis; eliminating 

the unauthorized use of cross-country travel on public and private lands; 

and working cooperatively with federal agencies to resolve valid existing 

rights, transportation needs, maintenance requirements, improvement 

projects, and other ROW and/or scope issues. 

Yes 

Minerals and Energy 

Development 

Management direction for this resource or resource use has not been 

completed. It is intended that management direction for this resource or 

resource use will be completed, subject to public comment, and adopted 

at some point in the future. 

Yes 

Special Designations 

Current settings, need for management changes, desired conditions, 

policies, goals, objectives, and criteria related to special designations 

were described by the county. Management actions must be consistent 

to the extent allowed by law with Garfield County’s General 

Management Plan. Unless directed by federal or state law, management 

actions that are contrary to the stated positions are inconsistent with 

Garfield County’s General Management Plan. Where no body of law 

exists regarding land management decisions or where decisions are left 

to the agencies’ deference or discretion, management actions must be 

consistent with the positions identified in this plan. 

No 

Wilderness The county identifies several desired conditions and policies related to No 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-9 

Resource Garfield County Resource Management Amendment Consistent

designating eligible and suitable wilderness identified by the county; 

releasing other lands from wilderness character; compensating the 

county for visitor services; ensuring that wilderness, primitive and nonmotorized types of recreation, and non–Wilderness Study Area 

(WSA)/wilderness characteristics areas be based on county-approved 

designations; and ensuring that BLM lands not designated as wilderness 

be developed to the extent allowed by law for commodity production and 

to enhance socioeconomic conditions. 

Research Natural/ 

Geological/Botanical 

Areas 

The county identifies several desired conditions and policies. Before 

designations are made, the proposal needs to meet the county’s 

identified criteria; a thorough inventory must be made to consider 

whether a similar area is already being protected; these areas must be 

consistent with the county’s plan and, absent federal law to the contrary, 

be subject to local law, ordinance, or other special consideration; and 

areas must be limited to only those that can provide significant scientific 

information and interpretive opportunities while preserving the custom 

and culture and enhancing socioeconomic conditions. 

N/A 

Scenic 

Byways/Highways 

It is the county’s objective to promote these designations as showcases 

of multiple use and to oppose management of adjacent lands that is 

inconsistent with the Garfield County General Management Plan. 

It is the policy of Garfield County to cooperate with other agencies to 

determine the demonstrated need and the minimum land necessary to 

accomplish desired outcomes. 

It is the policy of Garfield County to support only Scenic Highways that 

are consistent with local bodies of law, ordinances, and plans and are 

the subject of a cumulative environmental review that determines the 

impact on local and regional environments and social and economic 

impacts caused by designation. 

Yes 

Areas of Critical 

Environmental 

Concern 

The county will be proactive in the management of areas of critical 

environmental concern (ACEC). Approximately 1,041,245 acres of 

Garfield County’s 3,331,065 acres are included in Bryce Canyon 

National Park, Capitol Reef National Park, Canyonlands National Park, 

Glenn Canyon National Recreation Area, and the Grand Staircase–

Escalante National Monument (GSENM). There is also one designated 

Wilderness Area managed by the USFS. It is the county’s position that 

relevant/important scenic, cultural, and recreation lands (approximately 

one-third of the county) are already protected. 

The county will support only those ACEC designations that can be 

demonstrated to have relevant and important values as defined herein 

that are being threatened with irreparable damage. 

Yes 

Wilderness Study 

Areas 

It is the county’s policy to support Wilderness designation for lands that 

the county has deemed eligible and suitable for Wilderness under Public 

Law 88-577. 

It is the county’s policy to oppose Wilderness designation and/or 

management for wilderness characteristics on lands that the county has 

deemed are not eligible and suitable for Wilderness designation under 

Public Law 88-577. 

It is the county’s policy, to the extent allowed by law, that all lands 

deemed not eligible and suitable for Wilderness designation and/or 

management for wilderness characteristics be released from prescriptive 

management and returned to commodity production or multipleuse/sustained-yield management. 

It is the policy of the county to work cooperatively with land managing 

agencies, the State of Utah, and Utah’s Congressional Delegation to 

have the lands identified through the county review, study, and 

recommendation process appropriately designated and managed. 

Yes 
Chapter 5 Proposed RMP and Final EIS 

5-10 Kanab RMP 

Resource Garfield County Resource Management Amendment Consistent

The county agrees that some public lands need specific restrictions, but 

it believes those restrictions should be the minimum necessary and 

should be developed in a spirit of cooperation, ensuring the greatest use 

and enjoyment by the public and local residents. 

Areas identified in the Utah BLM Statewide Wilderness Final EIS as 

failing to meet outstanding solitude or primitive recreation standards 

should not be managed for primitive or semi-primitive non-motorized 

recreation. 

National Trails 

It is the policy of the county to consider each proposed trail on a caseby-case basis, considering other values that might be affected by 

designation, subject to goals and objectives of the Garfield County 

General Management Plan and demonstrated need including 

outstandingly remarkable values (ORV) emphasized by designation. 

Yes 

Wild and Scenic 

Rivers 

It is the county’s policy that, once undertaken, all Wild and Scenic River 

(WSR) evaluations be completed through the Suitability stage. 

It is the county’s policy to support only those river segments that meet 

the quality standards set forth by the county in a public supported 

process. 

Yes 

Backcountry/ 

Roadless/Primitive 

Areas 

It is the county’s goal to work cooperatively with federal land 

management agencies regarding designation of 

backcountry/roadless/primitive areas. 

It is the county’s policy to manage only those areas identified in the 

Garfield County General Management Plan as Rec Ib – Near Wilderness 

as Backcountry/Roadless/ Primitive. Any deviation from the plan without 

approval of the County Commission is inconsistent with the local 

planning process. 

Backcountry/roadless/primitive areas shall be designated and managed, 

to the extent allowed by law, in accordance with the county’s stated 

desired conditions. 

N/A 

It is the county’s goal to establish SRMAs only for resources that 

significantly enhance the socioeconomic vitality, community viability, 

custom, and culture while expanding agency financial, infrastructure, 

and management support to fully develop, use, and promote enjoyment 

of the resource. 

It is the county’s policy to oppose the designation of SRMAs where 

management scenarios restrict use and enjoyment of resources or 

where financial, infrastructure, and management commitments fail to 

fully develop use and enjoyment of resources. 

SRMAs are inconsistent with primitive recreation because SRMAs 

require intense management, increased facilities, and investments that 

impact the land. These requirements conflict with the concepts of 

primitive recreation (“untrammeled by man,” “without man’s influence,” 

and “infrequent contact with man and his influence”). 

SRMAs are an appropriate management tool to fulfill agency 

responsibility to ensure traditional, diverse recreation relating to crosscountry travel and open off-highway vehicle (OHV) use. 

The county will consider and support/oppose SRMA management on a 

case-by-case basis for lands that contain special features of recreation 

interest that do not qualify for ACEC, WSR, or other special designation. 

Yes 

Special Recreation 

Management Areas 

(SRMA) 

Failure to allocate at least 1 percent of agency land in the county as 

SRMAs (or other appropriate designations) for cross-country travel 

and/or open OHV use is considered an abrogation of recreation planning 

responsibility and is inconsistent with the Garfield County General 

Management Plan. 

No 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-11 

Resource Garfield County Resource Management Amendment Consistent

Non-WSA Lands with 

Wilderness 

Characteristics 

The county accepts and adopts the BLM determination reached in the 

original Wilderness Inventory that these lands clearly and obviously lack 

wilderness characteristics and incorporates the inventory and 

determinations by reference. 

The county adopts the determination identified on page A1, column 3, 

paragraph 1 of the Utah 1996 Wilderness Re-Inventory that these areas 

do not have wilderness characteristics on every acre. 

The county adopts the determination identified on A1, column 3, 

paragraph 1 of the Utah 1996 Wilderness Re-Inventory that non-WSA 

lands with wilderness characteristics located adjacent to WSAs were not 

evaluated. 

Where inconsistencies exist between the original wilderness inventory 

conducted as directed by Congress in response to the Wilderness Act of 

1964 and the Utah 1996 Wilderness Re-Inventory, the county adopts the 

original inventory and determinations as correct, accurate, and the 

best/most current data. In addition, the county rejects inconsistent 

findings of the Utah 1996 Wilderness Re-Inventory as inaccurate and 

based on subjective, unauthorized criteria. 

It is the county’s policy that non-WSA lands with wilderness 

characteristics be managed for commodity production or multiple use 

and sustained yield. Management actions must be consistent to the 

extent allowed by law with the Garfield County General Management 

Plan, and failure to comply will be considered arbitrary and capricious. 

No 

Visual Resource/ 

Scenery 

Management 

Visual resource management (VRM) is subjective and discretionary 

management that is not consistent with the county’s General 

Management Plan and fails to meet the standards required by FLPMA 

202(c). 

It is the county’s policy that any specific action to manage or change 

visual management or scenery classifications must comply with the 

Garfield County General Management Plan or be approved by the 

Garfield County Commission. 

The county General Management Plan will serve as the governing body 

of local law concerning the management of visual resources. Before any 

discretionary action can be taken or approved by federal land managers, 

it must be shown that the action has been subjected to direct, indirect, 

and total cumulative impact analysis; have the support of the local Board 

of County Commissioners; and be consistent with the county Resource 

Management Plan. 

Establishment of visual resource/scenery management classifications 

that place restrictions on public lands without considering cumulative 

impacts associated with congressional designations and preservation 

areas (National Parks, National Monuments, National Recreation Areas, 

and Designated Wilderness) is inconsistent with Garfield County’s 

General Management Plan. 

The county supports the least restrictive Visual Resource Classification 

allowed by law unless otherwise approved by the county General 

Management Plan or the County Commission. 

The county deems VRM scenarios that are more restrictive than the 

least restrictive allowed by law to be in conflict and inconsistent with the 

county General Management Plan unless authorized by the Plan or the 

County Commission. 

No 

No Surface 

Disturbance 

The county has developed a component for surface disturbing activities 

as part of the General Management Plan to provide consistency across 

agency boundaries. Before any action is taken that will place an area 

into this no surface occupancy (NSO) the following criteria shall be 

followed: 

No 
Chapter 5 Proposed RMP and Final EIS 

5-12 Kanab RMP 

Resource Garfield County Resource Management Amendment Consistent

1. A demonstrated need; threat to human health, safety, or welfare of the 

human environment; or a critical environmental issue that can be 

managed by no other designation must exist. 

2. A demonstrated need must be brought before the Garfield County 

Board of Commissioners for discussion. 

3. Prior to a final agency action the proposal must be brought to the 

attention of the Public Lands Steering Committee and local community 

governments, and public hearings must be held so that all aspects, 

issues, and concerns of local citizenry can be discussed. 

4. Best management practices (BMP) must be developed and an 

environmental document must be completed addressing the total 

cumulative impacts on the biological environment, social and emotional 

impacts, and economic impacts on the local area. 

5. When the process is complete, the Board of Commissioners will 

accept, reject, or suggest modifications of the proposal and make a final 

decision on which action will be in the best interest of the county. 

6. That decision will be considered as final local law in Garfield County. 

Special Protective 

Orders 

Special Protective Orders will be considered only as a management tool 

used as a last resort. 

It is the county’s policy that Special Protective Orders be used only in 

areas where there are remarkable values; a demonstrated need for the 

protection, safety, and health of persons or other human needs; 

emergency conditions; and with the concurrence of the Garfield County 

Commission. 

N/A 

Multi-Agency 

Concerns 

The Garfield County Commission is a duly elected body and represents 

a legal subdivision of state government. The county must be a full 

partner in all laws, ordinances, policies, planning, and needful decisions 

relating to management of public lands in Garfield County. 

With the increasing influx of visitors to public lands, providing public 

services has become increasingly burdensome. Federal and state 

agencies must accept their share of the responsibility in providing critical 

services. Managers and visitors are jointly responsible for impacts on 

public services. 

The county will classify public lands in the county consistent with federal 

procedures for visual resource/scenery management, recreation 

opportunity spectrum analysis, wise stewardship, and responsible 

protection of the health and welfare of the land. 

The county will support management of public lands in accordance with 

Garfield County’s General Management Plan and Land Use Policy. 

Multiple-use. lands administered by the Federal Government, unless 

specifically withdrawn through congressional mandate for specific 

purposes, must be managed under the principles of “multiple use and 

sustained yield.” Federal land managers are inconsistent with the 

definition of “multiple use.” Multiple use means, but is not necessarily 

limited to those items historically and traditionally practiced, both 

consumptive and non-consumptive, which include grazing, mining, 

recreation, oil and gas exploration, timber production (to include wood 

products such as fence posts and firewood), wildlife and vegetative 

management, and water use and development. Garfield County asserts 

these uses are generally compatible, and true “multiple use” 

management allows the land and its resources to be used for multiple 

uses simultaneously or in concert with each other. More than one use 

can occur at the same time, and many activities are mutually beneficial. 

Wilderness values should not be applied as suitability criteria in 

determining grazing capacities in designated wilderness or wilderness 

study areas. Rangeland health standards should be used for grazing 

Yes 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-13 

Resource Garfield County Resource Management Amendment Consistent

allocations. 

County custom, culture, and economic stability depend on agriculture, 

livestock production, mining, tourism, recreation, the timber industry, the 

continued use and availability of public lands, and accompanying 

resources. Federal and state management plans must identify and 

address the impacts their proposed management decisions and 

practices have on traditional resource uses, custom, and culture. 

Sufficient land within the county has been designated for primitive 

recreation and preservation purposes (parks, monuments, recreation 

areas, and wilderness). The county opposes additional lands 

administered under single use management schemes unless specifically 

approved by the County Commission. 

The county actively supports public land practices that provide for 

traditional multiple uses, support the custom and culture of the county, 

and enhance commodity production consistent with man’s role as 

steward of the land. 

Public Access. Garfield County supports motorized and non-motorized 

access to public lands. Access to public land has a direct impact on the 

county’s economic stability, custom, and culture. Open access maintains 

stability in the county. Garfield County will participate in all relevant 

federal and state access decisions, including RS 2477 determinations, 

Title V issues, closure discussions, and transportation decisions. 

The county has developed a transportation system that identifies the 

minimum infrastructure necessary to maintain the county’s custom, 

culture, and socioeconomic needs. County concurrence must be sought 

prior to any reduction in access to prevent negative impacts on the 

sustainability of local communities. 

Given the importance of public land access, the county asserts that 

roads, paths, ways, and trails constitute valid existing rights if created 

prior to the passage of FLPMA and/or enabling authority. 

Multi-Agency 

Concerns 

Sufficient land within the county has been designated for primitive 

recreation and preservation purposes (parks, monuments, recreation 

areas, and wilderness). The county opposes additional lands 

administered under single use management schemes unless specifically 

approved by the County Commission. 

The county declares federal actions regarding RS 2477 are unjust, 

illegal, and have placed an unfair burden on Garfield County to protect 

its ROWs. Garfield County will aggressively protect its right to public 

access. Agencies that adopt management alternatives that impact the 

transportation network prior to final determination of jurisdiction are 

failing to recognize valid existing rights. Restrictions on existing roads, 

paths, ways, and trails prior to final determinations of jurisdiction are 

speculative, arbitrary, capricious, and inconsistent with the Garfield 

County General Management Plan. 

No 

Livestock Grazing 

Wilderness values should not be applied as suitability criteria in 

determining grazing capacities in designated wilderness or WSAs. 

Rangeland health standards should be used for grazing allocations. 

County custom, culture, and economic stability depend on agriculture, 

livestock production, mining, tourism, recreation, the timber industry, the 

continued use and availability of public lands, and accompanying 

resources. Federal and state management plans must identify and 

address the impacts that their proposed management decisions and 

practices have on traditional resource uses, custom, and culture. 

Yes 

Lands/Realty 

Sufficient land within county has been designated for primitive recreation 

and preservation purposes (parks, monuments, recreation areas, and 

wilderness). The county opposes additional lands administered under 

Yes 
Chapter 5 Proposed RMP and Final EIS 

5-14 Kanab RMP 

Resource Garfield County Resource Management Amendment Consistent

single-use management schemes unless specifically approved by the 

County Commission. 

The county actively supports public land practices that provide for 

traditional multiple uses, support the county’s custom and culture, and 

enhance commodity production consistent with man’s role as steward of 

the land. 

Private and Public Land Ratios. Public land acreage currently owned 

and managed by federal and state agencies is more than sufficient for 

the public interest. Approximately 94 percent of the county is owned or 

controlled by federal and state entities. Sufficient acreage exists in the 

National Parks System, National Monument System, and other areas of 

special designation. The county has a “no net loss of private land” and 

“no expansion of National Parks/Monuments” position relative to federalstate property exchanges and transfers without the approval of the 

County Commission. The determination of “no net loss” should consider 

both acreage and values. The county supports a “net gain of private 

lands” regarding acreage and value. 

It is therefore the policy of the county to place maintenance and 

improvement of transportation facilities as a higher priority than 

protecting visual resources adjacent to those facilities. Where existing 

transportation facilities are present (roads, paths, ways, trails, airstrips, 

trailheads, parking areas, airports, etc.), the area is considered to have 

enhanced visual characteristics because the public has an opportunity to 

view it. BMPs that support appropriate visual resource objectives will be 

applied on transportation maintenance and improvement projects. 

The county supports motorized and non-motorized access to public 

lands. Access to public land has a direct impact on the county’s 

economic stability, custom, and culture. Open access maintains stability 

in the county. Garfield County will participate in all relevant federal and 

state access decisions, including RS 2477 determinations, Title V 

issues, closure discussions, and transportation decisions. 

The county has developed a transportation system that identifies the 

minimum infrastructure necessary to maintain the county’s custom, 

culture, and socioeconomic needs. County concurrence must be sought 

prior to any reduction in public land access to prevent negative impacts 

on the sustainability of local communities. 

Given the importance of public land access, the county asserts roads, 

paths, ways, and trails constitute valid existing rights if created prior to 

the passage of FLPMA and/or enabling authority. 

Yes 

Access 

The county declares federal actions regarding RS 2477 are unjust, 

illegal, and have placed an unfair burden on Garfield County to protect 

its ROWs. The county will aggressively protect its right to public access. 

Agencies that adopt management alternatives that impact the 

transportation network prior to final determination of jurisdiction are 

failing to recognize valid existing rights. 

No 

Recreation and 

Tourism 

Visitors to public lands have a direct bearing on the economic well being 

of the county and its communities. Visitors also impact county services 

including search and rescue, emergency medical, solid waste collection 

and disposal, law enforcement, and fire response. The county supports 

increased recreational activity on public lands. However, federal and 

state agencies must acknowledge and more aggressively address the 

impacts associated with their visitors. Federal and state land managers 

are jointly responsible with their visitors to compensate the county for 

public services. 

The county adopts BLM’s Final Wilderness EIS finding that primitive 

recreationists spend approximately $4.10 per day. 

Yes 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-15 

Table 5-3. Garfield County Economic Development Plan (2007)

Resource Garfield County Economic Development Plan Consistent 

Economic 

Development 

The county’s economy has expanded from chiefly farm-based and 

natural resource extraction to one which includes industry, retail, 

tourism, and other service-oriented businesses. The county must 

continue to seek innovative ways to diversify its economy and provide 

job opportunities for all county citizens, safeguard precious and 

irreplaceable resources, and wisely plan for change. 

Yes 

Table 5-4. Kane County General Plan (June 1998) 

Resource Kane County General Plan Consistent

Goals 

The county’s goal in regard to federal land management planning 

processes includes an active, ongoing partnership that will be consistent 

with county goals and policies when not constrained by federal law. 

Yes 

Agricultural Land 

Uses 

Ensure the retention of a viable and vibrant agricultural base by 

preserving appropriate area for permanent and temporary agricultural 

and open spaces. Do not allow uses adverse to the continuance of 

agricultural activities. 

Yes 

Transportation The resolution of the RS 2477 ROW controversy in Kane County is key 

to the county’s ability to manage transportation. Yes 

Environment 

The county will address erosion and salinity control, water quality 

impacts, and associated concerns when land use proposals are 

reviewed. Its goal is to maintain or improve the primary landscape, soil, 

vegetation, and watershed resources in a manner that perpetuates and 

sustains a diversity of uses while fully supporting the county’s custom, 

culture, economic stability, and viability. 

Yes 

Public Services and 

Facilities 

The county will identify needed utility and transportation corridors and 

will use BLM and USFS corridor plans. Yes 

Rehabilitation and 

Conservation 

The county’s conservation efforts will focus on the rehabilitation of the 

land base in order to improve the functioning of natural systems for the 

benefit of residents and visitors. 

Yes 

Economic 

Development 

The county will be an active partner with other governments to foster a 

sustainable, broad-based economy that allows traditional economic uses 

to remain vibrant while fostering new economic activities that expand 

economic opportunity, use available natural resources, and protect 

important scenic and social qualities. 

Yes 

The county insists that federal land management plans promote the 

multiple-use/sustained-yield concept of public lands use. Yes 

The county rejects federal attempts to impose integral vistas, Class I air 

attainment areas, buffer zones, critical habitat designation, and other 

means to further restrict uses of the small private land base. 

No 

The county will identify BLM parcels of land needed for community 

development purposes. These parcels will be noted in the 

Kanab/Escalante RMP. 

Yes 

Public Lands 

General 

The county maintains that BLM will continue to allow the use of federal 

lands for recreation and public purposes, including access roads and 

parking areas in locations receiving tourist visitation. Yes 
Chapter 5 Proposed RMP and Final EIS 

5-16 Kanab RMP 

Resource Kane County General Plan Consistent

The county believes that key scenic areas where tourist and local 

resident access is essential will be identified in the area BLM office and 

included on the General Plan map. 

Yes 

The county will not accept any form of ecosystem management of 

federal lands if such planning impacts the use and enjoyment of the few 

private land holdings. 

No 

The county’s position is that there will be no net increase of federal 

lands. Yes 

Visual Resource 

Management 

The county believes that VRM on federal lands cannot be allowed to 

impede the legal uses of private land. Yes 

Acquisition and 

Easements 

The county’s position of acquisition or easements across private lands 

by a federal land management agency should be reviewed by the 

County Commission and any concern should be fully addressed in the 

NEPA documentation for the acquisition. 

Yes 

Threatened and 

Endangered Species 

The county will continue to oppose any listing of a threatened or 

endangered species that does not include an analysis of the impacts on 

the economic base. 

N/A 

Social and Economic 

The county maintains that all federal land management agencies should 

include a full assessment of the social and economic impacts of 

management actions. 

Yes 

Rehabilitation 

The county wishes to provide for landscape vegetation maintenance and 

improvement that will support the restoration of suspended AUMs, 

allocation of continuously available temporary non-renewable use as 

active preference, and continued use and/or increased use of state 

school endowment trust lands. 

Yes 

Water Quality 

The county wants the requirements for water quality contained in the 

State of Utah Water Quality Plan to be met. It also maintains that vested 

water rights and control of in-stream flow should be complied with to 

help maintain/improve riparian and aquatic areas. 

Yes 

Habitat 

The county wishes that habitats be maintained, improved, or 

disturbances mitigated in order to sustain viable and harvestable 

populations of big game and upland game species as well as 

wetland/riparian habitat for waterfowl, furbearers, and a diversity of other 

game and non-game species. 

Yes 

Land Disposal 

The county wishes to use agricultural or mining entry, land exchange, 

and land sale for disposal of all public lands that are difficult and 

expensive to manage and do not serve a significant public need or 

where disposal will serve important public objectives. 

Yes 

Mineral Resources 

The county recognizes environmentally responsible exploration and 

development based on a preponderance of scientific evidence for 

locatable mineral, oil, gas, geothermal, and common variety mineral 

resources on BLM-administered lands opened to location under mining 

and other appropriate statutes. 

Yes 

Cultural Resources 

The county suggests a Management Action Plan that will determine the 

condition, content, and relevance of cultural resource sites and increase 

education, recreation, socio-cultural, and scientific uses of cultural and 

paleontological resources. 

Yes 

Conifer Management 

The county’s goal is to maintain or improve conifer tree health, diversity, 

and wildlife/watershed values through active management and to 

prevent pinyon-juniper encroachment. 

Yes 

Recreation The county provides for high-quality recreational opportunities and 

experiences at developed and undeveloped sites by allowing historic 

Yes 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-17 

Resource Kane County General Plan Consistent

uses and access, maintaining amenities, and providing new sites. It also 

pursues increased public access opportunities for motorized and nonmotorized settings through acquisition of ROWs or easements. The 

county recognizes that multiple recreation uses are mandated by the 

multiple-use concept and that BLM must provide for adequate recreation 

resources. 

WSAs and Wild and 

Scenic Rivers 

The county seeks immediate congressional designation action on all 

WSA and WSR recommendations to release these areas for multipleuse management and in the interim prevent, minimize, or mitigate 

impairment or degradation of such areas to the extent that congressional 

actions are not preempted. 

N/A 

ACEC Designations 

The county promotes multiple use and believes that the added 

management layer be evaluated and that areas should be released that 

no longer qualify. 

Yes 

Air Quality 

The county calls for compliance with the National Ambient Air Quality 

Act and State of Utah regulations and their standards to prevent 

significant deterioration. 

Yes 

Wilderness 

Characteristics 

The General Plan was 

amended at the end of 

the public lands 

section for the 

following areas: 

Canaan Mountain, 

Moquith Mountain, 

Orderville Canyon, 

Orderville Gulch, 

Vermilion Cliffs, 

Parunuweap Canyon, 

and Upper Kanab 

Creek. 

The county goals are to achieve and maintain a continuing yield of 

mineral resources, livestock grazing, water resources, and traditional 

access to outdoor recreational opportunities; open all roads that appear 

on the county’s most recent transportation map and provide for such 

additional roads and trails as may be necessary from time to time; 

protect prehistoric rock art, three dimensional structures, and other 

artifacts and sites recognized as culturally important and significant by 

the SHPO; manage so as to not interfere with the property rights of 

private landowners located in these regions; and manage the regions so 

as to not interfere with the fiduciary responsibility of the State of Utah 

School and Institutional Trust Lands Administration (SITLA) with respect 

to trust lands located in that region. The county believes that managing 

part or all of the regions for wilderness characteristics would violate 

FLPMA, contradict the state’s public land policy, and contradict the 

foregoing county plans of regions; that imposing any of the ACEC 

designation alternatives currently under consideration in the Kanab RMP 

revision process would contradict the county’s plan for managing the 

regions; that including any river segment in the National Wild and Scenic 

Rivers System would violate the National Wild and Scenic Rivers Act 

and related regulations, contradict the state’s public land policy, and 

contradict the county’s plan for managing the regions; and that a VRM 

Class I or II rating for any part of the regions would contradict the state’s 

public land policy and contradict the county’s plan for managing the 

regions. 

No 

Table 5-5. State of Utah Code 63j-4-401 

Resource State of Utah Code 63j-4-401 BLM 

ACECs It is the policy of the State of Utah to withhold 

support for ACEC designation unless or until 

relevant and important values or significant 

natural hazards are clearly identified and the area 

requires special management protections not 

afforded by normal multiple-use management. 

ACECs should be no larger than necessary and 

management should be no more restrictive than 

necessary to prevent irreparable damage to 

relevant and important values or protect human 

The potential ACECs brought forward for 

designation into the Proposed Plan have 

gone through a rigorous and stringent 

process in accordance with FLPMA, the 

planning regulations at 43 CFR 1600, Land 

Use Planning Handbook (H- 1601-1), and 

in accordance with BLM Manual 1613 and 

ACEC Policy and Procedures Guidelines 

(45 FR 57318). Appendix 14 outlines the 

process the interdisciplinary team 
Chapter 5 Proposed RMP and Final EIS 

5-18 Kanab RMP 

Resource State of Utah Code 63j-4-401 BLM 

safety. To the extent allowed by federal law, 

management prescriptions should comport with 

the plans and policies of the State and of the 

county where the proposed designation is located. 

These prescriptions should not result in 

management equivalent to that afforded 

congressionally designated wilderness areas. 

underwent to determine whether a 

nominated ACEC had relevance and/or 

importance values. The size of the 

proposed ACECs is limited only to the 

area(s) of geography where the relevance 

and importance values are manageable to 

protect and prevent irreparable damage. In 

the Proposed Plan, the potential ACECs 

generally do not have redundant special 

designations and/or other existing 

protections applied. 

However, the Cottonwood Canyon ACEC 

overlies a portion of a WSA because 

additional restrictions above those required 

under the IMP were necessary to protect 

the relevance and importance values of this 

ACEC. 

The potential ACECs carried forward into 

the Proposed Plan necessitate an ACEC 

designation because special management 

protection is necessary (outside of normal 

multiple-use management) to specifically 

protect the relevance and importance 

values within the areas identified. The 

special management prescriptions that 

have been proposed are narrowly tailored 

to protect the identified relevant and 

important values; none of which are 

recognized as wilderness resources. For 

these reasons, the potential ACEC 

decisions carried forward into the Proposed 

Plan are considered by BLM to be 

consistent with Utah Code 63j-4-401. 

Wild and Scenic 

Rivers 

It is the policy of the State of Utah that federal 

land managers should refrain from applying a 

non-impairment management standard to river 

segments inventoried as “eligible” for inclusions in 

the national Wild and Scenic Rivers and all 

eligible segments should promptly be evaluated 

for suitability. The State of Utah will work with 

federal land managers to identify suitable 

segments and work towards a recommendation to 

congress for designation where careful analysis: 

(1) identifies and evaluates regionally significant 

segments, (2) addresses the impact designation 

will have on physical, biological, and economic 

resources, (3) demonstrates that suitable 

segments have water present and flowing at all 

times, and (4) not interfere with water resources 

development. 

Interim management of suitable segments should 

not interfere with development of valid existing 

water rights, including development of waters 

apportioned to the State under all interstate 

compacts or agreements, including the Bear River 

The State of Utah has worked as a 

Cooperating Agency throughout this 

planning process and has been intimately 

involved with the BLM’s wild and scenic 

river planning process. The State has 

assisted Field Office specialists to help 

determine eligibility findings for each of the 

river segments, and has provided social 

and economic expertise and advice as the 

BLM determined which eligible segments to 

carry forward as suitable into the Proposed 

Plan. BLM has committed to working 

cooperatively among Federal, State, and 

local governments and communities during 

the post-planning wild and scenic river 

study phase when statewide 

recommendations for inclusion of river 

segments into the National Wild and Scenic 

Rivers System would go forward to 

Congress. Prior to this post-planning 

phase, BLM would work with affected 

partners to help identify in-stream flows 

necessary to protect the outstandingly 

remarkable values for which the subject 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-19 

Resource State of Utah Code 63j-4-401 BLM 

Compact and the Upper Colorado River Compact. 

To the extent allowable by federal law and where 

not in conflict with state law or policy, interim 

management of suitable segments and 

congressional recommendations for designation 

should be consistent with plans and policies of the 

county or counties where the river segment is 

located. 

river segments were found suitable via this 

planning process. Thus, because there are 

no effects of this planning decision on valid 

existing rights, and because suitability 

findings in this planning process do not 

create new water rights for the BLM, the 

land use planning wild and scenic river 

suitability determinations are found by BLM 

to be consistent with the Utah Code 63j-4-

401. 

Grazing It is the policy of the State of Utah that the citizens 

of the state are best served by applying multipleuse and sustained-yield principles in public land 

use planning and management. Public lands 

should continue to produce food and fiber, and 

the rural character and landscape should be 

preserved through a healthy and active 

agricultural and grazing industry. Land 

management plans should maximize forage 

availability for domestic livestock and wildlife use. 

The State favors active management to restore 

and maintain rangeland health, increase forage, 

and improve watershed for the mutual benefit of 

local communities, domestic livestock, and 

wildlife. 

Adjustments in AUM levels may occur as required 

by range and watershed conditions, based on 

scientific, on-the-ground analysis. Grazing AUMs 

should be placed in suspension where range 

conditions will not sustain the current level of 

AUMs or where necessary to protect range and 

watershed health. Any suspended AUMs should 

be returned to active use when range conditions 

improve. The State generally opposes forced 

relinquishment or forced retirement of grazing 

AUMs but will continue to recognize voluntary 

relinquishments and retirements agreed to prior to 

RMP revisions. 

Grazing decisions carried forward into the 

Proposed Plan are considered by BLM to 

be consistent with Utah Code 63j-4-401. 

Proposed Plan decisions on public lands 

would continue to promote a healthy active 

grazing industry. Forage allocations for 

livestock and wildlife are fully allocated on 

public lands. Numerous RMP decisions 

under other identified resources allow for 

the restoration and maintenance of 

rangeland and watershed health. For 

example, the Proposed Plan provides the 

umbrella to allow implementation-level 

actions for hazardous fuel reductions, fire 

rehabilitation, vegetation treatments, 

riparian improvements, range and wildlife 

habitat improvements, UPCD projects – 

including Healthy Lands Initiative projects, 

seed collection, etc. Minor, if any, 

adjustments to current permitted livestock 

AUMs are made in the Proposed Plan. 

Prior voluntary relinquishments and/or 

retirements have been recognized. 

Wilderness 

Characteristics 

It is the policy of the State of Utah to oppose 

management of public lands as wilderness except 

where congress designates lands as wilderness. 

Under State policy and FLPMA’s multiple-use 

mandate, BLM ascribed management 

prescriptions for non-WSA lands inventoried as 

possessing wilderness characteristics should take 

into account the long-term needs of future 

generations for renewable and non-renewable 

resources, including, but not limited to, recreation, 

range, timber, minerals, watershed, wildlife, and 

fish. Designation as VRM Class I, closure to oil 

and gas leasing, withdrawal from mineral entry, 

and closure to motorized and mechanized use 

affords protections comparable to those 

associated with formal wilderness designation and 

should be avoided for non-WSA lands with 

wilderness characteristics. Non-WSA lands with 

wilderness characteristics should be managed in 

The Proposed Plan identifies certain “nonWSA lands with wilderness characteristics” 

in order to protect, preserve, and maintain 

their wilderness characteristics. BLM 

recognizes that it cannot, through the 

planning process, designate these lands as 

WSAs nor is it possible to manage them in 

accordance with IMP. For example, there is 

no provision to meet the “non-impairment 

criteria” mandated in IMP for WSA 

management. However, in following 

Section 201 of FLPMA, BLM has 

maintained its wilderness inventory and 

has determined that lands previously found 

not to possess wilderness characteristics 

during the FLPMA Section 603 inventory 

process in the late 1970’s and early 1980’s, 

now have been determined to possess 

them. The focus of management in the 
Chapter 5 Proposed RMP and Final EIS 

5-20 Kanab RMP 

Resource State of Utah Code 63j-4-401 BLM 

a manner consistent with the multiple-use, 

sustained yield standard that applies to BLM 

lands other than congressionally designated 

wilderness or WSAs. 

areas carried forward in the Proposed Plan 

is to primarily provide for an experience of 

solitude and primitive recreation. This is 

enhanced by maintaining the naturalness 

of the geographic areas. However, 

management prescriptions do not mirror 

those for WSAs or designated wilderness 

since these two management objectives 

are sufficiently dissimilar that imposing 

similar prescriptions would not allow BLM 

to meet the planning objectives outlined in 

the Draft RMP/Draft EIS. WSAs and 

designated wilderness are rights-of-way 

exclusion areas, closed to fluid mineral 

leasing by law, and do not allow for surface 

disturbing activities. In comparison, lands 

with wilderness characteristics have no set 

management by either law, rule, regulation, 

or policy. The Proposed Plan would allow 

for surface disturbing activities where and 

when they are compatible with enhancing 

management objectives identified in the 

Proposed Plan. 

In order to ensure that BLM’s planning 

decisions regarding the management of 

wilderness characteristics are consistent 

with Utah law, potential adjustments may 

be made in the Record of Decision to 

nomenclature. This editorial change would 

not affect management or goals and 

objectives.

RS-2477 

Assertions 

The State of Utah will defend its interest, and that 

of its political subdivisions, in rights-of-way 

accepted under the self-effectuating grant process 

set forth in Revised Statute 2477 (repealed by the 

Federal Land Policy and Management Act of 

1976) and SUWA v. BLM, 425 F.3d 735 (10th Cir. 

2005). The State of Utah expects and requests 

the BLM to fully consider all information 

concerning individual rights-of-way submitted to 

BLM. Further, the State of Utah expects and 

requests BLM’s consideration of this information 

as part of the preparation and implementation of 

Resource Management or Management 

Framework Plans, and preparation or 

implementation of Transportation Plans as part of 

the ongoing inventory of resources on the public 

lands. 

The Proposed Plan makes no 

commitments with respect to any valid 

existing rights, particularly those 

concerning RS-2477. Chapter 1 of this land 

use plan states that resolution of this issue 

is outside the purview and scope of public 

lands planning efforts and must be 

adjudicated by a court of law or other legal 

means. Therefore, nothing in this plan 

extinguishes any valid rights-of-way or 

alters, in any way, the legal rights of the 

State of Utah to assert RS-2477 rights or to 

challenge any use restrictions imposed by 

the RMP that they believe are inconsistent 

with their rights. 

5.6 PUBLIC PARTICIPATION

The public participation process for the RMP/EIS has been ongoing throughout the development of the 

RMP/EIS and will continue to the Record of Decision (ROD). It includes a variety of efforts to identify 

and address public concerns and needs. In addition to formal public participation activities, informal 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-21 

contacts occur frequently with public land users, industry, and interested persons through meetings, field 

trips, telephone calls, or letters. All public participation applicable to the RMP/EIS has been documented 

and analyzed as part of the planning process and kept on file in the KFO. 

5.6.1 Notice of Intent and Public Scoping Period 

The planning process formally began with the publication of the NOI in the Federal Register on April 2, 

2004, which announced the BLM’s intent to revise its LUPs. The formal public scoping period ended on 

February 15, 2005. The purpose of scoping, as defined by NEPA, is to determine the scope and 

significance of issues related to a proposed action such as the development and implementation of a new 

RMP (40 CFR 1501.7). These issues guide the development of alternatives that will be evaluated in the 

EIS and will ultimately guide development of the RMP. Scoping also provides the public with an 

opportunity to learn about the management of public lands and helps the BLM to identify the public’s 

concerns regarding resources within the decision area. This section provides a summary of the scoping 

process. More information on the scoping process is available in the Scoping Report for the Kanab RMP 

and EIS. 

Public scoping meetings provided an opportunity for interested parties to submit scoping comments and 

to be involved early in the planning process (40 CFR 1501.7). The NOI announced that the BLM would 

hold “public meetings throughout the region in order to promote public involvement in the process.” 

These meetings were announced in the local media and through a planning bulletin and a follow-up 

postcard. Scoping meeting information was available on the active project website (www.kanabrmp.com). 

The news release was also posted on the Utah BLM website. Public scoping meeting announcements 

were available to the public on the project website as early as November 2004, and press releases on 

public meetings appeared on January 12, 2005. The BLM also posted fliers throughout the counties in 

locations of heavy traffic such as post offices, local convenience stores, supermarkets, municipal 

buildings, local businesses, and local recreation sites. Nearly 170 individuals registered at four scoping 

meetings (Table 5-6), providing hundreds of comments addressing a wide range of issues. The number of 

participants in communities closest to the planning area indicates the high level of local interest in the 

planning and management of the area. 

Table 5-6. Public Scoping Meeting Location/Attendance 

Meeting Location Meeting Date Attendance 

Salt Lake City, Utah January 13, 2005 31 

Kanab, Utah January 18, 2005 77 

Escalante, Utah January 19, 2005 30 

Panguitch, Utah January 20, 2005 29 

Total 167 

In addition to receiving comments from public scoping meetings, the BLM solicited written scoping 

comments. Written comments were accepted throughout the public scoping period. Comments received 

shortly after the deadline were accepted to accommodate mail delays. A total of 997 individuals submitted 

written scoping comments. These comments were accepted via mail, e-mail, video, and the RMP website 

(Table 5-7). 
Chapter 5 Proposed RMP and Final EIS 

5-22 Kanab RMP 

Table 5-7. Kanab RMP/EIS Written Comments Medium 

Method of Submittal Responses Received 

Mail or Delivered in Person 64 

E-Mail 904 

Oral (Video) 11 

Web 18 

Total Responses 997 

Throughout the scoping period, more than 1,160 individuals either attended public scoping meetings 

(Table 5-6) or provided comments to the BLM (Table 5-7). As the written comments were analyzed, both 

by computer comparison and by manual review, four general form letters were identified. These letters 

represent 848 (85 percent) of the 997 total responses. Identical letters were analyzed based on the issues 

they raised. Letters with additional text were reviewed manually to determine whether the additional text 

identified issues that the form portion of the letter had not already raised. It is important to note that such 

grouping of identical comments does not reduce the importance of the issues raised. NEPA regulations on 

scoping are clear that the scoping process is not a vote, but an opportunity to “determine the scope and the 

significant issues to be analyzed in depth in the environmental impact statement” and to “identify and 

eliminate from detailed study the issues which are not significant or which have been covered by prior 

environmental review” (40 CFR 1501.7). Therefore, if 800 letters raise the same issue and one letter 

raises a different issue, both issues must be equally considered. 

Analysis of approximately 600 unique comments resulted in the identification of issues to be addressed 

during development of the Kanab RMP. A majority of comments emphasized off-highway vehicle (OHV) 

management, recreation, areas of special designation, and wilderness characteristics. Other issues of high 

interest include livestock grazing, minerals and energy resources, access to public lands, and social and 

economic issues. For each public comment, a position-neutral issue was identified. This process was used 

for all scoping input. 

Further opportunities for public participation were provided in April 2005 during a data call for 

information (e.g., route data, resource inventories, and/or condition) and nominations for areas of critical 

environmental concern (ACEC) and WSRs. In January 2006, the public was invited to provide further 

input in the planning process by commenting on the preliminary ACEC and WSR reports. For each of 

these requests for comments, the BLM provided at least 30 calendar days for public response as directed 

by BLM planning regulations (43 CFR 1610.2(e)). 

5.6.2 Mailing List 

As directed by 43 CFR 1610.2(d), the BLM has established and maintained a list of “individuals and 

groups known to be interested in or affected by a resource management plan.” This list was initially 

developed from the KFO mailing list and supplemented/updated throughout the planning process. 

Scoping meeting participants were given the option to be added to the mailing list. In addition, 

individuals were able to add themselves to the project mailing list by registering on the project website, as 

well as through requests to be placed on the mailing list by contacting BLM staff. In addition, individuals, 

organizations, or agencies that included an address in written scoping comments were added to the 

mailing list. 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-23 

The mailing list was used during the distribution of planning bulletins and postcards throughout the 

planning process. Postcards were mailed to the entire list, announcing the availability of the Draft 

RMP/EIS and the Proposed RMP/Final EIS. 

5.6.3 Planning Bulletins 

Periodic bulletins and postcards have been developed to keep the public informed of the Kanab RMP 

planning process. Planning bulletins and postcards provided planning updates to individuals, 

organizations, government agencies, and tribes on the mailing list. These updates provided information 

about planning issues and the progress of the planning effort and invited information or comments. Table 

5-8 lists the planning bulletins and postcards that were mailed to the mailing list and placed on the project 

website. 

Table 5-8. Planning Bulletins/Postcards 

Date Released Contents 

December 2004 Bulletin: Described the general purpose and need of the new RMP, planning 

process, project schedule, and scoping meetings locations and dates 

January 2005 Postcard: Scoping meetings locations and dates 

April 2005 Bulletin: Scoping Report availability, results of scoping, request for data, updated 

planning schedule 

December 2005 

Bulletin: Results of data collection availability (Analysis of the Management 

Situation [AMS], Socioeconomic Baseline Report, Mineral Potential Report, 

Evaluation Report for ACECs, WSRs Report), summary of AMS, invitation for 

public input on ACEC and WSRs Reports, new website 

October 2007 Postcard: Draft RMP/EIS availability, public comment processes and dates, public 

meeting locations and dates 

July 2008 Postcard: Proposed RMP/Final EIS availability and information about the 30-day 

protest period 

5.6.4 Website 

The Kanab RMP project website serves as a virtual repository for documents related to RMP 

development, including announcements, bulletins, and RMP-related documents (e.g. mineral report, 

scoping report). Documents are posted as PDF files to ensure accessibility to the widest range of users. 

The web address of the project website has been adjusted several times throughout this planning process, 

as follows: 

• http://www.kanabrmp.com (December 2004–April 2005) 

• No project website available (April 2005–December 2005) 

• http://www.ut.blm.gov/landuseplanning/updates.htm (December 2005–February 2006) 

• http://www.blm.gov/rmp/ut/kanab/ (February 2006–Current). 

While the website had to be removed for a period of the planning process because of concerns with 

USDOI Internet security, other opportunities for public comment were made available (through bulletins 

and a public comment period). In addition, changes in the website location were announced in the regular 

bulletins. 
Chapter 5 Proposed RMP and Final EIS 

5-24 Kanab RMP 

The initial and current website provides the public with the opportunity to send requests to be added to the 

project mailing list to receive periodic bulletins and announcements. During the scoping period, the 

website also provided the opportunity for the general public to submit comments for consideration as part 

of scoping and to add themselves to the project mailing list to receive periodic newsletters and 

announcements. 

5.6.5 Notice of Availability of Draft RMP/EIS 

On October 2, 2007, the BLM filed the KFO Draft RMP/EIS with the EPA. On October 12, 2007, 

respectively, the BLM and EPA published a Notice of Availability in the Federal Register, which date 

marked the beginning of the formal 90-day public review comment period. The Draft RMP/EIS states that 

BLM is revising its current LUP and proposes several alternative ways of managing public lands within 

the Kanab Planning Area. The Draft RMP/EIS was designed to provide a comprehensive look at the 

impacts on natural and cultural resources and resource uses from various planning alternatives. The 

formal 90-day public comment period ended on January 10, 2008. The BLM provided hard copies and 

CDs of the Draft RMP/EIS to cooperating agencies; other federal, state, and local agencies; tribal 

representatives; and the Utah BLM Resource Advisory Committee members. Hard copies and CDs were 

made available to the public at the KFO, Utah State Office, and during public meetings. The Draft 

RMP/EIS was also placed on the BLM’s website and in its public room at the KFO, Utah State Office, 

Salt Lake City library, Garfield County library, and the Kanab City library. In addition, BLM distributed 

postcards to the project mailing list announcing the availability of the Draft RMP/EIS. 

5.6.6 Draft RMP/EIS Public Comment Meetings 

During the 90-day public comment period, the BLM held public meetings in five locations (Table 5-9) in 

an effort to inform the interested and affected public about the Draft RMP/EIS. These meetings were 

attended by 209 people, and were structured in an open house format with BLM specialists available to 

provide information and answer questions. The public was also able to request hard copies or CDs of the 

Draft RMP/EIS and submit written comments at the meetings. The public meetings were announced in 

local newspapers, on the project website, and through postcards mailed to individuals on the Kanab RMP 

mailing list. The BLM also posted fliers throughout the counties in locations of heavy traffic such as post 

offices, local convenience stores, supermarkets, municipal buildings, local businesses, and local 

recreation sites. 

Table 5-9. Draft RMP/EIS Public Comment Meeting Locations/Attendance 

Meeting Location Meeting Date Attendance 

Kanab, Utah November 27, 2007 91 

Escalante, Utah November 28, 2007 15 

Panguitch, Utah November 29, 2007 15 

St. George, Utah December 4, 2007 71 

Salt Lake City, Utah December 5, 2007 17 

Total 209 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-25 

5.6.7 Draft RMP/EIS Public Comment Response Process 

During the 90-day formal Draft RMP/EIS public comment period, the KFO received 8,571 comments. Of 

these, the BLM identified 8,084 to be form letters and 487 to be unique submissions. The BLM carefully 

compiled, reviewed, analyzed, and addressed all submissions, where substantive. Comments from 

cooperating agencies and responses to those comments are addressed in Section 5.6.9 below. Comments 

and responses to other substantive comments are provided in a table format on a CD attached to this 

document. In addition to comments received during the formal public comment period, the KFO received 

additional submissions after the close of the comment period, which BLM maintained in its files. 

According to NEPA, the BLM is required to identify and formally respond to all substantive public 

comments. The BLM developed a systematic process for sorting, reviewing, determining if substantive or 

non-substantive, and responding to substantive comments to ensure all substantive comments were 

tracked and the content seriously considered. A description of this system follows. 

First, BLM developed a coding structure to help sort comments into logical groups by topics and issues. 

Codes were derived from resources covered in the Draft EIS or by common issues. Submissions (letters, 

e-mails, faxes, etc.) were given a unique identifier for tracking purposes and then each submission was 

carefully reviewed to capture all comments, if substantive (more description of this process is set forth 

below). All substantive comments received can be tracked to the original submission. 

Second, BLM created a comment database. For each comment in a unique submission, BLM captured the 

name and address of the commenter, assigned a code to the comment, and captured the text of all 

substantive comments. 

The coding and comment database processes aimed at assisting the ID team in determining if the 

substantive issues raised by the public warranted modification of one or more of the alternatives or further 

analysis of issues and impacts. With the information provided through the public review process, the 

BLM reconsidered the draft alternatives, made changes as appropriate, and developed the Proposed 

RMP/Final EIS. Factual or grammatical errors that led to a change in text are not summarized but were 

incorporated into the Proposed RMP/Final EIS. 

Finally, BLM used the comment database to prepare a narrative summary of the substantive comments. 

Opinions, feelings, and preferences for one element or one alternative over another, and comments of a 

personal and/or philosophical nature were all read, analyzed, and considered, but because such comments 

are not substantive in nature, BLM did not respond to them. 

5.6.8 Public Comments 

During the public comment period, the BLM received 8,571 submissions at public meetings, through the 

project website, and by fax, e-mail, and regular mail from the public, cooperating agencies, other federal 

agencies, Indian tribes, organizations, and businesses. The BLM responded to substantive comments by 

making revisions to the Proposed RMP/Final EIS. If no change was warranted, the BLM responded to the 

substantive comment in writing. The response to substantive comments is included in a table format on a 

CD attached to this document. The BLM considered every comment in the content analysis process, 

whether it came repeatedly from many people with the same message(s) or from a single person raising a 

technical or personal point. In analyzing comments, the BLM emphasized the content of the comment 

rather than the number of times a comment was received. 

Respondents invested considerable time and effort to submit comments on the Draft RMP/EIS. 

Comments covered a wide spectrum of thoughts, opinions, ideas, and concerns. The most commonly 
Chapter 5 Proposed RMP and Final EIS 

5-26 Kanab RMP 

addressed themes included transportation, OHV management, special designations (ACECs, WSRs) and 

wilderness characteristics, recreation, and minerals/energy development. While each person’s viewpoint 

was diligently considered, the threshold analysis involved determining whether a comment was 

substantive or non-substantive. Because NEPA requires that BLM respond only to substantive comments, 

BLM relied on the CEQ’s regulations to determine what constituted a substantive comment. 

A substantive comment does one or more of the following: 

• Questions, with a reasonable basis, the accuracy of the information and/or analysis in the EIS 

• Questions, with a reasonable basis, the adequacy of the information and/or analysis in the EIS 

• Presents reasonable alternatives other than those presented in the Draft EIS that meet the purpose 

and need of the proposed action and addresses significant issues 

• Questions, with a reasonable basis, the merits of an alternative or alternatives 

• Causes changes in or revisions to the proposed action 

• Questions, with a reasonable basis, the adequacy of the planning process itself. 

The BLM NEPA Handbook identifies the following types of substantive comments: 

• Comments on the Adequacy of the Analysis. Comments that express a professional 

disagreement with the conclusions of the analysis or assert that the analysis is inadequate are 

substantive in nature but may or may not lead to changes in the Proposed RMP/Final EIS. 

Interpretations of analyses should be based on professional expertise. Where there is 

disagreement within a professional discipline, a careful review of the various interpretations is 

warranted. In some cases, public comments may necessitate a reevaluation of analytical 

conclusions. If after reevaluation the manger responsible for preparing the EIS (authorized officer 

[AO]) does not think that a change is warranted, the response should provide the rationale for that 

conclusion. 

• Comments Which Identify New Impacts, Alternatives, or Mitigation Measures. Public 

comments on a Draft EIS that identify impacts, alternatives, or mitigation measures that were not 

addressed in the draft are substantive. This type of comment requires the AO to determine if it 

warrants further consideration. If it does, the AO must determine whether the new impacts, new 

alternatives, or new mitigation measures should be analyzed in either the Final EIS, a supplement 

to the Draft EIS, or a completely revised and recirculated Draft EIS. 

• Disagreements with Significance Determinations. Comments that directly or indirectly 

question, with a reasonable basis, determinations regarding the significance or severity of impacts 

are substantive. A reevaluation of these determinations may be warranted and may lead to 

changes in the Final EIS. If after reevaluation the AO does not think that a change is warranted, 

the response should provide the rational for that conclusion. 

Non-substantive comments simply state a position in favor of or against an alternative or a management 

action proposed in an alternative, merely agree or disagree with BLM policy, provide information not 

directly related to issues or impact analyses, or otherwise express an unsupported personal preference or 

opinion. For additional clarification, types of non-substantive comments are as follows: 

• Expressions of Personal Preferences or Opinion. Comments that express personal preferences 

or opinions on the proposals are non-substantive and thus do not require further agency action. 

This includes comments in favor of or against the proposed action or alternatives; comments that 

only agree or disagree with BLM policy; or comments that raise, debate, or question a point of 

fact or policy. However, such comments are summarized whenever possible and brought to the 

attention of the AO. 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-27 

The BLM has reviewed and considered all non-substantive comments, but has not provided formal 

responses to such comments. Although non-substantive comments, including personal preferences and 

opinions, may be considered by the decision-maker as he or she chooses the agency’s proposed plan, they 

generally will not affect the analysis. Table 5-10 and Table 5-11 list the organizations and individuals that 

submitted substantive comments. 

Table 5-10. Organizations that Submitted Substantive Comments 

Beecher Films BLM Arizona Strip Field Office C-4 Ranch 

Canyon Country 4x4 Club Canyon Country Rural Alliance Capital Trail Vehicle Association 

Clarkson Draper & Beckstrom, LLC Coalition to Preserve Rock Art Colorado Plateau Archaeological 

Alliance 

Cox Creek Cattle Company ECOS Consulting Five County Association of 

Governments 

Garfield County Garkane Energy Cooperative, Inc. Grand Canyon Trust 

Hopi Tribe Kaibab Band of Paiute Indians Kanab City Public Works 

Kanab Irrigation Company Kane County Commission Kane County Conservation District, 

Utah Association of Conservation 

Districts (UACD) 

Kane County Water Conservancy 

District 

Land Use Volunteers of Kane 

County 

Lone Peak 4 Wheelers 

McDermott, Will & Emery National Park Service—Bryce 

Canyon National Park 

National Park Service—Zion 

National Park 

National Parks Conservation 

Association 

The Navajo Nation PacifiCorp 

Rising Sun 4X4 Club of Colorado Solihull Society Land Rover Club of 

Colorado 

State of Utah, Public Lands Policy 

Coordination Office 

Southern Utah Wilderness Alliance 

(SUWA) 

Theodore Roosevelt Conservation 

Partnership 

U.S. Environmental Protection 

Agency 

U.S. Fish and Wildlife Service, Utah 

Field Office 

U.S. Geological Survey Utah 4 Wheel Drive Association 

(U4WDA) 

Utah 4x4 Club Utah Farm Bureau Federation Utah Rivers Council 

Utah Rock Art Research Association Utah State Board of Education Wasatch Cruisers 

Western Watersheds Project, Inc. Western Wildlife Conservancy 

Table 5-11. Individuals that Submitted Substantive Comments 

Robert Aiken George and Frances Alderson Frank and Kaye Alleman 

David Armbruster Charles and Nancy Bagley Shane Baird 

Connie Ball Don Black Melanie Boone-Reznick 

Darren Brinkerhoff Norris Brown James Bulkeley 

Marleen Bussma Vaughn Bussma J. Capozzelli 

Tom Carter Bobbi Chaney Jack Christensen 

Dirk Clayson Wayne Cox McClain Cox 
Chapter 5 Proposed RMP and Final EIS 

5-28 Kanab RMP 

Debra Csenge Richard Csenge Evan Day 

Spencer Decker Nate Delaney David Devooght 

Scott Dissel Steven Edmunds Colin Esplin 

Merlin Esplin David Fackrell Walter Fertig 

Jerry and Cindy Foote Thomas Forsythe Anthony Frost 

Sean Frost Brent Gardner Mark Gardner 

Melissa Gardner Tobin Gardner Allen Gilberg 

Dale Grange Tom Grant Kent Grover 

John Gunning Lynn Hague Hal Hamblin 

Susan Hand Jana Hassett Josh Heaton 

Floyd Hiar Garrett Hill Tracy Hiscock 

Russell Howe Scott Howe William Hughes 

Lance Jackson Jennifer Kaufman Jan Kobialka 

Tyler Kokjohn Liz Kolle Alexander Kowalski 

Donald Kramer Karen Kramer Jacalyn and Charles Liebfried 

Christopher Lish Rebecca Mann Bill May 

James McEwen Jay McIlwaine Norman McKee 

Anne McKibbin Jim and Marge Norris Randy and Cynthia Norton 

Tim Peterson Lisa Rasmussen Tim Rasmussen 

Russell Regentine Charles Robinson Jim and Liz Robinson 

David Rodgers Betsy Shade Amber Sharkey 

James and Lorna Sills Desiree Smith Duane Smith 

Oliver Smith Samuel and Janet Smith Donald Sprecher 

Mark Sterkel Margaret Stone Earl Stuker 

Joan Thacher Sedona Thomason Mitch Thompson 

Ross Tocher Gary Tsujimoto Jim and Bonnie Vann 

John Veranth Bob Wallen Ray and Sharon Wells 

Laura Welp Glenn Wimpee Gary Wood 

Tony Wright Lo I and Won Yin Michelle Young 

Timothy Zimmer 

5.6.9 Summary of Comments and Responses 

The results of the content analysis were important to the development of the Proposed RMP/Final EIS. 

From the nearly 8,571 total submissions that BLM received on the Draft RMP/EIS, it extracted 1,111 

individual substantive comments. As required by law, BLM has summarized these comments in this 

Proposed RMP/Final EIS and has presented them along with a response. Comments from cooperating 

agencies and responses to those comments are presented below. The response to substantive comments is 

included on a CD attached to this document. 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-29 

Kaibab-Paiute Tribe Comments and Responses 

Comment: We ask that secondary (tertiary or quaternary) routes just north of our reservation be 

eliminated with the exception of those that we need to retain for administrative access, and otherwise 

made unavailable for public access if there is no other identified function.

Response: The routes in question are necessary in that they provide access to certain areas for 

recreational use such as hunting and OHV operation. However, illegal or unwanted access to reservation 

lands is a recognized problem, and the BLM is willing to work with the Kaibab-Paiute Tribe on gating 

procedures and fencing maintenance in an effort to control reservation access.

Comment: Ed Lamb’s Point is on the reservation and is private land, so it has been, and remains closed 

to non-Indians. Letters to the local newspaper and congressmen notwithstanding, non-Indians using any 

routes that cross the state line onto the reservation are in trespass and will be prosecuted.

Response: The Lamb’s Point route crosses the state line into the Kaibab-Paiute reservation. In 

consultation with the Tribe, the Lamb’s Point route is closed in the Proposed RMP/Final EIS.

Comment: To add insult to injury, according to the DRMP/DEIS, there are no guarantees that the 

archaeological sites will all be mitigated through data recovery - what is the rationale behind allowing 

anything less than 100% data recovery from all of the archaeological sites?

Response: Mitigation through data recovery generally consists of scientific excavation. Because 

excavation is a destructive process, it is used either as a last resort (when other forms of mitigation such 

as avoidance, mapping and collection, or photography are not applicable) or to answer certain research 

questions that cannot be answered otherwise. In some cases, such as with projects where disturbance of a 

large amount of land and cultural resource sites cannot be avoided, it is necessary to select a sample of the 

impacted sites for excavation. This selection process is performed through a data recovery plan. This plan 

is developed by archaeologists working in conjunction with concerned Native American tribes, the 

SHPO, and BLM cultural resource experts.

Comment: We would also argue on the basis of climate change, that the statement made on page 4-15 

about air quality impacts being neither irreversible nor irretrievable, is irresponsible at best.

Response: A growing body of scientific evidence supports the concern that global climate change will 

result from the continued build-up of greenhouse gases in the atmosphere. While uncertainties remain, 

particularly in the area of exact timing, magnitude and regional impacts of such changes, the vast majority 

of scientific evidence supports the view that continued increases in greenhouse gas emissions will lead to 

climate change. This information was added to Chapter 3 of the Proposed RMP/Final EIS and the air 

quality impact analysis was revised in Chapter 4. 

Comment: We require the BLM to follow an Executive Order (later strengthened in another Executive 

Order) that was left out of the RMP/DEIS as a Critical Element but to which the BLM remains subject. 

Please reference Executive Orders 11644 and 11989.

Response: Although not specifically identified in the Draft RMP/EIS, BLM policy and regulation related 

to OHVs is consistent with Executive Orders 11644 and 11989. Appendix K of the Draft RMP/EIS details 

the process used to formulate the transportation system alternatives. This Proposed RMP/Final EIS 

presents the resulting travel management plan, which is also consistent with Executive Orders 11644 and 

11989. 

Comment: Hog Canyon and large portions of Moquith Mountain can be written off, regardless of any 

other values they held at an earlier point in time. We would like to identify Hog Canyon for land disposal 

and let it be sold to the ATV [all-terrain vehicle] clubs for their own management. However, we feel that 
Chapter 5 Proposed RMP and Final EIS 

5-30 Kanab RMP 

those parts of Moquith Mountain that have suffered from OHV abuse would be best served by a transfer 

to Utah state management to become part of Coral Park Sand Dunes.

Response: The existing Hog Canyon OHV area provides a designated OHV area supporting BLM’s 

multiple-use mandate. This area does not meet the FLPMA Section 203 disposal criteria and therefore is 

not available for disposal (Lands and Realty section of Chapter 2 of the Proposed RMP/Final EIS). The 

Moquith Mountain area does not meet the FLPMA Section 203 disposal criteria and therefore is not 

available for disposal.

Comment: As the action described (Draft RMP/EIS alternatives) would have such a large impact on the 

tribal population, (which already suffers from lower wages in comparison to surrounding communities) 

this is a clear case of environmental injustice on a minority and low-income community. Please refer to 

the Environmental Justice section below.

Response: The environmental justice section in the Draft RMP/EIS has been revised to identify the tribe 

as an environmental justice population and to include an impact analysis on this population (Chapters 3 

and 4 of the Proposed RMP/Final EIS). 

Comment: The DRMP/DEIS does not take into account impacts to the socioeconomics, cultural 

resources and health of our people and our watershed. Therefore, we take exception to the conclusion 

that there are no impacts to environmental justice, and ask for a much more thorough analysis that 

includes the population of the reservation.

Response: The environmental justice section in the Draft RMP/EIS has been revised to identify the tribe 

as an environmental justice population and to include an impact analysis on this population (Chapters 3 

and 4 of the Proposed RMP/Final EIS). 

Comment: Being that we have a proven track record for good stewardship, we believe that a tribal I.D. 

should be sufficient to collect materials from the planning area rather than having to obtain permits. If 

that relationship later appears to jeopardize the natural resources, we would recognize a legitimate 

reason to require a permit basis.

Response: The BLM recognizes it has a very good relationship with the local tribes and their use of 

public resources. However, to ensure proper management of its resources, the BLM uses the permitting 

process to know where various activities are taking place and to what extent resource uses are occurring.

Kane County Comments and Responses 

Comment: The County proposes BLM consider recent amendments to the Kane County General Plan 

related to transportation and road issues in the DRMP/EIS planning process.

Response: The BLM did review the information submitted by Kane County and the comments on the 

Draft RMP/EIS. The information was used to make adjustments to the Proposed RMP (see Map 10 of the 

Proposed RMP/Final EIS). A consistency review of the Proposed RMP with the county master plans is 

included in Chapter 5.

Comment: RMP's must be consistent with county transportation plans to the maximum extent allowable 

under Federal Law (FLPMA 1712(c)(9)). The DRMP/EIS has not indicated that the County's plans are in 

any way inconsistent with Federal law.

Response: KFO did analyze and review Kane Country’s transportation plan as part of the travel 

management plan process (see Appendix K of the Draft RMP/EIS). However, certain routes with resource 

issues and concerns were considered for closure to meet RMP goals and objectives under the different 

alternatives. Based on comments from Kane County and the public during the public comment period on 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-31 

the Draft RMP/EIS and further BLM review, adjustments were made to the route network in the Proposed 

RMP/Final EIS (see Map 10 of the Proposed RMP/Final EIS). 

While county and federal planning processes under FLPMA are required to be as integrated and 

consistent as practical, the federal agency planning process is not bound by or subject to county plans, 

planning processes, or planning stipulations. The BLM will identify these conflicts in the Proposed 

RMP/Final EIS so that the state and local governments have a complete understanding of the impacts of 

the Proposed RMP on state and local management options. A consistency review of the Proposed RMP 

with the state and county master plans is included in Chapter 5.

Comment: RMP transportation planning must contain or incorporate by reference maps showing all 

roads in existence, including but not limited to R.S. 2477 and other roads that are part of the County's 

transportation plan, and all other existing roads known to the federal planning agency even if not 

included in a County transportation plan. The DRMP/EIS fails in this regard.

Response: There is no requirement for the BLM to include all roads in existence in the baseline route 

inventory including claimed RS 2477 routes. KFO conducted a complete route inventory in 2005 and 

2006 to develop a route baseline for use in the planning process. BLM employees with global positioning 

system (GPS) equipment digitized the routes while traveling on OHVs and by foot. The digitized route 

data was verified and prepared for interdisciplinary review. In addition, Garfield County provided route 

data in a GIS data layer. Data from the BLM inventory was overlaid with the Garfield County route data, 

and discrepancies were identified, reviewed, and resolved through ground-truthing and resource specialist 

review. Kane County provided paper maps with route data. These maps were reviewed, and any 

additional routes were ground-truthed with GPS and BLM employees. Where GPS data was incomplete, 

recent aerial photography was inspected to complete GIS data gaps. While inventorying the routes, staff 

collected surface type and primary and secondary usage associated with each route.

Comment: Kane County made several comments relating to planning decisions and their affect on RS 

2477 claimed right-of-ways. They also requested that BLM should not take action to close county 

transportation system highways until it has conducted non-binding determinations as to the validity and 

scope of existing rights established along the county’s highways by grants of Congress under RS 2477. 

Response: As stated in Chapter 1 of the Draft RMP/EIS (page 1-13) and Chapter 1 of the Proposed 

RMP/Final EIS under section 1.3.2, “The State of Utah and Kane and Garfield counties may hold valid 

existing rights-of-way in the planning area pursuant to Revised Statute (RS) 2477, Act of July 28 1866, 

chapter 262, 8, 14 Stat. 252, 253, codified at 43 USC 932. On October 21, 1976, Congress repealed R.S. 

2477 through passage of FLPMA. This RMP does not adjudicate, analyze, or otherwise determine the 

validity of claimed rights-of-way. However, nothing in the RMP extinguishes any valid right-of-way, or 

alters in any way the legal rights the state and counties have to assert and protect RS 2477 rights or to 

challenge in Federal court or other appropriate venue any use restrictions imposed by the RMP that they 

believe are inconsistent with their rights.” 

Comment: The DRMP/EIS fails to acknowledge the full American Association of State Highway and 

Transportation Officials (AASHTO) continuum, which includes "local roads" as an integral part of 

highway systems. The DRMP/EIS also fails to address the County's Class D roads, which are established 

and managed with the same public highway status as the County's Class B roads. The clear semantic 

attempt in the DRMP/EIS is to disavow county authority over Class D roads, thereby, assuming unilateral 

BLM authority over such public highways as "routes or ways." This point is addressed further in this 

section of comments. (see DRMP/EIS page 3-82 and 3-83.

Response: There is no requirement for the BLM to acknowledge or comply with AASHTO continuum. A 

“D” route does not equate to a county road assertion. The Draft RMP/EIS does not distinguish between 
Chapter 5 Proposed RMP and Final EIS 

5-32 Kanab RMP 

types of routes (e.g., D or B roads). The Draft RMP/EIS proposes four different alternatives to manage 

these routes. 

As specified in the Draft RMP/EIS, addressing RS 2477 assertions is beyond the scope of this planning 

effort. However, nothing extinguishes any right-of-way or alters in any way the legal rights the State and 

Counties have to assert and protect RS 2477 rights. 

Comment: BLM is now proceeding, through the DRMP/EIS process, to close long established 

county/state transportation system highways unilaterally, without any effort to consult regarding 

consistency with local planning, i.e., the Kane County Transportation System that has been in operation 

before the passage of FLPMA. BLM also failed to consider its legal duty and obligation prior to closing 

highways congressionally granted along R.S. 2477 rights-of-way.

Response: As specified in the Draft RMP/EIS, addressing RS 2477 assertions is beyond the scope of this 

planning effort. However, nothing extinguishes any right-of-way or alters in any way the legal rights the 

State and Counties have to assert and protect RS 2477 rights. 

Comment: The county formally proposes that its claims of congressionally granted ROWs, protected by 

the savings provisions of FLPMA and other provisions of the law, be considered as a relevant issue in the 

DRMP/EIS.

Response: Valid existing rights are considered Administrative Actions by the BLM and do not require a 

specific planning decision to implement. As noted in Chapter 1 under Planning Criteria and as outlined in 

the BLM Land Use Planning Handbook (Section 1601.06G), all decisions made in LUPs and subsequent 

implementation decisions are subject to valid existing rights. The BLM will work with holders of valid 

existing rights to modify proposed actions or activities, subject to agreements, to reduce the effect of the 

actions or activities on resource values and uses. These modifications may be necessary to maintain the 

choice of alternatives being considered during LUP development and implementation and may include 

appropriate stipulations, relocations, redesigns, or delay of proposed actions.

Comment: The Implementation Memorandum "directs affected Interior bureaus to revise any existing 

guidance or policies on R.S. 2477 rights of way consistent with the legal principles established in SUWA 

v. BLM and this memorandum and its attached guidelines." 

BLM planning team's failure to consider the county' right-of-way on the Whitehouse Road and the failure 

to properly consult with the County needs to be corrected. See SUWA v. BLM, Sierra Club v. Hodel and 

Norton RS. 2477 Policy Memorandum.

Response: The Whitehouse Road is located in the Grand Staircase–Escalante National Monument 

(GSENM) and is beyond the scope of this RMP. 

Comment: The Implementation Memorandum "directs affected Interior bureaus to revise any existing 

guidance or policies on R.S. 2477 rights of way consistent with the legal principles established in SUWA 

v. BLM and this memorandum and its attached guidelines." The GSENM and Utah State BLM have not 

complied with this bureau requirement. However, that failure does not absolve field office employees of 

their duty to fully comply with all lawful federal requirements. 

Response: As the KFO has explained in previous responses, adjudicating specific RS 2477 claims is 

beyond the scope of this land use planning effort. BLM acknowledges that it is bound to follow existing 

BLM and USDOI guidance with respect to all aspects of public land management, including requests 

from RS 2477 claimants to improve or maintain RS 2477 ROWs, whether they have been adjudicated in a 

separate proceeding or not. In light of this obligation, BLM believes that the county is referring to 

Instruction Memorandum (IM) 2006-161 (May 26, 2006) when it references the “Implementing 

Memorandum” in its comments on RS 2477 (see pages 8-10, Kane County Comments). As noted, BLM 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-33 

understands that it has an obligation to comply with all valid BLM policy, including IM 2006-161. 

However, because the Proposed RMP/Final EIS makes no decisions with respect to any individual or 

collective RS 2477 claim or claims, addressing how BLM would handle requests from Kane County for 

maintenance or improvement of any specific RS 2477 ROW would be inappropriate and outside the scope 

of the planning effort. BLM does not interpret Secretary Norton’s March 22, 2006 Guidelines, or BLM’s 

subsequent IM 2006-161, to require that BLM adjudicate a specific RS 2477 ROW in order to make land 

use planning decisions regarding areas open, closed, or limited to OHV travel, nor does BLM interpret 

this guidance as limiting BLM’s authority to identify roads open or closed to OHV travel. Both of these 

BLM decisions are appropriate and neither limits a valid RS 2477 claimant’s ability to request a 

determination for maintenance or improvement of an RS 2477 from BLM.

Comment: The DRMP/EIS fails to consider the importance of local government's historic responsibility 

to manage public highway systems across both federally managed lands and non-federally managed. 

lands.

Response: The process used to designate routes is explained in Appendix K of the Draft RMP/EIS. 

Current use and projected access needs or demands were considered in evaluating the travel management 

plan across the alternatives of the Draft RMP/EIS. Impacts on all resources and resource uses from OHV 

use and identified routes are contained in Chapter 4 of the Draft RMP/EIS. 

Comment: The planning team failed to adequately consider those materials in preparing the instant 

DRMP/EIS. The County requests BLM and its employee's review those previously submitted materials 

along with the documentation enclosed with these comments in complying with federal requirements that 

federal planning be consistent with local planning to the maximum extent possible unless constrained by 

federal law.

Response: The process used to designate routes is explained in Appendix K of the Draft RMP/EIS. Kane 

County provided paper maps with route data and its county plan. These maps were reviewed, and any 

additional routes were ground-truthed with GPS and BLM employees. 

FLPMA requires that the development of an RMP for public lands must be coordinated and consistent 

with county plans to the extent possible by law and inconsistencies between Federal and non-Federal 

Government plans be resolve to the extent practical (FLPMA, Title II, Section 202 (c)(9)). As a 

consequence, there will be an inconsistency that cannot be resolved or reconciled where state and local 

plans conflict with federal law. While county and federal planning processes under FLPMA are required 

to be as integrated and consistent as practical, the federal agency planning process is not bound by or 

subject to county plans, planning processes, or planning stipulations.

Comment: BLM planning documents indicate that that BLM, not the County is affecting the closures to 

County roads in the Hog Canyon area. BLM's position is both unnecessary and untenable to the County. 

The County respectfully requests formal consultation to resolve the Hog Canyon road closure 

controversy. (see Appendix

Response: The BLM and Kane County have worked cooperatively to resolve resource issues in the Hog 

Canyon area. BLM is committed to continued cooperation and partnership with the county on this issue.

Comment: The DRMP/EIS maps do not even show the Windmill Road on its maps. The road just 

disappeared. The County has provided information to BLM regarding the R.S. 2477 status of the road. 

Information is included as Appendix J and is incorporated in these comments as part of the County's 

administrative record of an important planning issue not considered. The County requests formal 

consultation to resolve the Windmill Road Closure/
Chapter 5 Proposed RMP and Final EIS 

5-34 Kanab RMP 

Response: Identifying and inventorying new ways within WSAs is beyond the scope of this plan. The 

route inventory within WSAs is based on the initial wilderness inventory (1979-1990). 

The RMP does not adjudicate, analyze, or otherwise determine the validity of the claimed ROWs. The 

BLM will update and adjust the transportation plan and elements of this RMP through plan maintenance 

as RS 2477 ROW assertions are acknowledged administratively or adjudicated by court decision.

Comment: Road Closures within WSAs. Road closures in the DRMP/EIS go beyond the legal 

presumption that BLM cannot unilaterally close and restrict Kane County Transportation System Class B 

and Class D Public Highways (see Appendix A and Appendix B). BLM also exceeded its agency authority 

under WSA interim management requirements by proposing to close roads - not based on the standard of 

impairment or degradation - but simply for the following arbitrary reason: Closures in Parunuweap 

Canyon, North Fork Virgin River, and Orderville Canyon WSAs will be reviewed to determine how OHV 

use in these areas should occur to protect wilderness values (emphasis added) (see DRMP/EIS page 1-

100). BLM did not provide analysis or documentation demonstrating that the public's use of the County's 

Class B and Class D roads and non-county roads are causing impairment or degradation to lands or 

resources within any of the WSAs.

Response: According to the IMP, “If impacts threaten to impair the area’s wilderness suitability, the 

BLM may limit or close the affected lands to the uses causing the problem.” This allows BLM to close 

ways within WSAs if they impact wilderness suitability. Pages 4-234 and 4-235 of the Draft RMP/EIS 

include an impact analysis of OHV use of identified routes (inventoried ways) continuing in the WSAs. In 

addition, BLM’s authority to close ways in WSAs is further discussed on page 2-30 of the Draft RMP 

under management actions for WSAs. 

Comment: The Court also acknowledged that a land use Plan "is not a final implementation decision" 

and that land use plans are normally not used to make site specific implementation decisions." If BLM 

implements road closures through a RMP/EIS ROD it evades IBLA review of the implementation 

decision.

Response: On page 2-1 of the Draft RMP/EIS, it states: “It should be noted that while most of these 

management actions are RMP level, the alternatives also consider the designation of individual routes, 

which is an implementation-level decision that can change over the life of the plan without amending the 

RMP (Appendix K of the Draft RMP/EIS).” These implementation-level decisions are generally 

appealable to the Interior Board of Land Appeals (IBLA) under 43 CFR 4.410. 

As described in the transportation management actions in the Proposed RMP/Final EIS: “BLM, in 

preparing its RMP designations and its implementation-level travel management plans, is following 

policy and regulation authority found at: 43 CFR 8340, 43 CFR 8364, and 43 CFR 9268.” 

Comment: The Kanab FO, at recent direction of the State BLM Office, is proposing to close roads that 

were not necessary to close at the time of Norton v. SUWA. The County submits that the closures were 

driven by State BLM direction and were determined primarily by map review at office desks. The 

proposed agency action was not initiated due to on-the-ground impacts amounting to impairment or 

degradation. BLM has not provided documentation supporting the closures.

Response: Certain routes with resource issues and concerns were considered for closure to meet RMP 

goals and objectives under the different alternatives. Based on comments from Kane County and the 

public during the public comment period on the Draft RMP/EIS and further BLM review, adjustments 

were made to the route network in the Proposed RMP/Final EIS (see Map 10 of the Proposed RMP/Final 

EIS).
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-35 

Comment: The County proposes BLM consider recent amendments to the Kane County General Plan 

related to outdoor recreation opportunities in the DRMP/EIS planning process.

Response: The BLM did review the information submitted by Kane County as its comments on the Draft 

RMP/EIS. A consistency review of the Proposed RMP/Final EIS and the Kane County General Plan is 

included in Chapter 5 of the Proposed RMP/Final EIS. 

Comment: The County strongly objects to the calculation of areas available for motorized versus 

nonmotorized recreation in general acreage terms. Aside from the open area at the Coral Pink Sand 

Dunes, the motorized RMZs and other areas permitting motorized travel are limit motorized travel/access 

to the linear distance of the highways, roads, routes, ways, or trails specifically allowing motorized 

travel. With the closure of areas to cross-country travel any acreage not allowing motorized travel is 

closed to non-motorized travel/access and recreation. The DRMP/EIS needs to calculate the linear 

mileage of routes allowing motorized travel and multiply that figure by ten feet as a reasonable average 

of route width. Acreage closed to motorized access in "limited" or" restricted" motorized areas needs to 

be attributed to nonmotorized travel in planning data. This distinction is critical in calculating and 

analyzing "balance" in considering multiple recreational uses in the planning area. It is also important to 

the local socio-economics and is an inconsistency with local planning. If BLM fails to address this issue 

the County will likely present the calculations as a protest to the plan.

Response: Special Recreation Management Area (SRMA) Recreation Management Zone (RMZ) titles 

(e.g., non-motorized RMZ and OHV RMZ) are not intended to reflect exclusive use of an area for one 

type of recreation activity. For example, there are identified routes open for motorized travel in nonmotorized RMZs. 

Actual acreage closed to motorized access in the limited to designated route category would vary 

depending on the route density in specific areas. For example, 10 miles of designated routes in a 40-acre 

parcel allows more motorized access than 5 miles of designated routes in a 40-acre parcel. 

Comment: The County received information questioning the accuracy of data presented in Table 3-26 

Recreation Visitation. The BLM should provide accurate data supporting the estimate of 20,000 

backpackers. Many of those hiker recreationalists concentrate use in specific areas such as the Wire 

Pass/Coyote Butte area, rather than in the whole of the planning area. The 12 hour user day is 

questionable and results in skewed data. The County believes OHV use is underestimated in the 

DRMP/EIS. The hunting data presented is not believed to be inconsistent with Utah Department of 

Wildlife information presented to the public. Recreation planning should be based on accurate data 

rather than unsubstantiated estimates. The County strongly objects to any reliance on data developed by 

the Sonoran Institute as stated in the County's previous administrative record.

Response: Table 3-26 in the Draft RMP/EIS is based on the recreation management information system 

(RMIS) data collected by the KFO. As stated on page 3-78 of the Draft RMP/EIS, “It is important to note 

that the visitation figures in Table 3-26 are only estimates and do not reflect actual visitation occurring in 

any given year for specific activities in specific areas. Many areas lack direct visitation monitoring 

facilities such as traffic counters or visitor registers. Direct monitoring by BLM staff is focused on areas 

of greater use or conflict. Discrepancies in actual use are also a result of the remote nature of much of the 

decision area that does not receive frequent monitoring. In addition, many of the popular use areas/trails 

are not designated and there is currently no way to accurately determine the actual amount of recreational 

use these areas receive.” As cited in Section 4.1.6, the recreation data is noted as incomplete; however, 

the best available data was used to compile baselines and depict trends in use. Visitor-days are calculated 

as described on pages 3-77 and 3-78. This is the standard BLM definition of visitor-days and is a common 

recreation unit of measure used among federal agencies.
Chapter 5 Proposed RMP and Final EIS 

5-36 Kanab RMP 

Comment: The County previously submitted a Dry Wash Travel Proposal on August 2, 2006. BLM failed 

to consult or consider the County's proposal in developing the DRMP/EIS.

Response: The proposal the commentor raises was considered in Alternative D of the Draft RMP/EIS 

(page 2-82). 

Comment: All SRMAs with a motorized focus should include direction regarding when and how 

additional or expanded routes/areas would be provided should there be a need. The DRMP/EIS should 

take a hard look at development of a mix of single track, i.e., motorcycle and mountain bicycle, and ATV 

trails. The DRMP/EIS should provide the opportunity for the future development of non-motorized trails, 

i.e., hiking and equestrian trails.

Response: As IM 2004-061 notes, plan maintenance can be accomplished through additional analysis and 

land use planning (e.g., activity level planning). BLM will collaborate with affected and interested parties 

in evaluating the designated road and trail network for suitability for active OHV management and 

envisioning potential changes in the existing system or adding new trails that would help meet current and 

future demands. Appendix K of the Draft RMP/EIS includes criteria to be considering in conducting these 

evaluations. 

Appendix D of the Draft RMP/EIS describes in more detail how the SRMAs will be managed. An activity 

level plan for each SRMA will be completed after the ROD is signed. 

Comment: Managing the subject lands (non-WSA lands with wilderness characteristics) according to the 

prescriptions outlined in Alternative C or according to the objectives common to all alternatives would 

clash with state and local policies and county plans for managing those lands, and would thus violate the 

consistency requirement of FLPMA Section 202(c)(9), federal law, BLM policy, and the State of 

Utah/USDOI Settlement Agreement of 2003. 

Response: BLM’s authority for managing lands to protect or enhance wilderness characteristics 

(Alternative C) is derived directly from FLPMA Section 202 (43 U.S.C. 1712). 

This section of BLM’s organic statute gives the Secretary of the Interior authority to manage public lands 

for multiple use and sustained yield. Nothing in this section constrains the Secretary’s authority to 

manage lands as necessary to “achieve integrated consideration of physical, biological, economic, and 

other sciences” (FLPMA, Section 202(c)(2) (43 U.S.C. 1712(c)(2))). Further, FLPMA makes it clear that 

the term “multiple use” means that not every use is appropriate for every acre of public land, and that the 

Secretary can “make the most judicious use of the land for some or all of these resources or related 

services over areas large enough to provide sufficient latitude for periodic adjustments in use” (FLPMA, 

Section 103(c) (43 U.S.C. 1702(c))). FLPMA intended for the Secretary of the Interior to use land use 

planning as a mechanism for allocating resource use, including wilderness character management, among 

the various resources in a way that provides uses for current and future generations. 

BLM has long acknowledged that FLPMA Section 603 (43 U.S.C. 1782) requiring a one-time wilderness 

review has expired. All current inventory of public lands is authorized by FLPMA Section 201 (43 U.S.C. 

1711). In September 2006, the Utah District Court affirmed that BLM retained authority to protect lands it 

determined to have wilderness characteristics in a manner substantially similar to the manner in which 

such lands are protected as WSAs. 

BLM is aware that there are specific state laws relevant to aspects of public land management that are 

discrete from and independent of federal law. However, BLM is bound by federal law. As a consequence, 

there may be inconsistencies that cannot be reconciled. FLPMA requires that BLM’s LUPs be consistent 

with state and local plans “to the extent practical,” but there will be an inconsistency that cannot be 

resolved where state and local plans conflict with federal law. BLM will identify these conflicts in the 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-37 

Proposed RMP/Final EIS so that the state and local governments have a complete understanding of the 

impacts of the Proposed RMP on state and local management options. 

Finally, the Utah v. Norton Settlement Agreement does not affect BLM’s authority to manage public 

lands. This Agreement merely remedied confusion by distinguishing between WSAs established under 

FLPMA Section 603 and those lands required to be managed under Section 603’s non-impairment 

standard, and other lands that fall within the discretionary FLPMA Section 202 land management process.

Comment: The area was also proposed by the County as part of a motorized SRMA and is used 

extensively by OHV recreationalists. BLM failed to consult in a meaningful way with the County, as a 

cooperating agency, in the management planning for this area.

Response: As directed by 43 CFR 1610.4, the BLM has collaborated with the cooperating agencies 

during data inventory and information collection, analysis of the management situation, formulation of 

alternatives, estimation of effects of alternatives, and selection of the preferred alternative, although the 

decision to select a preferred alternative remained the exclusive responsibility of the BLM (43 CFR 

1610.4-7). Throughout the planning process the BLM invited the cooperating agencies to provide 

planning information on various planning topics, including GIS data layers and other county- or statelevel information. The BLM invited designated representatives from the cooperating agencies to attend 

each ID team meeting. Representatives from the agencies were also invited to several sub-ID team 

meetings that specifically addressed resources within the agencies’ area of special expertise and/or 

resources for which they have jurisdiction by law. The BLM sought further input from all cooperating 

agencies by affording them the opportunity to review and provide comments on planning documents (i.e., 

Scoping Report, Socioeconomic Baseline Profile, Analysis of the Management Situation, Alternatives, 

and Preliminary Draft EIS). Throughout the planning process, the cooperating agencies worked with the 

BLM and provided verbal and/or written comments that helped to develop this Draft RMP/EIS.

Comment: Additionally DRMP/EIS fails to address and fully consider the impact of Alternatives B and C 

(and the interim management assumptions in Alternative A) on the Colorado River Compact.

Response: BLM RMP decisions with regards to Wild and Scenic River designation do not affect the 

Colorado River Compact. The Colorado River Compact granted the signatory states a general authority to 

impound water as necessary within their borders for the purpose of making beneficial use of waters 

allocated to each state under the compact. The compact did not establish specific rights to impound waters 

in specific locations within each state. The authority to create specific rights to build and operate storage 

facilities was delegated to state governments, which have the authority to allocate water within their 

boundaries. Absent a specific decree or state permit authorizing a storage structure, there is no specific 

right to store water at any location on the streams within the planning area. In addition, a legal prohibition 

on building storage structures does not occur as part of a BLM suitability determination on a stream 

reach. The legal prohibition occurs only when Congress acts to designate a specific stream reach as part 

of the National Wild and Scenic Rivers System (NWSRS). When making WSR designations, Congress is 

obligated to consider the impact of that designation on Utah’s rights under the Colorado River Compact 

and to consider the impact on existing storage decrees and permits.

Comment: The DRMP/EIS is conflicted in its language. On the one hand it recognizes its duties in 

stating, "all land tenure adjustments must be in conformance with applicable LUPs and be subject to 

valid existing rights." (emphasis added) )DRMP/EIS page 3-85). On the other hand, the section titled 

"Rights-of-Way" identifies 202 ROWs within the decision area but fails to recognize R.S. 2477 rights-ofway as they are protected in FLPMA sections 509(a), 701(a), and 701(h). The DRMP/EIS is remiss in 

excluding existing R.S. 2477 ROWs and multiple-use activities to the extent and on the basis addressed in 

the DRMP/EIS. (see DRMP/EIS page 4-193).
Chapter 5 Proposed RMP and Final EIS 

5-38 Kanab RMP 

Response: The Draft RMP/EIS is not conflicted in its language. As provided under the planning critieria 

in Chapter 1 of the Draft RMP/EIS, the RMP does not adjudicate, analyze, or otherwise determine the 

validity of the claimed ROWs. The BLM will update and adjust the transportation plan and elements of 

this RMP through plan maintenance as RS 2477 ROW assertions are acknowledged administratively or 

adjudicated by court decision.

Comment: Livestock grazing allotments withdrawn as grazing districts apply to the provisions 

acknowledged in the DRMP/EIS in stating, "BLM can make recommendations to designate, revoke, or 

extend withdrawals, but only the Secretary has the authority to actually take these actions." (see 

DRMP/EIS page 3-87). This language conflicts with other language purporting to "revoke" the use of 

grazing allotments.

Response: Withdrawal, as described on pages 3-86 and 3-87 of the Draft RMP/EIS and defined in the 

glossary, does not apply to livestock grazing management. Livestock grazing is managed according to its 

own policy and regulation. 

Comment: Use limits are similarly vague and seemingly insupportable and would be difficult to monitor 

or enforce. The DRMP/EIS analysis does not support the action and the action is inconsistent with local 

planning. It is yet another restriction that cannot or will not be enforced but will create controversy (see 

DRMP/EIS pages 2-41, 2-81, and 2-47).

Response: The special recreation permit management action allows for flexibility in determining if the 

permits are required. Permits are required based on the criteria listed on page 2-80. If a permit is required 

then the group size would be limited to 25 people. On a case-by-case basis, BLM can authorize 

exceptions to this limit after evaluation of possible or likely resource impacts.

Comment: The County respectfully requests that inconsistencies between the DRMP/EIS and the County's 

entire administrative record as established by these comments be adequately resolved before the ROD is 

approved.

Response: The BLM is aware that there are specific county and state plan decisions relevant to aspects of 

public land management that are discrete from and independent of federal law. FLPMA requires that the 

development of an RMP for public lands must be coordinated and consistent with county plans to the 

maximum extent possible by law and inconsistencies between Federal and non-Federal Government plans 

be resolve to the extent practical (FLPMA, Title II, Section 202 (c)(9)). However, BLM is bound by 

federal law. As a consequence, there will be an inconsistency that cannot be resolved or reconciled where 

state and local plans conflict with federal law. 

Thus, while county and federal planning processes under FLPMA are required to be as integrated and 

consistent as practical, the federal agency planning process is not bound by or subject to county plans, 

planning processes, or planning stipulations. The BLM will identify these conflicts in the Proposed 

RMP/Final EIS so that the state and local governments have a complete understanding of the impacts of 

the Proposed RMP on state and local management options. A consistency review of the Proposed RMP 

with the state and county master plans is included in Chapter 5.

Comment: To the extent the DRMP/EIS may propose to transfer those AUMs to wildlife or to watersheds, 

this would be counter to the aforementioned state statute, Kane County's General Plan, as well as BLM 

regulations that provide for non use.

Response: Management actions in the Draft RMP/EIS would reallocate 48 AUMS to wildlife 

(Alternative B) or suspend (Alternative C) the 48 AUMs for the Water Canyon Allotment. Based on 

comments received on the Draft RMP/EIS and further BLM review, the Water Canyon Allotment 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-39 

management decisions in the Proposed RMP would close the allotment to livestock grazing for the life of 

the plan with no reallocation or suspension of AUMs. 

The BLM’s grazing regulations allow the BLM to adjust permitted livestock use in its RMPs: “Permitted 

livestock use shall be based upon the amount of forage available for livestock grazing as established in 

the land use plan” (43 CFR 4110.2-2). The BLM Land Use Planning Handbook (BLM-H-1601-1) directs 

that RMPs are to identify lands available or not available for livestock grazing, but these decisions only 

apply over the life of the plan and are reversible through an LUP amendment. The handbook also directs 

that RMPs identify the amount of forage available for livestock (expressed in AUMs).

Comment: VRM I rating is restricted to Class I wilderness areas, congressionally designated wild and 

scenic river segments, and other areas where congressional decisions or legitimate administrative 

decisions have been made to preserve a natural landscape. RMPs are contrary to law to the extent they 

authorize VRM ratings beyond these parameters. VRM I ratings are illegal in WSAs. See BLM IM 2000-

96 and IMP H-8550-1. Moreover, a VRM I classification on WSA's conflicts with FLPMA Section 

1782(c), which expressly allows for the continuation of existing mining and grazing uses and mineral 

leasing in the manner and degree in which the same was conducted when FLPMA took effect.

Response: The FLPMA multiple-use mandate clearly identifies “natural scenic” resources as a multiple 

use (Section 103(c)). The prescribed management objective for visual resources in WSAs is to manage it 

as VRM Class I in accordance with Washington Office IM 2000-096 to retain the WSA’s character 

essentially unaltered by humans.

Comment: The County requests formal consultation regarding the provisions of special recreation 

permits in Alternative B. Special recreation permits are important to the County socio-economically. 

Attempts to prohibit motorized and mechanized tours on County highways in the Moquith Mountain and 

Elephant Cove Area is a serious concern to the County. The Cove Road along the East Fork of the Virgin 

River was adjudicated in state court as a public highway. The group size provisions appear to be 

subjective, unreasonable, and arbitrary and are particularly troubling to the County. What are they based 

on? Were they simply imported from other areas or are they based on specifically related sampling and 

research? For example, a Mexican Spotted Owl, if even inhabiting the area, may not be discomforted or 

disturbed if there were twenty (20) versus twelve (12) people passing through its territory on a County 

highway. The likelihood of even twenty (20) to twenty-five (25) recreationalists in one group affecting 

areas is somewhat slim. Why even set limits such as this unless the justification is crystal-clear.

Response: The special recreation permit management action allows for flexibility in determining if the 

permits are required. Permits are required based on the criteria listed on page 2-80. If a permit is required 

then the group size would be limited to 25 people. On a case-by-case basis, BLM can authorize 

exceptions to this limit after evaluation of possible or likely resource impacts. The numbers in the 

Mexican spotted owl example the commentor raises were developed in coordination with the USFWS for 

protection of this threatened species.

Comment: The County's SRMA proposal included both motorized and non-motorized RMZs. The 

DRMP/EIS, however, was developed without consultation with the County as a cooperating agency and 

did not adequately consider the County's proposal or even advise the County why it developed the 

DRMP/EIS in the way it did, significantly reducing the size of the proposed area. The County's SRMA 

proposal is part of the County's administrative record. The County requests formal consultation to 

resolve inconsistencies with local planning regarding the issue of SRMAs.

Response: BLM reviewed and considered the county’s SRMA proposal during the development of the 

alternatives. Due to resource concerns and management objectives, the county’s proposal was modified. 

Elements of the county’s proposal are included in the SRMAs management actions in the Proposed 

RMP/Final EIS. As directed by 43 CFR 1610.4, the BLM has collaborated with the cooperating agencies 
Chapter 5 Proposed RMP and Final EIS 

5-40 Kanab RMP 

during data inventory and information collection, analysis of the management situation, formulation of 

alternatives, estimation of effects of alternatives, and selection of the preferred alternative, although the 

decision to select a preferred alternative remained the exclusive responsibility of the BLM (43 CFR 

1610.4-7). Throughout the planning process the BLM invited the cooperating agencies to provide 

planning information on various planning topics, including GIS data layers and other county- or statelevel information. The BLM invited designated representatives from the cooperating agencies to attend 

each ID team meeting. Representatives from the agencies were also invited to several sub-ID team 

meetings that specifically addressed resources within the agencies’ area of special expertise and/or 

resources for which they have jurisdiction by law. The BLM sought further input from all cooperating 

agencies by affording them the opportunity to review and provide comments on planning documents (i.e., 

Scoping Report, Socioeconomic Baseline Profile, Analysis of the Management Situation, Alternatives, 

and Preliminary Draft EIS). Throughout the planning process, the cooperating agencies worked with the 

BLM and provided verbal and/or written comments that helped to develop this Draft RMP/EIS.

Comment: So managing the subject lands would violate the restrictions of BLM's own Instruction 

Memorandum No. 2003-275, which states "it is no longer BLM policy to continue to make formal 

determinations regarding wilderness character, designate new WSAs through the land use planning 

process, or manage any lands - [except Section 603 WSAs] in accordance with the non-impairment 

standard prescribed in the IMP [Interim Management Policy for WSAs]."

Response: BLM IM 2003-275 states: “The BLM will involve the public in the planning process to 

determine the best mix of resource use and protection consistent with the multiple-use and other criteria 

established in the FLPMA and other applicable laws, regulations and policies. Lands with wilderness 

characteristics may be managed to protect and/or preserve some or all of those characteristics. This may 

include protecting certain lands in their natural condition and/or providing opportunities for solitude, or 

primitive and unconfined types of recreation. 

The BLM can make a variety of land use plan decisions to protect wilderness characteristics, such as 

establishing Visual Resource Management (VRM) class objectives to guide the placement of roads, trails, 

and other facilities; establishing conditions of use to be attached to permits, leases, and other 

authorizations to achieve the desired level of resource protection; and designating lands as open, closed, 

or limited to Off Highway Vehicles (OHV) to achieve a desired visitor experience. 

Considering wilderness characteristics in the land use planning process may result in several outcomes, 

including, but not limited to: 1) emphasizing other multiple uses as a priority over protecting wilderness 

characteristics; 2) emphasizing other multiple uses while applying management restrictions (conditions of 

use, mitigation measures) to reduce impacts to some or all of the wilderness characteristics; 3) 

emphasizing the protection of some or all of the wilderness characteristics as a priority over other 

multiple uses (though the area will not be designated a WSA).” 

BLM used the guidance from BLM IM 2003-275 to develop management actions for lands with 

wilderness characteristics in the Draft RMP/EIS alternatives. Alternative C considered managing all nonWSA lands with wilderness characteristics (as determined by the BLM) to protect, preserve, and maintain 

wilderness characteristics. Based on public comments, during the public comment period, the BLM has 

revised the Proposed RMP/Final EIS to include management of several non-WSA lands with wilderness 

characteristics. In the Proposed RMP/Final EIS, management prescriptions for non-WSA lands with 

wilderness characteristics have been adjusted (see Chapter 2 and Map 7 of the Proposed RMP/Final EIS).

Comment: The State of Utah's policy and plan for managing BLM lands is substantially set forth in Utah 

Code § 63-38d-401(6), (7) and (8). It is self evident that the management prescriptions and restrictions in 

the proposed Alternative C and the stated objectives common to all alternatives are not inconsistent with 

the standards and policies set forth in this State statutory provision. There is no way for BLM to reconcile 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-41 

these sharp inconsistencies; in other words, there is no way for BLM to adopt Alternative C or pursue the 

stated objectives common to all alternatives for the Subject Lands and meet its legal obligations of 

consistency under FLPMA Section 202(c)(9).

Response: Alternative C considered managing all non-WSA lands with wilderness characteristics (as 

determined by the BLM) to protect, preserve, and maintain wilderness characteristics. Based on public 

comments, during the public comment period, BLM has revised the Proposed RMP/Final EIS to include 

management of several non-WSA lands with wilderness characteristics. In the Proposed RMP/Final EIS, 

management prescriptions for non-WSA lands with wilderness characteristics have been adjusted (see 

Chapter 2 and Map 7 of the Proposed RMP/Final EIS). While county and federal planning processes 

under FLPMA are required to be as integrated and consistent as practical, the federal agency planning 

process is not bound by or subject to county plans, planning processes, or planning stipulations.

Comment: Managing the subject lands (non-WSA lands with wilderness characteristics) according to the 

prescriptions outlined in Alternative C or according to the objectives common to all alternatives would 

arbitrarily and capriciously ignore the documentation and information submitted by Kane County which 

show the subject lands lack true wilderness character.

Response: As part of BLM’s wilderness characteristics inventory maintenance, BLM performed a 

combination of data and onsite reviews. This included specific field inspections, ID team review of data 

such as range files, county and BLM GIS data, and high-resolution 2006 aerial photographs. The BLM is 

confident of the high-standard approach used to inventory the public lands and stands by its findings, 

particularly the findings that involved wilderness characteristics inventory maintenance.

Comment: Managing BLM lands pursuant to any of the DRMP/EIS alternatives (or anything 

substantially like them) is inconsistent with the multiple use mandate of FLPMA, would circumvent the 

obvious lack of BLM authority to manage Post-603 Lands under any criteria other than multiple use, and 

would constitute a violation of the above-referenced terms of the 2003 Utah v. Norton Settlement 

Agreement.

Response: The BLM has long acknowledged that FLPMA Section 603 (43 U.S.C. 1782) requiring a onetime wilderness review has expired. All current inventory of public lands is authorized by FLPMA 

Section 201 (43 U.S.C. 1711). In September 2006, the Utah District Court affirmed that the BLM retained 

authority to protect lands it determined to have wilderness characteristics in a manner substantially similar 

to the manner in which such lands are protected as WSAs. The BLM’s authority for managing lands to 

protect or enhance wilderness characteristics is derived directly from FLPMA Section 202 (43 U.S.C. 

1712). This section of BLM’s organic statute gives the Secretary of the Interior authority to manage 

public lands for multiple use and sustained yield. Nothing in this section constrains the Secretary’s 

authority to manage lands as necessary to “achieve integrated consideration of physical, biological, 

economic, and other sciences” (FLPMA, Section 202(c)(2) (43 U.S.C. 1712(c)(2))). Further, FLPMA 

makes it clear that the term “multiple use” means that not every use is appropriate for every acre of public 

land, and that the Secretary can “make the most judicious use of the land for some or all of these 

resources or related services over areas large enough to provide sufficient latitude for periodic 

adjustments in use” (FLPMA, Section 103(c) (43 U.S.C. 1702(c))). FLPMA intended for the Secretary of 

the Interior to use land use planning as a mechanism for allocating resource use, including wilderness 

characteristics management, among the various resources in a way that provides uses for current and 

future generations. In addition, the BLM Land Use Planning Handbook (H-1601-1) directs BLM to 

“identify decisions to protect or preserve wilderness characteristics (naturalness, outstanding 

opportunities for solitude, and outstanding opportunities for primitive and unconfined recreation)” and to 

“include goals and objectives to protect the resource and management actions necessary to achieve these 

goals and objectives. For authorized activities, include conditions of use that would avoid or minimize 

impacts to wilderness characteristics.” Finally, the Utah v. Norton Settlement Agreement does not affect 
Chapter 5 Proposed RMP and Final EIS 

5-42 Kanab RMP 

BLM’s authority to manage public lands. This Agreement merely remedied confusion by distinguishing 

between WSAs established under FLPMA Section 603 and those lands required to be managed under 

Section 603’s non-impairment standard, and other lands that fall within the discretionary FLPMA Section 

202 land management process.

Comment: If DOI believes it can derive authority from the term "values" in Sections 201 and 202 as 

allowing BLM to manage for "wilderness characteristics" it must substantively differentiate that action 

from the recently repealed actions of Secretary Babbitt. The repealed actions of Secretary Babbitt and the 

current actions of DOI appear to be identical in purpose and effect. FLPMA section 103(i) defines 

wilderness as follows, "The term 'wilderness' as used in section 603 shall have the same meaning as it 

does in section 2(c) of the Wilderness Act... ". This definition, by what ever term (wilderness, wilderness 

characteristics, wilderness values, etc), would appear to restrict wilderness management to the authority 

of Section 603. Stipulation of the Utah negotiated settlement states, "Defendants will not establish, 

manage or otherwise treat public lands, other than Section 603 WSAs and Congressionally designated 

wilderness, as WSAs or as wilderness pursuant to the Section 202 process absent congressional 

authorization". (emphasis added) This and other issues need to be resolved before the BLM implements 

management for "wilderness character".

Response: The BLM has long acknowledged that FLPMA Section 603 (43 U.S.C. 1782) requiring a onetime wilderness review has expired. All current inventory of public lands is authorized by FLPMA 

Section 201 (43 U.S.C. 1711). In September 2006, the Utah District Court affirmed that the BLM retained 

authority to protect lands it determined to have wilderness characteristics in a manner substantially similar 

to the manner in which such lands are protected as WSAs. The BLM’s authority for managing lands to 

protect or enhance wilderness characteristics is derived directly from FLPMA Section 202 (43 U.S.C. 

1712). This section of BLM’s organic statute gives the Secretary of the Interior authority to manage 

public lands for multiple use and sustained yield. Nothing in this section constrains the Secretary’s 

authority to manage lands as necessary to “achieve integrated consideration of physical, biological, 

economic, and other sciences” (FLPMA, Section 202(c)(2) (43 U.S.C. 1712(c)(2))). Further, FLPMA 

makes it clear that the term “multiple use” means that not every use is appropriate for every acre of public 

land, and that the Secretary can “make the most judicious use of the land for some or all of these 

resources or related services over areas large enough to provide sufficient latitude for periodic 

adjustments in use” (FLPMA, Section 103(c) (43 U.S.C. 1702(c))). FLPMA intended for the Secretary of 

the Interior to use land use planning as a mechanism for allocating resource use, including wilderness 

characteristics management, among the various resources in a way that provides uses for current and 

future generations. In addition, the BLM Land Use Planning Handbook (H-1601-1) directs BLM to 

“identify decisions to protect or preserve wilderness characteristics (naturalness, outstanding 

opportunities for solitude, and outstanding opportunities for primitive and unconfined recreation)” and to 

“include goals and objectives to protect the resource and management actions necessary to achieve these 

goals and objectives. For authorized activities, include conditions of use that would avoid or minimize 

impacts to wilderness characteristics.” Finally, the Utah v. Norton Settlement Agreement does not affect 

BLM’s authority to manage public lands. This Agreement merely remedied confusion by distinguishing 

between WSAs established under FLPMA Section 603 and those lands required to be managed under 

Section 603’s non-impairment standard, and other lands that fall within the discretionary FLPMA Section 

202 land management process.

Comment: Even if BLM had the authority to manage for wilderness characteristics the area of the 

Glendale Bench, White Cliffs and John R Flat to not qualify. The Upper Kanab Creek and Four-Mile 

Canyon have County highways linking the lower Kanab Creek area to the Glendale Bench Highway. Both 

roads were established as public highways prior to October 21, 1976. The roads were machine 

constructed and multiple signature rocks indicate the roads were pioneer routes since, at least, the 1880s. 

Historic lime kiln sites exist along the road in Kanab Creek. The road accessing Sheep Spring and the 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-43 

spring area were machine constructed on top of the White Cliffs in T41S, R6W, Section 25. The area 

contains numerous other roads and improvements such as fences, springs, kilns, water tanks, etc.

Response: The ID team reviewed the areas and issues raised in the comment. As part of BLM’s 

wilderness characteristics inventory maintenance, BLM performed a combination of data and onsite 

reviews. This included specific field inspections, ID team review of data such as range files, county and 

BLM GIS data, and high-resolution 2006 aerial photographs. The BLM is confident of the high-standard 

approach used to inventory the public lands and stands by its findings, particularly the findings that 

involved wilderness characteristics inventory maintenance.

Comment: The County does not believe DRMP/EIS analysis supports expanding the Cottonwood Canyon 

beyond the tops of the canyon cliffs as being necessary for the purposes of the ACEC. The County 

requests formal consultation in order to resolve the inconsistency with local planning.

Response: The boundary of the Cottonwood Canyon ACEC was expanded to include relevant and 

important values associated with the existing ACEC that extend beyond the current boundary. Appendix 

H of the Draft RMP/EIS includes the process and criteria used to evaluate proposed ACECs. The process 

and criteria are based on FLPMA 43 CFR 1610.7-2 and BLM Manual 1613.

Comment: The DRMP/EIS grazing that would reduce grazing AUM levels is faulty because the 

DRMP/EIS fails to articulate a legal or factual basis to reduce domestic livestock. BLM may not 

implement an across the board reduction in permitted grazing use in the RMP.

Response: The Draft RMP/EIS does not propose an across-the-board reduction in permitted grazing use 

in the RMP. The few allotments where temporary adjustments/reallocations are proposed are fully 

explained on pages 2-64 and 2-65 in the Draft RMP/EIS.

Comment: Kane County objects to the extent any grazing alternative in the DRMP/EIS attempts to 

authorize the retirement of any grazing permits and their reallocation to wildlife. (For example, refer to 

the transfer of AUMs to wildlife mentioned at Page 2-3). This violates the Taylor Grazing Act, 43 U.S.C. 

§ 315, FLPMA, 43 U.S.C. § 1742, and the terms of the Executive Orders No. 6910,54 I.D. 539 (l934), and 

No. 6964 (Feb. 5, 1935), which withdrew public lands as chiefly valuable for grazing.

Response: The Draft RMP/EIS does not attempt to authorize the retirement of grazing permits. The few 

allotments where temporary adjustments/reallocations are proposed are fully explained on pages 2-64 and 

2-65 in the Draft RMP/EIS. 

The Draft RMP/EIS does not purport to reclassify lands as “chiefly valuable for grazing” as addressed in 

the Taylor Grazing Act. BLM’s grazing regulations allow BLM to adjust permitted livestock use in its 

RMPs: “Permitted livestock use shall be based upon the amount of forage available for livestock grazing 

as established in the land use plan” (43 CFR 4110.2-2). The BLM Land Use Planning Handbook (BLMH-1601-1) directs that RMPs are to identify lands available or not available for livestock grazing, but 

these decisions only apply over the life of the plan and are reversible through an LUP amendment. The 

handbook also directs that RMPs identify the amount of forage available for livestock (expressed in 

AUMs).

Comment: Particularly offensive and antithetical to Utah State water law and water rights, is the stated 

management action at page 2-28 to prohibit impoundments, diversions, channelizations and rip-rapping. 

Kane County grieves this provision as a frontal assault on State administered water rights duly 

adjudicated under Utah's water law system This incursion into Utah's water rights violates basic tenets of 

federalism, the enumerated powers doctrine of the of Article I and the Ninth and Tenth Amendments to 

the United States Constitution, and the Due Process Clause of Fifth Amendment to the Constitution.
Chapter 5 Proposed RMP and Final EIS 

5-44 Kanab RMP 

Response: There is no effect on water rights or in-stream flows related to suitability findings made in an 

LUP decision, barring congressional action. Even if Congress were to designate rivers into the NWSRS, 

any such designation would have no effect on existing, valid water rights. Section 13(b) of the Wild and 

Scenic Rivers Act states that jurisdiction over water is determined by established principles of law. In 

Utah, the state has jurisdiction over water. Although the Wild and Scenic Rivers Act implies a federal 

reserved water right for designated rivers, it does not require or specify any amount, and instead 

establishes that only the minimum amount for purposes of the Act can be acquired. Because the State of 

Utah has jurisdiction over water, BLM would be required to adjudicate the right, as would any other 

entity, by application through state processes. Thus, for congressionally designated rivers, BLM may 

assert a federal reserved water right to appurtenant and unappropriated water with a priority date as of the 

date of designation (junior to all existing rights), but only in the minimum amount necessary to fulfill the 

primary purpose of the reservation. In practice, however, federal reserved water rights have not always 

been claimed if alternative means of ensuring sufficient flows are adequate to sustain the ORVs.

Comment: Moreover, Kane County believes that BLM's process by which it attempted to study Wild 

Scenic River suitability is procedurally flawed by its failure to follow NEPA procedures and Wild and 

Scenic guidelines for determining suitability.

Response: Appendix G of the Draft RMP/EIS details the steps undertaken in the eligibility review 

process including the identification of ORVs as well as the suitability considerations by eligible river 

segments. The BLM complied with all applicable federal laws, regulations, and policies in the WSRs 

study process. The BLM is confident of the high-standard approach used to evaluate river segments and 

stands by its eligibility and suitability findings.

Comment: BLM should conclude that no proposed segment in Kane County is suitable for designation, 

for the additional reason that prohibitions on impoundment that accompany designation would violate the 

preexisting rights of impoundment granted under the 1922 Colorado River Compact. Furthermore, it is 

obvious BLM failed to consider for NEPA purposes, the impact of a suitability designation on the preexisting right of impoundment provided under the 1922 Colorado River Compact. Kane County cannot 

support a position recommending any river segment in Kane County as suitable.

Response: BLM RMP decisions with regards to Wild and Scenic River designation do not affect the 

Colorado River Compact. The compact did not establish specific rights to impound waters in specific 

locations within each state. The Draft RMP/EIS evaluated impacts that would result if the eligible rivers 

were determined suitable and managed to protect their free-flowing nature, tentative classification, and 

ORVs. It also addressed impacts that would result if the eligible rivers were determined not suitable and 

their values were not provided protective management (Draft RMP/EIS, Appendix G, pages G-13 and G14. 

Barring congressional action, there is no effect on water rights or in-stream flows related to suitability 

findings made in an LUP decision. Even if Congress were to designate rivers into the NWSRS, any such 

designation would have no effect on existing water rights. Section 13(b) of the Wild and Scenic Rivers 

Act states that jurisdiction over waters is determined by established principles of law. In Utah, the state 

has jurisdiction over water. Although the Wild and Scenic Rivers Act implies a federal reserved water 

right for designated rivers, it does not require or specify any amount, and as noted above confirms that 

Utah has jurisdiction over water rights. The BLM would be required to adjudicate the water right in the 

same manner as any other entity, by application through state processes. Thus, for congressionally 

designated rivers, the BLM may assert a federal reserved water right for appurtenant and unappropriated 

water with a priority date as of the date of designation (junior to all existing rights), but only in the 

minimum amount necessary to fulfill the primary purpose of the reservation.
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-45 

Comment: Kane County objects to any language in the DRMP/EIS which purports to manage any 

segments under special prescriptions to preserve alleged notions of suitability. All such language should 

be substituted with language substantially similar to the following: "River corridors of eligible rivers will 

be managed according to other resource values consistent with the principles of Multiple Use and 

Sustained Yield, unless and until such time as Congress may designate such corridors for inclusion in the 

National Wild and Scenic River System."

Response: FLPMA gives the BLM broad authority to manage the public lands, including management of 

eligible and suitable river segments. For eligible rivers, it is BLM’s policy to protect certain values 

identified in the eligibility determination process to ensure that a decision on suitability can be made. To 

accomplish this objective, the BLM’s management prescriptions must protect the free-flowing character 

and tentative classifications and identify ORVs of eligible rivers according to the prescriptions and 

directions of the current, applicable LUP per BLM Manual Section 8351.32C. The BLM Manual further 

states that should a determination on suitability not be made during the planning process, “the RMP must 

prescribe protective management measures to ensure protection shall be afforded the river and adjacent 

public land area pending the suitability determination” (Section 8351.33A). NEPA specifies that while 

work on the EIS is in progress, BLM cannot undertake or authorize any actions in the interim that would 

prejudice the RMP decision or, in this case, the suitability determination (40 CFR 1505.1 (c)(3)). A caseby-case evaluation of potential impacts resulting from a proposed action must be made to ensure that all 

eligible rivers are not limited from being considered for suitability among the range of RMP alternatives, 

thus eliminating the opportunity to prejudice the decision. Implementation of the interim management to 

protect eligible rivers, therefore, is applied through site-specific NEPA analysis of environmental impacts 

on a case-by-case basis. The NEPA compliance, required for all federal actions that could significantly 

affect the environment, ensures that BLM considers alternatives to the proposed action and provides BLM 

with an opportunity to apply mitigation measures that will reduce impacts on a given resource such as an 

eligible stream. This mechanism of applying management must be in conformance with the current LUP. 

Protective prescriptions would be applied to rivers determined suitable in the ROD for the Field Office 

RMP. Resource allocations (such as those for visual resources, OHV use, and mineral leasing) compatible 

with protecting river values would be prescribed for suitable river corridors as part of the decision. In 

addition, no special management objectives would be applied to eligible rivers determined not to be 

suitable in the ROD. Instead, they would be managed without additional consideration according to the 

provisions of the plan.

Comment: Even with respect to any segments deemed suitable (which Kane County opposes for any 

segment in the county), the correct language in the DRMP/EIS should be the following: "Manage river 

segments deemed suitable according to other resource values consistent with the principles of multiple 

use and sustained yield with respect to that corridor, unless and until such time as Congress may 

designate such corridors for inclusion in the National Wild and Scenic River System."

Response: FLPMA gives the BLM broad authority to manage the public lands, including management of 

eligible and suitable river segments. For eligible rivers, it is BLM’s policy to protect certain values 

identified in the eligibility determination process to ensure that a decision on suitability can be made. To 

accomplish this objective, the BLM’s management prescriptions must protect the free-flowing character 

and tentative classifications and identify ORVs of eligible rivers according to the prescriptions and 

directions of the current, applicable LUP per BLM Manual Section 8351.32C. The BLM Manual further 

states that should a determination on suitability not be made during the planning process, “the RMP must 

prescribe protective management measures to ensure protection shall be afforded the river and adjacent 

public land area pending the suitability determination” (Section 8351.33A). NEPA specifies that while 

work on the EIS is in progress, BLM cannot undertake or authorize any actions in the interim that would 

prejudice the RMP decision or, in this case, the suitability determination (40 CFR 1505.1 (c)(3)). A caseby-case evaluation of potential impacts resulting from a proposed action must be made to ensure that all 

eligible rivers are not limited from being considered for suitability among the range of RMP alternatives, 
Chapter 5 Proposed RMP and Final EIS 

5-46 Kanab RMP 

thus eliminating the opportunity to prejudice the decision. Implementation of the interim management to 

protect eligible rivers, therefore, is applied through site-specific NEPA analysis of environmental impacts 

on a case-by-case basis. The NEPA compliance, required for all federal actions that could significantly 

affect the environment, ensures that BLM consider alternatives to the proposed action and provides BLM 

with an opportunity to apply mitigation measures that will reduce impacts on a given resource such as an 

eligible stream. This mechanism of applying management must be in conformance with the current LUP. 

Protective prescriptions would be applied to rivers determined suitable in the ROD for the Field Office 

RMP. Resource allocations (such as those for visual resources, OHV use, and mineral leasing) compatible 

with protecting river values would be prescribed for suitable river corridors as part of the decision. In 

addition, no special management objectives would be applied to eligible rivers determined not to be 

suitable in the ROD. Instead, they would be managed without additional consideration according to the 

provisions of the plan.

Comment: BLM should not consider drainages or river segments as eligible for inclusion in the W&SRA 

system unless the DRMP/EIS: a. clearly demonstrates that water is present and flowing freely at all times, 

12 months out of the year; b. clearly demonstrates that a required water-related value is present and 

considered outstandingly remarkable within a region of comparison consisting of one of the three 

physiographic provinces in the state, and that the rationale and justification for the conclusions are 

disclosed; c. evaluates in detail whether and how inclusion of the drainage or segment will affect local 

and state economies, agricultural and industrial operations and interests, tourism, water rights, water 

quality, water resource planning, and access to and across river corridors in both upstream and 

downstream directions from the proposed drainage or river segment; d. clearly demonstrate that the 

foregoing analysis and review be applied in a manner consistent with that of other federal agencies; e. 

clearly demonstrates that such inclusion will not result in eliminating or straying from the multipleuse/sustained-yield management standard previously applicable to the given area. f. clearly demonstrates 

that all known studies regarding the potential inclusion to the State for review and action by the 

Legislature and Governor, and that any comments from the State and Counties will be included in the 

relevant documents forwarded to the United States Congress.

Response: According to the Wild and Scenic River Review in the State of Utah Process and Criteria for 

Interagency Use (July 1996), “there are no specific requirements concerning minimum flow for an 

eligible segment.” The BLM is aware that there are specific state laws relevant to aspects of public land 

management that are discrete from and independent of federal law. However, BLM is bound by federal 

law. As a consequence, there may be inconsistencies that cannot be reconciled. FLPMA requires that 

BLM’s LUPs be consistent with state and local plans “to the extent practical,” but there will be an 

inconsistency that cannot be resolved where state and local plans conflict with federal law. Appendix G of 

the Draft RMP/EIS details the steps undertaken in the eligibility review process including the 

identification of ORVs and the suitability considerations by eligible river segments. The BLM complied 

with all applicable federal laws, regulations, and policies in the WSR study process. As per BLM Manual 

8351, Wild and Scenic Rivers-Policy and Program, Section .32C, all eligible rivers are considered in the 

EIS for the planning effort as to their suitability for congressional designation into the NWSRS. With any 

suitability determination made in the ROD for the Proposed RMP/Final EIS, the free-flowing, ORVs, and 

tentative classification of rivers would continue to be protected until Congress makes a decision on 

designation.

Comment: BLM has no authority to impose Visual Resource Management (VRM) Class I or II 

management prescriptions on proposed WSRA segments. An RMP is contrary to law to the extent it 

authorizes such restrictions.

Response: The FLPMA multiple-use mandate clearly identifies “natural scenic” resources as a multiple 

use (Section 103(c)). The BLM may choose to manage WSR corridors as either VRM Class I or VRM 

Class II to protect and preserve the natural scenic resources in accordance with the FLPMA multiple-use 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-47 

mandate. Furthermore, BLM Manual 8351 directs that tentatively “wild” and “scenic” river segments 

should be managed as VRM Class I.

Comment: The DRMP/EIS must not lend support to the unfounded notion that water rights in any river 

segment somehow accrue to BLM by virtue of a Wild and Scenic River eligibility or suitability 

determination.

Response: There is no effect on water rights or in-stream flows related to suitability findings made in an 

LUP decision, barring congressional action. Even if Congress were to designate rivers into the NWSRS, 

any such designation would have no affect on existing, valid water rights. Section 13(b) of the Wild and 

Scenic Rivers Act states that jurisdiction over waters is determined by established principles of law. In 

Utah, the state has jurisdiction over water. Although the Wild and Scenic Rivers Act implies a federal 

reserved water right for designated rivers, it does not require or specify any amount, and instead 

establishes that only the minimum amount for purposes of the Act can be acquired. Because the State of 

Utah has jurisdiction over water, BLM would be required to adjudicate the right, as would any other 

entity, by application through state processes. Thus, for congressionally designated rivers, BLM may 

assert a federal reserved water right to appurtenant and unappropriated water with a priority date as of the 

date of designation (junior to all existing rights), but only in the minimum amount necessary to fulfill the 

primary purpose of the reservation. In practice, however, federal reserved water rights have not always 

been claimed if alternative means of ensuring sufficient flows are adequate to sustain the ORVs.

Comment: The DRMP/EIS should make available every tool available and site-specific decisions should 

control the type of W tools employed on a given project. (see DRMP/EIS page 41).

Response: The type of tools that can be used in WSAs is determined by the IMP. In emergency 

situations, the IMP allows for authorized use of motorized tools.

Comment: BLM must do a better job of consulting with SITLA to assure adequate and reasonable access 

to State owned lands. Restricting access to inholding properties cannot be used for that purpose and must 

be corrected in the DRMP/EIS. The County's rights- of-way across SITLA sections must not be infringed 

by closing access across BLM lands to the SITLA sections.

Response: In accordance with the Cotter decision, BLM must also provide access to SITLA lands. 

Section 501 FLPMA states BLM is to address reasonable access across public lands. BLM Utah IM UT 

83-130 and BLM WO IM 85-579 provide access to non-federally owned land surrounded by public land 

managed under the authority of FLPMA. This concept is emphasized by adding the following to the 

RMP: “As per the Cotter Decision, reasonable access to Sstate lands would be authorized for economic 

purposes” (see lands and realty decisions in Chapter 2). 

Garfield County Comments and Responses 

Comment: While we recognize the field office's efforts to date, the DEIS does not address consistency 

between neighboring jurisdictions' management objectives. We encourage the BLM to analyze the 

management objectives applicable to adjacent lands. We also encourage the BLM to disclose, as part of 

the Final EIS, specific areas of management conflict and steps the Kanab Field Office will take to resolve 

conflicting management objectives.

Response: The KFO has coordinated with the neighboring field offices in developing consistent 

management across field office boundaries. In addition, BLM has coordinated with other federal land 

management agencies on relevant issues and resources and will continue to work to resolve any potential 

conflicts. 
Chapter 5 Proposed RMP and Final EIS 

5-48 Kanab RMP 

Comment: These RFDSs and alternatives constitute reasonably foreseeable actions and must be 

considered in cumulative impact analysis. They indicate how much development is anticipated to occur 

over the lifetime of the plans. Other federal agencies within the region may have ongoing plans or 

projections for management actions on their lands. Reasonably foreseeable future actions should be 

identified and considered as part of the analysis.

Response: The Draft RMP/EIS addresses the past, present, and reasonably foreseeable future actions. The 

existing condition and trend of the various resources described in the Draft RMP/EIS Chapter 3 (e.g., soil 

resources, water resources, livestock grazing, transportation, and minerals and energy) are the result of 

past management actions. Therefore, impacts from past management actions are reflected in the baseline 

condition of resources as described in Chapter 3 of the Draft RMP/EIS. Anticipated impacts from present 

actions and proposed future actions are reflected in Chapter 4 of the Draft RMP/EIS. Anticipated impacts 

from actions associated with the alternatives are in the Draft RMP/EIS Chapter 4, Sections 4.1 through 4-

5. Anticipated impacts from actions outside the decision area, including management of lands by adjacent 

field offices and agencies, are contained in Draft RMP/EIS Chapter 4, Section 4.6. The cumulative impact 

section of the Proposed RMP/Final EIS has been revised to more accurately describe the incremental 

impacts from federal and non-federal actions. 

Comment: Garfield County made several comments relating to planning decisions and their affect on RS 

2477 claimed right-of-ways. They also requested that BLM should not take action to close routes without 

county concurrence.

Response: As stated in Chapter 1 of the Draft RMP/EIS (page 1-13) and Chapter 1 of the Proposed 

RMP/Final EIS under section 1.3.2, “The State of Utah and Kane and Garfield counties may hold valid 

existing rights-of-way in the planning area pursuant to Revised Statute (RS) 2477, Act of July 28 1866, 

chapter 262, 8, 14 Stat. 252, 253, codified at 43 USC 932. On October 21, 1976, Congress repealed R.S. 

2477 through passage of FLPMA. This RMP does not adjudicate, analyze, or otherwise determine the 

validity of claimed rights-of-way. However, nothing in the RMP extinguishes any valid right-of-way, or 

alters in any way the legal rights the state and counties have to assert and protect RS 2477 rights or to 

challenge in federal court or other appropriate venue any use restrictions imposed by the RMP that they 

believe are inconsistent with their rights.” 

Comment: Conclusions that increased emissions will results primarily from OHV activities are not 

supported. Considering the lack of available data which limits the forecasting, plan trends of air quality 

and the uncertainties associated with the qualitative analysis, Garfield County finds that additional 

quantitative analysis needs to be completed prior to any prescriptive management actions. Such analysis 

must include a verification of the statewide emissions inventory report and identification of the emission 

generators.

Response: The best available data was used to conservatively estimate the emissions from OHV sources. 

Prescriptive management actions for OHV use were not necessarily based on air quality concerns. The 

travel management plan was based on critiera that considered environmental sensitivity, wildlife habitats, 

access needs, and management objectives for the area. 

Comment: It should be noted, Garfield County is willing to work cooperatively with the Bureau of Land 

Management to enhance wildlife settings and reduce impacts from roads where practical and feasible. 

Unilateral action to restrict, close or impact County roads is a failure to be subject to valid existing 

rights, is a violation of collaborative rights doctrine and is not consistent to the maximum extent allowed 

by law with Garfield County's General Management Plan.

Response: The BLM coordinated the travel management plan with Garfield County throughout the RMP 

process. The BLM is unaware of any situations on individual routes described in the comment. The 

process used to designate routes is explained in Appendix K of the Draft RMP/EIS. Garfield County 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-49 

provided route data in a GIS data layer. Data from the BLM inventory was overlaid with the Garfield 

County route data, and discrepancies were identified, reviewed, and resolved through ground-truthing and 

resource specialist review. These maps were reviewed, and any additional routes were ground-truthed 

with GPS and BLM employees. 

Comment: Garfield County has identified and designated an OHV route system by ordinance. The BLM 

must be consistent to the maximum extent allowed by law with the local ordinance.

Response: The process used to designate routes is explained in Appendix K of the Draft RMP/EIS. 

Garfield County provided route data in a GIS data layer. Data from the BLM inventory was overlaid with 

the Garfield County route data, and discrepancies were identified, reviewed, and resolved through 

ground-truthing and resource specialist review. These maps were reviewed, and any additional routes 

were ground-truthed with GPS and BLM employees. 

FLPMA requires that the development of an RMP for public lands must be coordinated and consistent 

with county plans to the extent possible by law and inconsistencies between Federal and non-Federal 

Government plans be resolve to the extent practical (FLPMA, Title II Section 202 (c)(9)). As a 

consequence, there will be an inconsistency that cannot be resolved or reconciled where state and local 

plans conflict with federal law. While county and federal planning processes under FLPMA are required 

to be as integrated and consistent as practical, the federal agency planning process is not bound by or 

subject to county plans, planning processes, or planning stipulations.

Comment: None of the alternatives is fully consistent with Garfield County's General Management Plan 

and the County's Visual Resource Management Map.

Response: The BLM is aware that there are specific county and state plan decisions relevant to aspects of 

public land management that are discrete from and independent of federal law. FLPMA requires that the 

development of an RMP for public lands must be coordinated and consistent with county plans to the 

extent possible by law and inconsistencies between Federal and non-Federal Government plans be resolve 

to the extent practical (FLPMA, Title II, Section 202 (c)(9)). However, BLM is bound by federal law. As 

a consequence, there will be an inconsistency that cannot be resolved or reconciled where state and local 

plans conflict with federal law. 

Thus, while county and federal planning processes under FLPMA are required to be as integrated and 

consistent as practical, the federal agency planning process is not bound by or subject to county plans, 

planning processes, or planning stipulations. The BLM will identify these conflicts in the Proposed 

RMP/Final EIS so that the state and local governments have a complete understanding of the impacts of 

the Proposed RMP on state and local management options. A consistency review of the Proposed RMP 

with the state and county master plans is included in Chapter 5.

Comment: In addition, the RMP fails to consider cumulative impacts of reasonable foreseeable decisions 

across the entire County and the cumulative impact of congressionally designated preservation areas 

within Garfield County.

Response: The Draft RMP/EIS addresses the past, present, and reasonably foreseeable future actions. The 

existing condition and trend of the various resources described in the Draft RMP/EIS Chapter 3 (e.g., soil 

resources, water resources, livestock grazing, transportation, and minerals and energy) are the result of 

past management actions. Therefore, impacts from past management actions are reflected in the baseline 

condition of resources as described in Chapter 3 of the Draft RMP/EIS. Anticipated impacts from present 

actions and proposed future actions are reflected in Chapter 4 of the Draft RMP/EIS. Anticipated impacts 

from actions associated with the alternatives are in the Draft RMP/EIS Chapter 4, Section 4.1 through 4-

5. Anticipated impacts from actions outside the decision area, including management of lands by adjacent 

field offices and agencies, are contained in Draft RMP/EIS Chapter 4, Section 4.6. The cumulative impact 
Chapter 5 Proposed RMP and Final EIS 

5-50 Kanab RMP 

section of the Proposed RMP/Final EIS has been revised to more accurately describe the incremental 

impacts from federal and non-federal actions.

Comment: Currently 2/3 of Garfield County's total land base is prescriptively managed under some type 

of congressional designation. Prior to managing any lands covered by the Kanab RMP as VRM Class I, 

Class II or Class III, a comparative analysis across agency boundaries needs to be conducted.

Response: The visual resource inventory (VRI) is based on criteria that provide for the objective 

evaluation of a landscape. The Draft RMP/EIS provides a reasonable range of alternatives for VRM 

classifications. BLM policy does not require a comparative analysis across agency boundaries. 

Comment: Any unilateral decision by the Bureau of land management to close ways without consulting 

Garfield County and/or without evaluating valid existing rights is inconsistent with the Garfield County 

General Management Plan and a violation of law.

Response: The following language was added to the RMP management decisions: 

“BLM, in preparing its RMP designations and its implementation-level travel management plans, is 

following policy and regulation authority found at 43 CFR 8340, 43 CFR 8364, and 43 CFR 9268. 

Where the authorized officer determines that OHVs are causing or would cause considerable adverse 

impacts, the authorized officer shall close or restrict such areas. Local highway authorities would be 

consulted as appropriate. The public would be notified. 

BLM could impose limitations on the types of vehicles allowed on specific designated routes if 

monitoring indicates that a particular type of vehicle is causing disturbance to the soil, wildlife habitat, or 

cultural or vegetative resources, especially by off-road travel in an area that is limited to designated 

routes.” 

FLPMA requires that the development of an RMP for public lands must be coordinated and consistent 

with county plans to the extent possible by law and inconsistencies between Federal and non-Federal 

Government plans be resolve to the extent practical (FLPMA, Title II, Section 202 (c)(9)). As a 

consequence, there will be an inconsistency that cannot be resolved or reconciled where state and local 

plans conflict with federal law. While county and federal planning processes under FLPMA are required 

to be as integrated and consistent as practical, the federal agency planning process is not bound by or 

subject to county plans, planning processes, or planning stipulations. 

Comment: Garfield County has established goals, policy and criteria for SRMAs. SRMA establishment 

must be consistent to the maximum extent allowed by law with the Garfield County General Management 

Plan.

Response: The BLM is aware that there are specific county and state plan decisions relevant to aspects of 

public land management that are discrete from and independent of federal law. FLPMA requires that the 

development of an RMP for public lands must be coordinated and consistent with county plans to the 

extent possible by law and inconsistencies between Federal and non-Federal Government plans be resolve 

to the extent practical (FLPMA, Title II, Section 202 (c)(9)). However, BLM is bound by federal law. As 

a consequence, there will be an inconsistency that cannot be resolved or reconciled where state and local 

plans conflict with federal law. 

Thus, while county and federal planning processes under FLPMA are required to be as integrated and 

consistent as practical, the federal agency planning process is not bound by or subject to county plans, 

planning processes, or planning stipulations. The BLM will identify these conflicts in the Proposed 

RMP/Final EIS so that the state and local governments have a complete understanding of the impacts of 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-51 

the Proposed RMP on state and local management options. A consistency review of the Proposed RMP 

with the state and county master plans is included in Chapter 5.

Comment: However, given the qualitative nature of the analysis and the lack of reliable quantitative 

data, Garfield County does not concur with the emission totals identified in the in the alternatives. 

Considering the level of detail provided in the analysis, specific quantification's are not justified.

Response: The best available data was used to conservatively estimate the emissions from OHV sources. 

Prescriptive management actions for OHV use were not necessarily based on air quality concerns. The 

travel management plan was based on criteria that considered environmental sensitivity, wildlife habitats, 

access needs, and management objectives for the area. 

Comment: In addition, the County calls upon the BLM to cooperate in the implementation of Garfield 

County's Protection of Cultural Resource Ordinance and in the development of a facility to research, 

store and display cultural resources found in the area.

Response: The KFO has an ongoing agreement with Southern Utah University for the curation of 

archaeological artifacts recovered from BLM lands. These artifacts must be curated at facilities meeting 

specific conditions, and no such facility currently exists in Garfield County. Because the BLM has a 

research facility at the Escalante Science Center in Escalante, Utah, the BLM is unlikely to fund a 

Garfield County curational facility in the near future. The county is welcome to pursue a county facility 

and to cooperate with the BLM in use of the existing Escalante research facilities. 

Comment: Managing the subject lands (non-WSA lands with wilderness characteristics) according to the 

prescriptions outlined in Alternative C or according to the objectives common to all alternatives would 

clash with state and local policies and county plans for managing those lands, and would thus violate the 

consistency requirement of FLPMA Section 202(c)(9), federal law, BLM policy, and the State of 

Utah/USDOI Settlement Agreement of 2003.

Response: BLM’s authority for managing lands to protect or enhance wilderness characteristics 

(Alternative C) is derived directly from FLPMA Section 202 (43 U.S.C. 1712). 

This section of BLM’s organic statute gives the Secretary of the Interior authority to manage public lands 

for multiple use and sustained yield. Nothing in this section constrains the Secretary’s authority to 

manage lands as necessary to “achieve integrated consideration of physical, biological, economic, and 

other sciences” (FLPMA, Section 202(c)(2) (43 U.S.C. 1712(c)(2))). Further, FLPMA makes it clear that 

the term “multiple use” means that not every use is appropriate for every acre of public land, and that the 

Secretary can “make the most judicious use of the land for some or all of these resources or related 

services over areas large enough to provide sufficient latitude for periodic adjustments in use” (FLPMA, 

Section 103(c) (43 U.S.C. 1702(c))). FLPMA intended for the Secretary of the Interior to use land use 

planning as a mechanism for allocating resource use, including wilderness character management, among 

the various resources in a way that provides uses for current and future generations. 

BLM has long acknowledged that FLPMA Section 603 (43 U.S.C. 1782) requiring a one-time wilderness 

review has expired. All current inventory of public lands is authorized by FLPMA Section 201 (43 U.S.C. 

1711). In September 2006, the Utah District Court affirmed that BLM retained authority to protect lands it 

determined to have wilderness characteristics in a manner substantially similar to the manner in which 

such lands are protected as WSAs. 

BLM is aware that there are specific state laws relevant to aspects of public land management that are 

discrete from and independent of federal law. However, BLM is bound by federal law. As a consequence, 

there may be inconsistencies that cannot be reconciled. FLPMA requires that BLM’s LUPs be consistent 

with state and local plans “to the extent practical,” but there will be an inconsistency that cannot be 
Chapter 5 Proposed RMP and Final EIS 

5-52 Kanab RMP 

resolved where state and local plans conflict with federal law. BLM will identify these conflicts in the 

Proposed RMP/Final EIS so that the state and local governments have a complete understanding of the 

impacts of the Proposed RMP on state and local management options. 

Finally, the Utah v. Norton Settlement Agreement does not affect BLM’s authority to manage public 

lands. This Agreement merely remedied confusion by distinguishing between WSAs established under 

FLPMA Section 603 and those lands required to be managed under Section 603’s non-impairment 

standard, and other lands that fall within the discretionary FLPMA Section 202 land management process.

Comment: SRMA establishment associated with Alternatives B and C is inconsistent with Garfield 

County’s General Management Plan.

Response: As directed by 43 CFR 1610.4, BLM has collaborated with Garfield County during data 

inventory and information collection, analysis of the management situation, formulation of alternatives, 

estimation of effects of alternatives, and selection of the preferred alternative, although the decision to 

select a preferred alternative remained the exclusive responsibility of BLM (43 CFR 1610.4-7). BLM 

invited designated representatives from the cooperating agencies to attend each ID team meeting. 

Representatives from the agencies were also invited to several sub-ID team meetings (including meetings 

that addressed how and where SRMA management would be arrayed in the alternatives) that specifically 

addressed resources within the agencies’ area of special expertise and/or resources for which they have 

jurisdiction by law. Throughout the planning process, the cooperating agencies worked with BLM and 

provided verbal and/or written comments that helped to develop this Draft RMP/EIS.

While county and federal planning processes under FLPMA are required to be as integrated and 

consistent as practical, the federal agency planning process is not bound by or subject to county plans, 

planning processes, or planning stipulations. The BLM will identify these conflicts in the Proposed 

RMP/Final EIS so that the state and local governments have a complete understanding of the impacts of 

the Proposed RMP on state and local management options. A consistency review of the Proposed RMP 

with the state and county master plans is included in Chapter 5.

Comment: However, unless facilities, visitation and investment meet criteria established in Garfield 

County's General Management Plan, SRMA establishment in the Escalante area is inconsistent with the 

County's planning efforts.

Response: As directed by 43 CFR 1610.4, BLM has collaborated with Garfield County during data 

inventory and information collection, analysis of the management situation, formulation of alternatives, 

estimation of effects of alternatives, and selection of the preferred alternative, although the decision to 

select a preferred alternative remained the exclusive responsibility of BLM (43 CFR 1610.4-7). BLM 

invited designated representatives from the cooperating agencies to attend each ID team meeting. 

Representatives from the agencies were also invited to several sub-ID team meetings (including meetings 

that addressed how and where SRMA management would be arrayed in the alternatives) that specifically 

addressed resources within the agencies’ area of special expertise and/or resources for which they have 

jurisdiction by law. Throughout the planning process, the cooperating agencies worked with BLM and 

provided verbal and/or written comments that helped to develop this Draft RMP/EIS.

While county and federal planning processes under FLPMA are required to be as integrated and 

consistent as practical, the federal agency planning process is not bound by or subject to county plans, 

planning processes, or planning stipulations. The BLM will identify these conflicts in the Proposed 

RMP/Final EIS so that the state and local governments have a complete understanding of the impacts of 

the Proposed RMP on state and local management options. A consistency review of the Proposed RMP 

with the state and county master plans is included in Chapter 5.
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-53 

Comment: Failure to be consistent with County's plan creates significant detrimental impacts to the 

custom, culture, socioeconomic base, health, and welfare of the County.

Response: While county and federal planning processes under FLPMA are required to be as integrated 

and consistent as practical, the federal agency planning process is not bound by or subject to county plans, 

planning processes, or planning stipulations. The BLM will identify these conflicts in the Proposed 

RMP/Final EIS so that the state and local governments have a complete understanding of the impacts of 

the Proposed RMP on state and local management options. A consistency review of the Proposed RMP 

with the state and county master plans is included in Chapter 5. 

The impacts to local custom, culture, socioeconomics, and public safety are addressed in Chapter 4 of the 

Draft RMP/EIS and the Proposed RMP/Final EIS (see section 4.5 of the Draft RMP/EIS). 

Comment: Moreover, Garfield County believes that BLM's process by which it attempted to study Wild & 

Scenic River suitability is procedurally flawed by its failure to follow NEPA procedures and Wild and 

Scenic guidelines for determining Outstandingly Remarkable Values, regional significance and suitability 

criteria.

Response: Appendix G of the Draft RMP/EIS details the steps undertaken in the eligibility review 

process including the identification of ORVs and the suitability considerations by eligible river segments. 

The BLM complied with all applicable federal laws, regulations, and policies in the WSRs study process. 

Garfield County did amend its general plan with criteria for WSRs. However the amended plan was 

provided to BLM after the Draft RMP/EIS alternatives were developed and formulated. 

The BLM is aware that there are specific state laws relevant to aspects of public land management that are 

discrete from and independent of federal law. However, BLM is bound by federal law. As a consequence, 

there may be inconsistencies that cannot be reconciled. FLPMA requires that BLM’s LUPs be consistent 

with state and local plans “to the extent practical,” but there will be an inconsistency that cannot be 

resolved where state and local plans conflict with federal law. The BLM will identify these conflicts in 

the Proposed RMP/Final EIS so that the state and local governments have a complete understanding of 

the impacts of the Proposed RMP on state and local management options.

Comment: Furthermore, it is obvious BLM failed to consider for NEPA purposes, the impact of a 

suitability designation on the pre-existing right of impoundment provided under the 1922 Colorado River 

Compact. Garfield County cannot support a position recommending any river segment considered in the 

DRMP/EIS in Garfield County as suitable.

Response: BLM RMP decisions with regards to Wild and Scenic River designation do not affect the 

Colorado River Compact. The compact did not establish specific rights to impound waters in specific 

locations within each state. The Draft RMP/EIS evaluated impacts that would result if the eligible rivers 

were determined suitable and managed to protect their free-flowing nature, tentative classification, and 

ORVs. It also addressed impacts that would result if the eligible rivers were determined not suitable and 

their values were not provided protective management (Draft RMP/EIS, Appendix G, pages G-13 and G14. 

Barring congressional action, there is no effect on water rights or in-stream flows related to suitability 

findings made in an LUP decision. Even if Congress were to designate rivers into the NWSRS, any such 

designation would have no effect on existing water rights. Section 13(b) of the Wild and Scenic Rivers 

Act states that jurisdiction over waters is determined by established principles of law. In Utah, the state 

has jurisdiction over water. Although the Wild and Scenic Rivers Act implies a federal reserved water 

right for designated rivers, it does not require or specify any amount, and as noted above confirms that 

Utah has jurisdiction over water rights. BLM would be required to adjudicate the water right in the same 

manner as any other entity, by application through state processes. Thus, for congressionally designated 
Chapter 5 Proposed RMP and Final EIS 

5-54 Kanab RMP 

rivers, BLM may assert a federal reserved water right for appurtenant and unappropriated water with a 

priority date as of the date of designation (junior to all existing rights), but only in the minimum amount 

necessary to fulfill the primary purpose of the reservation.

Comment: The County has concerns that the BLM's identification of VRM inventory classes has led to a 

self-effectuating class protection scheme, rather than a source of information to be considered within the 

proposed resource use allocation schemes within each of the Draft' s alternatives.

Response: The VRI is based on criteria that provide for the objective evaluation of a landscape. The VRI 

is not an on-the-ground management tool. It is used to develop the VRM classes, with consideration of 

other resource activities.

Comment: Lands south of SR 12 and East of Tropic comprise less than 160 contiguous acres, are 

surrounded by private lands and, in one case contain an old dump. The plan proposes managing these 

lands as VRM Class II. The proposed classification is unjustified considering the lack of control over 

adjacent lands, the isolated, small nature of BLM parcels and existing disturbances on the land. The RMP 

appears to carry empirical inventories forward without any analysis regarding adjacent lands, impacts 

resultant from the classifications, existing disturbances or other pertinent factors.

Response: The VRI is based on criteria (including scenic quality, sensitivity level analysis, distance 

zones, and key observation points, per BLM H-8410-1) that provide for the objective evaluation of a 

landscape. The issues raised by the commentor were included in the VRI evaluation and in subsequent 

VRM alternatives. The Draft RMP/EIS provides a reasonable range of alternatives for VRM 

classifications. 

Comment: Garfield County agrees with the concept of bringing VRM Classes into conformance with the 

adopted plan. However, Garfield County's General Management Plan regarding visual resources should 

be implemented to the maximum extent allowed by law instead of the options presented by BLM.

Response: The BLM KFO is aware that Garfield County updated its General Management Plan in 2007. 

The revised General Management Plan was provided to BLM late in the planning process and was 

reviewed in development of the Proposed RMP/Final EIS. The BLM is aware that there are specific 

county and state plan decisions relevant to aspects of public land management that are discrete from and 

independent of federal law. FLPMA requires that the development of an RMP for public lands must be 

coordinated and consistent with county plans to the extent possible by law and inconsistencies between 

Federal and non-Federal Government plans be resolve to the extent practical (FLPMA, Title II, Section 

202 (c)(9)). However, BLM is bound by federal law. As a consequence, there will be an inconsistency 

that cannot be resolved or reconciled where state and local plans conflict with federal law. Thus while 

county and federal planning processes under FLPMA are required to be as integrated and consistent as 

practical, the federal agency planning process is not bound by or subject to county plans, planning 

processes, or planning stipulations. The BLM will identify these conflicts in the Proposed RMP/Final EIS 

so that the state and local governments have a complete understanding of the impacts of the Proposed 

RMP on state and local management options. A consistency review of the Proposed RMP with the state 

and county master plans is included in Chapter 5.

Comment: To the extent the DRMP/EIS may propose to transfer those AUMs to wildlife or to watersheds, 

this would be counter to the aforementioned state statute, Garfield County's general plan, as well as BLM 

regulations that provide for non use.

Response: Management actions in the Draft RMP/EIS would reallocate 48 AUMS to wildlife 

(Alternative B) or suspend (Alternative C) the 48 AUMs for the Water Canyon Allotment. Based on 

comments received on the Draft RMP/EIS and further BLM review, the Water Canyon Allotment 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-55 

management decisions in the Proposed RMP would close the allotment to livestock grazing for the life of 

the plan with no reallocation or suspension of AUMs. 

BLM’s grazing regulations allow BLM to adjust permitted livestock use in its RMPs: “Permitted 

livestock use shall be based upon the amount of forage available for livestock grazing as established in 

the land use plan” (43 CFR 4110.2-2). The BLM Land Use Planning Handbook (BLM-H-1601-1) directs 

that RMPs are to identify lands available or not available for livestock grazing, but these decisions only 

apply over the life of the plan and are reversible through an LUP amendment. The handbook also directs 

that RMPs identify the amount of forage available for livestock (expressed in AUMs).

Comment: Garfield County has recently adopted a protection of cultural resources ordinance that deals 

with many of the aspects contained herein. The management plan needs to be revised to make it 

consistent to the maximum extent allowed by law with the local ordinance. The local ordinance needs to 

be made part of the administrative record and is incorporated by reference.

Response: BLM has reviewed the Garfield County cultural resource ordinance. However, cultural 

resource management is governed by federal law, regulation, and policy. BLM is aware that there are 

specific county and state plan decisions relevant to aspects of public land management that are discrete 

from and independent of federal law. FLPMA requires that the development of resource management 

planning for public land must be coordinated with and consistent with county plans to the extent the 

Secretary finds practical by law and must resolve to the extent practicable inconsistencies between 

Federal and non-Federal Government plans (FLPMA, Title II, Section 202 (c) (9)). However, BLM is 

bound by federal law. As a consequence, there will be an inconsistency that cannot be resolved or 

reconciled where state and local plans conflict with federal law. Thus while county and federal planning 

processes under FLPMA are required to be as integrated and consistent as practicable, the federal agency 

planning process is not bound by or subject to county plans, planning processes, or planning stipulations. 

BLM will identify these conflicts in the Proposed RMP/Final EIS so that the state and local governments 

have a complete understanding of the impacts of the Proposed RMP on state and local management 

options. A consistency review of the Proposed RMP with the state and county master plans has been 

included in Chapter 5.

Comment: It should also be noted, Garfield County believes the BLM should only employ the term 

"critical habitat" when referring to the legal habitat designations for endangered and threatened species 

under the Endangered Species Act. The County also calls upon the BLM to use the "crucial habitat" 

designations mapped by the Division of Wildlife Resources solely as descriptive wildlife habitat 

characterizations and not as exclusion zones for other multiple uses. The County also questions the 

practice of altering these designations from alternative to alternative. Crucial habitat is defined based on 

DWR's wildlife inventories and may be refined or altered by the State as conditions require.

Response: The Draft RMP/EIS uses the terms “critical” and “crucial” as recommended in the comment. 

Based on an agreement with the State of Utah, the crucial habitat mapped by the UDWR is the basis for 

seasonal restrictions for big game habitats. The seasonal restrictions for oil and gas leasing is being 

consistently applied across six BLM field offices in Utah revising their RMPs. 

Comment: Garfield County opposes prohibition of surface disturbing activities or surface occupancy 

within 1/2 mile of active, suitable (currently inactive), or potential reintroduction Utah prairie dog 

habitats/sites. Prairie dogs have migrated to roads, industrial sites and private lands subject to 

significant disturbance and activity. The 1/2 mile buffer is not substantiated by the species' colonization 

habits. Garfield County calls upon the BLM and other federal agencies to cooperate in developing a Utah 

Prairie Dog habitat conservation plan that fulfills the intent of the Endangered Species Act and allows for 

reasonable use, enjoyment and development of public lands.
Chapter 5 Proposed RMP and Final EIS 

5-56 Kanab RMP 

Response: The current prescriptions were developed in coordination with the USFWS on the 

programmatic LUP BAs and associated conservation measures. The Utah Prairie Dog Recovery Plan is 

currently (2008) being revised by the Utah Prairie Dog Recovery team and USFWS. As noted in the Draft 

RMP/EIS Chapter 2 (page 2-10), the BLM will “Implement Recovery Plan, Conservation Agreement, and 

Strategy decisions to increase populations and improve habitat of special status species, including 

federally listed species, by enhancing, protecting, and restoring occupied and potential habitat.”

Comment: Garfield County opposes this alternative. Rerouting existing rights-of-way on public land 

should be evaluated on a case-by-case basis. Inactive prairie dog habitat may no longer be viable, and 

populations may have left the area. Each case should be evaluated on its own merits, and best 

management practice should be implemented prior to relocation, unless agreed to by the affected parties.

Response: The current prescriptions were developed in coordination with the USFWS on the 

programmatic LUP BAs and associated conservation measures. ROWs are evaluated on a case-by-case 

basis with site-specific NEPA. The “potential to disturb active and inactive Utah prairie dog colonies” 

would be determined in those site-specific documents, with mitigations or conservation measures 

developed to address site-specific conditions.

Comment: Garfield County supports vegetation treatments, but opposes arbitrary acreage limits placed 

on most treatments. It is recognized that budgets, time, weather, and other constraints will control the 

acreage treated. However, the BLM should not be limited to arbitrary levels if the land may be benefited 

by additional treatments and management resources exist to complete the work.

Response: The management action to perform vegetation treatments on an average of 22,300 acres a year 

is designed to give BLM management flexibility in performing vegetation treatments. As stated on page 

2-42 of Alternative B, Chapter 2 of the Draft RMP/EIS, the treatment of 22,300 acres a year is the 

maximum average amount of acres that would potentially be treated per year. This average is based on the 

ecological threshold that the vegetation communities are adapted to based on the research described in 

Chapter 3 of the Draft RMP/EIS. This research is summarized in Table 3-8, which identifies the 

thresholds of disturbance for the 20-year planning window for each vegetation type under frequent and 

infrequent disturbance regimes.

Comment: The County opposes arbitrary limits on vegetative treatments. If opportunities exist to improve 

vegetative resources, progress should not be postponed because of arbitrary limits established in the plan 

because vegetative treatments generally provide beneficial impacts to soils, water, air, recreation, 

wildlife, livestock, and many other uses of public lands.

Response: The management action to perform vegetation treatments on an average of 22,300 acres a year 

is designed to give BLM management flexibility in performing vegetation treatments. As stated on page 

2-42 of Alternative B, Chapter 2 of the Draft RMP/EIS, the treatment of 22,300 acres a year is the 

maximum average amount of acres that would potentially be treated per year. This average is based on the 

ecological threshold that the vegetation communities are adapted to based on the research described in 

Chapter 3 of the Draft RMP/EIS. This research is summarized in Table 3-8, which identifies the 

thresholds of disturbance for the 20-year planning window for each vegetation type under frequent and 

infrequent disturbance regimes.

Comment: There is no way for the BLM to reconcile these sharp inconsistencies; in other words, there is 

no way for the BLM to adopt Alternative C or pursue the stated objectives common to all alternatives for 

the Subject Lands and meet its legal obligations of consistency under FLPMA Section 202(c)(9).

Response: Alternative C considered managing all non-WSA lands with wilderness characteristics (as 

determined by the BLM) to protect, preserve, and maintain wilderness characteristics. Based on public 

comments, during the public comment period, BLM has revised the Proposed RMP/Final EIS to include 
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Kanab RMP 5-57 

management of several non-WSA lands with wilderness characteristics. In the Proposed RMP/Final EIS, 

management prescriptions for non-WSA lands with wilderness characteristics have been adjusted (see 

Chapter 2 and Map 7 of the Proposed RMP/Final EIS). While county and federal planning processes 

under FLPMA are required to be as integrated and consistent as practical, the federal agency planning 

process is not bound by or subject to county plans, planning processes, or planning stipulations.

Comment: In addition to analysis required by the County's General Management Plan, Garfield County 

also calls upon BLM to provide a detailed explanation of the rationale and authority for management of 

lands solely because of wilderness characteristics, and why such management does not circumvent the 

provisions of the statutorily required wilderness review process. Further, the BLM must fully disclose the 

rationale and evidence which it believes supports a changed finding for those lands found not to have 

wilderness characteristics in the first survey in the late 1970s and early 1980s. Such rationale and 

evidence must contain a discussion of the detailed criteria used, nature and extent of the review, detailed 

field notes, and all other relevant evidence and legal reasoning. See 43 USC § 1701(1) and Utah Code § 

63-38d-401(6)(b).

Response: The BLM has long acknowledged that FLPMA Section 603 (43 U.S.C. 1782) requiring a onetime wilderness review has expired. All current inventory of public lands is authorized by FLPMA 

Section 201 (43 U.S.C. 1711). In September 2006, the Utah District Court affirmed that the BLM retained 

authority to protect lands it determined to have wilderness characteristics in a manner substantially similar 

to the manner in which such lands are protected as WSAs. The BLM’s authority for managing lands to 

protect or enhance wilderness characteristics is derived directly from FLPMA Section 202 (43 U.S.C. 

1712). This section of BLM’s organic statute gives the Secretary of the Interior authority to manage 

public lands for multiple use and sustained yield. Nothing in this section constrains the Secretary’s 

authority to manage lands as necessary to “achieve integrated consideration of physical, biological, 

economic, and other sciences” (FLPMA, Section 202(c)(2) (43 U.S.C. 1712(c)(2))). Further, FLPMA 

makes it clear that the term “multiple use” means that not every use is appropriate for every acre of public 

land, and that the Secretary can “make the most judicious use of the land for some or all of these 

resources or related services over areas large enough to provide sufficient latitude for periodic 

adjustments in use” (FLPMA, Section 103(c) (43 U.S.C. 1702(c))). FLPMA intended for the Secretary of 

the Interior to use land use planning as a mechanism for allocating resource use, including wilderness 

characteristics management, among the various resources in a way that provides uses for current and 

future generations. In addition, the BLM Land Use Planning Handbook (H-1601-1) directs BLM to 

“identify decisions to protect or preserve wilderness characteristics (naturalness, outstanding 

opportunities for solitude, and outstanding opportunities for primitive and unconfined recreation)” and to 

“include goals and objectives to protect the resource and management actions necessary to achieve these 

goals and objectives. For authorized activities, include conditions of use that would avoid or minimize 

impacts to wilderness characteristics.” Finally, the Utah v. Norton Settlement Agreement does not affect 

BLM’s authority to manage public lands. This Agreement merely remedied confusion by distinguishing 

between WSAs established under FLPMA Section 603 and those lands required to be managed under 

Section 603’s non-impairment standard, and other lands that fall within the discretionary FLPMA Section 

202 land management process. 

As part of BLM’s wilderness characteristics inventory maintenance, BLM performed a combination of 

data and onsite reviews. This included specific field inspections, ID team review of data such as range 

files, county and BLM GIS data, and high-resolution 2006 aerial photographs. BLM is confident of the 

high-standard approach used to inventory the public lands and stands by its findings, particularly the 

findings that involved wilderness characteristics inventory maintenance.

Comment: Managing the subject lands (non-WSA lands with wilderness characteristics) according to the 

prescriptions outlined in Alternative C or according to the objectives common to all alternatives would 
Chapter 5 Proposed RMP and Final EIS 

5-58 Kanab RMP 

arbitrarily and capriciously ignore the documentation and information developed by BLM which show 

the subject lands lack true wilderness character.

Response: As part of BLM’s wilderness characteristics inventory maintenance, BLM performed a 

combination of data and onsite reviews. This included specific field inspections, ID team review of data 

such as range files, county and BLM GIS data, and high-resolution 2006 aerial photographs. BLM is 

confident of the high-standard approach used to inventory the public lands and stands by its findings, 

particularly the findings that involved wilderness characteristics inventory maintenance.

Comment: Originally, Bryce Canyon National Park identified a 330 foot boundary around the Park as 

not containing wilderness character. This is believed to have accommodated the existing barbed wire 

fence and impacts by man necessary to identify the boundary of Park. In the mid 1990s, the nonwilderness boundary zone was reevaluated by Bryce Canyon National Park. Although the Park was 

prohibited from altering their official recommendation, the National Park Service determined that the 

width of the non-WSA area should be reduced from 330 feet 50 feet. As a result the East of Bryce area is 

bounded on one side by lands identified by Bryce Canyon National Park as not meeting wilderness 

criteria and on the other sides by state Route 12 and Tropic town.

Response: In designating other wilderness areas throughout the country, Congress has not required a setback from busy roads and man-made structures to ensure that sights and sounds are not present from the 

moment a user steps into the area. Requiring such a standard for non-WSA lands with wilderness 

characteristics would result in a higher standard than that implemented by Congress for many designated 

wilderness areas. The 1999 Wilderness Inventory findings for the East of Bryce area are that the area is 

contiguous to the National Park and that the contiguous lands managed by the NPS have been 

administratively endorsed for wilderness.

Comment: Analysis also indicates that a significant portion of the 800 acres is impacted by the sights and 

sounds of Tropic Town and SR 12. These characteristics disqualify the area as one that has outstanding 

opportunities for solitude, and outstanding opportunities for primitive recreation.

Response: In designating other wilderness areas throughout the country, Congress has not required a setback from busy roads and man-made structures to ensure that sights and sounds are not present from the 

moment a user steps into the area. Requiring such a standard for non-WSA lands with wilderness 

characteristics would result in a higher standard than that implemented by Congress for many designated 

wilderness areas. The 1999 Wilderness Inventory findings for the East of Bryce area are that the area is 

contiguous to the National Park and that the contiguous lands managed by the NPS have been 

administratively endorsed for wilderness.

Comment: The prescriptions of Alternative C and the stated objectives common to all alternatives are 

substantially similar, if not more restrictive, than the restrictions of the BLM IMP for WSAs. Thus the 

proposal to so manage the subject lands squarely contradicts BLM’s own IM 2003-275.

Response: BLM IM 2003-275 states: “The BLM will involve the public in the planning process to 

determine the best mix of resource use and protection consistent with the multiple-use and other criteria 

established in the FLPMA and other applicable laws, regulations and policies. Lands with wilderness 

characteristics may be managed to protect and/or preserve some or all of those characteristics. This may 

include protecting certain lands in their natural condition and/or providing opportunities for solitude, or 

primitive and unconfined types of recreation. 

The BLM can make a variety of land use plan decisions to protect wilderness characteristics, such as 

establishing Visual Resource Management (VRM) class objectives to guide the placement of roads, trails, 

and other facilities; establishing conditions of use to be attached to permits, leases, and other 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-59 

authorizations to achieve the desired level of resource protection; and designating lands as open, closed, 

or limited to Off Highway Vehicles (OHV) to achieve a desired visitor experience. 

Considering wilderness characteristics in the land use planning process may result in several outcomes, 

including, but not limited to: 1) emphasizing other multiple uses as a priority over protecting wilderness 

characteristics; 2) emphasizing other multiple uses while applying management restrictions (conditions of 

use, mitigation measures) to reduce impacts to some or all of the wilderness characteristics; 3) 

emphasizing the protection of some or all of the wilderness characteristics as a priority over other 

multiple uses (though the area will not be designated a WSA).” 

BLM used the guidance from BLM IM 2003-275 to develop management actions for lands with 

wilderness characteristics in the Draft RMP/EIS alternatives. Alternative C considered managing all nonWSA lands with wilderness characteristics (as determined by the BLM) to protect, preserve, and maintain 

wilderness characteristics. Based on public comments, during the public comment period, BLM has 

revised the Proposed RMP/Final EIS to include management of several non-WSA lands with wilderness 

characteristics. In the Proposed RMP/Final EIS, management prescriptions for non-WSA lands with 

wilderness characteristics have been adjusted (see Chapter 2 and Map 7 of the Proposed RMP/Final EIS). 

Comment: In as much as BLM has no established criteria for ACEC consideration and in as much as the 

County has established objective criteria, failure to evaluate ACECs using Garfield County's criteria is 

considered arbitrary, capricious and inconsistent with the Garfield County General Management Plan. 

Garfield County's General Management Plan and ACEC criteria are incorporated by reference.

Response: Appendix H of the Draft RMP/EIS includes the process and criteria used to evaluate proposed 

ACECs. The process and criteria are based on FLPMA, 43 CFR 1610.7-2, and BLM Manual 1613. 

Garfield County did amend its general plan with criteria for ACECs. However the amended plan was 

provided to BLM after the Draft RMP/EIS alternatives were developed and formulated.

Comment: The Final RMP should contain and rely on a more aggressive, robust monitoring program so 

resource managers and users can communicate, learn, assign responsibilities, and use adaptive 

management to meet land health objectives.

Response: It is BLM policy to monitor existing livestock use levels, forage utilization, and the trend of 

resource condition and make necessary adjustments on an allotment or watershed basis. These actions are 

activity-based actions and are part of the implementation of an RMP to ensure that Standards for 

Rangeland Health are met, as well the other objectives of the RMP. Regulations at 43 CFR 4130.3 require 

that the terms and conditions under which livestock are authorized “ensure conformance with the 

provisions of subpart 4180” and the Standards for Rangeland Health, and further at 43 CFR 4130.3-1 

require that “livestock grazing use shall not exceed the livestock carrying capacity of the allotment.”

Comment: The DRMP/EIS grazing that would reduce grazing AUM levels is faulty because the 

DRMP/EIS fails to articulate a legal or factual basis to reduce domestic livestock. BLM may not 

implement an across the board reduction in permitted grazing use in the RMP.

Response: The Draft RMP/EIS does not propose an across-the-board reduction in permitted grazing use 

in the RMP. The few allotments where temporary adjustments/reallocations are proposed are fully 

explained on pages 2-64 and 2-65 in the Draft RMP/EIS.

Comment: Garfield County objects to the extent any grazing alternative in the DRMP/EIS attempts to 

authorize the retirement of any grazing permits and their reallocation to wildlife. (For example, refer to 

the transfer of AUMs to wildlife mentioned at Page 2-3). This violates the Taylor Grazing Act, 43 U.S.C. 

§ 315, FLPMA, 43 U.S.C. § 1742, and the terms of the Executive Orders No. 6910, 54 J.D. 539 (1934), 

and No. 6964 (Feb. 5, 1935), which withdrew public lands as chiefly valuable for grazing.
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5-60 Kanab RMP 

Response: The Draft RMP/EIS does not attempt to authorize the retirement of grazing permits. The few 

allotments where temporary adjustments/reallocations are proposed are fully explained on pages 2-64 and 

2-65 in the Draft RMP/EIS. 

The Draft RMP/EIS does not purport to reclassify lands as “chiefly valuable for grazing” as addressed in 

the Taylor Grazing Act. BLM’s grazing regulations allow BLM to adjust permitted livestock use in its 

RMPs: “Permitted livestock use shall be based upon the amount of forage available for livestock grazing 

as established in the land use plan” (43 CFR 4110.2-2). The BLM Land Use Planning Handbook (BLMH-1601-1) directs that RMPs are to identify lands available or not available for livestock grazing, but 

these decisions only apply over the life of the plan and are reversible through an LUP amendment. The 

handbook also directs that RMPs identify the amount of forage available for livestock (expressed in 

AUMs).

Comment: Garfield County's resource management has identify has found that 3% to 5% of Garfield 

County's lands need to be set aside for open/cross-country OHV use. The BLM's plan fails to identify 

suitable areas in Garfield County for such use.

Response: The Draft RMP/EIS considered a range of alternatives that included open OHV use in 466,600 

acres to no cross-country OHV use. This range of alternatives included the top soil pit as an open OHV 

area. The BLM KFO is also aware that Garfield County updated its General Management Plan in 2007. 

The revised General Management Plan was provided to BLM late in the planning process, and it was 

reviewed in development of the Proposed RMP/Final EIS. The BLM is aware that there are specific 

county and state plan decisions relevant to aspects of public land management that are discrete from and 

independent of federal law. FLPMA requires that the development of an RMP for public lands must be 

coordinated and consistent with county plans to the extent possible by law and inconsistencies between 

Federal and non-Federal Government plans be resolve to the extent practical (FLPMA, Title II, Section 

202 (c)(9)). However, BLM is bound by federal law. As a consequence, there will be an inconsistency 

that cannot be resolved or reconciled where state and local plans conflict with federal law. Thus while 

county and federal planning processes under FLPMA are required to be as integrated and consistent as 

practical, the federal agency planning process is not bound by or subject to county plans, planning 

processes, or planning stipulations. The BLM will identify these conflicts in the Proposed RMP/Final EIS 

so that the state and local governments have a complete understanding of the impacts of the Proposed 

RMP on state and local management options. A consistency review of the Proposed RMP with the state 

and county master plans is included in Chapter 5.

Comment: In accordance with Garfield County's General Management Plan, Garfield County calls upon 

the BLM to identify and designate other areas that are suitable for open/cross country OHV use and that 

do not impact special status species. Garfield County supports the aggressive, proactive treatment 

scenarios which benefit special status species.

Response: The Draft RMP/EIS considered a range of alternatives that included open OHV use in 466,600 

acres to no cross-country OHV use. This range of alternatives included the top soil pit as an open OHV 

area that does not impact special status species habitat. The BLM KFO is aware that Garfield County 

updated its General Management Plan in 2007. The revised General Management Plan was provided to 

BLM late in the planning process, and it was reviewed in development of the Proposed RMP/Final EIS. 

The BLM will continue to coordinate with Garfield County and interested parties in the development of 

OHV recreation and protection of special status species habitats.

Comment: BLM asserts it will honor all valid, existing rights. However, it appears that this statement 

may only apply to oil and gas, minerals, and grazing; no mention is made of water rights. Under Utah 

law, approved and perfected water rights are considered real property. BLM actions may affect the value 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-61 

of this real property. Because of this, the State Engineer recommends that the BLM consider the impact 

its actions may have on water rights in general and non-BLM water rights in particular.

Response: BLM is obligated by law to honor valid, existing rights. Similarly, holders of valid, existing 

rights are obligated to honor federal laws regarding the use of federal lands for the exercise of those 

rights. BLM does not foresee frequent situations in which BLM’s obligations under federal law would 

cause the agency to take actions that would prevent the holders from fully exercising their valid existing 

rights. BLM works diligently with the owners of valid, existing rights to prevent such situations from 

occurring. If the holder of a valid, existing right believes the BLM has taken an action that prevents the 

exercise of that right, the proper venue for determining equitable compensation or mitigation is in a court 

of valid jurisdiction, not within the context of an LUP.

Comment: Garfield County's supports active protection of water resources. However, given the lack of 

quantitative analysis, prescriptive management practices are not justified except on a case-by-case basis, 

where water resources are being threatened.

Response: The Draft RMP/EIS includes BMPs and management prescriptions to actively protect water 

sources.

Comment: Criteria used by the BLM are inconsistent with the Garfield County General Management 

Plan and with suggestions made by the County throughout the planning process.

Response: The revised General Management Plan was provided to BLM late in the planning process, and 

it was reviewed in development of the Proposed RMP/Final EIS. The BLM is aware that there are specific 

county and state plan decisions relevant to aspects of public land management that are discrete from and 

independent of federal law. FLPMA requires that the development of an RMP for public lands must be 

coordinated and consistent with county plans to the extent possible by law and inconsistencies between 

Federal and non-Federal Government plans be resolve to the extent practical (FLPMA, Title II, Section 

202 (c)(9)). However, BLM is bound by federal law. As a consequence, there will be an inconsistency 

that cannot be resolved or reconciled where state and local plans conflict with federal law. Thus while 

county and federal planning processes under FLPMA are required to be as integrated and consistent as 

practical, the federal agency planning process is not bound by or subject to county plans, planning 

processes, or planning stipulations. The BLM will identify these conflicts in the Proposed RMP/Final EIS 

so that the state and local governments have a complete understanding of the impacts of the Proposed 

RMP on state and local management options. A consistency review of the Proposed RMP with the state 

and county master plans is included in Chapter 5.

Comment: It is Garfield County's policy that the suitability determination phase is the proper time to 

begin analysis concerning any potential federal reserved water rights. At a minimum, Garfield County 

calls upon the BLM to catalog all valid, existing water rights which may be affected by any Wild and 

Scenic River eligibility or suitability designation, identify the maximum, minimum and anticipated 

impacts to said water rights and identify potential solutions to all potential water right conflicts.

Response: There is no law, regulation, or policy requiring the BLM to catalog valid existing water rights 

when evaluating wild and scenic river eligibility and suitabitly in the LUP process. Additionally, there is 

no effect on water rights or in-stream flows related to suitability findings made in an LUP decision, 

barring congressional action. Even if Congress were to designate rivers into the NWSRS, any such 

designation would have no effect on existing, valid water rights. Section 13(b) of the Wild and Scenic 

Rivers Act states that jurisdiction over waters is determined by established principles of law. In Utah, the 

state has jurisdiction over water. Although the Wild and Scenic Rivers Act implies a federal reserved 

water right for designated rivers, it does not require or specify any amount, and instead establishes that 

only the minimum amount for purposes of the Act can be acquired. Because the State of Utah has 

jurisdiction over water, BLM would be required to adjudicate the right, as would any other entity, by 
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5-62 Kanab RMP 

application through state processes. Thus, for congressionally designated rivers, BLM may assert a 

federal reserved water right to appurtenant and unappropriated water with a priority date as of the date of 

designation (junior to all existing rights), but only in the minimum amount necessary to fulfill the primary 

purpose of the reservation. In practice, however, federal reserved water rights have not always been 

claimed if alternative means of ensuring sufficient flows are adequate to sustain the ORVs.

Comment: Garfield County disputes the eligibility analysis associated with Three-mile Creek and 

disagrees with the eligibility determination. Decisions identifying Three Mile Creek as eligible and/or 

suitable for inclusion in the Wild and Scenic River System are inconsistent with the Garfield County 

General Management Plan and are unfounded.

Response: Appendix G of the Draft RMP/EIS details the steps undertaken in the eligibility review 

process including the identification of ORVs and the suitability considerations by eligible river segments. 

The BLM complied with all applicable federal laws, regulations, and policies in the WSRs study process. 

The BLM is aware that there are specific state laws relevant to aspects of public land management that are 

discrete from and independent of federal law. However, BLM is bound by federal law. As a consequence, 

there may be inconsistencies that cannot be reconciled. FLPMA requires that BLM’s LUPs be consistent 

with state and local plans “to the extent practical,” but there will be an inconsistency that cannot be 

resolved where state and local plans conflict with federal law. The BLM will identify these conflicts in 

the Proposed RMP/Final EIS so that the state and local governments have a complete understanding of 

the impacts of the Proposed RMP on state and local management options.

Comment: Particularly offensive and antithetical to Utah State water law and water rights, is the stated 

management action at page 2-28 to prohibit impoundments, diversions, channelizations and rip-rapping. 

Garfield County grieves this provision as a frontal assault on State administered water rights duly 

adjudicated under Utah's water law system and constitutes. This incursion into Utah's water rights 

violates basic tenets of federalism, the enumerated powers doctrine of Article I and the Ninth and Tenth 

Amendments to the United States Constitution, and the Due Process Clause of the Fifth Amendment to the 

Constitution.

Response: As stated on page 2-28 of the Draft RMP/EIS the BLM can only affect these developments 

(e.g. impoundments, diversions) “to the extent the BLM is authorized under law.” BLM could only affect 

such projects if they required BLM action such as ROWs, leases, or other permits. These restrictions on 

development are consistent with BLM Wild and Scenic River policy (see BLM H-8351). However, there 

is no effect on water rights or in-stream flows related to suitability findings made in an LUP decision, 

barring congressional action. Even if Congress were to designate rivers into the NWSRS, any such 

designation would have no effect on existing, valid water rights. Section 13(b) of the Wild and Scenic 

Rivers Act states that jurisdiction over waters is determined by established principles of law. In Utah, the 

state has jurisdiction over water. Although the Wild and Scenic Rivers Act implies a federal reserved 

water right for designated rivers, it does not require or specify any amount, and instead establishes that 

only the minimum amount for purposes of the Act can be acquired. Because the State of Utah has 

jurisdiction over water, BLM would be required to adjudicate the right, as would any other entity, by 

application through state processes. Thus, for congressionally designated rivers, BLM may assert a 

federal reserved water right to appurtenant and unappropriated water with a priority date as of the date of 

designation (junior to all existing rights), but only in the minimum amount necessary to fulfill the primary 

purpose of the reservation. In practice, however, federal reserved water rights have not always been 

claimed if alternative means of ensuring sufficient flows are adequate to sustain the ORVs.

Comment: The referenced Three Mile Creek river segment deemed suitable under that alternative is not 

appropriate for classification and designation by Congress in the National Wild and Scenic River System, 

for the following reasons : 1) the mere presence of the targeted species does not constitute an 

Outstandingly Remarkable Value; 2) the targeted species is being stocked by the Utah Division of 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-63 

Wildlife Resources and does not naturally occur in the segment; 3) the targeted species does not provide 

opportunities for recreational fishing; 4) the reach has been significantly impacted by man including 

revisions to the natural cross section; 5) the reach has no local, regional or national significance; and 6) 

the reach would not be a worthy addition to the national system.

Response: Appendix G of the Draft RMP/EIS details the steps undertaken in the eligibility review 

process including the identification of ORVs and the suitability considerations by eligible river 

segments.In following the criteria established in Appendix G, the Three Mile Creek segment was found 

eligible. However, it was determined not suitable (under Alternatives B and D of the Draft RMP/EIS) and 

is not carried forward into the Proposed RMP/FEIS. The BLM complied with all applicable federal laws, 

regulations, and policies in the WSRs study process. 

Comment: To manage eligible and suitable segments as if they were already designated for inclusion by 

Congress also incorrectly implies that a federal reserved water right exists, thereby impacting the future 

management and utilization of valid existing water rights above, below and within the subject segment 

corridor.

Response: FLPMA gives the BLM broad authority to manage the public lands, including management of 

eligible and suitable river segments. For eligible rivers, it is BLM’s policy to protect certain values 

identified in the eligibility determination process to ensure that a decision on suitability can be made. To 

accomplish this objective, the BLM’s management prescriptions must protect the free-flowing character 

and tentative classifications and identify ORVs of eligible rivers according to the prescriptions and 

directions of the current, applicable LUP per BLM Manual Section 8351.32C. The BLM Manual further 

states that should a determination on suitability not be made during the planning process, “the RMP must 

prescribe protective management measures to ensure protection shall be afforded the river and adjacent 

public land area pending the suitability determination” (Section 8351.33A). NEPA specifies that while 

work on the EIS is in progress, BLM cannot undertake or authorize any actions in the interim that would 

prejudice the RMP decision or, in this case, the suitability determination (40 CFR 1505.1 (c)(3)). A caseby-case evaluation of potential impacts resulting from a proposed action must be made to ensure that all 

eligible rivers are not limited from being considered for suitability among the range of RMP alternatives, 

thus eliminating the opportunity to prejudice the decision. Implementation of the interim management to 

protect eligible rivers, therefore, is applied through site-specific NEPA analysis of environmental impacts 

on a case-by-case basis. The NEPA compliance, required for all federal actions that could significantly 

affect the environment, ensures that BLM considers alternatives to the proposed action and provides BLM 

with an opportunity to apply mitigation measures that will reduce impacts on a given resource such as an 

eligible stream. This mechanism of applying management must be in conformance with the current LUP. 

Protective prescriptions would be applied to rivers determined suitable in the ROD for the Field Office 

RMP. Resource allocations (such as those for visual resources, OHV use, and mineral leasing) compatible 

with protecting river values would be prescribed for suitable river corridors as part of the decision. In 

addition, no special management objectives would be applied to eligible rivers determined not to be 

suitable in the ROD. Instead, they would be managed without additional consideration according to the 

provisions of the plan.

Comment: All such language should be substituted with language substantially similar to the following: 

"River corridors of eligible rivers will be managed according to other resource values consistent with the 

principles of multiple use and sustained yield, unless and until such time as Congress may designate such 

corridors for inclusion in the National Wild and Scenic River System." Even with respect to any segments 

deemed suitable (which Garfield County opposes for any segment in the county), the correct language in 

the DRMP/EIS should be the following: "Manage river segments deemed suitable according to other 

resource values consistent with the principles of multiple use and sustained yield with respect to that 

corridor, unless and until such time as Congress may designate such corridors for inclusion in the 

National Wild and Scenic River System."
Chapter 5 Proposed RMP and Final EIS 

5-64 Kanab RMP 

Response: FLPMA gives the BLM broad authority to manage the public lands, including management of 

eligible and suitable river segments. For eligible rivers, it is BLM’s policy to protect certain values 

identified in the eligibility determination process to ensure that a decision on suitability can be made. To 

accomplish this objective, the BLM’s management prescriptions must protect the free-flowing character 

and tentative classifications and identify ORVs of eligible rivers according to the prescriptions and 

directions of the current, applicable LUP per BLM Manual Section 8351.32C. The BLM Manual further 

states that should a determination on suitability not be made during the planning process, “the RMP must 

prescribe protective management measures to ensure protection shall be afforded the river and adjacent 

public land area pending the suitability determination” (Section 8351.33A). NEPA specifies that while 

work on the EIS is in progress, BLM cannot undertake or authorize any actions in the interim that would 

prejudice the RMP decision or, in this case, the suitability determination (40 CFR 1505.1 (c)(3)). A caseby-case evaluation of potential impacts resulting from a proposed action must be made to ensure that all 

eligible rivers are not limited from being considered for suitability among the range of RMP alternatives, 

thus eliminating the opportunity to prejudice the decision. Implementation of the interim management to 

protect eligible rivers, therefore, is applied through site-specific NEPA analysis of environmental impacts 

on a case-by-case basis. The NEPA compliance, required for all federal actions that could significantly 

affect the environment, ensures that BLM considers alternatives to the proposed action and provides BLM 

with an opportunity to apply mitigation measures that will reduce impacts on a given resource such as an 

eligible stream. This mechanism of applying management must be in conformance with the current LUP. 

Protective prescriptions would be applied to rivers determined suitable in the ROD for the Field Office 

RMP. Resource allocations (such as those for visual resources, OHV use, and mineral leasing) compatible 

with protecting river values would be prescribed for suitable river corridors as part of the decision. In 

addition, no special management objectives would be applied to eligible rivers determined not to be 

suitable in the ROD. Instead, they would be managed without additional consideration according to the 

provisions of the plan.

Comment: Recreation and Public Purpose (R&PP) proposals should be considered as situations where 

the existing riparian areas would be enhanced. RP&P proposals by the counties consider management of 

riparian areas by public entities and should not be summarily dismissed simply because of the presence 

of riparian vegetation.

Response: R&PP leases could be considered for riparian areas, if the conditions in the Draft RMP/EIS 

Chapter 2 decision would be met. Not all R&PP leases would meet these conditions. Therefore, R&PP 

leases with riparian resources would be evaluated on a case-by-case basis.

Comment: For this reason, it is in the best interests of the United States as well as the State of Utah that 

the Final RMP create a robust and effective program for land tenure adjustments.

Response: BLM’s mandate is to retain lands in federal management unless the lands meet the criteria 

specified in FLPMA Section 203 for sale and other disposal actions as provided for under other 

authorities (such as exchange and R&PP). Objectives for BLM’s lands and realty program are discussed 

under the lands and realty common to all alternatives section in Chapter 2, page 2-26 of the Draft RMPEIS.

Comment: Garfield County believes the Draft RMP fails to address adequately these two major issues: 

The impact of BLM management decisions on state trust lands, and the need for a substantially more 

robust program for land tenure adjustments between the BLM and the State of Utah. BLM has an 

obligation to include in its planning an effective and timely means of addressing the impact of federal 

land actions on in-held school trust lands.

Response: BLM’s mandate is to retain lands in federal management unless the lands meet the criteria 

specified in FLPMA Section 203 for sale and other disposal actions as provided for under other 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-65 

authorities (such as exchange and R&PP). Objectives for BLM’s lands and realty program are discussed 

under the lands and realty common to all alternatives section in Chapter 2, page 2-26 of the Draft RMPEIS. 

During processing of any proposed land tenure adjustment, BLM is required through the planning process 

to notify and coordinate with adjacent landowners and other interested parties. 

In addition, the Draft RMP/EIS has been revised to include an impact analysis on oil and gas 

development on SITLA lands from BLM management of non-WSA lands with wilderness characteristics.

State of Utah Comments and Responses 

Comment: The State of Utah will be analyzing final proposed plans in light of the official policy and 

planning statements of this state law (63j-4-401), and incorporates the entirety of this law in our 

comments. The state requests that pages 1-17 and 1-18 be amended to include the plans and policies 

indicated by this law.

Response: Chapter 1 of the Proposed RMP/Final EIS have been revised to include the state law (63j-4-

401) requested by the commentor. A consistency review of this state law is included in Chapter 5 of the 

Proposed RMP/Final EIS. 

Comment: Although these particular studies do not coincide with the Kanab Field Office Planning Area, 

the Field Office should consider the information presented in terms of the economic benefits generated in 

any reasonably foreseeable development scenario discussed in the Final plan.

Response: BLM has reviewed the studies that the State of Utah provided. The Utah Public Lands Study: 

Key Social Survey Findings for Kane and Garfield Counties was considered for insights into local 

community social values. The BLM acknowledges the currency and relevance of several of the study’s 

findings, and has incorporated them as Appendix 10 of the Proposed RMP/Final EIS. However, as the 

study suggests, interpretations are best done for the State of Utah as whole rather than at the county level 

because of the small number of respondents in some counties such as Kane and Garfield counties. 

The University of Utah’s The Structure and Economic Impact of Utah’s Oil and Gas Exploration and 

Production Industry, Phase I—The Uinta Basin, and Phase II—Carbon and Emery Counties, studies were 

found to have no information that would have altered the approach taken in the economic impact analyses 

of Chapter 4 in the Draft RMP/EIS. 

Comment: The state encourages the Kanab Field Office to impose these emission standards as lease 

conditions for all new and relocated engines, and as conditions of approval for all new APDs.

Response: The air quality and minerals and energy management decisions were revised to address the 

commenters concerns (see Chapter 2 of the Proposed RMP/Final EIS).

Comment: • Photo chemical modeling to evaluate the formation of ozone and chemically reactive 

particulate matter, as both of these pollutants are currently trending upwards in the rural parts of Utah. 

Models used for the analysis of ozone and PM2.5 should include the chemistry module needed to estimate 

the formation of secondary pollutants, e.g., a photochemical grid model such as the EPA's Community 

Multi-scale Air Quality model (CMAQ). • Project evaluations should assume, within the reasonably 

foreseeable development scenarios, that leasing and exploration will result in full-field development and 

modeling should reflect reasonably foreseeable full-field development. • Existing emission sources that 

may have coincident impacts and modeling must address emissions from other nearby existing or planned 

sources. • Modeling must reflect anticipated worst-case meteorological conditions for each dispersion 

scenario, e.g., the meteorological condition for high near-field impacts would be different than the 
Chapter 5 Proposed RMP and Final EIS 

5-66 Kanab RMP 

meteorological conditions leading to high long-range transport. • The analysis must address attainment 

of all applicable air quality related requirements and standards. This includes an evaluation of all 

criteria pollutants with specific emphasis on PM2.5, ozone, and their precursors. • The analysis must 

address impacts to visual resources and other air quality related values that have been identified by the 

federal land managers.

Response: The quantification of potential future impacts to air quality from potential future emission 

sources requires the application of dispersion modelling. The application of dispersion models in the 

absence of specific detailed information about those sources, such as emission rate and source location, 

may result in large uncertainty. This uncertainty in the estimation of the potential impacts could 

compromise the reliability of those estimations. A site-specific air quality impact analysis will be 

conducted in site-specific NEPA on a case-by-case basis. This quantitative analysis could apply a photochemical grid model such as CAMx or CMAQ to estimate potential regional ozone concentrations, and 

would include emissions from reasobaly foreseeable sources. The analysis would not be based on worstcase assumptions, since CEQ guidance explicitly calls for reasonable-but conservative assumptions. 

Comment: SITLA's development of inholdings for cabin sites or other purposes consistent with its 

governing mandate may substantially defeat the purpose of the special designation.

Response: Current BLM Utah state policy is to give priority to the State of Utah land exchanges, and 

such exchanges do not require a land use planning decision.

Comment: SITLA believes the Draft RMP fails to address adequately these two major issues: The impact 

of BLM management decisions on state trust lands, and the need for a substantially more robust program 

for land tenure adjustments between the BLM and the State of Utah. BLM has an obligation to include an 

effective and timely means of addressing the impact of federal land actions on in-held school trust lands.

Response: BLM’s mandate is to retain lands in federal management unless the lands meet the criteria 

specified in FLPMA Section 203 for sale and other disposal actions as provided for under other 

authorities (such as exchange and R&PP). Objectives for BLM’s lands and realty program are discussed 

under the lands and realty common to all alternatives section in Chapter 2, page 2-26 of the Draft RMPEIS. 

During processing of any proposed land tenure adjustment, BLM is required through the planning process 

to notify and coordinate with adjacent landowners and other interested parties. 

In addition, the Draft RMP/EIS has been revised to include an impact analysis on oil and gas 

development on SITLA lands from BLM management of non-WSA lands with wilderness characteristics. 

Comment: While we recognize the Field Office's efforts to date, the DEIS does not adequately address 

consistency between neighboring jurisdictions' management objectives. We encourage the BLM to 

analyze the management objectives applicable to adjacent lands. We also encourage the BLM to disclose, 

as part of the Final EIS, specific areas of management conflict and steps the Kanab Field Office will take 

to resolve conflicting management objectives.

Response: The BLM is aware that there are specific county and state plan decisions relevant to aspects of 

public land management that are discrete from and independent of federal law. FLPMA requires that the 

development of an RMP for public lands must be coordinated and consistent with county plans to the 

extent possible by law and inconsistencies between Federal and non-Federal Government plans be resolve 

to the extent practical (FLPMA, Title II, Section 202 (c)(9)). However, BLM is bound by federal law. As 

a consequence, there will be an inconsistency that cannot be resolved or reconciled where state and local 

plans conflict with federal law. 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-67 

Thus, while county and federal planning processes under FLPMA are required to be as integrated and 

consistent as practical, the federal agency planning process is not bound by or subject to county plans, 

planning processes, or planning stipulations. The BLM will identify these conflicts in the Proposed 

RMP/Final EIS so that the state and local governments have a complete understanding of the impacts of 

the Proposed RMP on state and local management options. A consistency review of the Proposed RMP 

with the state and county master plans is included in Chapter 5.

Comment: Other federal agencies within the region, such as the U.S. Forest Service, may have RFDSs or 

similar projections for development on their lands. These should be identified and considered within the 

analysis. Such an analysis is especially important for air quality related values, wildlife habitat, and 

social and economic impacts.

Response: The Draft RMP/EIS addresses the past, present, and reasonably foreseeable future actions. The 

existing condition and trend of the various resources described in the Draft RMP/EIS Chapter 3 (e.g., soil 

resources, water resources, livestock grazing, transportation, and minerals and energy) are the result of 

past management actions. Therefore, impacts from past management actions are reflected in the baseline 

condition of resources as described in Chapter 3 of the Draft RMP/EIS. Anticipated impacts from present 

actions and proposed future actions are reflected in Chapter 4 of the Draft RMP/EIS. The cumulative 

impact analysis has been revised in Chapter 4 of the Proposed RMP/Final EIS to more clearly describe 

the impact on the environment which results from the incremental impact of the Proposed RMP when 

added to other past, present, or reasonably foreseeable future action. 

Comment: The state encourages the BLM to prepare and consider a detailed transportation analysis. 

This analysis should be similar to the Utah Department of Transportation's Analysis of Freight Traffic 

Associated with Oil and Gas Development in the Uinta Basin (Oct. 2006).

Response: The air quality emissions calculations take into account qualitative impacts on air quality from 

transportation and maintenance associated with oil and gas facilities. BLM is not required to provide a 

detailed transportation analysis in this planning/NEPA process. 

Comment: The economic analysis assumes that all authorized AUMS are used. See 3-108. However, page 

3-76 notes that active use is actually 42 percent. Accordingly, the analysis may not accurately assess 

actual economic impacts.

Response: As stated on page 4-246 of the Draft RMP/EIS the socioeconomic analysis considers a range 

of livestock use per alternative. This range includes current active use of approximately 42 percent of 

total permitted use and the total permitted use. 

Comment: We suggest that either in addition to or in lieu of the stipulated inventory identification 

priority areas under the management common to all alternatives and each specific alternative, the BLM 

develop a specific ongoing program, ideally proposed or specifically described in the RMP, and designed 

to identify and target identification efforts under section 110 of the National Historic Preservation Act.

Response: Priorities for Section 110 inventories have been outlined in the RMP (see table, page 2-56). As 

can be seen, those areas associated with OHV use have been given high priority due to the recognized 

direct and cumulative impacts associated with OHV use. In addition, this list includes areas that have not 

yet been inventoried and those areas immediately surrounding communities, where use levels are higher 

than in more removed areas. Section 110 inventories are used for research and gathering base information 

for proactive studies and are generally funded as a lower priority than Section 106 inventories. While an 

overall Section 110 inventory plan could be developed, changing research and informational needs would 

probably make a set plan difficult to follow. 
Chapter 5 Proposed RMP and Final EIS 

5-68 Kanab RMP 

Comment: In addition, we suggest that the BLM work with the state to ensure that other potential areas 

of high cultural resource densities or values be examined for potential conflicts with other resources and 

alternatives.

Response: Priorities for Section 110 inventories have been outlined in the RMP (see table, page 2-56). As 

can be seen, those areas associated with OHV use have been given high priority due to the recognized 

direct and cumulative impacts associated with OHV use. In addition, this list includes areas that have not 

yet been inventoried and those areas immediately surrounding communities, where use levels are higher 

than in more removed areas. Section 110 inventories are used for research and gathering base information 

for proactive studies and are generally funded as a lower priority than Section 106 inventories. While an 

overall Section 110 inventory plan could be developed, changing research and informational needs would 

probably make a set plan difficult to follow. 

Comment: Therefore, we suggest that the BLM specify in the RMP the subsequent development of 

specific cultural resource management plans (or a single plan) or use of programmatic agreements for 

responding to recreation and travel occurring in the Kanab FO. These plans/agreements could 

incorporate existing proposals for monitoring and targeted field inventory of cultural resources in 

recreation areas and travel to identify issues and develop processes for resolving any potential resource 

conflicts. The plans could also provide for means of effective public input into determining areas where 

recreation, travel and cultural resources could be managed for mutual benefit, such as potential heritage 

tourism development.

Response: Priorities for Section 110 inventories have been outlined in the RMP (see table, page 2-56). As 

can be seen, those areas associated with OHV use have been given high priority due to the recognized 

direct and cumulative impacts associated with OHV use. In addition, this list includes areas that have not 

yet been inventoried and areas immediately surrounding communities, where use levels are higher than in 

more removed areas. Section 110 inventories are used for research and gathering base information for 

proactive studies and are generally funded as a lower priority than Section 106 inventories. While an 

overall Section 110 inventory plan could be developed, changing research and informational needs would 

probably make a set plan difficult to follow. The BLM will continue to coordinate with the State of Utah, 

other agencies, and interested parties in the implementation of the RMP.

Comment: It must be assumed that all the well would be drilled outside of the closed areas, but the total 

closed area in C is twice that in A. It also states that 56 percent of the areas closed to leasing in C occur 

within areas of high potential for oil and gas. Please resolve these inconsistencies.

Response: Bullet number four on page 4-198 of the Draft RMP/EIS states: “The RFD for 90 oil and gas 

wells would not vary by alternative due to the low level of development anticipated, acres open for 

leasing (with standard, moderate, or major constraints) under each alternative, and the historic levels of 

development.” 

Comment: The socioeconomics section for oil and gas drilling and production is incomplete. The RFD 

predicts one new petroleum field while no economic impact is included in the DEIS. The one existing oil 

field, Upper Valley, could be used as a model to predict economic impacts. Section 4.3.6 (p. 4-198) 

predicts 90 wells, (70 exploratory and 20 production), and that would not vary by alternative. This 

section should at least be expanded to include the economic impact of an Upper Valley class oil field.

Response: The socioeconomic analysis for oil and gas drilling and production is complete. The 

development of one new oil and gas field has been considered in the socioeconomic analysis. As noted in 

Table 4-32 on page 4-245 of the Draft RMP/EIS, the socioeconomic analysis is based on the the 

development of 20 production wells in a single field. 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-69 

Comment: Designated routes called "training trails" offer a significant length of sustainable trail within 

a confined area that provide the experience these young riders are seeking. Off trail riding has become 

almost non-existent since these trails were put in place.

Response: Identifying routes as “training trails” was not considered as part of this RMP process. 

However, the BLM is willing to work with cooperators and interested parties in developing such trails or 

areas at the activity/implementation level of planning.

Comment: It appears that all action alternatives would impose class I VRM management objectives on 

significantly more acreage than is inventoried as having scenic values commensurate with class I 

management. Please clarify why the BLM Kanab Field Office's management options reflect a significant 

departure from inventoried conditions. Specifically, please explain how the Kanab Field Office would 

manage for values that the most recent inventory data indicates are not in existence.

Response: VRM management objectives are intended to result from, and conform with, the resource 

allocation decisions made in the RMP. Furthermore, those allocation decisions are not necessarily 

predicated on the visual resource inventory. For example, an area of pristine class A scenery may be 

better managed for a relatively high level of facility development or resource extraction, in which case the 

RMP might assign that area a VRM class III or class IV, so that those likely contrasts to the existing 

landscape could be accommodated when needed. On the other hand, an area with less-than-spectacular 

scenery could be assigned VRM class I if BLM determines that visual resources for the public lands 

surrounding that site should be maintained with very little impairment for the enjoyment of future 

generations of visitors. 

For the Proposed RMP, the great majority of the acreage assigned VRM class I across the action 

alternatives consists of WSA acreage. In regard to VRM prescriptions for WSAs, BLM Washington 

Office Instruction Memorandum No. 2000-096 states that "all WSAs should be classified as Class I, and 

managed according to VRM Class I management objectives until such time as the Congress decides to 

designate the area as wilderness or release it for other uses.”

Comment: BLM's identification of VRM inventory classes has led to a self-effectuating class protection 

scheme, rather than a source of information to be considered within the proposed resource use allocation 

schemes within each of the Draft's alternatives.

Response: The VRI is based on criteria that provide for the objective evaluation of a landscape. The VRI 

is not an on-the-ground management tool. It is used to develop the VRM classes, with consideration from 

other resource activities.

Comment: The state objects if the Draft RMP does not make information supporting the VRM inventory 

class determinations proposed by the BLM available for review. The state also objects if the rationale for 

each VRM management class is not presented or if the impacts on resource uses are not fully disclosed in 

the analysis of impacts.

Response: Pages 3-64 to 3-66 of the Draft RMP/EIS identify the existing scenic values in the decision 

area and describe the visual resource inventory class objectives.

Comment: See BLM Instruction Memorandum 2003-275 - Change 1 at Attachment 1. Please clarify how 

the proposed management plan is consistent with this management direction.

Response: Recreation facilities or improvements in WSAs would comply with the IMP. While the 

commentor refers to SRMAs in WSAs, IM 2003-275, Attachment 1, is in reference to non-WSA lands 

with wilderness characteristics and does not apply to WSAs.
Chapter 5 Proposed RMP and Final EIS 

5-70 Kanab RMP 

Comment: Please clarify: (1) what a community market strategy is; (2) the extent to which the SRMA 

overlaps the Moquith Mountain WSA; (3) where these areas overlap, how BLM will manage for intensive 

motorized recreation while protecting solitude and outstanding opportunities for a primitive and 

unconfined type of recreation; and (4) where these areas overlap, how intensive management for 

motorized recreation comports with FLPMA's non-impairment mandate.

Response: A community market strategy includes a community or communities dependent on public 

lands recreation and/or related tourism use, growth, and/or development. Major investments in facilities 

and visitor assistance are authorized within SRMAs where BLM’s strategy is to target demonstrated 

community recreation-tourism market demand. Approximately 11,500 acres of the Moquith Mountain 

WSA (15,190 acres) is included in the Moquith Mountain SRMA. The sand dunes portion of the WSA 

will be managed primarily for motorized recreation. The IMP allows for open OHV use in sand dunes and 

continued use of inventoried ways in WSAs during the WSA phase. The IMP does not specify that ways 

will be opened or closed. The OHV open area in the Moquith Mountain WSA has been designated for 

OHV use since during the initial WSA inventory in 1979-80. The OHV open area has been in use without 

impairing the wilderness characteristics for which it was inventoried. Chapter 4 describes impacts from 

the presence and use of OHV ways and routes in WSAs.

Comment: Please clarify the extent to which the SRMA and WSA overlap. ] Please also explain why the 

development that could occur consistent with this objective: (1) protects solitude and outstanding 

opportunities for a primitive and unconfined type of recreation and, (2) is consistent with FLPMA's nonimpairment mandate.

Response: Approximately 11,500 acres of the Moquith Mountain WSA (15,190 acres) is included in the 

Moquith Mountain SRMA. The sand dunes portion of the WSA will be managed primarily for motorized 

recreation. The IMP allows for open OHV use in sand dunes and continued use of inventoried ways in 

WSAs during the WSA phase. The IMP does not specify that ways will be opened or closed. The OHV 

open area in the Moquith Mountain WSA has been designated for OHV use since during the initial WSA 

inventory in 1979-80. The OHV open area has been in use without impairing the wilderness 

characteristics for which it was inventoried. Chapter 4 describes impacts from the presence and use of 

OHV ways and routes in WSAs.

Comment: Please clarify the extent to which the SRMA and WSA overlap. For those areas that overlap, 

please also explain why the activities that could occur in these areas are consistent with: (1) protection of 

solitude and outstanding opportunities for a primitive and unconfined type of recreation, and (2) 

FLPMA's non-impairment mandate.

Response: Approximately 11,500 acres of the Moquith Mountain WSA (15,190 acres) is included in the 

Moquith Mountain SRMA. The sand dunes portion of the WSA will be managed primarily for motorized 

recreation. The IMP allows for open OHV use in sand dunes and continued use of inventoried ways in 

WSAs during the WSA phase. The IMP does not specify that ways will be opened or closed. The OHV 

open area in the Moquith Mountain WSA has been designated for OHV use since during the initial WSA 

inventory in 1979-80. The OHV open area has been in use without impairing the wilderness 

characteristics for which it was inventoried. Chapter 4 describes impacts from the presence and use of 

OHV ways and routes in WSAs.

Comment: On a related note, the state believes the BLM should only employ the term "critical habitat" 

when referring to the legal habitat designations for endangered and threatened species under the 

Endangered Species Act. The state requests that the BLM use the "crucial habitat" designations mapped 

by the Division of Wildlife Resources solely as descriptive wildlife habitat designations, not as automatic 

exclusion zones, for other multiple uses.

Response: The Draft RMP/EIS uses the terms "“critical” and “crucial” as recommended in the comment.
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-71 

Comment: On page 2-47, regarding management actions for the Bonneville Cutthroat Trout and 

Colorado River Cutthroat Trout, the RMP should reference and include management practices as 

recommended in the Range-Wide Conservation Agreement and Strategy for the Bonneville Cutthroat 

Trout (Oncorhynchus clarki utah) and the Conservation Agreement and Strategy for Colorado River 

Cutthroat Trout (Oncorhynchus clarki pleuriticus) in the state of Utah. Both documents included input 

from the BLM and should be listed in the Kanab Field Office RMP/EIS cited references as well as all 

relevant Conservation Agreements or Recovery Plans in which BLM is a signatory.

Response: Conservation agreements for special status species are mentioned in the Draft RMP/EIS, 

Chapter 2 (page 2-10), in the Management Actions for Special Status Species Conservation and Habitat 

Enhancement; in Chapter 3, Table 3-13, under UDWR Status; and elsewhere in the Draft RMP/EIS. Draft 

RMP/EIS Appendix M also includes a list of recovery plans and conservation agreements. The 

Bonneville cutthroat trout and Colorado River cutthroat trout conservation agreements have been added to 

this list and to the references in the Proposed RMP/Final EIS.

Comment: On page 2-48, the preferred alternative (B) reads, "[a]void new ROWs with high profile 

structures (e.g., buildings, storage structures, overhead powerlines, wind turbines, towers, and windmills) 

within 1 mile of an active Greater sage-grouse lek or in brood rearing habitat." Further, it states, 

"Manage oil and gas leasing as open subject to major constraints (NSO) within 1/2 mile of a Greater 

sage-grouse lek site." The buffer used for protection of sage-grouse habitat from development should be 2 

miles, following the currently accepted management guidelines set forth by Connelly et al. (2000) and the 

2002 Utah Strategic Management Plan for Sage-Grouse. Further, use of the word "avoid" is vague and 

the only mitigation offered is seasonal limitations on development. There are currently no alternatives or 

reparations known to suitably replace a sage-grouse. lek. As such, the UDWR recommends adoption of 

stronger language and appropriate avoidance measures for sage-grouse habitat, i.e., "Preclude new 

ROWs with high-profile structures (e.g., buildings, storage tanks, overhead powerlines, wind turbines, 

towers, and windmills) within 2 miles of a Greater sage-grouse lek and/or in crucial brood rearing and 

winter habitats." Any exceptions to this buffer distance should be made with the concurrence of the state.

Response: The BLM has used the most recent scientific data available on energy development impacts to 

greater sage-grouse. The proposed plan would impose a 1/2 mile NSO stipulation around each lek, and a 

timing limitation during the nesting/early brood-rearing season within 2 miles of a lek to protect nesting 

sage-grouse. Those protective stipulations would provide greater protection of sage-grouse and their 

habitat than is currently recommended by the 2002 Utah Strategic Management Plan for Sage-grouse and 

is consistent with current State of Utah sage-grouse habitat development recommendations. As sagegrouse seasonal habitats are better defined through on-going and future cooperative telemetry research 

efforts, BLM will have better information with which to make decisions and propose BMPs to future 

development actions, such as oil and gas development, proposed in greater sage-grouse habitat, to avoid 

or minimize future greater sage-grouse habitat disturbances. 

Comment: The BLM acknowledges that extraction activities on and within the Alton coal field will likely 

result in displacement or loss of the local population. This population is the southern-most known 

population of Greater sage-grouse. This acknowledgment should coincide with significant measures to 

protect remaining sage-grouse habitat administered by the Kanab BLM. Loss of this population would 

result in a net decrease in the Greater sage-grouse range.

Response: Potential or likely impacts to the greater sage-grouse lek and adjacent seasonal habitats within 

the proposed Alton coal field are being analyzed in the Alton Coal Lease by Application EIS. Alternatives 

and mitigation measures to enhance nearby sage-grouse habitats in an effort to provide additional habitat 

for displaced sage-grouse to move into, will be considered and analyzed in that NEPA document. The 

Proposed RMP contains several management prescriptions to protect and improve sage-grouse habitat. 
Chapter 5 Proposed RMP and Final EIS 

5-72 Kanab RMP 

Comment: The current percentage of areas functioning as potential natural communities is not stated in 

the DEIS. The absence of this critical information makes it impossible to determine whether the objectives 

identified for Alternatives B, C, or D would result in improved conditions. Please clarify the existing 

conditions.

Response: Table 3-5 (Draft RMP/EIS page 3-17) contains the successional status for the Kanab decision 

area.

Comment: On page 2-39, alternatives B and C state, " [d]o not allow new surface disturbing activities 

within 330 ft (660 ft in Alt. C) of riparian/wetland areas unless it could be shown that (1) there are no 

practical alternatives, (2) all long-term impacts could be fully mitigated, or (3) the activity would benefit 

and enhance the riparian area." This statement suggests that a finding of "no practical alternative" alone 

would justify having no restrictions on surface disturbing activities near riparian areas. Failure to 

mitigate long-term impacts to riparian areas may have significant impacts to fish and wildlife species that 

depend on these rare habitats in Southern Utah. This statement should read, "[d]o not allow new surface 

disturbing activities within 330 (or 660 ft) of riparian/wetland areas unless it could be shown that (1) 

there are no practical alternatives and all long-term impacts will be mitigated to the fullest extent 

practical, or (2) the activity would benefit and enhance the riparian area. "

Response: Managing the springs and riparian areas as described by the commentor would be contrary to 

the Utah Riparian Policy (IM-UT-2005-091). The buffer zones are not the only protection available for 

riparian zones. Mitigations for each riparian area would be developed on a case-by-case basis to best meet 

the conditions at the point of impact to implement the policies and procedures of the riparian program and 

other resources and land uses.

Comment: On page 2-42, under Vegetation Restoration Treatments, 22,300 acres is the treated acres 

maximum per year for all alternatives. This includes wildfire restoration efforts. Utah's Division of 

Wildlife Resources has previously requested that wildfire restoration be excluded from this acreage cap. 

This "cap" of annual treatment areas could prohibit or prevent execution of planned and/or funded 

projects if a large wildfire impacted the subject management area. The state does not support an 

arbitrary limit to cooperative, multi-agency restoration efforts on BLM land if funding and resources are 

available.

Response: Vegetation restoration treatments do not include wildfire restoration efforts. These efforts are 

Emergency Stabilization and Rehabilitation actions and are addressed on Draft RMP/EIS page 2-19. 

These actions are implemented following wildfires to assist in the recovery of vegetation communities.

Comment: First, the review form contains conflicting statements regarding examination as part of the 

1979 initial wilderness proposal. Please resolve these discrepancies. Second, the review form states that 

for units 1 and 3, opportunities for primitive and unconfined recreation are "not outstanding," and relies 

on the existence of outstanding opportunities within the contiguous WSA to satisfy this requirement.

Response: The review form does not have conflicting statements. The Orderville Canyon area was 

inventoried in 1979-1980, but this is not the same area of Orderville Canyon that was evaluated for 

wilderness characteristics as part of this RMP. As stated in Chapter 3 of the Draft RMP/EIS on page 3-67: 

“Units that are contiguous to federal lands with wilderness characteristics as identified above were 

evaluated for naturalness alone. Opportunities for solitude and primitive recreation were assumed to be 

present in association with the larger contiguous area.” 

As part of BLM’s wilderness characteristics inventory maintenance, BLM performed a combination of 

data and onsite reviews. This included specific field inspections and ID team review of data such as range 

files, county and BLM GIS data, and high-resolution 2006 aerial photographs. The BLM is confident of 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-73 

the high-standard approach used to inventory the public lands and stands by its findings, particularly the 

findings that involved wilderness characteristics inventory maintenance. 

Comment: Thus, the state asks BLM to provide a detailed explanation of the rationale and authority for 

management of lands solely because of wilderness characteristics, and why such management does not 

circumvent the provisions of the statutorily required wilderness review process. Further, the BLM must 

fully disclose the rationale and evidence which it believes supports a changed finding for those lands 

found not to have wilderness characteristics in the earlier surveys. Such rationale and evidence must 

contain a discussion of the detailed criteria used, nature and extent of the review, detailed field notes, and 

all other relevant evidence and legal reasoning.

Response: The BLM has long acknowledged that FLPMA Section 603 (43 U.S.C. 1782) requiring a onetime wilderness review has expired. All current inventory of public lands is authorized by FLPMA 

Section 201 (43 U.S.C. 1711). In September 2006, the Utah District Court affirmed that the BLM retained 

authority to protect lands it determined to have wilderness characteristics in a manner substantially similar 

to the manner in which such lands are protected as WSAs. The BLM’s authority for managing lands to 

protect or enhance wilderness characteristics is derived directly from FLPMA Section 202 (43 U.S.C. 

1712). This section of BLM’s organic statute gives the Secretary of the Interior authority to manage 

public lands for multiple use and sustained yield. Nothing in this section constrains the Secretary’s 

authority to manage lands as necessary to “achieve integrated consideration of physical, biological, 

economic, and other sciences” (FLPMA, Section 202(c)(2) (43 U.S.C. 1712(c)(2))). Further, FLPMA 

makes it clear that the term “multiple use” means that not every use is appropriate for every acre of public 

land, and that the Secretary can “make the most judicious use of the land for some or all of these 

resources or related services over areas large enough to provide sufficient latitude for periodic 

adjustments in use” (FLPMA, Section 103(c) (43 U.S.C. 1702(c))). FLPMA intended for the Secretary of 

the Interior to use land use planning as a mechanism for allocating resource use, including wilderness 

characteristics management, among the various resources in a way that provides uses for current and 

future generations. In addition, the BLM Land Use Planning Handbook (H-1601-1) directs BLM to 

“identify decisions to protect or preserve wilderness characteristics (naturalness, outstanding 

opportunities for solitude, and outstanding opportunities for primitive and unconfined recreation)” and to 

“include goals and objectives to protect the resource and management actions necessary to achieve these 

goals and objectives. For authorized activities, include conditions of use that would avoid or minimize 

impacts to wilderness characteristics.” Finally, the Utah v. Norton Settlement Agreement does not affect 

BLM’s authority to manage public lands. This Agreement merely remedied confusion by distinguishing 

between WSAs established under FLPMA Section 603 and those lands required to be managed under 

Section 603’s non-impairment standard, and other lands that fall within the discretionary FLPMA Section 

202 land management process.

Comment: In addition to these cautions, the state requests that, in weighing management options for the 

Final RMP, BLM give strong consideration to recommendations submitted by local government and not 

manage lands to protect wilderness character where such management would, in the opinion of local 

governments, be contrary to the interests of local residents.

Response: FLPMA Sections 103, 201, and 202 direct the BLM to take into account the national interest 

as well as the local interest. In accordance with FLPMA and BLM rules, regulations, and policies, the 

BLM must provide for the balanced management of all resources and resource uses on public lands. The 

BLM gave strong consideration to the concerns of local governments throughout the planning process. In 

particular, Kane and Garfield counties are cooperating agencies and have been active cooperators, 

including during the development of alternatives where non-WSA lands with wilderness characteristics 

were considered.
Chapter 5 Proposed RMP and Final EIS 

5-74 Kanab RMP 

Comment: Accordingly, we strongly encourage the Kanab Field Office to consider and disclose: (1) what 

percentage of each non-WSA area identified as possessing wilderness characteristics is subject to valid 

existing rights; and (2) what percentage of each such area has high potential for oil, gas, or mineral 

development.

Response: As described on page 3-67 of the Draft RMP/EIS, there are no leases in the non-WSA lands 

with wilderness characteristics. All of these areas have high development potential for oil and gas and 

moderate potential for coal development as shown on Maps 3-18 and 3-19 of the Draft RMP/EIS.

Comment: Pages 2-59 and 2-60 list 16 such areas as being protected under Alternative C. However, 

pages 3-67 through 3-71 list and discuss 15 such areas as being evaluated; of these, only 10 were 

determined to possess wilderness characteristics.

Response: In Chapter 3 of the Draft RMP/EIS, the Jolly Gulch area was included in the description of 

Orderville Canyon. In Chapter 2 of the Draft RMP/EIS, the Jolly Gulch area was listed separately, which 

resulted in 16 areas. Orderville Canyon, including Jolly Gulch, is among the 10 areas determined to 

possess wilderness characteristics. The Black Hills, Heaps Canyon, Little Valley Canyon, North Escalante 

Canyons, and Paria/Hackberry areas were incorrectly added to Chapter 2 of the Draft RMP/EIS. As 

described on page 3-67 of the Draft RMP/EIS, these five areas were not found to have wilderness 

characteristics and should not have been included in Chapter 2. The Proposed RMP/Final EIS has been 

revised accordingly.

Comment: First, the review form discusses the appearance of naturalness but makes no mention of the 

existence of outstanding opportunities for solitude or a primitive or unconfined type of recreation. We 

discourage the BLM from concluding that areas posses wilderness characteristics without first evaluating 

both criteria. Second, for Unit 1A, the review form notes there "are no obvious signs of manmade 

intrusions or facility development outside a couple of trails or fencelines." However, the attached map 

shows a GPS indicated road bisecting the western portion of this unit.

Response: As part of BLM’s wilderness characteristics inventory maintenance, BLM performed a 

combination of data and onsite reviews. Part of the review included the criteria for existence of 

outstanding opportunities for solitude and primitive or unconfined recreation. This included specific field 

inspections and ID team review of data such as range files, county and BLM GIS data, and highresolution 2006 aerial photographs. The BLM is confident of the high-standard approach used to 

inventory the public lands and stands by its findings, particularly the findings that involved wilderness 

characteristics inventory maintenance. For the specific unit cited in the comment, the area as a whole 

exhibits naturalness, even though there may be occasional instances of man-made structures or routes.

Comment: In reviewing Orderville Canyon, the Kanab Field Office concluded that the area's small size 

limited the availability of outstanding opportunities for solitude or a primitive or unconfined type of 

recreation. The review form for Parunuweap Canyon, however, notes that such opportunities exist within 

this 166 acre area. Please clarify this apparent discrepancy.

Response: As part of BLM’s wilderness characteristics inventory maintenance, BLM performed a 

combination of data and onsite reviews. This included specific field inspections and ID team review of 

data such as range files, county and BLM GIS data, and high-resolution 2006 aerial photographs. The 

BLM is confident of the high-standard approach used to inventory the public lands and stands by its 

findings, particularly the findings that involved wilderness characteristics inventory maintenance. Each 

area was evaluated on its own merits. Therefore, areas of different vegetative cover and topography could 

be expected to offer varying degrees of solitude or opportunities for primitive or unconfined type of 

recreation. 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-75 

Comment: As part of the consistency review, BLM should make every effort to consider and incorporate 

these considerations in its decision.

Response: The BLM is aware that there are specific county and state plan decisions relevant to aspects of 

public land management that are discrete from and independent of federal law. FLPMA requires that the 

development of an RMP for public lands must be coordinated and consistent with county plans to the 

extent possible by law and inconsistencies between Federal and non-Federal Government plans be 

resolved to the extent practical (FLPMA, Title II, Section 202 (c)(9)). However, BLM is bound by federal 

law. As a consequence, there will be an inconsistency that cannot be resolved or reconciled where state 

and local plans conflict with federal law. Thus while county and federal planning processes under 

FLPMA are required to be as integrated and consistent as practical, the federal agency planning process is 

not bound by or subject to county plans, planning processes, or planning stipulations. The BLM will 

identify these conflicts in the Proposed RMP/Final EIS so that the state and local governments have a 

complete understanding of the impacts of the Proposed RMP on state and local management options. A 

consistency review of the Proposed RMP with the state and county master plans is included in Chapter 5.

Comment: The state is concerned that the discussions and analyses of potential and proposed ACECs the 

draft RMP do not meet the standards required by either federal or state law. The discussion and analysis 

is superficial in nature, and lacks sufficient information to identify the purpose and need for each 

potential ACEC or the impacts of its potentia1 designation to be determined. The state is concerned that 

the record for each proposed ACEC consists solely of a recitation that certain natural features or 

processes within the area are, a priori, important and relevant because of a simple reiteration of the 

regulatory requirements, and that no examination of the proposed management scheme exists.

Response: BLM complied with all applicable federal laws, regulations, and policies in the ACEC study 

process. Appendix H of the Draft RMP/EIS includes the process and criteria used to evaluate proposed 

ACECs. The process and criteria are based on FLPMA 43 CFR 1610.7-2 and BLM Manual 1613.

Comment: Finally, the statutory requirement to determine the probability of irreparable damage to the 

important and relevant values is completely missing.

Response: Section 4.4.1 of Chapter 4 of the Draft RMP/EIS includes an analysis of the probability of 

irreparable damage to the relevant and important values. Appendix H of the Draft RMP/EIS includes the 

process and criteria used to evaluate proposed ACECs. The process and criteria are based on FLPMA 43 

CFR 1610.7-2 and BLM Manual 1613.

Comment: Given the strict protections afforded by WSA designation, please explain why additional 

special management action is required to prevent irreparable damage.

Response: The BLM has separate policies and guidelines, as well as criteria, for establishing ACECs and 

WSAs. These differing criteria make it possible that the same lands will qualify as both an ACEC and a 

WSA but for different reasons. The BLM is required to consider these different policies. The values 

protected by WSA management prescriptions do not necessarily protect those values found relevant and 

important in ACEC evaluation, and vice versa. The relevant and important values of ACECs within or 

adjacent to WSAs were noted in the ACEC Evaluation (Appendix H of the Draft RMP/EIS). The ACECs 

are evaluated and ranked based on the presence or absence of the stated relevant and important values. 

None of these values includes wilderness characteristics.

Comment: Because of the value of grazing, state policy discourages permanent closure of grazing 

allotments and encourages the reinstatement of suspended AUMs when range conditions permit. 

Permanent closure precludes using grazing as a tool for improving watershed health, wildlife habitat, 

and the economic benefits of livestock production.
Chapter 5 Proposed RMP and Final EIS 

5-76 Kanab RMP 

Response: The BLM does not propose the permanent closure of allotments or portions thereof. However, 

certain allotments may be closed or unavailable to grazing over the life of the plan. The allotments 

considered as not available are spread by alternative. Subsequent revisions of the LUP may consider 

opening these areas to livestock grazing.

Comment: Please clarify whether the RMP would provide direction regarding grazing within riparian 

areas and if so, what requirements would apply. If no such requirements would apply, please explain 

BLM's change in management approach.

Response: Evaluation and adjustment of grazing management practices (e.g., stocking rates, season of 

use, and changes in livestock kind) for individual or groups of allotments will be addressed at the 

implementation stage (see BLM Handbook 1601, Appendix C, page 14). Range/riparian condition and 

stocking rates are reviewed during the grazing permit renewal process. All reasonably available 

monitoring data is analyzed to make any necessary management changes to provide for the sustained 

yield and responsible use of the public lands prior to the permit renewal. The KFO will monitor 

range/riparian condition and adjust grazing management practices for specific allotments to meet the 

Standards for Rangeland Health as noted in 43 CFR 4180.

Comment: BLM asserts it will honor all valid, existing rights. However, it appears that this statement 

may only apply to oil and gas, minerals, and grazing; no mention is made of water rights. Under Utah 

law, approved and perfected water rights are considered real property.

Response: BLM is obligated by law to honor valid, existing rights. Similarly, holders of valid, existing 

rights (including water rights) are obligated to honor federal laws regarding the use of federal lands for 

the exercise of those rights. BLM does not foresee frequent situations in which BLM’s obligations under 

federal law would cause the agency to take actions that would prevent the holders from fully exercising 

their valid existing rights. BLM works diligently with the owners of valid, existing rights (including water 

rights) to prevent such situations from occurring. If the holder of a valid, existing right believes the BLM 

has taken an action that prevents the exercise of that right, the proper venue for determining equitable 

compensation or mitigation is in a court of valid jurisdiction, not within the context of an LUP.

Comment: BLM actions may affect the value of this real property. Because of this, the State Engineer 

recommends that the BLM consider the impact its actions may have on water rights in general and on 

non-BLM water rights in particular.

Response: The Federal Government has delegated the authority to allocate water within state boundaries 

to state governments. Water uses are regulated by the State Engineer. This means that property owners 

must seek water rights from state governments to obtain and provide water for private uses. BLM does 

not foresee frequent situations in which BLM’s obligations under federal law would cause the agency to 

take actions that would prevent the holders from fully exercising their valid existing rights. BLM works 

diligently with the owners of valid, existing rights (including water rights) to prevent such situations from 

occurring. If the holder of a valid, existing right believes BLM has taken an action that prevents the 

exercise of that right, the proper venue for determining equitable compensation or mitigation is in a court 

of valid jurisdiction, not within the context of an LUP.

Comment: Page 2-37 indicates that, under alternatives B and C, BLM would not allow discharge of 

produced waters in the Colorado River Basin. Please clarify what, if any, portion(s) of the Kanab Field 

Office area would not be subject to this provision.

Response: The Sevier River Basin drains into the Great Basin and not into the Colorado River Basin. 

This encompasses the BLM land in the Panguitch Valley.
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-77 

Comment: The law indicates, among other things, that river segments proposed for inclusion in the 

NWSRS should contain water at all times and possess an outstandingly remarkable value which is 

significant within a physiographic regional context, and that studies of the effects of designation on uses 

within the river corridor, as well as upstream and downstream from the corridor, are analyzed and 

disclosed.

Response: According to the “Wild and Scenic River Review in the State of Utah Process and Criteria for 

Interagency Use” (July 1996), “there are no specific requirements concerning minimum flow for an 

eligible segment.” The BLM is aware that there are specific state laws relevant to aspects of public land 

management that are discrete from and independent of federal law. However, BLM is bound by federal 

law. As a consequence, there may be inconsistencies that cannot be reconciled. FLPMA requires that 

BLM’s LUPs be consistent with state and local plans “to the extent practical,” but there will be an 

inconsistency that cannot be resolved where state and local plans conflict with federal law. The BLM will 

identify these conflicts in the Proposed RMP/Final EIS so that the state and local governments have a 

complete understanding of the impacts of the Proposed RMP on state and local management options.

Comment: The state is also concerned about suitability findings for those streams where there are 

significant water diversions upstream of the subject reach, most of which are for irrigation.

Response: According the “Wild and Scenic River Review in the State of Utah Process and Criteria for 

Interagency Use” (July 1996), Congress has allowed for the existence of some human modification of a 

riverway, such as the presence of impoundments or major dams above or below a segment under review 

(including those that may regulate the flow regime through the segment). The existence of minor dams, 

diversion structures, and rip-rap within the segment shall not by themselves render a reach ineligible.

Comment: While federal reserved water rights are not asserted prior to designation, those stream 

reaches found suitable are managed as if they were designated.

Response: Barring congressional action, there is no effect on water rights or in-stream flows related to 

suitability findings made in an LUP decision. Even if Congress were to designate rivers into the NWSRS, 

any such designation would have no effect on existing water rights. Section 13(b) of the Wild and Scenic 

Rivers Act states that jurisdiction over waters is determined by established principles of law. In Utah, the 

state has jurisdiction over water. Although the Wild and Scenic Rivers Act implies a federal reserved 

water right for designated rivers, it does not require or specify any amount and, as noted above, confirms 

that Utah has jurisdiction over water rights. The BLM would be required to adjudicate the water right in 

the same manner as any other entity, by application through state processes. Thus, for congressionally 

designated rivers, the BLM may assert a federal reserved water right for appurtenant and unappropriated 

water with a priority date as of the date of designation (junior to all existing rights), but only in the 

minimum amount necessary to fulfill the primary purpose of the reservation.

Comment: The state strongly encourages the BLM to work with the state and industry to accommodate 

off-site mitigation for surface disturbing actions on projects that are expected to have long-term impacts 

to crucial wildlife habitats. Further, the BLM should include an index (for example, 1 acre impacted: 4 

acres mechanically restored) in the RMP/EIS for all development in crucial wildlife habitat. Mitigation 

alternatives could include rangeland and habitat restoration, noxious weed control, prescribed fire, or 

mitigation banking-thus, improving and protecting wildlife habitat elsewhere.

Response: The Draft RMP/EIS, Chapter 2, in the Special Status Species section (pages 2-44 and 2-45) 

and the Vegetation section (page 2-40), includes decisions that address mitigation (onsite and offsite). 

Onsite and/or offsite compensatory mitigation is better determined on a site-specific/species-specific basis 

as projects are proposed.
Chapter 5 Proposed RMP and Final EIS 

5-78 Kanab RMP 

Comment: The first concern being some of the land identified is actually owned by Utah State Parks and 

Recreation. The United States Congress transferred the land to Utah State Parks in 1998 ("Attachment 

G"). The maps and Appendix E should be modified to exclude the area transferred. We would also like to 

see the remainder of the parcels adjacent to Kodachrome Basin State Park that are identified for tenure 

adjustment, remain with the BLM. If the BLM has concerns with management of those parcels, Utah State 

Parks and Recreation would like to pursue acquiring this land under the Recreation and Public Purposes 

Act. The state currently maintains a trailhead, access road, and waterline across the property identified 

by alternatives Band D. The land provides important recreation opportunities, as well as, a secondary 

access to the State Park. If the land were sold to a private party the park would see significant impacts to 

access, recreation, and resources. With respect to the land tenure adjustments in the area directly east of 

Kodachrome Basin State Park, Alternative C is most favorable.

Response: BLM will check the maps in the Proposed RMP/Final EIS to ensure that jurisdiction is 

correctly represented. These parcels are identified in the RMP as available for disposal. Local, county, or 

state governments may apply for any of the parcels identified in the tables for FLPMA Section 203 sale or 

other public land under other current authorities for public purposes. Preference is generally given to 

applicants that would provide a public benefit.

Comment: Many designated OHV routes cross property owned by SITLA. To avoid having these routes 

closed in the future by sale of these lands, rights-of-way should be placed in public ownership. Programs 

and funding are in place to accomplish this goal.

Response: Page 2-26 of the Draft RMP-EIS specifically states, “Acquire lands or interests in lands to 

complement existing resource values and uses.”

Comment: The need for BLM to give priority to state-federal land exchanges has been recognized by 

BLM in the BLM Manual.

Response: The Proposed RMP/Final EIS has been modified to include the following objective in Chapter 

2, page 2-26: “Give exchanges with the State of Utah priority consideration, particularly for inholdings.”

Utah Board of Education Comments and Responses 

Comment: As more specifically set forth below, the State Board of Education believes that the Draft RMP 

fails to address adequately these two major issues: the financial impact, including economic 

opportunities lost, of BLM management decisions on school trust lands, and the need for a substantially 

more robust program for land tenure adjustments between the BLM and SITLA.

Response: BLM’s mandate is to retain lands in federal management unless the lands meet the criteria 

specified in FLPMA Section 203 for sale and other disposal actions as provided for under other 

authorities (such as exchange and R&PP). Objectives for BLM’s lands and realty program are discussed 

under the lands and realty common to all alternatives section in Chapter 2, page 2-26, of the Draft 

RMP/EIS. 

During processing of any proposed land tenure adjustment, BLM is required through the planning process 

to notify and coordinate with adjacent landowners and other interested parties. 

In addition, the Draft RMP/EIS has been revised to include an impact analysis on oil and gas 

development on SITLA lands from BLM management of non-WSA lands with wilderness characteristics. 

Comment: For this reason, the State Board of Education strongly disagrees with the BLM's analytical 

assumption that non-BLM lands would be minimally directly impacted by RMP decisions, since BLM 

does not make land decisions on non-BLM lands.
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-79 

Response: Non-BLM lands could be indirectly impacted by RMP decisions both positively and 

negatively. The socioeconomic impact analysis in Chapter 4 of the Draft RMP/EIS has been modified to 

acknowledge that the closure of adjoining public lands to oil and gas leasing may have a potentially 

negative impact on SITLA’s mineral revenue. 

The BLM provides for reasonable access to all SITLA lands. Chapter 2 of the Draft RMP/EIS was 

modified to include: “As per the Cotter Decision, reasonable access to state lands would be authorized for 

economic purposes.”

Comment: We suggest an analytical assumption sentence be included which says "The BLM appreciates 

that our decisions on how to manage our lands directly affect the ability of the Utah public schools to 

receive the revenue from profitable management of these lands, as intended by Congress when they were 

granted."

Response: Non-BLM lands could be indirectly impacted by RMP decisions both positively and 

negatively. The analysis in Chapter 4 of the Draft RMP/EIS has been modified accordingly. 

Comment: Specifically, the BLM does not consider multiple use or sustained yield mandates required by 

FLPMA in the Lands and Realty Objectives section. None of the alternatives adequately analyze the loss 

of revenue from formally or effectively limiting or eliminating the mineral development in many of the 

lands subject to special designations and restrictive viewsheds. There are references to number of wells 

to be allowed in Appendix I- Reasonable Foreseeable Development Scenario, but no indication what that 

means in terms of lost revenue to the United States, the State of Utah, local governments, and Utah's 

school trust, and the effect of that revenue loss under EPCA.

Response: Non-BLM lands could be indirectly impacted by RMP decisions both positively and 

negatively. The socioeconomic impact analysis in Chapter 4 of the Draft RMP/EIS has been modified to 

acknowledge that the closure of adjoining public lands to oil and gas leasing may have a potentially 

negative impact on SITLA’s mineral revenue. 

Comment: The discussion of coal development and the effect, should the BLM not lease its available coal 

in the KFO Planning Area, is also very limited.

Response: The decision in the RMP is limited to identifying areas that are found suitable for further coal 

leasing consideration. Currently, the coal program is administered under lease by application and not a 

proactive leasing program. The impact analysis assumes the development of one coal mine, currently 

being processed (in a separate EIS) under a lease by application. 

Comment: In this respect, the Resource Management Plan includes an unconstitutional taking, and the 

BLM must include specific provisions in the RMP to adequately compensate the school trust, through 

exchanges or purchase.

Response: The BLM recognizes that under Utah v. Andrus the state is entitled to reasonable access 

across public lands to school trust lands, including those located within WSAs and other areas where 

management prescriptions would restrict general public access. Any restrictions such as route closures 

within these management areas pertain to general public access. Public access to OHV routes on public 

lands is accomplished through travel management planning. We make a distinction between closures to 

the public, and state access entitlements and access needs of others that can be addressed as specific needs 

arise. Land tenure adjustment efforts including pending and anticipated land exchanges between the BLM 

and the state should properly focus on SITLA lands located within WSAs and other special management 

areas identified in RMPs. 
Chapter 5 Proposed RMP and Final EIS 

5-80 Kanab RMP 

The concern about Draft RMP/EIS access restrictions other than those for general public access, such as 

the designation of ROW avoidance or exclusion areas, can be clarified with specific mention in the 

Proposed RMP/Final EIS that these designations are subject to state access entitlements under Utah v. 

Andrus, as described above.

Comment: In the Reasonably Foreseeable Development Scenario section, it should again be noted that 

BLM withdrawals and special designations directly affect development of oil and gas on school trust 

lands. The BLM should assume that, in addition to the loss of oil and gas wells on BLM lands, the school 

trust lands will suffer a proportionally equal loss according to the proposed special designations under 

each alternative.

Response: Non-BLM lands could be indirectly impacted by RMP decisions both positively and 

negatively. The socioeconomic impact analysis in Chapter 4 of the Draft RMP/EIS has been modified to 

acknowledge that the closure of adjoining public lands to oil and gas leasing may have a potentially 

negative impact on SITLA’s mineral revenue. 

Comment: In the Alternatives Impacts section, it should be stated that to the extent the BLM creates new 

areas managed for preservation, such as ACECs or areas managed for "wilderness characteristics", such 

designation has a direct economic impact on the Utah school trust.

Response: Non-BLM lands could be indirectly impacted by RMP decisions both positively and 

negatively. The socioeconomic impact analysis in Chapter 4 of the Draft RMP/EIS has been modified to 

acknowledge that the closure of adjoining public lands to oil and gas leasing may have a potentially 

negative impact on SITLA’s mineral revenue. 

Comment: The BLM must do an economic study of the value of the minerals in each of those areas so 

that the RMP clearly sets forth the economic impact of the decision to set these lands aside. Restrictive 

designations additionally increase the cost of access to school trust lands, they may impair marketability, 

and they do require the expenditure of trust resources in pursuing land exchanges with the BLM. These 

facts should be acknowledged appropriately in the discussion of socioeconomic impacts.

Response: Non-BLM lands could be indirectly impacted by RMP decisions both positively and 

negatively. The socioeconomic impact analysis in Chapter 4 of the Draft RMP/EIS has been modified to 

acknowledge that the closure of adjoining public lands to oil and gas leasing may have a potentially 

negative impact on SITLA’s mineral revenue. 

Comment: The BLM should re-consider whether it can impose its standards on split estate lands where it 

does not own the surface. This action diminishes the rights of the surface owners, whether fee or trust 

lands, to develop the land in the manner the owner sees fit. So long as the operator of an oil and gas well, 

for example, has obtained a satisfactory surface use agreement that can be included in the Application for 

Permit to Drill to the BLM, the BLM should not unilaterally limit mineral development.

Response: Information regarding leasing and development on split estate lands is found at the following 

Washington Office website: www.blm.gov/bmp/Split_Estate.htm. 

IM No. 2003-202 outlines the policy, procedures, and conditions for approving oil and gas operations on 

split estate lands. In particular, the BLM will not consider and APD or a Sundry Notice administratively 

or technically complete until the federal lessee or its operator certifies that an agreement with the surface 

owner exists, or until the lessee or its operator complies with Onshore Oil and Gas Order No. 1. 

Compliance with Onshore Oil and Gas Order No. 1 requires the federal mineral lessee or its operator to 

enter into good-faith negotiations with the private surface owner to reach an agreement for the protection 

of surface resources and reclamation of the disturbed areas, or payment in lieu thereof, to compensate the 

surface owner for loss of crops and damages to tangible improvements, if any. In addition, the BLM will 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-81 

invite the surface owner to participate in the onsite inspection and will take into consideration the needs 

of the surface owner when reviewing the APD. The BLM will offer the surface owner the same level of 

surface protection BLM provides on federal surface (IM No. 89-201). 

Comment: The Draft RMP fails to address the impact of these closures on the economic value of the 

affected school trust lands in either this section or its section on socioeconomic impacts of the preferred 

alternative.

Response: Non-BLM lands could be indirectly impacted by RMP decisions both positively and 

negatively. The socioeconomic impact analysis in Chapter 4 of the Draft RMP/EIS has been modified to 

acknowledge that the closure of adjoining public lands to oil and gas leasing may have a potentially 

negative impact on SITLA’s mineral revenue. 

Comment: Under the Takings Clause of the United States Constitution, no road that accesses a school 

trust land section, within the RMP, should be closed without trustee consent. It is anticipated that SITLA 

would take the necessary legal action, on behalf of the beneficiary, to prevent such a closure.

Response: The travel plan provides restrictions to the public for recreational purposes, but does not 

restrict uses permitted or authorized by the BLM. State inholdings may or may not currently have access, 

depending upon whether or not existing vehicle routes lead to them. Under different alternative scenarios, 

existing routes may be proposed for closure. The BLM’s policy, as required by the Cotter decision (State 

of Utah v. Andrus, October 1, 1979), is that “the State must be allowed access to the State school trust 

lands so that those lands can be developed in a manner that will provide funds for the common school.” 

This decision confined the issue of access to situations directly involving economic revenues generated 

for the school trust. The recreation restrictions do not prohibit the state from reasonable access to its lands 

for economic purposes through separate permit authorization as specified by the Cotter decision. Routes 

to state sections may not have been identified for recreational purposes due to resource conflicts or actual 

route conditions.

Comment: The document contains no economic analysis on the loss of income tax revenue to the uniform 

school fund, which comprises all of the State of Utah's contribution to public education.

Response: Non-BLM lands could be indirectly impacted by RMP decisions both positively and 

negatively. The socioeconomic impact analysis in Chapter 4 of the Draft RMP/EIS has been modified to 

acknowledge that the closure of adjoining public lands to oil and gas leasing may have a potentially 

negative impact on SITLA’s mineral revenue. 

Comment: Reasonable access to school trust lands, across the BLM lands, should be provided for under 

all alternatives. This can be done as a "Management Common to All Alternatives" notation, with a 

notation that access to school trust lands will be granted, even if an area is otherwise an avoidance 

exclusion area for right-of-ways. Under the law, as laid out in Andrus v. Utah, the BLM is obligated to 

provide reasonable access to all school trust lands, including such lands located within wilderness study 

areas.

Response: In accordance with the Cotter decision, BLM must also provide access to SITLA lands. 

FLPMA Section 501 states that BLM is to address reasonable access across public lands. BLM Utah IM 

UT 83-130 and BLM WO IM 85-579 provide access to non-federally owned land surrounded by public 

land managed under FLPMA authority.

Comment: At the very least, the Draft RMP should be amended to specifically state that: (1) Continued 

motorized administrative access on "non-designated" routes providing access to school trust lands will be 

permitted to the State of Utah, SITLA, and its permittees and grantees, notwithstanding any closure to the 

general public; (2) The State of Utah, SITLA, and its permittees and grantees may undertake reasonable 
Chapter 5 Proposed RMP and Final EIS 

5-82 Kanab RMP 

maintenance activities to preserve and improve existing access across the BLM lands, after consultation 

and appropriate environmental review by the BLM; and (3) Existing routes that are the sole access to 

school trust lands will not be reclaimed without full BLM consultation with, and written approval by, 

SITLA, after consultation with the State Board of Education and its designated representatives.

Response: In accordance with the Cotter decision, BLM must also provide access to SITLA lands. 

FLPMA Section 501 states that BLM is to address reasonable access across public lands. BLM Utah IM 

UT 83-130 and BLM WO IM 85-579 provide access to non-federally owned land surrounded by public 

land managed under FLPMA authority.

Comment: The section on Land Tenure Adjustments should specifically reference the need for federal 

acquisition of school trust lands that are captured by federal reservations and withdrawals, such as 

wilderness study areas, and the balancing need to provide other productive lands for the school trust to 

acquire. The RMP should specifically address lands more appropriately managed by the school trust and 

non-federal lands that could be more appropriately managed by the BLM, and identify potentially 

productive lands that could be used to facilitate the exchange.

Response: The Proposed RMP/Final EIS has been modified to include the following objective in Chapter 

2, page 2-26: “Give exchanges with the State of Utah priority consideration, particularly for inholdings.”

Comment: Specifically, the Planning Issues Identified section should include discussion and detailed 

reference to the issue of inheld school lands in special designation categories, particularly WSAs, 

ACECs, and areas to be managed for “wilderness characteristics,” and the need to give priority to 

resolution of the issue.

Response: The Proposed RMP/Final EIS has been modified to include the following objective in Chapter 

2, page 2-26: “Give exchanges with the State of Utah priority consideration, particularly for inholdings.”

5.7 RECORD OF DECISION

Following publication by the EPA and BLM of a Notice of Availability of the Proposed RMP/Final EIS 

in the Federal Register and distribution of the Proposed RMP/Final EIS, a 30-day protest period runs. In 

addition, a 60-day Governor’s Consistency Review period begins the same day as the protest period. In 

other words, the protest period runs concurrently with the first half of the 60-day Governor’s Consistency 

The State Director will approve the Proposed RMP/Final EIS by issuing a public ROD, which is a concise 

document summarizing the findings and decisions brought forth from the Proposed RMP. However, 

approval shall be withheld on any portion of a plan being protested until final action has been completed 

on such protest. Before such approval is given, there shall be public notice and opportunity for public 

comment on any significant change made to the proposed plan. Among other decisions, the proposed 

ACEC designations and OHV categories (limitations and closures) will be approved when the ROD is 

signed. 

5.8 LIST OF PREPARERS

Table 5-12 lists those primarily responsible for preparing the Proposed RMP/Final EIS and presents their 

qualifications. 
Proposed RMP and Final EIS Chapter 5 

Kanab RMP 5-83 

Table 5-12. List of Preparers 

Name Education Project Role 

Bureau of Land Management 

Daniel Alberts GIS Analyst 

Randy Beckstrand B.S., Range Science 

Air Quality, Soil and Water Resources, 

Riparian, Watersheds, Forestry, 

Livestock Grazing 

Susan Caplan B.S., Meteorology 

M.S., Watershed Science Air Quality 

Tom Christensen B.S., Forestry 

M.S., Forest Recreation 

Visual Resources, Wilderness 

Characteristics, Recreation, 

Transportation, Wilderness, WSR, 

Special Management Areas 

Lisa Church B.S., Wildlife and Fisheries Ecology 

Riparian, Watersheds, Special Status 

Species (wildlife), Fish and Wildlife, 

Special Management Areas, Biological 

Assessment (BA) 

Larry Crutchfield Public Affairs, Public Outreach 

Carson Gubler B.S., Biology/Botany 

Air Quality, Soil and Water Resources, 

Watersheds, Vegetation, Special Status 

Species (plants), Fire and Fuels 

Management, Livestock Grazing 

Doug Powell B.S., Geology 

M.S.,Hazardous Waste Management Minerals and Energy, Hazardous Waste 

John Reese B.S., Rangeland Resources Fire and Fuels Management, Forestry, 

Livestock Grazing 

Keith Rigtrup B.A., Economics Project Manager, Planning 

Coordination, Socioeconomics 

Alan Titus 

B.S., Geology 

M.S., Geology 

Ph.D., Geology 

Paleontology 

Hugh Wolfe Lands and Realty 

Matthew Zweifel B.S., Anthropology 

M.A., Archeology 

Cultural Resources 

Booz Allen Hamilton 

Erik Anderson 

B.S., Civil and Environmental Engineering 

M.S., (in progress), Environmental Policy 

and Management 

Project Manager, Air Quality, Soil and 

Water Resources, Riparian, 

Watersheds, Minerals, Hazardous 

Materials 

Quincy Bahr 

B.S., Natural Resources Management and 

Planning 

M.S., (in progress), Natural Resources 

Management and Planning 

Assistant Project Manager, Cultural 

Resources, Fire and Fuels 

Management, Livestock Grazing, 

Paleontology, ACEC, Special 

Management Areas, Visual Resources, 

Wilderness Characteristics, Recreation, 

Transportation, Wilderness, WSR, WSA 
Chapter 5 Proposed RMP and Final EIS 

5-84 Kanab RMP 

Name Education Project Role 

Bryan Klyse 

B.A., Social Science (Environment) 

MESM, Environmental Science and 

Management 

Lands and Realty, Vegetation, Forestry 

and Woodland Products 

Bill Lamb B.S., Range Management Senior Public Lands Advisor 

Melanie Martin 

B.S.A., Environmental Protection 

M.A.S., Environmental Policy and 

Management 

Wildland Fire Ecology, Vegetation, 

Forestry and Woodland Products 

Pamela Middleton 

B.A., Biology 

M.A.S., Environmental Policy and 

Management 

Fish and Wildlife, Special Status 

Species, Editing 

Richard Pinkham 

B.A., Geography 

M.S., Natural Resource Policy and 

Management 

Socioeconomics, Socioeconomic 

Baseline Report 

Warner Reeser 

B.A., Mathematics 

M.S., Atmospheric Science 

Ph.D., Earth Resources 

Air Quality 

Mike Sumner B.S., Recreation Resource Management Visual Resources, Transportation, 

Document Preparation 

Victoria Wasem B.S., Marine and Freshwater Biology Air Quality 

Caitlin Willoughby 

B.A., Geology (Environmental Science, 

minor) 

GIS Certification and Coastal Zone 

Management Certification 

M.L.S., Library and Informational Science 

GIS Certification 

GIS Analyst 

Rocky Mountain Environmental Research 

Megan Robinson B.S., Biology, Zoology, and Chemistry Biological Assessment 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-1 

GLOSSARY 

Acquisition. The Bureau of Land Management (BLM) acquires land, easements, and other real property 

rights when it is in the public interest and consistent with approved land use plans (LUP). The BLM’s 

land acquisition program is designed to (1) improve management of natural resources through 

consolidation of federal, state, and private lands; (2) increase recreational opportunities, preserve open 

space, and/or ensure accessibility of public lands; (3) secure key property necessary to protect habitat 

for threatened and endangered species, promote high-quality riparian areas, and promote biological 

diversity; (4) preserve archaeological and historical resources; and (5) implement specific acquisitions 

authorized by Acts of Congress. 

Activity Plan. A type of implementation plan (see Implementation Plan); an activity plan usually 

describes multiple projects and applies best management practices to meet LUP objectives. Examples of 

activity plans include interdisciplinary management plans, habitat management plans, recreation area 

management plans, and allotment management plans (from H-1601-1, BLM Land Use Planning 

Handbook). 

Active Use. Livestock grazing term meaning the current authorized use, including livestock grazing and 

conservation use. Active use may constitute a portion, or all, of permitted use. Active use does not 

include temporary non-use or suspended use of forage within all or a portion of an allotment (43 Code 

of Federal Regulations [CFR] 4100.0-5). 

Actual Use. Livestock grazing term meaning where, how many, what kind or class of livestock, and how 

long livestock graze on an allotment or on a portion or pasture of an allotment (43 CFR 4100.0-5). 

Administrative Use. Official use related to management and resources of the public lands by federal, 

state, or local governments or non-official use sanctioned by an appropriate authorization instrument, 

such as right-of-way (ROW), permit, lease, or maintenance agreement. 

Administrative Route. Routes that are limited to administrative (official or authorized) users only. 

Administrative Purposes. Administrative use functions involving regular maintenance or operation of 

facilities or programs. 

Air Quality. A measure of the health-related and visual characteristics of the air, often derived from 

quantitative measurements of the concentrations of specific injurious or contaminating substances. 

Refers to standards for various classes of land as designated by the Air Pollution Control Act of 1955; 

Clean Air Act of 1963, as amended; and Air Quality Act of 1967. 

All-Terrain Vehicle (ATV). A wheeled or tracked vehicle, other than a snowmobile or work vehicle, 

designed primarily for recreational use or for the transportation of property or equipment exclusively on 

undeveloped roads, trails, marshland, open country, or other unprepared surfaces (from BLM National 

Management Strategy for OHV Use on Public Lands). 

Allotment. An area of land designated and managed for livestock grazing (43 CFR 4100.0-5) (from H4180-1, BLM Standards for Rangeland Health). 

Allotment Management Plan (AMP). A document prepared in consultation with the grazing lessees or 

permittees involved that applies to livestock operations on the public lands and that (1) prescribes the 

manner in and extent to which livestock operations will be conducted to meet the multiple-use, 
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G-2 Kanab RMP 

sustained-yield, economic, and other needs and objectives as determined for the lands by the Secretary 

concerned; (2) describes the type, location, ownership, and general specifications for the range 

improvements to be installed and maintained on the lands to meet the livestock grazing and other 

objectives of land management; and (3) contains such other provisions relating to livestock grazing and 

other objectives found by the Secretary concerned to be consistent with the provisions of this Act and 

other applicable law (from Federal Land Policy and Management Act [FLPMA], Title 43, Chapter 35, 

Subchapter I 1702(k)). 

Analysis of the Management Situation (AMS). Assessment of the current management direction. It 

includes a consolidation of existing data needed for analyzing and resolving identified issues, a 

description of current BLM management guidance, and a discussion of existing problems and 

opportunities for solving them. 

Animal Unit Month (AUM). A standardized measurement of the amount of forage necessary for the 

sustenance of one cow unit or its equivalent for 1 month (about 800 pounds of usable air-dried forage). 

Appropriate Management Response (AMR). The response to a wildland fire based on an evaluation of 

risks to firefighter and public safety; the circumstances under which the fire occurs, including weather 

and fuel conditions; natural and cultural resource management objectives; protection priorities; and 

values to be protected. The evaluation also must include an analysis of the context of the specific fire 

within the overall local area, geographic area, or national wildland fire situation. 

Areas of Critical Environmental Concern (ACEC). Areas within the public lands in which special 

management attention is required (when such areas are developed or used or where no development is 

required) to protect and prevent irreparable damage to important historic, cultural, or scenic values; fish 

and wildlife resources; or other natural systems or processes or to protect life and safety from natural 

hazards (from FLPMA, Title 43, Chapter 35, Subchapter I 1702(a)). 

Assessment. The act of evaluating and interpreting data and information for a defined purpose (from H1601-1, BLM Land Use Planning Handbook). 

Authorized Officer. A federal employee who has the delegated authority to make a specific decision. 

Avoidance Area. Areas with sensitive resources and/or values where ROWs and Section 302 permits, 

leases, and easements would be strongly discouraged. Authorizations made in avoidance areas would 

have to be compatible with the purpose for which the area was designated and not be otherwise feasible 

on lands outside the avoidance area. 

Backcountry. A recreation setting classification characterized by a naturally appearing landscape with 

human modifications not readily noticeable, small areas with limited evidence of surface or vegetative 

disturbances, and little or no evidence of primitive roads or motorized use. Small, isolated structures 

may be present. Contains some primitive trails made of native materials (e.g., log bridges and carved 

wooden signs).

Backcountry Byways. Vehicle routes that traverse scenic corridors using secondary or backcountry road 

systems. National backcountry byways are designated by the type of road and vehicle needed to travel 

the byway. 

Benefits-Based Recreation. A management framework, philosophy, or approach to providing recreation 

and trail resources, facilities, and programs that focuses on identifying the economic, environmental, 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-3 

and social benefits to target recreation users. This management approach builds on existing activity, 

facility, or demographic group orientations but focuses on the outcomes or changes in the target groups. 

Best Management Practices (BMP). A suite of techniques that guide or may be applied to management 

actions to aid in achieving desired outcomes. BMPs are often developed in conjunction with LUPs, but 

they are not considered an LUP decision unless the LUP specifies that they are mandatory. The 

practices may be updated or modified without a plan amendment if they are not mandatory (from H1601-1, BLM Land Use Planning Handbook). 

Big Game. Indigenous ungulate wildlife species that are hunted (e.g., elk, deer, bison, bighorn sheep, and 

pronghorn). 

Biological Assessment (BA). The document prepared by or under the direction of the BLM concerning 

listed and proposed species and designated and proposed critical habitat that may be present in the 

action area. The document contains the BLM’s determination of potential effects of the action on such 

species and habitat. BAs are required for formal consultations and conferences on “major construction 

projects.” They are recommended for all formal consultations and formal conferences and many 

informal consultations in which a written evaluation of the effects of an action on listed or proposed 

species and on designated or proposed critical habitat is needed (from M-6840, Special Status Species 

Manual). 

Biological Opinion (BO). The document that includes (1) the U.S. Fish and Wildlife Service’s (USFWS) 

and/or National Marine Fisheries Service’s (NMFS) opinion as to whether or not a federal action is 

likely to jeopardize the continued existence of listed species or to result in the destruction or adverse 

modification of designated critical habitat; (2) a summary of information on which the opinion is based; 

and (3) a detailed discussion of the effects of the action on listed species or designated critical habitat. 

Depending on the determination of jeopardy or non-jeopardy, the BO may contain reasonable and 

prudent alternatives, a statement of anticipated take of listed animals, and conservation 

recommendations for listed plants (from M-6840, Special Status Species Manual).

Candidate Species. Taxa for which the USFWS has sufficient information on their status and threats to 

support proposing the species for listing as endangered or threatened under the Endangered Species Act 

(ESA) but for which issuance of a proposed rule is currently precluded by higher priority listing actions. 

Separate lists for plants, vertebrate animals, and invertebrate animals are published periodically in the 

Federal Register (from M-6840, Special Status Species Manual). 

Casual Use. Any short-term non-commercial activity ordinarily resulting in no or negligible disturbance 

of the public lands, resources, or improvements. Casual use generally includes surveying, marking 

routes, and data collection. It also includes collecting of geochemical, rock, soil, or mineral specimens 

using hand tools, hand panning, and non-motorized sluicing. It also generally includes use of metal 

detectors, gold spears, and other battery-operated devices for sensing the presence of minerals, and 

hand and battery-operated dry-washers. Casual use excludes the use of mechanized earth-moving 

equipment, truck-mounted drilling equipment, suction dredges, and motorized vehicles in areas 

designated as closed to off-highway vehicles (OHV), chemicals, or explosives. It also excludes 

occupancy or operations in which the cumulative effects of the activities result in more than negligible 

disturbance. 

Cherry-Stemming. Drawing the boundaries of a special management area to exclude the acreage and 

disturbance of a road/way. 
Glossary Proposed RMP and Final EIS 

G-4 Kanab RMP 

Class of Livestock. Livestock grazing term meaning the ages and/or sex groups of a kind of livestock (43 

CFR 4100.0-5). 

Closed. Generally denotes that an area is unavailable for a particular use or uses; refers to specific 

definitions found in law, regulations, or policy guidance for application to individual programs. For 

example, 43 CFR 8340.0-5 sets forth the specific meaning of “closed” as it relates to OHV use, and 43 

CFR 8364 defines “closed” as it relates to closure and restriction orders (from H-1601-1, BLM Land

Use Planning Handbook). 

Code of Federal Regulations (CFR). The official codification of the current, general, and permanent 

regulations of Federal Government activities. 

Collaboration. A cooperative process in which interested parties, often with widely varied interests, work 

together to seek solutions with broad support for managing public and other lands (from H-1601-1, 

BLM Land Use Planning Handbook). 

Collaborative Partnerships or Collaborative Stewardship. Refers to people working together, sharing 

knowledge and resources, to achieve desired outcomes for public lands and communities within 

statutory and regulatory frameworks (from H-1601-1, BLM Land Use Planning Handbook). 

Conformance. Means that a proposed action shall be specifically provided for in the LUP or, if not 

specifically mentioned, shall be clearly consistent with the goals, objectives, or standards of the 

approved LUP (from H-1601-1, BLM Land Use Planning Handbook). 

Conservation Agreement. A formal written document agreed to by USFWS and/or NMFS and another 

federal agency, state agency, local government, or the private sector to achieve the conservation of 

candidate species or other special status species through voluntary cooperation. It documents the 

specific actions and responsibilities for which each party agrees to be accountable. The objective of a 

conservation agreement is to reduce threats to a special status species or its habitat. An effective 

conservation agreement may lower species’ listing priority or eliminate the need for listing (from 

M6840, Special Status Species Manual). 

Conservation Strategy. A strategy outlining current activities or threats that are contributing to the 

decline of a species, along with the actions or strategies needed to reverse or eliminate such a decline or 

threats. Conservation strategies are generally developed for species of plants and animals that are 

designated as BLM-sensitive species or that USFWS or National Oceanic and Atmospheric 

Administration (NOAA) Fisheries have determined to be federal candidates under the ESA (from H1601-1, BLM Land Use Planning Handbook). 

Consistency. Means that the proposed LUP does not conflict with officially approved plans, programs, 

and policies of tribes, other federal agencies, and state and local governments (to the extent practical 

within federal law, regulation, and policy) (from H-1601-1, BLM Land Use Planning Handbook). 

Cooperating Agency. Assists the lead federal agency in developing an Environmental Assessment (EA) 

or Environmental Impact Statement (EIS). The Council on Environmental Quality (CEQ) regulations 

implementing the National Environmental Policy Act of 1969 (NEPA) define a cooperating agency as 

any agency that has jurisdiction by law or special expertise for proposals covered by NEPA (40 CFR 

1501.6). Any federal, state, or local government jurisdiction with such qualifications may become a 

cooperating agency by agreement with the lead agency (from H-1601-1, BLM Land Use Planning 

Handbook). 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-5 

Council on Environmental Quality. An advisory council to the President of the United States 

established by NEPA. It reviews federal programs to analyze and interpret environmental trends and 

information. 

Critical Habitat. (1) The specific areas within the geographical area currently occupied by a species, at 

the time it is listed in accordance with ESA, on which are found those physical or biological features (i) 

essential to the conservation of the species and (ii) that may require special management considerations 

or protection, and (2) specific areas outside the geographical area occupied by a species at the time it is 

listed upon determination by the USFWS and/or NMFS that such areas are essential for the 

conservation of the species. Critical habitats are designated in 50 CFR 17 and 226. The constituent 

elements of critical habitat are those physical and biological features of designated or proposed critical 

habitat essential to the conservation of the species (from M6840, Special Status Species Manual). 

Crucial Value Habitat. Any particular range or habitat component that directly limits a community, 

population, or subpopulation to reproduce and maintain itself at a certain level over the long term. Such 

habitat includes sensitive use areas that, because of limited abundance and/or unique qualities, 

constitute irreplaceable critical requirements for high-interest wildlife. It may also include highly 

sensitive habitats, including fragile soils that have little or no reclamation potential. Restoration or 

replacement of these habitats may not be possible. Examples include the most crucial (critical) summer 

and/or winter range or concentration areas; critical movement corridors; breeding and rearing 

complexes; spawning areas; developed wetlands; Class 1 and 2 streams, lakes, ponds, or reservoirs; and 

riparian habitats critical to high-interest wildlife. 

Crucial Winter Range. The portion of the winter range to which a wildlife species is confined during 

periods of heaviest snow cover. 

Cryptobiotic Crust. Biological communities that form a surface layer or crust on some soils. These 

communities consist of cyanobacteria (blue-green bacteria), micro fungi, mosses, lichens, and green 

algae and perform many important functions, including fixing nitrogen and carbon, maintaining soil 

surface stability, and preventing erosion. Cryptobiotic crusts also influence the nutrient levels of soils 

and the status and germination of plants in the desert. These crusts are slow to recover after severe 

disturbance. 

Cultural Resource or Cultural Property. A definite location of human activity, occupation, or use 

identifiable through field inventory (survey), historical documentation, or oral evidence. The term 

includes archaeological, historic, or architectural sites, structures, or places with important public and 

scientific uses, and may include definite locations (sites or places) of traditional cultural or religious 

importance to specified social and/or cultural groups. Cultural resources are concrete, material places 

and things that are located, classified, ranked, and managed through the system of identifying, 

protecting, and using for public benefit described in this manual series (from M-8100-1, BLM Cultural 

Resources Management). 

Cultural Resource Inventory Classes. (See BLM Manual, Section 8110.21.) Class I: Existing Data 

Inventory. A study of published and unpublished documents, records, files, registers, and other sources, 

resulting in analysis and synthesis of all reasonably available data. Class I inventories encompass 

prehistoric, historic, and ethnological/sociological elements and are in large part chronicles of past land 

uses. They may have major relevance to current land use decisions. Class II: Sampling Field Inventory.

A statistically based sample survey designed to help characterize the probable density, diversity, and 

distribution of archaeological properties in a large area by interpreting the results of surveying limited 

and discontinuous portions of the target area. Class III: Intensive Field Inventory. A continuous, 

intensive survey of an entire target area aimed at locating and recording all archaeological properties 
Glossary Proposed RMP and Final EIS 

G-6 Kanab RMP 

that have surface indications by walking close-interval parallel transects until the area has been 

thoroughly examined. Class III methods vary geographically, conforming to the prevailing standards for 

the region involved (from M-8100-1, BLM Cultural Resources Management). 

Cumulative impact. The impact on the environment resulting from the incremental impact of the action 

when added to other past, present, and reasonably foreseeable future actions regardless of what agency 

(federal or non-federal) or person undertakes such other actions. Cumulative impacts can result from 

individually minor but collectively significant actions taking place over a period of time (from H-1790-

1, BLM NEPA Handbook). 

Designated Roads and Trails. Specific roads and trails identified by the BLM (or other agencies) where 

some type of motorized vehicle use is appropriate and allowed either seasonally or yearlong (from H1601-1, BLM Land Use Planning Handbook). 

Dispersed or Extensive Recreation. Recreation activities of an unstructured type that are not confined to 

specific locations or dependent on recreation sites. Example of these activities may be hunting, fishing, 

off-road vehicle use, hiking, and sightseeing. 

Disposal. Transfer of public land out of federal ownership to another party through sale, exchange, 

Recreation and Public Purposes (R&PP) Act, Desert Land Entry, or other land law statutes. 

Disruptive Activities. Activities that preclude basic life functions for a species. These activities could 

result in individuals leaving a currently used area; increased stress on the individual; and/or not breeding, 

young abandonment, or aberrant behavior. 

Easement. An interest in land entitling the owner or holder, as a matter or right, to enter upon land owned 

by another party for a particular purpose. 

Ecological Site. A kind of land with a specific potential natural community and specific physical site 

characteristics, differing from other kinds of land in their ability to produce distinctive kinds and 

amounts of vegetation and to respond to management. Ecological sites are defined and described with 

information about soil, species composition, and annual production (BLM 2001a).

Ecological Site Description. A written narrative of the description of soils, climate, vegetation, uses, and 

potential of a kind of land with specific physical characteristics to produce distinctive kinds and 

amounts of vegetation (BLM 2001a).

Ecological Site Inventory. A resource inventory that involves the use of soils information to map 

ecological sites and plant communities and the collection of natural resource and vegetation attributes. 

The sampling data from each of these soil-vegetation units, referred to as site write-up areas (SWA), 

become the baseline data for natural resource management and planning (BLM 2001a).

Ecological Succession. An ecosystem’s gradual evolution to a stable state or climax. If through the 

ability of its populations and elements an ecosystem can absorb changes, it tends to persist and become 

stable through time. 

Eligibility. Qualification of a river for inclusion into the National Wild and Scenic Rivers System through 

the determination (professional judgment) that it is free-flowing and, with its adjacent land area, 

possesses at least one river-related value considered to be outstandingly remarkable (from M-8351, 

BLM WSR Policy and Program). 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-7 

Endangered Species. Any species that is in danger of extinction throughout all or a significant portion of 

its range (from M6840, Special Status Species Manual). 

Environmental Assessment (EA). (a) A concise public document for which a federal agency is 

responsible that serves to (1) briefly provide sufficient evidence and analysis for determining whether to 

prepare an EIS or a finding of no significant impact, (2) aid an agency’s compliance with NEPA when 

no EIS is necessary, and (3) facilitate preparation of an EIS when one is necessary. (b) Shall include 

brief discussions of the need for the proposal, alternatives as required by Section 102(2)(E), 

environmental impacts of the proposed action and alternatives, and a listing of agencies and persons 

consulted (from H-1790-1, BLM NEPA Handbook). 

Environmental Impact Statement (EIS). A detailed statement prepared by the responsible official in 

which a major federal action that significantly affects the quality of the human environment is 

described, alternatives to the proposed action provided, and effects analyzed (from BLM National 

Management Strategy for OHV Use on Public Lands). 

Ephemeral Stream. A stream that flows only in direct response to precipitation and whose channel is at 

all times above the water table. Ephemeral streams generally do not flow continuously for more than 

30 days and generally have more robust upland vegetation than that found outside of the ephemeral 

riparian-wetland area (U.S. Department of the Interior [USDOI] 1998). 

Exclusion Area. Areas with sensitive resources and/or values where ROWs and Section 302 permits, 

leases, and easements would not be authorized.

Executive Order (EO). An EO is a presidential directive with the force of law. It does not need 

congressional approval. The Supreme Court has upheld EOs as valid either under the general 

constitutional grant of executive powers to the President or if authority for it was expressly granted to 

the President by the Congress. Congress can repeal or modify an EO by passing a new law; however, it 

must be signed by the President or overridden by his veto. 

Extensive Recreation Management Area (ERMA). A public lands unit identified in LUPs containing 

all acreage not identified as a Special Recreation Management Area (SRMA). Recreation management 

actions within an ERMA are limited to only those of a custodial nature. 

Facies. A lateral or vertical variation in the lithologic or paleontologic characteristics of a geologic 

formation that differs as a group from that elsewhere in the same formation. It is caused by or reflects a 

change in the depositional environments (Stokes 1986; Skinner & Porter 1992). 

Federal Lands. As used in this document, lands owned by the United States, without reference to how 

the lands were acquired or what federal agency administers the lands. The term includes mineral estates 

or coal estates underlying private surface, but excludes lands held by the United States in trust for 

Indians, Aleuts, or Eskimos (see also Public Land). 

Federal Land Policy and Management Act (FLPMA) of 1976. Public Law 94-579, October 21, 1976, 

often referred to as BLM’s “Organic Act,” which provides the majority of BLM’s legislated authority, 

policy direction, and basic management guidance (from BLM National Management Strategy for OHV 

Use on Public Lands). 

Federal Register. A daily publication that reports Presidential and federal agency documents (from BLM 

National Management Strategy for OHV Use on Public Lands). 
Glossary Proposed RMP and Final EIS 

G-8 Kanab RMP 

Fire Management Plan. A strategic implementation-level plan that defines a program to manage 

wildland fire, fuel reduction, and fire rehabilitation based on an area’s approved Resource Management 

Plan (RMP). Fire Management Plans must address a full range of fire management activities that 

support ecosystem sustainability, values to be protected, protection of firefighter and public safety, 

public health, and environmental issues. The plans must be consistent with resource management 

objectives and activities of the area. 

Fiscal Year. The Federal Government’s annual accounting period that begins on October 1 and ends on 

September 30 of the following calendar year. 

Fluid Minerals. Oil, gas, coalbed natural gas, and geothermal resources. 

Forage. Vegetation of all forms available and of a type used for animal consumption. 

Fragile Soils. Soils with intrinsic properties and in areas that make them especially susceptible to erosion. 

These properties include high salt concentrations, very fine textures, shallow depths, and steep slopes 

(more than 30%).

Front Country. A recreation setting classification characterized by a setting on or near improved roads 

but away from highways that includes moderate evidence of human modification that generally 

harmonizes with the surrounding natural landscape. Surface and vegetative modifications are common. 

Structures, including small reservoirs, powerlines, and microwave installations, are generally scattered, 

remaining visually subordinate. Recreation facilities (e.g., campsites, restrooms, trails, and interpretive 

signs) are generally small and rustic.

Functioning at Risk. (1) Condition in which vegetation and soil are susceptible to losing their ability to 

sustain naturally functioning biotic communities. Human activities, past or present, may increase the 

risks (Rangeland Reform Final Environmental Impact Statement at 26). (2) Uplands or riparian-wetland 

areas that are properly functioning, but in which a soil, water, or vegetation attribute makes them 

susceptible to degradation and lessens their ability to sustain natural biotic communities. Uplands are 

particularly at risk if their soils are susceptible to degradation. Human activities, past or present, may 

increase the risks (Rangeland Reform Draft Environmental Impact Statement Glossary). See also 

Properly Functioning Condition and Nonfunctioning Condition (from H-4180-1, BLM Standards for 

Rangeland Health). 

Geographic Information System (GIS). A system of computer hardware, software, data, people, and 

applications that capture, store, edit, analyze, and graphically display a potentially wide array of 

geospatial information (from H-1601-1, BLM Land Use Planning Handbook). 

Goal. A broad statement of a desired outcome; usually not quantifiable and may not have established time 

frames for achievement (from H-1601-1, BLM Land Use Planning Handbook). 

Guideline. A practice, method, or technique determined to be appropriate to ensure that standards can be 

met or that significant progress can be made toward meeting the standard. Guidelines are tools such as 

grazing systems, vegetative treatments, or improvement projects that help managers and permittees to 

achieve standards. Guidelines may be adapted or modified when monitoring or other information 

indicates the guideline is not effective, or a better means of achieving the applicable standard becomes 

appropriate (from H-4180-1, BLM Standards for Rangeland Health). 

Habitat. The place where an organism (plant or animal) lives. There are four major divisions of habitat, 

namely, terrestrial, freshwater, estuarine, and marine (from M6840, Special Status Species Manual). 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-9 

Habitat Management Plan (HMP). An officially approved activity plan for a specific geographic area 

of public land. An HMP identifies wildlife habitat and related objectives, defines the sequence of 

actions to be implemented to achieve the objectives, and outlines procedures for evaluating 

accomplishments. 

Heritage Tourism. A form of recreation that involves experiencing the settings, activities, and people 

that represent the past and present experiences, stories, and peoples. It may include historic, cultural, 

and natural resources and may be dispersed, self-guided, or tour-guided in any recreational setting.

High-Value Habitat. Any particular habitat that sustains a community, population, or subpopulation. It 

includes intensive use areas that because of relative wide distribution do not constitute crucial (Utah 

Division of Wildlife Resources [UDWR] critical) values but are highly important to high-interest 

wildlife. It may also include moderately sensitive habitats of high-interest species that have low 

reclamation potential. Class 3 streams, lakes, ponds, or reservoirs. Reconstruction or enhancement of 

these areas may be possible, but should be avoided if not possible. Examples include less crucial 

(critical) but more widely distributed summer and/or winter ranges, important feeding areas, areas of 

high wildlife diversity and/or density of high-interest species, natural wetlands, and all other riparian 

areas. 

Historic Climax Plant Community. The plant community considered to best typify the potential plant 

community of an ecological site prior to the advent of European man (BLM 2001a).

Hydrology. The science dealing with the properties, distribution, and circulation of water. 

Impacts (or Effects). Environmental consequences (the scientific and analytical basis for comparison of 

alternatives) as a result of a proposed action. Effects may be either direct, which are caused by the 

action and occur at the same time and place, or indirect, which are caused by the action and are later in 

time or farther removed in distance, but are still reasonably foreseeable, or cumulative (from BLM 

National Management Strategy for OHV Use on Public Lands). 

Implementation Decisions. Decisions that take action to implement LUP decisions; generally appealable 

to the Interior Board of Land Appeals under 43 CFR 4.410 (from H-1601-1, BLM Land Use Planning 

Handbook). 

Implementation Plan. A sub-geographic or site-specific plan written to implement decisions made in an 

LUP. Implementation plans include activity plans and project plans (they are types of implementation 

plans) (from H-1601-1, BLM Land Use Planning Handbook). 

Indian Tribe (or tribe). Any Indian group in the conterminous United States that the Secretary of the 

Interior recognizes as possessing tribal status (listed periodically in the Federal Register) (from H1601-1, BLM Land Use Planning Handbook). 

Indicators. Components of a system whose characteristics (presence or absence, quantity, distribution) 

are used as an index of an attribute (e.g., rangeland health attribute) that are too difficult, inconvenient, 

or expensive to measure (Interagency Technical Reference 1734-8, 2000) (from H-4180-1, BLM 

Standards for Rangeland Health). 

Interdisciplinary Team. Staff specialists representing identified skill and knowledge needs working 

together to resolve issues and provide recommendations to an authorized officer (from H-4180-1, BLM 

Standards for Rangeland Health). 
Glossary Proposed RMP and Final EIS 

G-10 Kanab RMP 

Intermittent or Seasonal Stream. A stream that flows only at certain times of the year when it receives 

water from springs or from some surface source such as melting snow in mountainous areas. Generally, 

intermittent streams flow continuously for periods of at least 30 days and usually have visible 

vegetation or physical characteristics reflective of permanent water influences, such as the presence of 

cottonwoods (USDOI 1998). 

Land Tenure Adjustments. Ownership or jurisdictional changes are referred as “Land Tenure 

Adjustments.” To improve the manageability of BLM lands and improve their usefulness to the public, 

the BLM has numerous authorities for “repositioning” lands into a more consolidated pattern, disposing 

of lands, acquiring lands, and entering into cooperative management agreements. These land pattern 

improvements are completed primarily through the use of land exchanges, but also through land sales, 

land acquisitions, jurisdictional transfers to other agencies, and the use of cooperative management 

agreements and leases. 

Land Use Allocation. The identification in a LUP of the activities and foreseeable development that are 

allowed, restricted, or excluded for all or part of the decision area, based on desired future conditions 

(from H-1601-1, BLM Land Use Planning Handbook). 

Land Use Plan (LUP). A set of decisions that establish management direction for land within an 

administrative area, as prescribed under the planning provisions of FLPMA; an assimilation of LUPlevel decisions developed through the planning process outlined in 43 CFR 1600, regardless of the scale 

at which the decisions were developed. The term includes RMPs and Management Framework Plans 

(MFP) (from H-1601-1, BLM Land Use Planning Handbook). 

Land Use Plan Amendment. The process for considering or making changes in the terms, conditions, 

and decisions of approved RMPs or MFPs. Usually only one or two issues are considered that involve 

only a portion of the decision area (from H-1601-1, BLM Land Use Planning Handbook). 

Land Use Plan Decision. Establishes desired outcomes and actions needed to achieve them. Decisions 

are reached using the planning process in 43 CFR 1600. When they are presented to the public as 

proposed decisions, they can be protested to the BLM Director. They are not appealable to the Interior 

Board of Land Appeals (from H-1601-1, BLM Land Use Planning Handbook). 

Lease. An authorization or contract by which one party conveys the use of property to another party in 

return for rental payments. FLPMA Section 302 provides BLM’s authority to issue leases for the use, 

occupancy, and development of the public lands. Leases are also authorized under the R&PP Act for an 

established or definitely proposed project for which there is a reasonable timetable of development and 

satisfactory development and management plans (43 CFR 2741.5). Leases are issued for purposes such 

as communication sites, parks, and other recreational facilities. The regulations establishing procedures 

for the processing of these leases are found in 43 CFR 2920 and 2740. 

Lease Stipulation. A modification of the terms and conditions on a lease form at the time of the lease 

sale. 

Leaseable Minerals. Those minerals or materials designated as leasable under the Mineral Leasing Act 

of 1920, as amended. They include coal, phosphate, asphalt, sulphur, potassium, sodium minerals, oil, 

and gas. 

Lek. An assembly area where birds, especially Greater sage-grouse, carry on display and courtship 

behavior. 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-11 

Limited. An area restricted at certain times, in certain areas, and/or to certain vehicular use. These 

restrictions may be of any type, but can generally be accommodated within the following type of 

categories: numbers of vehicles, types of vehicles, time or season of vehicle use, permitted use only, use 

on existing roads and trails, use on designated routes, and other restrictions (from BLM National 

Management Strategy for OHV Use on Public Lands). 

Limited-Value Habitat. Habitat that is abundant and not essential to sustain a community, population, or 

subpopulation. Occasional use areas that are either sparsely populated or that show sporadic or 

unpredictable use by high-interest wildlife. These areas have limited reclamation potential. Wildlife 

may be displaced due to the common occurrence of these habitats. Examples include yearlong deer 

range of low habitat quality; Class 5 and 6 streams, lakes, ponds, or reservoirs; and low-quality habitat 

in juxtaposition to areas of higher wildlife values. 

Locatable Minerals. Minerals subject to exploration, development, and disposal by staking mining 

claims as authorized by the Mining Law of 1872, as amended. This includes deposits of gold, silver, 

and other uncommon minerals not subject to lease or sale. 

Low-Value Habitat. Habitat that is abundant and not essential to sustain a community, population, or 

subpopulation. 

Management Decision. A decision made by the BLM to manage public lands. Management decisions 

include LUP decisions and implementation decisions (from H-1601-1, BLM Land Use Planning 

Handbook). 

Management Opportunities. A component of the analysis of the management situation and actions or 

management directions that could be taken to resolve issues or management concerns. 

Middle Country. A recreation setting classification characterized by a naturally setting landscape except 

for obvious primitive roads, with subtle human modifications, small areas with limited evidence of 

surface or vegetative disturbances, and evidence of primitive roads or motorized use. Small, isolated 

structures may be present. Contains maintained and marked trails, simple trailhead developments, 

improved signs, and very basic toilets.

Mineral. A naturally formed chemical element or compound having a definite chemical composition and, 

usually, a characteristic crystal form. A mineral is generally considered to be inorganic, although 

organic compounds are classified as minerals by some (American Geological Institute 1974). The term 

is also sometimes informally used to refer to resources such as oil, gas, coal, and stone that are derived 

from the earth. 

Mineral Entry. The filing of a claim on public land to obtain the right to any locatable minerals it may 

contain. 

Mineral Materials. Materials such as sand and gravel and common varieties of stone, pumice, pumicite, 

and clay that are not obtainable under the mining or leasing laws, but that can be acquired under the 

Materials Act of 1947, as amended. 

Mining Claim. A parcel of land that a miner takes and holds for mining purposes, having acquired the 

right of possession by complying with the Mining Law and local laws and rules. A mining claim may 

contain as many adjoining locations as the locator may make or buy. There are four categories of 

mining claims: lode, placer, millsite, and tunnel site. 
Glossary Proposed RMP and Final EIS 

G-12 Kanab RMP 

Mitigation. A method or process by which impacts from actions may be made less injurious to the 

environment through appropriate protective measures. 40 CFR 1508.20 further defines mitigation as (1) 

avoiding the impact altogether by not taking a certain action or parts of an action; (2) minimizing an 

impact by limiting the degree or magnitude of the action and its implementation; (3) rectifying the 

impact by repairing, rehabilitating, or restoring the affected environment; (4) reducing or eliminating 

the impact over time by preservation and maintenance; and (5) compensating for the impact by 

replacing or providing substitute resources or environments. 

Monitoring (Plan Monitoring). The process of tracking the implementation of LUP decisions and 

collecting and assessing data/information necessary to evaluate the effectiveness of land use planning 

decisions (from H-1601-1, BLM Land Use Planning Handbook). 

Multiple Use. The management of the public lands and their various resource values so that they are used 

in the combination that will best meet the present and future needs of the American people; making the 

most judicious use of the land for some or all of these resources or related services over areas large 

enough to provide sufficient latitude for periodic adjustments in use to changing needs and conditions; 

the use of some land for less than all of the resources; a combination of balanced and diverse resource 

uses that takes into account the long-term needs of future generations for renewable and nonrenewable 

resources, including but not limited to recreation; range; timber; minerals; watershed; wildlife and fish; 

and natural scenic, scientific, and historical values; and harmonious and coordinated management of the 

various resources without permanent impairment of the productivity of the land and the quality of the 

environment with consideration being given to the relative values of the resources and not necessarily 

to the combination of uses that will give the greatest economic return or the greatest unit output (from 

FLPMA, Title 43 Chapter 35, Subchapter I 1702[c]). 

National Environmental Policy Act of 1969. NEPA establishes policy, sets goals (Section 101), and 

provides means (Section 102) for carrying out the policy. Section 102(2) contains “action-forcing” 

provisions to make sure that federal agencies act according to the letter and spirit of the Act. The 

President, federal agencies, and the courts share responsibility for enforcing the Act so as to achieve the 

substantive requirements of Section 101. 

National Register. The National Register of Historic Places, expanded and maintained by the Secretary 

of the Interior, as authorized by Section 2(b) of the Historic Sites Act and Section 101(a)(1)(A) of the 

National Historic Preservation Act (NHPA). The National Register lists cultural properties found to 

qualify for inclusion because of their local, state, or national significance. Eligibility criteria and 

nomination procedures are found in 36 CFR 60. The Secretary’s administrative responsibility for the 

National Register is delegated to the National Park Service (from M-8100-1, BLM Cultural Resources 

Management). 

National Wild and Scenic River System. A system of nationally designated rivers and their immediate 

environments that have outstandingly remarkable values such as; scenic, recreational, geologic, fish and 

wildlife, historic, cultural, and other similar values and are preserved in a free-flowing condition. The 

system consists of three river classifications: (1) “recreational”—rivers or sections of rivers that are 

readily accessible by road or railroad and that may have some development along their shorelines and 

may have undergone some impoundments or diversion in the past; (2) “scenic”—rivers or sections of 

rivers free of impoundments with shorelines or watersheds still largely undeveloped but accessible in 

places by roads; and (3) “wild”—rivers or sections of rivers free of impoundments and generally 

inaccessible except by trails, with watersheds or shorelines essentially primitive and waters unpolluted. 

All rivers or river segments in these classifications must possess at least one outstandingly remarkable 

value that is river related. 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-13 

Naturalness. Lands and resources exhibit a high degree of naturalness when affected primarily by the 

forces of nature and where the imprint of human activity is substantially unnoticeable. The BLM has 

authority to inventory, assess, and/or monitor the attributes of the lands and resources on public lands, 

which taken together are an indication of an area’s naturalness. These attributes may include the 

presence or absence of roads and trails, fences, and other improvements; the nature and extent of 

landscape modifications; the presence of native vegetation communities; the resemblance to preEuropean settlement condition; and the connectivity of habitats (from IM-2003-275, Change 1, 

Considerations of Wilderness Characteristics in LUP, Attachment 1). 

No Surface Occupancy. A fluid minerals leasing constraint that prohibits occupancy or disturbance on 

all or part of the lease surface to protect special values or uses. Lessees may exploit the fluid mineral 

resources under the leases restricted by this constraint through use of directional drilling from sites 

outside the area. 

Noxious Weed. A plant species designated by federal or state law as generally possessing one or more of 

the following characteristics: aggressive and difficult to manage; parasitic; a carrier or host of serious 

insects or disease; or non-native, new, or not common to the United States. 

Objective. A description of a desired condition for a resource. Objectives can be quantified and measured 

and, where possible, have established time frames for achievement (from H-1601-1, BLM Land Use 

Planning Handbook). 

Off-Highway Vehicle (OHV). Any motorized vehicle capable of or designed for travel on or 

immediately over land, water, or other natural terrain, excluding (1) any non-amphibious registered 

motorboat; (2) any military, fire, emergency, or law enforcement vehicle while being used for 

emergency purposes; (3) any vehicle whose use is expressly authorized by the authorized officer or 

otherwise officially approved; (4) vehicles in official use; and (5) any combat or combat support vehicle 

when used for national defense (from H-1601-1, BLM Land Use Planning Handbook). 

Official Use. Use by an employee, agent, or designated representative of the Federal Government or one 

of its contractors in the course of his or her employment, agency responsibilities, or representation 

(from BLM National Management Strategy for OHV Use on Public Lands). 

Old-Growth. Old-growth forests are ecosystems distinguished by old trees and related structural features. 

Old-growth encompasses the later stages of stand development that typically differ from earlier stages 

in several ways including tree size; accumulations of large dead, woody material; number of canopy 

layers; species composition; and ecosystem function (from BLM IM-2005-110). 

Open. Generally denotes that an area is available for a particular use or uses. Refer to specific program 

definitions found in law, regulations, or policy guidance for application to individual programs (from 

H-1601-1, BLM Land Use Planning Handbook). For example, 43 CFR 8340.0-5 defines the specific 

meaning of “open” as it relates to OHV use as “an area where all types of vehicle use is permitted at all 

times, anywhere in the area subject to the operating regulations and vehicle standards set forth in” 43 

CFR 8341 and 8342 (43 CFR 8340.0-5(f)). 

Outstandingly Remarkable Values (ORV). Values among those listed in Section 1(b) of the Wild and 

Scenic Rivers Act: “scenic, recreational, geological, fish and wildlife, historical, cultural, or other 

similar values.” Other similar values that may be considered include ecological, biological or botanical, 

paleontological, hydrological, scientific, or research values (from M-8351, BLM WSR Policy and 

Program). 
Glossary Proposed RMP and Final EIS 

G-14 Kanab RMP 

Perennial Stream. A stream that flows continuously. Perennial streams are generally associated with a 

water table in the localities through which they flow. 

Permit. A short-term, revocable authorization to use public lands for specific purposes, FLPMA Section 

302 provides the BLM’s authority to issue permits for the use, occupancy, and development of the 

public lands. Permits are issued for purposes such as commercial or non-commercial filming, 

advertising displays, commercial or non-commercial croplands, apiaries, harvesting of native or 

introduced species, temporary or permanent facilities for commercial purposes (does not include mining 

claims), residential occupancy, construction equipment storage sites, assembly yards, oil rig stacking 

sites, mining claim occupancy if the residential structures are not incidental to the mining operation, 

and water pipelines and well pumps related to irrigation and non-irrigation facilities. The regulations 

establishing procedures for the processing of these permits are found in 43 CFR 2920. 

Permitted Use. The forage allocated by or under the guidance of an applicable LUP for livestock grazing 

in an allotment under a permit or lease, and that is expressed in AUMs (43 CFR 4100.0-5) (from H4180-1, BLM Standards for Rangeland Health). 

Plan of Operations. A plan for mining exploration and development that an operation must submit to the 

BLM for approval when more than 5 acres a year will be disturbed or when an operator plans to work in 

an area of critical environmental concern or a wilderness area. A Plan of Operations must be submitted 

for any new operation that began after January 20, 2001, and that has production, regardless of acreage 

disturbed. A Plan of Operations must document in detail all actions that the operator plans to take from 

exploration through reclamation. 

Planning Criteria. The standards, rules, and other factors developed by managers and interdisciplinary 

teams for their use in forming judgments about decision-making, analysis, and data collection during 

planning. Planning criteria streamline and simplify the resource management planning actions (from H1601-1, BLM Land Use Planning Handbook). 

Potential Natural Community (PNC). The biotic community that would become established if all 

successional sequences were completed without interference by man under the present environmental 

conditions. Natural disturbances are inherent in development. PNCs can include naturalized non-native 

species (BLM 2001a).

Prescribed Fire. Any fire ignited by management action to meet specific objectives. A written approved 

prescribed fire plan must exist, and NEPA requirements must be met prior to ignition (from H-9214-1, 

BLM Prescribed Fire Management Handbook). 

Primitive. A recreation setting classification characterized by a setting that is essentially an unmodified 

natural environment with extremely rare evidence of surface or vegetative disturbances. Trails may be 

present and suited for wilderness use. Structures are small and extremely rare. Enforcement presence is 

very rare.

Primitive and Unconfined Recreation. Those activities that provide dispersed, undeveloped recreation 

which do not require facilities or motorized equipment (from BLM Manual 8560, Section 08, 

Subsection A). 

Project Plan. A type of implementation plan (see Implementation Plan). A project plan typically 

addresses individual projects or several related projects. Examples of project plans include prescribed 

burn plans, trail plans, and recreation site plans (from H-1601-1, BLM Land Use Planning Handbook). 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-15 

Proper Functioning Condition (PFC). (1) An element of the Fundamentals of Rangeland Health for 

watersheds, and therefore a required element of state or regional standard and guidelines under 43 CFR 

4180.2(b). (2) A condition in which vegetation and ground cover maintain soil conditions that can 

sustain natural biotic communities. For riparian areas, the process of determining function is described 

in BLM Technical Reference (TR) 1737-9. (3) Riparian-wetland areas are functioning properly when 

adequate vegetation, landform, or large woody debris is present to dissipate stream energy associated 

with high water flows, thereby reducing erosion and improving water quality; filter sediment, capture 

bed load, and aid floodplain development; improve floodwater retention and groundwater recharge; 

develop root masses that stabilize streambanks against cutting action; develop diverse ponding and 

channel characteristics to provide the habitat and the water depth, duration, and temperature necessary 

for fish production, waterfowl breeding, and other uses; and support greater biodiversity. The 

functioning condition of riparian-wetland areas is influenced by geomorphic features, soil, water, and 

vegetation. (4) Uplands function properly when the existing vegetation and ground cover maintain soil 

conditions capable of sustaining natural biotic communities. The functioning condition of uplands is 

influenced by geomorphic features, soil, water, and vegetation. See also, Nonfunctioning Condition and 

Functioning at Risk (from H-4180-1, BLM Standards for Rangeland Health). 

Proposed Species. Species that have been officially proposed for listing as threatened or endangered by 

the Secretary of the Interior. A proposed rule has been published in the Federal Register (from M6840, 

Special Status Species Manual). 

Public Land. Land or interest in land owned by the United States and administered by the Secretary of 

the Interior through the BLM without regard to how the United States acquired ownership, except lands 

located on the Outer Continental Shelf and land held for the benefit of Indians, Aleuts, and Eskimos 

(from H-1601-1, BLM Land Use Planning Handbook). 

Range Improvement. An authorized physical modification or treatment designed to improve production 

of forage; change vegetation composition; control patterns of use; provide water; stabilize soil and 

water conditions; and restore, protect, and improve the condition of rangeland ecosystems to benefit 

livestock, wild horses and burros, and fish and wildlife. The term includes, but is not limited to 

structures, treatment projects, and use of mechanical devices or modifications achieved through 

mechanical means (43 CFR 4100.0-5) (from H-4180-1, BLM Standards for Rangeland Health). 

Rangeland. A kind of land on which the native vegetation, climax, or natural potential consists 

predominantly of grasses, grasslike plants, forbs, or shrubs. Rangeland includes lands revegetated 

naturally or artificially to provide a non-crop plant cover that is managed like native vegetation. 

Rangeland may consist of natural grasslands, savannahs, shrublands, most deserts, tundra, alpine 

communities, coastal marshes, and wet meadows (from H-4180-1, BLM Standards for Rangeland 

Health). 

Recreation and Public Purposes Act. The R&PP Act provides for the lease and sale of public lands 

determined valuable for public purposes. The objective of the R&PP Act is to meet the needs of state 

and local government agencies and non-profit organizations by leasing or conveying public land 

required for recreation and public purpose uses. Examples of uses made of R&PP lands are parks and 

greenbelts, sanitary landfills, schools, religious facilities, and camps for youth groups. The Act provides 

substantial cost-benefits for land acquisition and provides for recreation facilities or historical 

monuments at no cost. 

Recreation Management Zones (RMZ). Subunits within a SRMA managed for distinctly different 

recreation products. Recreation products are comprised of recreation opportunities, the natural resource 

and community settings within which they occur, and the administrative and service environment 
Glossary Proposed RMP and Final EIS 

G-16 Kanab RMP 

created by all affecting recreation-tourism providers, within which recreation participation occurs (from 

H-1601-1, BLM Land Use Planning Handbook).

Recreation River. A Wild and Scenic River Tentative Classification that applies to those rivers or 

sections of rivers readily accessible by road or railroad that may have some development along their 

shorelines and that may have undergone some impoundment or diversion in the past and possess at least 

one river-related outstandingly remarkable value. 

Relict Plant Community. A remnant or fragment of the vegetation of an area that remains from a former 

period when the vegetation was more widely distributed. 

Resource Management Plan (RMP). A BLM planning document, prepared in accordance with FLPMA 

Section 202, that presents systematic guidelines for making resource management decisions. An RMP 

is based on an analysis of an area’s resources, its existing management, and its capability for alternative 

uses. RMPs are issue oriented and developed by an interdisciplinary team with public participation. 

Resource Use Level. The level of use allowed within an area, based on the desired outcomes and land use 

allocations in the LUP. Targets or goals for resource use levels are established on an areawide or broad 

watershed level in the LUP. Site-specific resource use levels are normally determined at the 

implementation level, based on site-specific resource conditions and needs as determined through 

resource monitoring and assessments (from H-1601-1, BLM Land Use Planning Handbook). 

Right-of-Way (ROW). The public lands authorized to be used or occupied for the construction, 

operation, maintenance, and termination of a project, pursuant to a ROW authorization. 

Riparian Area. A form of wetland transition between permanently saturated wetlands and upland areas. 

A riparian area is defined as an area of land directly influenced by permanent (surface or subsurface) 

water. Riparian areas exhibit vegetation or physical characteristics that reflect the influence of 

permanent surface or subsurface water. Typical riparian areas include lands along, adjacent to, or 

contiguous with perennially and intermittently flowing rivers and streams, hanging gardens, and areas 

surrounding seeps and springs. Excluded are ephemeral streams or washes that lack vegetation and 

depend on free water in the soil. 

Rural. A recreation setting classification characterized by a substantially modified natural setting with 

culturally modified landscapes constantly in view. The setting may include pastoral, agricultural 

landscapes. Surface and vegetative modifications are typical, and constructed roads and highways are 

present. Structures are readily apparent and may include small dominant clusters, including 

campgrounds, group shelters, boat launches, and exhibits.

Salable Minerals. Common variety minerals on the public lands, such as sand and gravel, which are used 

mainly for construction and are disposed of by sales or special permits. 

Scenic Backways. Paved or unpaved routes that have roadsides or corridors of special aesthetic, cultural, 

or historic value in more remote, less visited locations. The corridor may contain outstanding scenic 

vistas, unusual geologic features, or other intrinsic qualities such as cultural, historic, natural, 

recreational, and archaeological values. Scenic Backways can be designated at either the state level or 

by the BLM during the land use planning process. 

Scenic Byways. Highway routes that have roadsides or corridors of special aesthetic, cultural, or historic 

value. The corridor may contain outstanding scenic vistas, unusual geologic features, or other intrinsic 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-17 

qualities such as cultural, historic, natural, recreational, and archaeological values. Scenic Byways can 

be designated at either the state or the federal level. 

Scenic Quality. The relative worth of a landscape from a visual perception point of view. 

Scenic River. A Wild and Scenic River Tentative Classification that applies to those rivers or sections of 

rivers that is free of impoundments and whose shorelines are largely undeveloped but accessible in 

places by roads and possess at least one river-related outstandingly remarkable value. 

Scoping. An early and open process for determining the scope of issues to be addressed and for 

identifying the significant issues related to a proposed action. This involves the participation of affected 

federal, state, and local agencies and any affected Indian tribe, proponent of the action, and other 

interested persons unless there is a limited exception under 40 CFR 1507.3I. 

Section 7 Consultation. The requirement of Section 7 of the ESA that all federal agencies consult with 

USFWS or NMFS if a proposed action may affect a federally listed species or its critical habitat. 

Section 106 Compliance. The requirement of NHPA Section 106 that any project funded, licensed, 

permitted, or assisted by the Federal Government be reviewed for impacts to significant historic 

properties and that the State Historic Preservation Officer and the Advisory Council on Historic 

Preservation be allowed to comment on a project. 

Sensitive Soils. Soils that have a high wind or water erosion hazard, are difficult to reclaim or restore due 

to physical and chemical properties (e.g., high salt or gypsum concentrations, high rock content, or low 

available water), or that are more susceptible to impacts and damage due to high water tables (hydric or 

wetland/riparian soils) or very fine surface textures. Information used to identify sensitive soils includes 

soils surveys, ecological site descriptions, local monitoring records, and research studies. 

Sensitive Species. Those species designated by a State Director, usually in cooperation with the state 

agency responsible for managing the species and state natural heritage programs, as sensitive. They are 

those species that (1) could become endangered in or extirpated from a state or within a significant 

portion of its distribution; (2) are under status review by USFWS and/or NMFS; (3) are undergoing 

significant current or predicted downward trends in habitat capability that would reduce a species’ 

existing distribution; (4) are undergoing significant current or predicted downward trends in population 

or density such that federal listed, proposed, or candidate or state listed status may become necessary; 

(5) typically have small and widely dispersed populations; (6) inhabit ecological refugia or other 

specialized or unique habitats; or (7) are state listed but which may be better conserved through 

application of BLM sensitive species status (from M6840, Special Status Species Manual). 

Significant. An effect that is analyzed in the context of the proposed action to determine the degree or 

magnitude of importance of the effect, whether beneficial or adverse. The degree of significance can be 

related to other actions with individually insignificant but cumulatively significant impacts. 

Special Recreation Management Area (SRMA). A public lands unit identified in LUPs to direct 

recreation funding and personnel to fulfill commitments made to provide specific, structured recreation 

opportunities (i.e., activity, experience, and benefit opportunities). The BLM recognizes three distinct 

types of SRMAs: destination, community, and undeveloped (from H-1601-1, BLM Land Use Planning 

Handbook). 
Glossary Proposed RMP and Final EIS 

G-18 Kanab RMP 

Special Status Species. Includes proposed species, listed species, and candidate species under the ESA; 

state-listed species; and BLM State Director-designated sensitive species (see BLM Manual 6840, 

Special Status Species Policy) (from H-1601-1, BLM Land Use Planning Handbook). 

Socioeconomic Study Area. The geographic area used for estimation and analysis of economic and 

social impacts, consisting of the entirety of Garfield and Kane counties. 

Solitude. The state of being alone or remote from habitations; isolation; a lonely, unfrequented, or 

secluded place. The emphasis is on the opportunities a person has to avoid the sights, sounds, and 

evidence of other people within a particular area (from BLM Manual 8560, Section 08, Subsection A). 

Standard. A description of the physical and biological conditions or degree of function required for 

healthy, sustainable lands (e.g., Land Health Standards). To be expressed as a desired outcome (goal) 

(from H-1601-1, BLM Land Use Planning Handbook). 

State Listed Species. Species listed by a state in a category implying but not limited to potential 

endangerment or extinction. Listing is either by legislation or regulation (from M6840, Special Status 

Species Manual). 

Strutting Ground. An area used by Greater sage-grouse in early spring for elaborate, ritualized courtship 

displays (see also Lek). 

Substantial Value Habitats. Any particular habitat that is common or of intermediate importance. 

Existence areas are used regularly by high-interest wildlife, but are moderate levels with little or no 

concentrated use. These areas may also include moderately sensitive habitats of high-interest species 

with moderate reclamation potential. Wildlife uses may be displaced in response to development. 

Examples include extensive summer and/or winter ranges receiving regular use well below carrying 

capacity having little potential for increase due to other limiting factors; Class 4 streams, lakes, ponds, 

or reservoirs; and areas of moderate habitat quality.

Succession. The progressive replacement of plant communities on a site that leads to the potential natural 

plant community (i.e., attaining stability). Primary succession entails simultaneous succession of soil 

from parent material and vegetation. Secondary succession occurs following disturbances on sites that 

previously supported vegetation and entails plant succession on the more mature soils (BLM 2001a).

Successional Status. The present state of vegetation and soil protection of an ecological site in relation to 

the potential natural community for the site. Successional status is the expression of the relative degree 

to which kinds, proportions, and amounts of plants in a community resemble that of the potential 

natural community. The four classes of successional status ratings, expressed in terms of similarity to 

the potential natural community, are: 0% to 25% early seral class, 26% to 50% mid seral, 51% to 76% 

late seral, and 76% to 100% PNC (BLM 2001a).

Suppression. All the work of extinguishing or containing a fire, beginning with its discovery. 

Surface Disturbance. Greater than casual use actions created through mechanized or mechanical means 

that would cause soil mixing and result in alteration or removal of soil and vegetation, exposing the 

mineral soil to erosive processes to the extent that reclamation may be required. These actions may 

include the use of mechanized earth-moving equipment; truck-mounted drilling equipment; geophysical 

exploration; vehicle travel off routes in areas designated as limited or closed to OHV use; placement of 

surface facilities such as utilities, pipelines, structures, and oil and gas wells; new road construction; 

and use of pyrotechnics, explosives, and hazardous chemicals. Surface disturbing activities would not 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-19 

include livestock grazing, low-impact vegetation management tools (e.g., bullhog, hand thinning, or 

Dixie harrow), cross-country hiking, driving on designated routes, and scientific excavation and/or 

mitigation of limited scope approved by the Field Office Manager. 

Surface Occupancy. Placement or construction on the land surface (either temporary or permanent) for 

more than 14 days requiring continual service or maintenance. Casual use is not included. 

Suspended Use. Temporarily withheld use that is shown on a grazing permit, but is not available for 

active use because of a decision issued by the Authorized Officer or by agreement. 

Take. Harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect, or attempt to engage in any 

such conduct. The term applies only to fish and wildlife (from M6840, Special Status Species Manual). 

Threatened Species. Any species that is likely to become an endangered species within the foreseeable 

future throughout all or a significant portion of its range (from M6840, Special Status Species Manual). 

Timing Limitation (Seasonal Restriction). A fluid minerals leasing constraint that prohibits surface use 

during specified time periods in order to protect identified resource values. The constraint does not 

apply to the operation and maintenance of production facilities unless analysis demonstrates that such 

constraints are needed and that less stringent, project-specific constraints would be insufficient. 

Total Maximum Daily Load (TMDL). An estimate of the total quantity of pollutants (from all sources 

including point, non-point, and natural) that may be allowed into waters without exceeding applicable 

water quality criteria (from H-1601-1, BLM Land Use Planning Handbook). 

Undertaking. A project, activity, or program funded in whole or in part under the direct or indirect 

jurisdiction of a federal agency, including those carried out by or on behalf of a federal agency; those 

carried out with federal financial assistance; those requiring a federal permit, license, or approval; and 

those subject to state or local regulation administered pursuant to a delegation or approval by a federal 

agency. 

Unsuitability Criteria. Criteria of the federal coal management program by which lands may be assessed 

as unsuitable for all or certain stipulated methods of coal mining (43 CFR 3461.5). 

Utility. A service provided by a public utility, such as electricity, telephone, or water. 

Valid Existing Rights. Legal “rights” or interest that are associated with a land or mineral estate and that 

cannot be divested from the estate until that interest expires or is relinquished. Lands within the 

decision area are subject to various authorizations, some giving “rights” to the holders and some of 

which could be construed as providing valid but lesser interests. Valid existing rights are established by 

various laws, leases, and filings under federal law. 

Mineral: Authorizations for activities on existing mineral leases and mining claims are governed by 

valid existing rights. Valid existing rights vary from case to case with respect to oil and gas leases, 

mineral leases, and mining claims, but generally involve rights to explore, develop, and produce 

within the constraints of laws, regulations, and policies at the time the lease/claim was established 

or authorized. 

Non-Mineral: There are other situations, unrelated to minerals, in which the BLM has authorized 

some use of public land or has conveyed some limited interest in public land. The authorization 

may be valid and existing and may convey some “right” or interest. Many ROWs, easements, and 
Glossary Proposed RMP and Final EIS 

G-20 Kanab RMP 

leases granted on public land are in this category. These types vary from case to case, but the details 

of each one are specified in the authorizing document. Valid and existing authorizations of this type 

would continue to be allowed subject to the terms and conditions of the authorizing document. 

RS 2477: Some government entities may have a valid existing right to an access route under Revised 

Statute (RS) 2477, Act of June 26, 1866, ch. 262, §8, 14 Stat. 251 (codified as amended at 43 

U.S.C. 932 until repealed in 1976 by FLPMA, Public Law 94-579, Section 706(a), Stat. 2744, 2793 

[1976]), which granted “the ROW for the construction of highways over public lands, not reserved 

for public uses.” 

Access: The presence of non-federal land and resources within the decision area has implications 

because owners of non-federal land or mineral rights surrounded by public land are entitled to 

reasonable access to their land or resources (State of Utah v Andrus, 1979). Reasonable access is 

defined as access that the Secretary of the Interior deems adequate to secure the owner reasonable 

use and enjoyment of the non-federal land. Such access is subject to rules and regulations 

governing the administration of public land. In determining reasonable access, the BLM has 

discretion to evaluate and would consider such things as proposed construction methods and 

location, reasonable alternatives, and reasonable terms and conditions as are necessary to protect 

the public interest and resources of the decision area. 

Other: There are a variety of other land use authorizations that do not involve the granting of legal 

“rights” or interests. Outfitter and guide permits are an example. These permits authorize certain 

uses of public land for a specified time, under certain conditions, without conveying a right, title, or 

interest in the land or resources used. If at any time it is determined that an outfitter and guide 

permit, other such permit, or any activities under those permits are not consistent with the approved 

RMP, then the authorization would be adjusted, mitigated, or revoked where legally possible. 

Grazing permits are also in this category. Grazing permits or leases convey no right, title, or interest 

in the land or resources used. Other applicable laws and regulations govern changes to existing 

grazing permits and levels of livestock grazing. 

Visual Resources. The visible physical features of a landscape (topography, water, vegetation, animals, 

structures, and other features) that constitute the scenery of an area. 

Visual Resource Management (VRM). The inventory and planning actions taken to identify visual 

values and establish objectives for managing those values, and the management actions taken to achieve 

the visual management objectives. 

Visual Resource Management Classes. VRM classes define the degree of acceptable visual change 

within a characteristic landscape. A class is based on the physical and sociological characteristics of any 

given homogeneous area and serves as a management objective. There are four classes. Each class has 

an objective that prescribes the amount of change allowed in the characteristic landscape, as described 

below. 

Class I: The objective for VRM Class I is to preserve the existing character of the landscape. This 

class provides for natural ecological changes; it does not preclude very limited management 

activity. The level of change to the characteristic landscape should be very low and must not attract 

attention. 

Class II: The objective for VRM Class II is to retain the existing character of the landscape. The level 

of change to the characteristic landscape should be low. Management activities may be seen, but 

should not attract the attention of the casual observer. Any changes must repeat the basic elements 
Proposed RMP and Final EIS Glossary 

Kanab RMP G-21 

of form, line, color, and texture found in the predominant natural features of the characteristic 

landscape. 

Class III: The objective for VRM Class III is to partially retain the existing character of the 

landscape. The level of change to the characteristic landscape should be moderate. Management 

activities may attract attention but should not dominate the view of the casual observer. Any 

changes should repeat the basic elements of form, line, color, and texture found in the predominant 

natural features of the characteristic landscape. 

Class IV: The objective for VRM Class IV is to provide for management activities that require major 

modification of the existing character of the landscape. The level of change to the characteristic 

landscape can be high. These management activities may dominate the view and be the major focus 

of viewer attention. However, every attempt should be made to minimize the impact of these 

activities through careful location; minimal disturbance; and repeating the basic elements of form, 

line, color, and texture found in the predominant natural features of the characteristic landscape. 

Visual Sensitivity Levels. Measures of public concern (e.g., high, medium, or low) for the maintenance 

of scenic quality. 

Water Quality. The chemical, physical, and biological characteristics of water with respect to its 

suitability for a particular use. 

Watershed. The fifth level of the hydrologic unit delineation system. A watershed is coded with 10 

numerical digits, and watersheds range in size from 40,000 to 250,000 acres (Subcommittee on Spatial 

Water Data 2000) (from H-4180-1, BLM Standards for Rangeland Health). 

Watershed Health. Watersheds are in or making significant progress toward properly functioning 

physical condition, including their upland, riparian-wetland, and aquatic components; soil and plant 

conditions support infiltration, soil moisture storage, and the release of water that are in balance with 

climate and landform and maintain or improve water quality, water quantity, and timing and duration of 

flow (BLM 1997a). 

Way. A trace maintained solely by the passage of vehicles which has not been improved and/or 

maintained by mechanical means to ensure relatively regular and continuous use (from H-8550-1, 

Interim Management Policy for Lands Under Wilderness Review). 

Wild River. A Wild and Scenic River Tentative Classification that applies to those rivers or sections of 

rivers that are free of impoundments and generally inaccessible except by trail, with watersheds or 

shorelines essentially primitive and waters unpolluted and possess at least one river-related 

outstandingly remarkable value. These represent vestiges of primitive America. 

Wilderness. A congressionally designated area of undeveloped federal land retaining its primeval 

character and influence, without permanent improvements or human habitation, that is protected and 

managed to preserve its natural conditions and that (1) generally appears to have been affected mainly 

by the forces of nature, with human imprints substantially unnoticeable; (2) has outstanding 

opportunities for solitude or a primitive and unconfined type of recreation; (3) has at least 5,000 acres 

or is large enough to make practical its preservation and use in an unimpaired condition; and (4) may 

also contain ecological, geological, or other features of scientific, educational, scenic, or historic value. 

Wilderness Characteristics. Features of the land associated with the concept of wilderness that 

specifically deal with naturalness and opportunities for solitude and primitive unconfined recreation. 
Glossary Proposed RMP and Final EIS 

G-22 Kanab RMP 

These characteristics may be considered in land use planning when BLM determines that those 

characteristics are reasonably present, of sufficient value (condition, uniqueness, relevance, importance) 

and need (trend, risk), and are practicable to manage (from IM-2003-275, Change 1, Considerations of 

Wilderness Characteristics in LUP, Attachment 1). 

Wilderness Study Area (WSA). Areas that have been inventoried and found to have wilderness 

characteristics as described in FLPMA Section 603 and Section 2(c) of the Wilderness Act of 1964. 

These areas are under study for possible inclusion as a Wilderness Area in the National Wilderness 

Preservation System. 

Wildfire: An unplanned, unwanted wildland fire including unauthorized human-caused fires, escaped 

wildland fire use events, escaped prescribed fire projects, and all other wildland fires where the 

objective is to put the fire out. 

Wilding. A plant growing uncultivated in the wild either as a native or an escape. Specifically, the 

collection of such whole live plants. 

Wildland Fire. Any fire, regardless of ignition source, that is burning outside of a prescribed fire and any 

fire burning on public lands or threatening public land resources, where no fire prescription standards 

have been prepared (from H-1742-1, BLM Emergency Fire Rehabilitation Handbook). 

Wildland Fire Use. The management of naturally ignited wildland fires to accomplish specific pre-stated 

resource management objectives in pre-defined geographic areas outlined in Fire Management Plans. 

Wildland-Urban Interface (WUI). The line, area, or zone in which structures and other human 

development meet or intermingle with undeveloped wildland or vegetative fuels. 

Withdrawal. Removal or withholding an area of federal land from settlement, sale, location, or entry, 

under some or all of the general land laws, for the purpose of limiting activities under those laws in 

order to maintain other public values in the area or reserving the area for a particular public purpose or 

program; or transferring jurisdiction over an area of federal land, other than “property” governed by the 

Federal Property and Administrative Services Act, as amended (40 U.S.C. 472), from one department, 

bureau, or agency to another department, bureau, or agency (from FLPMA, Title 43, Chapter 35, 

Subchapter I 1702(j)). 

Woodland. A forest community occupied primarily by non-commercial species such as juniper, pinyon 

pine, mountain mahogany, or quaking aspen groves; all western juniper forestlands are considered 

woodlands because juniper is classified as a non-commercial species. 
Proposed RMP and Final EIS Abbreviations and Acronyms 

Kanab RMP A-1 

ABBREVIATIONS AND ACRONYMS 

AASHTO American Association of State Highway and Transportation Officials 

ACEC Area of Critical Environmental Concern 

AML Abandoned Mine Lands 

AMR Appropriate Management Response 

AMS Analysis of the Management Situation 

AO Authorized Officer 

APD Application for Permit to Drill (an oil or gas well) 

APP Avian Protection Plan 

ATV All-Terrain Vehicle 

AUM Animal Unit Month 

AVF Alluvial Valley Floors 

BA Biological Assessment 

BCC Birds of Conservation Concern 

BHCA Bird Habitat Conservation Areas 

BLM Bureau of Land Management 

BMP Best Management Practice 

BTU British Thermal Unit 

CAA Clean Air Act 

CBGA Cedar/Beaver/Garfield/Antimony (Resource Management Plan) 

CBNG Coalbed Natural Gas 

CEQ Council on Environmental Quality 

CFR Code of Federal Regulations 

CMAQ Community Multi-Scale Air Quality (a model) 

CO Carbon Monoxide 

COA Condition of Approval 

CSP Concentrating Solar Power 

CSU Controlled Surface Use (oil and gas leasing stipulation) 

DPC Desired Plant Community 

DWFC Desired Wildland Fire Condition 

EA Environmental Assessment 

EAR Environmental Analysis Record 

EIS Environmental Impact Statement 

EO Executive Order 

EPA Environmental Protection Agency 

EPCA Energy Policy and Conservation Act (of 1975) 

ERMA Extensive Recreation Management Area 

ESA Endangered Species Act (of 1973) 

ESR Emergency Stabilization and Rehabilitation 

FLPMA Federal Land Policy and Management Act (of 1976) 

FMP Fire Management Plan 

FO Field Office 

FRCC Fire Regime Condition Class 

FY Fiscal Year 

GIS Geographic Information Systems 

GPS Global Positioning System 

GSENM Grand Staircase–Escalante National Monument 

HAP Hazardous Air Pollutants 

HMP Habitat Management Plan 
Abbreviations and Acronyms Proposed RMP and Final EIS 

A-2 Kanab RMP 

HUC Hydrologic Unit Code 

IBLA Interior Board of Land Appeals 

IC Incident Commander (Appendix 8 only) 

ID Team Interdisciplinary Team 

IM Instruction Memorandum 

IMP BLM Interim Management Policy for Lands Under Wilderness Review 

IMPROVE Interagency Monitoring of Protected Visual Environments 

IPCC Intergovernmental Panel on Climate Change 

IWJV Intermountain West Joint Venture (migratory birds) 

KFO Kanab Field Office 

KPA Kanab Planning Area 

KRCRA Known Recoverable Coal Resource Areas 

kV Kilovolt 

LUP Land Use Plan 

MBTA Migratory Bird Treaty Act 

MFP Management Framework Plan 

MMS Minerals Management Service 

MOA Memorandum of Agreement 

MOU Memorandum of Understanding 

MSO Mexican Spotted Owl 

NAAQS National Ambient Air Quality Standards 

NAGPRA Native American Grave Protection and Repatriation Act 

NAWMP North American Waterfowl Management Plan 

NEPA National Environmental Policy Act (of 1969) 

NHPA National Historic Preservation Act 

NOI Notice of Intent 

NOx Nitrogen Oxides 

NPS National Park Service 

NRA National Recreation Area 

NRCS Natural Resource Conservation Service 

NRHP National Register of Historic Places 

NSB National Scenic Byway 

NSO No Surface Occupancy 

NWSRS National Wild and Scenic Rivers System 

OHV Off-Highway Vehicle 

ORV Outstandingly Remarkable Value 

OSM Office of Surface Mining 

PAC Protected Activity Center (Mexican spotted owls) 

PEIS Programmatic Environmental Impact Statement 

PFC Proper Functioning Condition (of riparian/wetland areas) 

PIF Partners in Flight 

PILT Payment in Lieu of Taxes 

PM2.5 Particulate Matter (less than 2.5 microns in diameter) 

PM10 Particulate Matter (less than 10 microns in diameter) 

PNC Potential Natural Community 

PSD Prevention of Significant Deterioration 

R&I Relevant and Important 

R&PP Recreation and Public Purposes Act 

RFD Reasonably Foreseeable Development 

RMA Recreation Management Area 

RMIS Recreation Management Information System 
Proposed RMP and Final EIS Abbreviations and Acronyms 

Kanab RMP A-3 

RMP Resource Management Plan (BLM land use plan under FLPMA) 

RMZ Recreation Management Zone 

ROD Record of Decision 

ROW Right-of-Way 

RPM Resource Protection Measure (fire stipulations) 

RS 2477 Revised Statute 2477 (mining law related to road rights-of-way) 

RUP Recreation Use Permit 

SHPO State Historic Preservation Officer 

SITLA School and Institutional Trust Lands Administration 

SMCRA Surface Mining Control and Reclamation Act of 1977 

SOx Sulfur Oxides 

SO2 Sulfur Dioxide 

SOP Standard Operating Procedure 

SR State Route 

SRMA Special Recreation Management Area 

SRP Special Recreation Permit 

SSS Special Status Species 

SWReGAP Southwest Regional Gap Analysis Project 

SUWA Southern Utah Wilderness Alliance 

T&E Threatened and/or Endangered (species as per the ESA of 1973) 

TDS Total Dissolved Solids 

TL Timing Limitation 

TLCA Toyota Land Cruiser Association 

TMDL Total Maximum Daily Load 

UACD Utah Association of Conservation Districts 

UDAQ Utah Division of Air Quality 

UDEQ Utah Department of Environmental Quality 

UDOT Utah Department of Transportation 

UDWR Utah Division of Wildlife Resources 

UGS Utah Geological Survey 

U.S.C. United States Code 

USDA United States Department of Agriculture 

USDOI United States Department of the Interior 

USFS United States Forest Service 

USFWS United States Fish and Wildlife Service 

USGS United States Geological Survey 

USU Utah State University 

VOC Volatile Organic Compounds 

VRI Visual Resource Inventory 

VRM Visual Resource Management 

WO Washington Office 

WRCC Western Regional Climate Center 

WSA Wilderness Study Area 

WSR Wild and Scenic River 

WUI Wildland Urban Interface 
Abbreviations and Acronyms Proposed RMP and Final EIS 

A-4 Kanab RMP 

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Proposed RMP and Final EIS References 

Kanab RMP R-1 

REFERENCES 

Adams, R. and D. Simmons. 1999. Ecological effects of fire fighting foams and retardants. New South 

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recharge in arid and semiarid regions. Soil Science Soc. of America J. 58:6–14.

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Armour, C.L. 1991. The effects of livestock grazing on riparian and stream ecosystems. Fisheries 

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Bradley, A.F., N.V. Noste, and W.C. Fischer. 1992. Fire Ecology of Forests and Woodlands in Utah, 

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Brimson, M.M. [Chair]. 2001. Riparian Areas: Functions and Strategies for Management. National 

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pinyon-juniper woodlands: Effects of mechanical overstory reduction and slash treatments 

alternatives. Journal of Environmental Management 64. pp. 179–197. 
References Proposed RMP and Final EIS 

R-2 Kanab RMP 

Buenger, B. 2003. The Impact of Wildland and Prescribed Fire on Archaeological Resources. PhD 

Dissertation. Submitted to the Department of Anthropology, University of Kansas. 

http://www.blm.gov/heritage/docum/Fire/Dissertation_Buenger.htm. 

Bureau of Land Management (BLM). No date. Guidelines for Recreation Management for Public Lands 

in Utah. 

Bureau of Land Management (BLM). 1979. Intermountain Power Project Draft Environmental 

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Bureau of Land Management (BLM). 1986. Utah BLM Statewide Desert Bighorn Sheep Management 

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Bureau of Land Management (BLM). 1991a. Riparian-Wetland Initiative for the 1990s. 

Bureau of Land Management (BLM). 1991b. Utah Statewide Wilderness Study Report, Volume IIA. 

BLM Utah State Office, Salt Lake City, UT. 

Bureau of Land Management (BLM). 1997a. Standards for Rangeland Health and Guidelines for Grazing 

Management for BLM Lands in Utah. United States Department of the Interior, Bureau of Land 

Management, Utah State Office. 

Bureau of Land Management (BLM). 1997b. Final Arizona Statewide Wild & Scenic Rivers Study 

Report/Record of Decision. Arizona State Office: Phoenix, AZ.

Bureau of Land Management (BLM). 1998. Revised Guidelines for Domestic Sheep and Goat 

Management in Native Wild Sheep Habitats. 

Bureau of Land Management (BLM). 1999a. Utah Wilderness Inventory. 

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Record of Decision and Resource Management Plan. United States Department of the Interior, 

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R-18 Kanab RMP 

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BLM Mission 

To sustain the health, diversity, and productivity of the public lands for the use and 

enjoyment of present and future generations. 

BLM-UT-PL-08-002-1610 

UT-110-2007-022 

FES 08-24 





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Proposed RMP and Final EIS Table of Contents 

Kanab RMP i 

TABLE OF CONTENTS 

VOLUME I 

ABSTRACT 

TABLE OF CONTENTS 

EXECUTIVE SUMMARY 

CHAPTER 1—INTRODUCTION, PURPOSE AND NEED 

CHAPTER 2—PROPOSED KANAB RESOURCE MANAGEMENT PLAN 

CHAPTER 3—AFFECTED ENVIRONMENT 

CHAPTER 4—ENVIRONMENTAL CONSEQUENCES OF THE PROPOSED KANAB RESOURCE

MANAGEMENT PLAN 

CHAPTER 5—CONSULTATION AND COORDINATION 

GLOSSARY 

ABBREVIATIONS AND ACRONYMS 

REFERENCES 

VOLUME II 

APPENDICES 

MAPS 
Table of Contents Proposed RMP and Final EIS 

ii Kanab RMP 

VOLUME II TABLE OF CONTENTS 

APPENDICES 

Appendix 1. Best Management Practices for Land Uses 

Appendix 2. Best Management Practices for Raptors and Their Associated Habitats 

Appendix 3. Surface Stipulations Applicable to Oil and Gas Leasing and Other Surface Disturbing 

Activities 

Appendix 4. Recreation Management for Special Recreation Management Areas and the Kanab 

Extensive Recreation Management Area 

Appendix 5. Lands Designated for Potential Disposal Via Federal Land Policy and Management Act 

Section 203 Sale 

Appendix 6. Kanab Field Office: Coal Unsuitability Report 

Appendix 7. Travel Management/Route Designation Process 

Appendix 8. Wildland Fire Resource Protection Measures and Reasonable and Prudent Measures, 

Terms and Conditions, and Reporting Requirements Identified Through Section 7 

Consultation 

Appendix 9. Conservation Measures, Oil and Gas Lease Notices, and Recovery Plans for Threatened 

and Endangered Species 

Appendix 10. Utah Public Lands Study: Key Social Survey Findings for Garfield and Kane Counties 

Appendix 11. Changes Between the Draft RMP/EIS and the Proposed RMP/Final EIS 

Appendix 12. State of Utah Letter Addressing Air Quality 

Appendix 13. Wild and Scenic Rivers Study Process 

Appendix 14. Areas of Critical Environmental Concern Evaluation Report 

Appendix 15. Reasonably Foreseeable Development Scenario 

Appendix 16. Summary of County General Plan Public Land Decisions 
Proposed RMP and Final EIS Table of Contents 

Kanab RMP iii 

MAPS 

Map 1 Land Ownership 

Map 2 Mule Deer Habitat 

Map 3 Elk Habitat 

Map 4 Pronghorn Habitat 

Map 5 Priority Areas for Vegetation Treatment – Proposed RMP 

Map 6 Visual Resource Management – Proposed RMP 

Map 7 Non-WSA Lands Managed for Wilderness Characteristics – Proposed RMP 

Map 8 Special Recreation Management Areas – Proposed RMP 

Map 9 Off-Highway Vehicle Area Designations – Proposed RMP 

Map 10 Route Designations – Proposed RMP 

Map 11 Right-of-Way Restrictions – Proposed RMP 

Map 12 Locatable Minerals – Recommended Withdrawals – Proposed RMP 

Map 13 Areas Available for FLPMA Section 203 Sales – Proposed RMP 

Map 14 Oil and Gas Leasing – Proposed RMP 

Map 15 Areas Available for Further Coal Leasing Consideration – Proposed RMP 

Map 16 Mineral Material (Salable) Disposal – Proposed RMP 

Map 17 Areas of Critical Environmental Concern – Proposed RMP 

Map 18 Suitable Wild and Scenic Rivers – Proposed RMP 

Map 19 General Surface Disturbance Restrictions – Proposed RMP 

Map 20 EPCA Analysis – Proposed RMP 

Map 21 Surface Geology 

Map 22 Physiographic Sub-Units 

Map 23 Precipitation 

Map 24 Areas with Fragile Soils or Relict Vegetation 

Map 25 Fourth-Order Watersheds (Hydrologic Sub-Basins) 

Map 26 Vegetation Communities and Associations 

Map 27 Inventoried Riparian/Wetland Areas 

Map 28 Mexican Spotted Owl Critical Habitat 

Map 29 Greater Sage-Grouse Brooding and Winter Habitat 

Map 30 Desert Bighorn Sheep Habitat 

Map 31 Paleontological Resource Potential 

Map 32 Non-WSA Lands Inventoried for Wilderness Characteristics 

Map 33 Livestock Grazing Allotments 

Map 34 Inventoried Routes 

Map 35 Oil and Gas Development Potential and Existing Oil and Gas Leases and Fields 

Map 36 Coal Development Potential 

Map 37 Gypsum Development Potential 

Map 38 Sand and Gravel Development Potential 

Map 39 Stone and Clay Development Potential 

Map 40 Wilderness and Wilderness Study Areas 

Map 41 Byways, Backways, and Historic Trails 

Map 42 Socioeconomic Study Area 
Table of Contents Proposed RMP and Final EIS 

iv Kanab RMP 

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Proposed RMP and Final EIS Appendix 1 

Kanab RMP A1-1 

APPENDIX 1—BEST MANAGEMENT PRACTICES FOR 

LAND USES 

Best management practices (BMP) are those land and resource management techniques determined to be 

the most effective and practical means of maximizing beneficial results and minimizing conflicts and 

negative environmental impacts from management actions. BMPs can include structural and nonstructural 

controls, specific operations, and maintenance procedures. BMPs can be applied before, during, and after 

activities to reduce or eliminate negative environmental impacts. BMPs are not one-size-fits-all solutions. 

BMPs should be selected and adapted through interdisciplinary analysis to determine which management 

practices are necessary to meet the goals and objectives of the Resource Management Plan (RMP). The 

best practices and mitigation measures for a particular site are evaluated through the site-specific National 

Environmental Policy Act process and vary to accommodate unique, site-specific conditions and local 

resource conditions. 

BMPs described in this appendix are designed to assist in achieving RMP goals and objectives. These 

BMPs could apply, where appropriate, to all use authorizations, including projects initiated by the Bureau 

of Land Management (BLM). BMPs are dynamic and should not be interpreted as specific direction at the 

same level as RMP decisions. BMPs are selected and implemented as necessary, based on site-specific 

conditions, to meet resource objectives for specific management actions. 

This appendix does not provide an exhaustive list of BMPs. Additional BMPs may be identified during an 

interdisciplinary process when evaluating site-specific management actions. Implementation and 

effectiveness of BMPs need to be monitored to determine whether they are achieving RMP goals and 

objectives. Adjustments to BMPs can be made as necessary to ensure that RMP goals and objectives are 

being met as well as to conform to changes in BLM regulations, policy, and direction or new scientific 

information. In addition, project proponents can suggest alternate conditions that could accomplish the 

same result. 

Because the management of environmental impacts is an ongoing process, continual refinement of BMP 

design is necessary. This process can be described in these five steps: (1) selection of the design of a 

specific BMP, (2) application of the BMP, (3) monitoring, (4) evaluation, and (5) feedback. Data gathered 

through monitoring is evaluated and used to identify changes needed in BMP design and application or in 

the monitoring program. 

BMPs have been developed and used by numerous energy companies and state and federal agencies 

throughout the nation. Development and sharing of BMPs represents a commitment to the idea that smart 

planning and responsible follow-through manage and, in some cases, reduce impacts on resources, both 

now and in the future. BMPs developed by other agencies should be considered in addition to those 

identified in this document. Some of these other BMPs are contained in the following documents and 

websites: 

• Utah’s Forest Water Quality Guidelines: A Practical User’s Guide for Landowners, Loggers, and 

Resource Managers (State of Utah, Department of Natural Resources, Division of Forestry, Fire 

and State Lands). As of November 2006, an electronic version of this document was available at 

http://extension.usu.edu/forestry/Management/UtFWQGuide/Assets/PDFDocs/UFWQGBOO.pdf. 

• Coalbed Methane Best Management Practices: A Handbook – 2006 Update (Western Governors’ 

Association). As of November 2006, an electronic version of this document was available at 

www.westgov.org/wga/initiatives/coalbed. 
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A1-2 Kanab RMP 

• Low-Volume Roads Engineering Best Management Practices Field Guide (U.S. Forest Service). As 

of November 2006, an electronic version of this document was available at 

www.blm.gov/bmp/field%20guide.htm. 

• Water-Road Interaction Technology Series Documents (U.S. Forest Service). As of November 

2006, electronic versions of these documents were available at www.stream.fs.fed.us/water-road. 

• National Menu of Stormwater Best Management Practices (U.S. Environmental Protection 

Agency). As of November 2006, electronic versions of these documents were available at 

http://cfpub.epa.gov/npdes/stormwater/menuofbmps/con_site.cfm. 

• BLM Vegetation Treatments Using Herbicides Final Programmatic Environmental Impact 

Statement Record of Decision, September 2007. As of April 2008, an electronic version of this 

document was available at http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. 

• Technical Information Sheets: Specific and Detailed BMP Guidance (Bureau of Land 

Management). As of November 2006, an electronic version of this document was available through 

hyperlinks located at www.blm.gov/bmp/Technical_Information.htm. 

• WO IM 2007-021 Integration of Best Management Practices into Applications for Permit to Drill 

Approvals and Associated Rights of Way. This document establishes formal BLM policy on the 

inclusion and use of BMPs with energy development. As of November 2006, an electronic version 

of this document was available at http://www.blm.gov/wo/st/en/prog/energy/oil_and_gas/ 

best_management_practices.html. 

• Surface Operating Standards and Guidelines for Oil and Gas Exploration and Development: The 

Gold Book (BLM). As of November 2006, an electronic version of this document was available 

through hyperlinks located at www.blm.gov/bmp/Technical_Information.htm. 

In addition, this appendix contains conservation measures identified jointly by the BLM and the U.S. Fish 

and Wildlife Service (USFWS) as needed to protect specific threatened or endangered species. These 

conservation measures are targeted to specific species and must be considered and applied as appropriate. 

POTENTIAL BEST MANAGEMENT PRACTICES

Surface Disturbing Activities 

• Areas subject to surface disturbance should be evaluated for the presence of cultural resources or 

values. This is usually accomplished through the completion of a cultural clearance. An on-theground inspection by a qualified archaeologist, historian, or paleontologist is required. In cases 

where cultural resources are found, the preferred response would be to modify the proposed action 

to avoid the cultural resource (avoidance). If avoidance is not possible, actions would be taken to 

preserve the data or value represented by the cultural resource (mitigation). 

• Areas subject to surface disturbance would be evaluated for the presence of threatened, endangered, 

or candidate animal or plant species. This is usually accomplished through the completion of a 

biological clearance. An on-the-ground inspection by a qualified biologist is required. In cases 

where threatened, endangered, or candidate species are affected, the preferred response would be to 

modify the proposed action to avoid the species or its habitat (avoidance). If avoidance of a 

threatened, endangered, or candidate species or its habitat is not possible, a Section 7 consultation 

with USFWS would be required and a biological assessment would be prepared to recommend 

actions to protect the species or its habitat. 

• Special design and reclamation measures may be required to protect scenic and natural landscape 

values. These measures may include transplanting trees and shrubs, mulching and fertilizing 

disturbed areas, using low-profile permanent facilities, and painting to minimize visual contrasts. 

Surface disturbing activities may be moved to avoid sensitive areas or to reduce the visual effects of 

the activities. 
Proposed RMP and Final EIS Appendix 1 

Kanab RMP A1-3 

• Above-ground facilities requiring painting should be designed to blend in with the surrounding 

environment. 

• Reclamation should be implemented concurrently with construction and site operations to the 

extent possible. Final reclamation actions should be initiated within 6 months of the termination of 

operations unless otherwise approved in writing by the authorized officer. 

• Fill material should be pushed into cut areas and up over back slopes. Depressions should not be 

left that would trap water or form ponds. 

• Design pipeline crossings through riparian areas and across stream channels to minimize impacts to 

these resources. 

Mineral Exploration and Development 

• Reduce impacts on wildlife and visual resources by applying the following, as appropriate: 

– Directional drilling of oil and gas wells

– Drilling of multiple wells from a single pad

– Closed drilling systems

– Cluster development

– Below-ground wellheads

– Remote well monitoring

– Piping of produced liquids to centralized tank batteries off site to reduce traffic to individual 

wells

– Transportation planning (e.g., to reduce road density and traffic volumes)

– Compensation mitigation

– Noise reduction techniques and designs

– Installation of raptor anti-perch devices in Greater sage-grouse habitat 

– Monitoring of wildlife populations during drilling operations

– Avoidance of human activity between 8 p.m. and 8 a.m. from March 1 through May 15 

within 1⁄4 mile of the perimeter of occupied Greater sage-grouse leks

– Onsite bioremediation of oil field waste and spills

– Removal of trash, junk, waste, and other materials not in current use.

• Reclaim all disturbed surface areas promptly, performing concurrent reclamation as necessary, and 

minimize the total amount of surface disturbance. 

• Strip all surface soil prior to conducting operations, stockpiling, and reapplying during reclamation, 

regardless of soil quality. Minimize the length of time soil remains in stockpiles and the depth or 

thickness of stockpiles. 

• Strip and separate soil surface horizons where feasible and reapply in proper sequence during 

reclamation. 

• Establish vegetation cover on soil stockpiles that are to be in place longer than 1 year. 

• Construct and rehabilitate temporary roads, consistent with intended use, to minimize total surface 

disturbance. 

• Consider temporary measures such as silt fences, straw bales, and mulching to trap sediment in 

sensitive areas until reclaimed areas are stabilized with vegetation. 

• Bury distribution powerlines and/or flow lines in or adjacent to access roads. 

• Perform interim reclamation of well locations and access roads after wells are put into production. 

• Reshape all areas to be permanently reclaimed to the approximate original contour, providing for 

proper surface drainage. 

Road Design and Maintenance 

• Keep access roads to a minimum, using them only when necessary. 
Appendix 1 Proposed RMP and Final EIS 

A1-4 Kanab RMP 

• Design roads to minimize total disturbance, to conform to topography, and to minimize disruption 

of natural drainage patterns. 

• Design and maintenance of roads will conform to the BLM Manual and American Association of 

State Highway and Transportation Officials standards where applicable. 

• Locate roads on stable terrain (such as ridgetops, natural benches, and flatter transitional slopes 

near ridges and valley bottoms and moderate sideslopes) and away from slumps, slide-prone areas, 

concave slopes, clay beds, and where rock layers are parallel to the slope. Locate roads on welldrained soil types; avoid wet areas. 

• Construct roads for surface drainage by using outslopes, crowns, grade changes, drain dips, 

waterbars, and/or insloping to ditches as appropriate. Maintain drain dips, waterbars, road crowns, 

insloping, and outsloping, as appropriate, during road maintenance. Grade roads only as necessary. 

• Slope the road base to the outside edge for surface drainage for local spurs or minor collector roads 

where low-volume traffic and lower traffic speeds are anticipated. This also is recommended in 

situations where long intervals between maintenance will occur and where minimum excavation is 

wanted. Outsloping is not recommended on steep slopes. Sloping the road base to the inside edge is 

an acceptable practice on roads with steep sideslopes and where the underlying soil formation is 

very rocky and not subject to appreciable erosion or failure. 

• Construct arterial and collector roads with crown and ditching where traffic volume, speed, and 

intensity and user comfort are considerations. Recommended gradients range from 0 percent to 15 

percent where crown and ditching may be applied, as long as adequate drainage away from the road 

surface and ditch lines is maintained. 

• Construct roads when soils are dry and not frozen, if possible, in soil types with a low sand 

component. When these types of soils or road surfaces become saturated to a depth of 3 inches, 

BLM-authorized activities should be limited or cease unless otherwise approved by the authorized 

officer. 

• Retain vegetation between roads and streams to filter runoff caused by roads. 

• Use culverts that pass, at a minimum, a 50-year storm event and/or have a minimum diameter of 24 

inches for permanent stream crossings and a minimum diameter of 18 inches for road crossdrains. 

• Strip and stockpile topsoil ahead of construction of new roads if feasible. Reapply soil to cuts and 

fillslopes prior to revegetation. 

• Use existing roads whenever possible instead of constructing new roads. 

Rights-of-Way and Utility Corridors 

• Rights-of-way (ROW) and utility corridors should use areas adjoining or adjacent to previously 

disturbed areas whenever possible. 

• Disturbed areas within road ROWs and utility corridors should be stabilized by vegetation practices 

designed to hold soil in place and minimize erosion. Vegetation cover should be reestablished to 

increase infiltration and provide additional protection from erosion. 

• Sediment barriers should be constructed when needed to slow runoff, allow deposition of sediment, 

and prevent transport from the site. Straining or filtration mechanisms also may be employed for 

the removal of sediment from runoff. 

Noxious Weed Management 

• To reduce the potential for the introduction of noxious weeds, all equipment should be cleaned off, 

by pressure washing, prior to operating on BLM lands. Removal of all dirt, grease, and plant parts 

that may carry noxious weed seeds or vegetative parts is required. 
Proposed RMP and Final EIS Appendix 1 

Kanab RMP A1-5 

• All seed, hay, straw, mulch, and other vegetation material transported and used on public land 

weed-free zones for site stability, rehabilitation, or project facilitation should be certified by a 

qualified federal, state, or county officer as free of noxious weeds and noxious weed seed. 

Reducing Impacts on Visual Resource Management Class II and 

Class III Areas

• Bury distribution powerlines and flow lines in or adjacent to access roads.

• Repeat form, line, color, and texture elements to blend facilities with the surrounding landscape.

• Paint all above-ground structures not requiring safety coloration an environmental color that is two 

shades darker than the surrounding environment.

• Perform final reclamation recontouring of all disturbed areas, including access roads, to the original 

contour or a contour that blends with the surrounding topography.

• Avoid facility placement on steep slopes, ridgetops, and hilltops.

• Reclaim unused well pads within 1 year.

Developed Recreation Sites 

• Construct recreation sites and provide appropriate sanitation facilities to minimize impacts on 

resource values and public health and safety and to minimize user conflicts of approved activities 

and access within an area as appropriate. 

• Use public education and/or physical barriers (such as rocks, posts, and vegetation) to direct or 

preclude uses and to minimize impacts on resource values. 

Riparian/Wetland Areas 

• Avoid locating roads, trails, and landings in wetlands. 

• Locate, identify, and mark riparian management areas during the design of projects that may cause 

adverse impacts on riparian management areas. 

• Keep open water free from slash. 

• Avoid equipment operation in areas of open water, seeps, and springs. 

• Use low-ground-pressure equipment (floatation tires or tracks) as necessary to minimize rutting and 

compaction. 

Water Developments 

• Work in springs and stream beds should be done by hand where possible. If machinery is needed in 

these areas, select equipment that minimizes disturbance. 

• After construction of spring head boxes, troughs, pipelines, and well sites, the areas should be 

cleaned up and refuse removed. 

• Cuts, fills, and excavations should be dressed and seeded to blend with surroundings. Pipelines 

should be buried where possible. 

• Original water sources should be protected, and fenced if required, and an offstream watering 

supply should be provided near the site. 

• The size of storage tanks and troughs should accommodate the expected needs of livestock and 

wildlife using them. 

• Water should be left at the site for wildlife. Wells should be cased to prevent cave-ins, and well 

sites should be fenced. 

• Storage structures should be designed to provide water for wildlife. Drinking ramps should be 

installed, and their heights should not prohibit young wildlife from obtaining water. 
Appendix 1 Proposed RMP and Final EIS 

A1-6 Kanab RMP 

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Proposed RMP and Final EIS Appendix 2 

Kanab RMP A2-1 

APPENDIX 2—BEST MANAGEMENT PRACTICES FOR 

RAPTORS AND THEIR ASSOCIATED HABITATS 

I. INTRODUCTION

Raptors, or Birds of Prey, are found on public lands throughout Utah. Approximately 31 species of 

raptors use public lands for at least a portion of their life cycle. These include 20 diurnal raptors, 

including the eagles, hawks, falcons, osprey, turkey vulture, and California condor, and 11 mostly 

nocturnal owl species. At least 16 of the diurnal raptors are known to nest, roost, and forage on public 

lands; two others are probable nesters within the southern part of the state. The California condor is 

known to use public lands for roosting and foraging, but is not currently known to nest within the state. 

The rough-legged hawk is a winter resident that uses public lands for foraging. All of the owl species 

nest, roost, and forage on public lands in Utah. 

Eight of Utah’s raptors are considered to be special status species by the Bureau of Land Management 

(BLM) and currently receive enhanced protection from the BLM, in addition to the regulatory authority 

provided by the Migratory Bird Treaty Act (MBTA), which covers all raptor species. The Mexican 

spotted owl is listed as a federally threatened species and is afforded the protection and the Section 7 

consultation requirements of the Endangered Species Act (ESA). The bald eagle was removed from the 

list of threatened and endangered species by the U.S. Fish and Wildlife Service (USFWS) in June 2007. 

The bald eagle and the golden eagle are protected by the provisions of the Eagle Protection Act. The 

California condor is a federally endangered species; however, the birds found in southern Utah are part of 

an Experimental Non-Essential Population reintroduced to northern Arizona under Section 10(j) of the 

ESA. The BLM is required to treat the condor as a species proposed for listing for ESA Section 7 

purposes. The northern goshawk is managed by a multi-agency Conservation Agreement. The ferruginous 

hawk, short-eared owl, and burrowing owl are listed as Wildlife Species of Concern by the Utah Division 

of Wildlife Resources (UDWR, May 12, 2006) and are therefore recognized as BLM state-sensitive 

species under the BLM 6840 Manual. BLM’s 6840 policy states, “BLM shall ... ensure that actions 

authorized, funded, or carried out ... do not contribute to the need for the species to become listed.”

Future raptor management on BLM lands in Utah will be guided by the use of these best management 

practices (BMP), which are BLM-specific recommendations for implementation of the USFWS Utah 

Field Office’s Guidelines for Raptor Protection From Human and Land Use Disturbances (Guidelines). 

The Guidelines were originally developed by USFWS in 1999 and were updated in 2002 to reflect 

changes brought about by court and policy decisions and to incorporate Executive Order 13186, 

Responsibilities of Federal Agencies To Protect Migratory Birds. The Guidelines were provided to BLM 

and other land management agencies in an attempt to provide raptor management consistency, while 

ensuring project compatibility with the biological requirements of raptors and encouraging an ecosystem 

approach to habitat management. 

These BMPs, or specific elements of the BMPs that pertain to a proposal, should be attached as 

Conditions of Approval (COA) to all BLM use authorizations that have the potential to adversely affect 

nesting raptors or would cause occupied nest sites to become unsuitable for nesting in subsequent years. 

Raptor management is a dynamic and evolving science; consequently, as the science evolves, these BMPs 

will undergo subsequent revision. As more information becomes available through implementation of 

these raptor BMPs, and as our knowledge of raptor life-cycle requirements increases, findings will be 

incorporated into future revisions of the Guidelines. In addition, BLM and the U.S. Department of Energy 
Appendix 2 Proposed RMP and Final EIS 

A2-2 Kanab RMP 

are initiating a 3-year Raptor Radii study that will test traditional spatial and seasonal nest buffers during 

oil and gas development activities for a select suite of species. Study results will also be incorporated into 

new BMP revisions. 

To adequately manage raptors and their habitats, and to reduce the likelihood of a raptor species being 

listed under the ESA, BLM-authorized or BLM-proposed management activities and/or land disturbing 

actions would be subject to the criteria and processes specified within these BMPs. The implementation 

of raptor spatial and seasonal buffers under the BMPs would be consistent with Table 2 of the Guidelines,

included here as Attachment 2. As specified in the Guidelines, modifications of spatial and seasonal 

buffers for BLM-authorized actions would be permitted as long as protection of nesting raptors is 

ensured. State and/or federally listed, proposed, and candidate raptor species, as well as BLM statesensitive raptor species, should be afforded the highest level of protection through this BMP process; 

however, all raptor species would continue to receive protection under the MBTA. Modification of the 

buffers for threatened or endangered species would be considered pending results of Section 7 

consultations with USFWS. 

As stated in the Guidelines, spatial and seasonal buffers should be considered as the best available 

recommendations for protecting nesting raptors under a wide range of activities statewide. However, they 

are not necessarily site-specific to proposed projects. Land managers should evaluate the type and 

duration of the proposed activity, the position of topographic and vegetative features, the sensitivity of the 

affected species, the habituation of breeding pairs to existing activities in the proposed project area, and 

the local raptor nesting density when determining site-specific buffers. BLM would be encouraged to 

informally coordinate with UDWR and USFWS any time a site-specific analysis shows that an action 

may have an adverse impact on nesting raptors. The coordination would determine if the impact could be 

avoided or must be mitigated and, if so, determine appropriate and effective mitigation strategies. 

Potential modifications of the spatial and seasonal buffers identified in the Guidelines may provide a 

viable management option. Modifications would ensure that nest protection would occur, while allowing 

various management options that may deviate from the suggested buffers within the Guidelines, which if 

adequately monitored could provide valuable information for incorporation into future management 

actions. 

Seasonal raptor buffers from Attachment 2 should be reviewed by local raptor nesting authorities who are 

knowledgeable of raptor nesting chronologies within their local areas. For those nesting raptors for which 

local nesting chronologies remain uncertain, the seasonal buffers provided in Attachment 2 should serve 

as the default. However, for those raptor species whose known nesting chronologies differ from the 

seasonal buffers provided in Attachment 2, the local seasonal buffers may be used as a modification of the 

Guidelines. 

Criteria that would need to be met, prior to implementing modifications to the spatial and seasonal buffers 

in the Guidelines, include the following: 

1. Completion of a site-specific analysis by a wildlife biologist or other qualified individual 

(Attachment 1). 

2. Written documentation by the BLM Field Office wildlife biologist, identifying the proposed 

modification and affirming that implementation of the proposed modification would not 

affect nest success or the suitability of the site for future nesting. Modification of the 

Guidelines would not be recommended if it is determined that adverse impacts on nesting 

raptors would occur or that the suitability of the site for future nesting would be 

compromised. 
Proposed RMP and Final EIS Appendix 2 

Kanab RMP A2-3 

3. Development of a monitoring and mitigation strategy by a BLM biologist or other raptor 

biologist. Impacts of authorized activities would be documented to determine if the 

modifications were implemented as described in the environmental documentation or COA 

and were adequate to protect the nest site. Should adverse impacts be identified during 

monitoring of an activity BLM would follow an appropriate course of action, which may 

include cessation or modification of activities that would avoid, minimize, or mitigate the 

impact, or, with the approval of UDWR and USFWS, BLM could allow the activity to 

continue while requiring monitoring to determine the full impact of the activity on the 

affected raptor nest. A monitoring report would be completed and forwarded to UDWR for 

incorporation into the Natural Heritage Program raptor database. 

In a further effort to provide additional support and expertise to local BLM field biologists, a network of 

biologists from various agencies with specific expertise in raptor management has been identified and 

included as Attachment 3. The personnel identified have extensive backgrounds in raptor management 

issues and are available, upon request, to assist BLM field biologists on a case-by-case basis. Field 

biologists are encouraged to use this network, via informal conferences, with one or more of the 

individuals identified. This coordination should be clearly distinguished from the consultation process 

required under ESA Section 7. Individuals on the expert panel should not be expected to provide formal 

advice, but should serve as a sounding board for discussing potential affects of a proposal as well as 

potential mitigation measures on specific projects that may be useful to BLM biologists. 

II. HABITAT ENHANCEMENT

As recommended in the Guidelines, raptor habitat management and enhancement, both within and outside 

of buffers, would be an integral part of these BMPs, with the understanding that in order for raptors to 

maintain high densities and maximum diversity, it is necessary that the habitat upon which they and their 

prey species depend be managed to promote healthy and productive ecosystems. Habitat loss or 

fragmentation would be minimized and/or mitigated to the extent practical and may include such 

measures as drilling multiple wellheads per pad, limiting access roads and avoiding loop roads to well 

pads, effectively rehabilitating or restoring plugged and abandoned well locations and access roads that 

are no longer required, rehabilitating or restoring areas affected by wildland fires to prevent domination 

by non-native invasive annual species, or implementing vegetation treatments and riparian restoration 

projects to achieve Standards for Rangeland Health. 

In some cases, artificial nesting structures located in areas where preferred nesting substrates are limited, 

but where prey base populations are adequate and human disturbances are limited, may enhance some 

raptor populations or may serve as mitigation for impacts occurring in other areas. 

III. PROTECTION OF NEST SITES AND BUFFER ZONES

As stated in the Guidelines, protection of occupied and unoccupied nests is important because not all 

raptor pairs breed every year, nor do they always use the same nest within a nesting territory. Individual 

raptor nests left unused for a number of years are frequently reoccupied if all the nesting attributes that 

originally attracted a nesting pair to a location are still present. Nest sites are selected by breeding pairs 

for the preferred habitat attributes provided by that location. 

Raptor nest buffer zones are established for planning purposes because the nest serves as the focal point 

for a nesting pair of raptors. The buffer should serve as a threshold for potential adverse impacts on nest 
Appendix 2 Proposed RMP and Final EIS 

A2-4 Kanab RMP 

initiation and productivity. Actions proposed within these buffer zones are considered potentially 

impacting, and therefore trigger the need for consideration of site-specific recommendations. 

Seasonal (temporal) buffer zones are conservation measures intended to schedule potentially impacting 

activities to periods outside of the nesting season for a particular raptor species. These seasonal 

limitations are particularly applicable to actions proposed within the spatial buffer zone of a nest for short 

duration activities, such as pipeline or powerline construction, seismic exploration activity, vegetative 

treatments, fence or reservoir construction, or permitted recreational events, where subsequent human 

activity would not be expected to occur. 

Spatial buffer zones are those physical areas around raptor nest sites where seasonal conservation 

measures or surface occupancy restrictions may be applied, depending on the type and duration of 

activity, distance and visibility of the activity from the nest site, adaptability of the raptor species to 

disturbance, etc. Surface occupancy restrictions should be used for actions that would involve human 

activities within the buffer zone for a long duration (more than one nesting season) and that would cause 

an occupied nest site to become unsuitable for nesting in subsequent years. 

Unoccupied Nests 

All Activities, Including All Mineral Leases: Surface disturbing activities occurring outside of the 

breeding season (seasonal buffer), but within the spatial buffer, would be allowed during a minimum 3-

year nest monitoring period, as long as the activity would not cause the nest site to become unsuitable for 

future nesting, as determined by a wildlife biologist. Facilities and other permanent structures would be 

allowed if they meet the above criteria. 

Examples of typical surface disturbing actions occurring outside of the seasonal buffer that may not be 

expected to affect nest production or future nesting suitability include pipelines, powerlines, 

seismographic exploration, communication sites, an oil or gas well with offsite facilities that does not 

require routine maintenance, recreation events, fence or reservoir construction, vegetative treatments, and 

other actions with discrete starting and ending times and for which subsequent human activity or heavy 

equipment operation within the spatial buffer would not be expected to occur or could be scheduled 

outside of the seasonal buffer in subsequent years. 

Surface disturbing activities that would be expected to potentially affect nest production or nest site 

suitability include oil and gas facilities requiring regular maintenance, sand and gravel operations, road 

systems, wind energy projects, mining operations, and other actions requiring continual, random human 

activity or heavy equipment operation during subsequent nesting seasons. 

A nest site that does not exhibit evidence of use, such as greenery in the nest, fresh whitewash, obvious 

nest maintenance, and the observed presence of adults or young at the nest, for a period of 3 consecutive 

years (verified through monitoring) would be deemed abandoned and all seasonal and spatial restrictions 

would cease to apply to that nest. All subsequent authorizations for permanent activities within the spatial 

buffer of the nest could be permitted. If the nest becomes reoccupied after authorized activities are 

completed, conservation measures would be considered to reduce potential adverse affects and to comply 

with the MBTA and the Eagle Protection Act. 

The 3-year non-use standard varies from the Guidelines’ suggested 7-year non-use standard before 

declaring nest abandonment. This variation is based upon a similar standard that has been applied for 

more than 20 years in two administrative areas within Utah. Empirical evidence would suggest that the 3-

year non-use standard has been effective in conserving raptor species. The 3-year standard has been 

applied without legal challenge or violation of “Take” under the MBTA or the Eagle Protection Act. 
Proposed RMP and Final EIS Appendix 2 

Kanab RMP A2-5 

Because prey base populations are known to be cyclic, and because raptor nest initiation or nesting 

success can be affected by drought and other random natural events, care should be taken when applying 

the 3-year non-activity standard. The 3-year nest occupancy monitoring requirement should be viewed as 

a minimum time period during those years of optimal raptor nesting conditions. During suboptimal raptor 

nesting years, when nesting habitat may be affected by drought, low prey base populations, fire, or other 

events, the monitoring standard should be increased to allow raptors the opportunity to reoccupy nesting 

sites when nesting conditions become more favorable. 

Occupied Nests 

All Activities: Land use activities that would have an adverse impact on an occupied raptor nest would 

not be allowed within the spatial or seasonal buffer. 

IV. CONSIDERATION OF MITIGATION MEASURES

Alternatives, including denial of the proposal, should be identified, considered, and analyzed in a National 

Environmental Policy Act (NEPA) document anytime an action is proposed within the spatial buffer zone 

of a raptor nest. Selection of a viable alternative that avoids an impact on nesting raptors should be 

selected over attempting to mitigate those impacts. If unavoidable impacts are identified, mitigation 

measures should be applied as necessary to mitigate adverse impacts of resource uses and development on 

nesting raptors. Monitoring of the effectiveness of the mitigation measures should be mandatory and 

should be included as a Condition of Approval. 

V. SPECIFIC STRATEGIES TO BE IMPLEMENTED REGARDING OTHER 

RESOURCE USES

The following are management strategies designed to reduce or eliminate potential conflicts between 

raptors and other resource uses. This is a list of examples and is not intended to be an all-inclusive list. In 

all cases, when an activity on BLM lands is proposed and a NEPA document is developed, the SiteSpecific Analysis (Attachment 1) may be implemented to identify and either avoid or mitigate impacts on 

raptors from the proposal. These strategies apply to both BLM and applicant-generated proposals. 

A. Cultural Resources 

Excavation and studies of cultural resources in caves and around cliff areas should be delayed until a 

qualified biologist surveys the area to be disturbed or impacted by the activity for the presence of raptors 

or nest sites. If nesting raptors are present, the project should be rescheduled to occur outside of the 

seasonal buffer recommended by the Guidelines. 

B. Forestry and Harvest of Woodland Products 

Timber harvest would be subject to NEPA analysis and would be conducted in a manner that would avoid 

impacts on raptor nests. This could also apply to areas identified for wood gathering and firewood sales. 

C. Hazardous Fuel Reduction/Habitat Restoration Projects 

Hazardous fuel reduction projects and shrubsteppe restoration projects should be reviewed for possible 

impacts on nesting raptors. Removal of trees containing either stick nests or nesting cavities, through 

prescribed fire or mechanical or manual treatments, should be avoided. 
Appendix 2 Proposed RMP and Final EIS 

A2-6 Kanab RMP 

It is important to note that certain raptor species are tied to specific habitat types, and that consideration 

must be made on a site-specific basis when vegetation manipulation projects are proposed in order to 

determine which raptor species may benefit and which may be negatively affected by the vegetation 

composition post-treatment. 

D. Livestock Grazing 

Rangelands and riparian areas should be managed in a manner that promotes healthy, productive 

rangelands and functional riparian systems. Rangeland Health Assessments should be conducted on each 

grazing allotment, and rangeland guidelines should be implemented where Standards for Rangeland 

Health are not being met, to promote healthy rangelands. 

Locations of sheep camps and other temporary intrusions would be located in areas away from raptor nest 

sites during the nesting season. Placement of salt and mineral blocks also would be located away from 

nesting areas. 

Season of use, type of livestock, and target utilization levels of key species affect vegetative community 

attributes (such as percent cover and composition) and influence small mammal and avian species 

diversity and density. While not all raptor species would be affected in the same way, livestock 

management practices that maintain or enhance vegetative attributes will preserve prey species density 

and diversity, which will benefit the raptor resource. 

E. Off-Highway Vehicle Use 

Special Recreation Management Areas (SRMA) that are developed for off-highway vehicle (OHV) use 

would not be located in areas that have important nesting, roosting, or foraging habitats for raptors. 

OHV use would be limited to designated roads, trails, and managed open areas. Lands categorized as 

open for OHV use should not be in areas important to raptors for nesting, roosting, and foraging. 

When proposals for OHV events are received, the area to be impacted would be surveyed by a qualified 

wildlife biologist to determine if the area is used by raptors. Potential conflicts would be identified and 

either avoided or mitigated prior to the issuance of any permit. 

F. Oil and Gas Development 

The Code of Federal Regulations (CFR), 43 CFR 3101.1-2, allows for well site location and timing to be 

modified from that requested by the lessee to mitigate conflicts at the proposed site. It states that the 

location can be moved up to 200 meters, and the timing of the actual drilling can be delayed for up to 60 

days to mitigate environmental concerns. The regulation also allows BLM to move a location more than 

200 meters, or delay operations more than 60 days, to protect sensitive resources if supporting rationale 

and lesser restrictions are ineffective. The Site-Specific Analysis (Attachment 1) would provide the 

supporting rationale. Provisions also are present within Sections 3 and 6 of the Standard Lease Form, 

which require compliance with existing laws and would allow BLM to impose additional restrictions at 

the permitting phase if the restrictions will prevent violation of law, policy, or regulation or avoid undue 

and unnecessary degradation of lands or resources. (Additional stipulations and mitigations would be 

applied to coal developments and other energy-related developments as directed by the Guidelines and as 

directed in Chapter 2 of the Environmental Impact Statement.) 
Proposed RMP and Final EIS Appendix 2 

Kanab RMP A2-7 

G. Realty 

Lands proposed for disposal, which include raptor nesting, roosting, or foraging areas, would be analyzed 

and evaluated for the relative significance of these resources before a decision is made for disposal or 

retention. 

A priority list of important raptor habitat areas, especially for federally listed or state-sensitive raptor 

species, on state and private lands should be developed and used as lands to be acquired by BLM when 

opportunities arise to exchange or otherwise acquire lands. 

Lands and realty authorizations would include appropriate conservation measures to avoid and/or mitigate 

impacts on raptors. 

H. Recreation 

Development of biking trails near raptor nesting areas would be avoided. 

Rock climbing activities would be authorized only in areas where there are no conflicts with cliff-nesting 

raptors. 

In recreation high-use areas where raptor nest sites have been made unsuitable by existing disturbance or 

habitat alteration, mitigation to replace nest sites with artificial nest structures in nearby suitable habitat, if 

it exists, and seasonal protection of nest sites through fencing or other restrictions should be considered. 

Dispersed recreation would be monitored to identify where this use may be impacting the nesting success 

of raptors. 

I. Wild Horse Program 

In areas where wild horse numbers are determined to be in excess of the carrying capacity of the range, 

removal of horses, as described in the various herd management area plans, would continue in order to 

prevent further damage to rangelands. 

VI. INVENTORY AND MONITORING 

Each field office should cooperatively manage a raptor database, with UDWR and USFWS, as part of the 

BLM corporate database. Raptor data should be collected and compiled using the Utah Raptor Data 

Collection Standards developed by the Utah State Office so that personnel from other agencies can access 

the data. Appropriate protocols for survey and monitoring should be followed when available. This 

database should be updated as new inventory and monitoring data becomes available. The data also 

should be forwarded to UDWR and the Natural Heritage Program, which has been identified as the 

central repository for raptor data storage for the State of Utah. 

Use of seasonal employees and volunteers, as well as Challenge Cost Share projects, should be used to 

augment the inventory and monitoring of raptor nests within a planning area, with the data entered into 

the aforementioned databases at the close of each nesting season. Project proponents, such as energy 

development interests, would be encouraged to participate and help support an annual raptor nest 

monitoring effort within their areas of interest. 
Appendix 2 Proposed RMP and Final EIS 

A2-8 Kanab RMP 

Active nest sites should be monitored during all authorized activities that may have an impact on the 

behavior or survival of the raptors at the nest site. A qualified biologist would conduct the monitoring and 

document the impacts of the activity on the species. A final report of the impacts of the project should be 

placed in the Environmental Assessment file, with a copy submitted to the Natural Heritage Program. The 

report would be made available for review, should identify which activities may affect raptor-nesting 

success, and should be used to recommend appropriate buffer zones for various raptor species. 

As data is gathered and impact analyses are more accurately documented, adaptive management 

principles should be implemented. Authorization of future activities should take new information into 

account, better protecting raptors, while potentially allowing more development and fewer restrictions if 

data indicates that current restrictions are beyond those necessary to protect nesting raptors or conversely 

indicates that current guidance is inadequate for protection of nesting raptors. If monitoring detects an 

impact on bird behavior, especially one that might result in "take" the activity could be suspended or 

modified so that the impacts are avoided or removed. 
Proposed RMP and Final EIS Appendix 2 

Kanab RMP A2-9 

ATTACHMENT 1: SITE-SPECIFIC ANALYSIS DATA SHEET

Observer(s) Date____________________________ 

1. Conduct a site visit to the area of the proposed action and complete the raptor nest site 

data sheet according to BLM data standards. 

2. Area of Interest Documentation (Bold items require completion, other information is optional) 

State Office Management Unit_________________

Project ID#

Location (Description)

Legal T , R , Sec. , 1/4, , 1/4, or UTM Coordinates 

Latitude Longitude 

Photos Taken Y ( ) N ( ) 

Description of photos: 

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________

______________________________________________________________________________ 

Raptor Species Confirmed Unconfirmed 

Distance From Proposed Disturbance to: Nest _________________________________ 

 Perch

 Roost

Line of Site Evaluation From: Nest

 Perch

 Roost

Extent of Disturbance: Permanent Temporary 

Distance from Nest/Roost Acreage 
Appendix 2 Proposed RMP and Final EIS 

A2-10 Kanab RMP 

Length of Time Timing Variations Disturbance Frequency 

Other Disturbance Factors: Yes (If yes, explain what and include distances from nest to 

disturbances) No 

Approximate Age of Nest: New Historical: (Number of Years) 

Evidence of Use (Describe): 

Habitat Values Impacted: 

Proportion of Habitat Impacted (Relate in terms of habitat available): 

Estimated Noise Levels of Project (dB):____________ 

Available Alternative(s) (e.g., location, season, technology): 

Associated Activities:
Proposed RMP and Final EIS Appendix 2 

Kanab RMP A2-11 

Cumulative Effects of Proposal and Other Actions in Habitat Not Associated With the 

Proposal: 

Potential for Site Rehabilitation: High Low

Notes/Comments: 

Summary of Proposed Modifications:

Possible modifications to the spatial and seasonal buffers within the USFWS Utah Field Office 

Guidelines include the following: 

Rationale: 

Summary of Proposed Mitigation Measures:

Possible mitigation measures related to the proposal include the following: 

Rationale: 

Summary of Alternatives Considered:

Possible alternatives to the proposal include the following: 
Appendix 2 Proposed RMP and Final EIS 

A2-12 Kanab RMP 

Rationale: 

Recommendation to FO Manager Based on Above Findings: 

 

Field Office Wildlife Biologist Date 
Proposed RMP and Final EIS Appendix 2 

Kanab RMP A2-13 

ATTACHMENT 2: NESTING PERIODS AND RECOMMENDED BUFFERS 

FOR RAPTORS IN UTAH

The following table is adapted from Table 2 of the Guidelines. 

Species 

Spatial 

Buffer 

(miles) 

Seasonal 

Buffer 

Incubation 

# Days 

Brooding, 

# Days 

PostHatch 

Fledging, 

# Days 

PostHatch 

Post-Fledge 

Dependency 

to Nest, # 

Days1

Bald eagle 1.0 1/1–8/31 34–36 21–28 70–80 14–20 

Golden eagle 0.5 1/1–8/31 43–45 30–40 66–75 14–20 

Northern goshawk 0.5 3/1–8/15 36–38 20–22 34–41 20–22 

Northern harrier 0.5 4/1–8/15 32–38 21–28 42 7 

Cooper’s hawk 0.5 3/15–8/31 32–36 14 27–34 10 

Ferruginous hawk 0.5 3/1–8/1 32–33 21 38–48 7–10 

Red-tailed hawk 0.5 3/15–8/15 30–35 35 45–46 14–18 

Sharp-shinned hawk 0.5 3/15–8/31 32–35 15 24–27 12–16 

Swainson’s hawk 0.5 3/1–8/31 33–36 20 36–40 14 

Turkey vulture 0.5 5/1–8/15 38–41 14 63–88 10–12 

California condor 1.0 NN 56–58 5–8 weeks 5–6 months 2 months 

Peregrine falcon 1.0 2/1–8/31 33–35 14–21 35–49 21 

Prairie falcon 0.25 4/1–8/31 29–33 28 35–42 7–14 

Merlin 0.5 4/1–8/31 28–32 7 30–35 7–19 

American kestrel NN2 4/1–8/15 26–32 8–10 27–30 12 

Osprey 0.5 4/1–8/31 37–38 30–35 48–59 45–50 

Boreal owl 0.25 2/1–7/31 25–32 20–24 28–36 12–14 

Burrowing owl 0.25 3/1–8/31 27–30 20–22 40–45 21–28 

Flammulated owl 0.25 4/1–9/30 21–22 12 22–25 7–14 

Great horned owl 0.25 12/1–9/30 30–35 21–28 40–50 7–14 

Long-eared owl 0.25 2/1–8/15 26–28 20–26 30–40 7–14 

Northern saw-whet owl 0.25 3/1–8/31 26–28 20–22 27–34 7–14 

Short-eared owl 0.25 3/1–8/1 24–29 12–18 24–27 7–14 

Mexican spotted owl 0.5 3/1–8/31 28–32 14–21 34–36 10–12 

Northern pygmy owl 0.25 4/1–8/1 27–31 10–14 28–30 7–14 

Western screech owl 0.25 3/1–8/15 21–30 10–14 30–32 7–14 

Common barn owl NN2 2/1–9/15 30–34 20–22 56–62 7–14 

1

 Length of post-fledge dependency period to parents is longer than reported in this table. Reported dependency periods reflect 

the amount of time the young are still dependent on the nest site (e.g., they return to the nest for feeding). 

2

 As a result of apparent high population densities and ability to adapt to human activity, a spatial buffer is currently considered 

not necessary (NN) for maintenance of American kestrel or common barn owl populations. Actions resulting in direct mortality of

individual birds and “take” of known nest sites are unlawful. 
Appendix 2 Proposed RMP and Final EIS 

A2-14 Kanab RMP 

ATTACHMENT 3: UTAH RAPTOR MANAGEMENT EXPERTS FROM 

VARIOUS AGENCIES

The following list of personnel contains individuals from various Utah and federal agencies who are 

recognized experts in the field of raptor ecology or have extensive field experience in managing raptor 

resources with competing land uses. The list is provided to inform BLM field biologists and managers of 

this network of specialized experts who may be able to assist, as time permits, with specific raptor 

management issues. Individuals in the Utah raptor network also have well-established contacts with an 

informal extended network of highly qualified raptor ecologists outside the state (e.g., U.S. Geological 

Survey, state wildlife agencies, and universities) who could provide an additional regional perspective. 

This list is not intended to replace or interfere with established lines of communication but rather 

supplement these lines of communication. 

Utah BLM David Mills david_mills@blm.gov 435-896-1571 

Utah BLM Steve Madsen steve_c_madsen@blm.gov 801-539-4058 

UDWR Dr. Jim Parrish jimparrish@utah.gov 801-538-4788 

UDWR Brian Maxfield brianmaxfield@utah.gov 435-790-5355 

USFWS Laura Romin laura_romin@usfws.gov 801-975-3330 

USFWS Diana Whittington diana_whittington@usfws.gov 801-975-3330 

U.S. Forest Service Chris Colt ccolt@fs.fed.us 801-896-1062 

HawkWatch 

International Jeff Smith jsmith@hawkwatch.org 801-484-6808 
Proposed RMP and Final EIS Appendix 2 

Kanab RMP A2-15 

ATTACHMENT 4: REFERENCES CITED

Code of Federal Regulations, 43 CFR 3101.1-2, Leasing Regulations. 

Endangered Species Act (ESA), 16 U.S.C. 1513-1543. 

Migratory Bird Treaty Act (MBTA), 16 U.S.C. 703-712. 

Romin, Laura A., and James A. Muck. 2002. Utah Field Office Guidelines for Raptor Protection From 

Human and Land Use Disturbances. U.S. Department of the Interior, U.S. Fish and Wildlife 

Service, Utah Field Office, Salt Lake City, Utah. 

U.S. Department of the Interior, Bureau of Land Management. 1997. Standards for Rangeland Health and

Guidelines for Grazing Management on BLM Lands in Utah. 

U.S. Department of the Interior, Bureau of Land Management, 6840 Manual. 
Appendix 2 Proposed RMP and Final EIS 

A2-16 Kanab RMP 

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Proposed RMP and Final EIS Appendix 3 

Kanab RMP A3-1 

APPENDIX 3—SURFACE STIPULATIONS 

APPLICABLE TO OIL AND GAS LEASING AND 

OTHER SURFACE DISTURBING ACTIVITIES 

This appendix lists surface stipulations for oil and gas leasing referred to throughout this Proposed 

Resource Management Plan (RMP)/Final Environmental Impact Statement (EIS). This list of surface 

stipulations only applies to the Proposed RMP and is a subset of the list in Appendix C of the Draft 

RMP/EIS. These surface stipulations would also apply, where appropriate and practical, to other surface 

disturbing activities (and occupancy) associated with land use authorizations, permits, and leases issued 

on Bureau of Land Management (BLM) lands. The stipulations would not apply to other activities and 

uses where they are contrary to laws, regulations, or policy for specific land use authorizations. The intent 

is to manage other activities and uses as consistent as possible with oil and gas leasing. 

Surface disturbing activities are those that normally result in more than negligible disturbance to public 

lands. These activities normally involve disturbance to soils and vegetation to the extent that reclamation 

is required. They include, but are not limited to, the use of mechanized earth-moving equipment; truckmounted drilling equipment; geophysical exploration; off-road vehicle travel in areas designated as 

limited or closed to off-highway vehicle (OHV) use; placement of surface facilities such as utilities, 

pipelines, structures, and oil and gas wells; new road construction; and use of pyrotechnics, explosives, 

and hazardous chemicals. Surface disturbing activities would not include livestock grazing, cross-country 

hiking, driving on designated routes, and minimum impact filming permits. 

DESCRIPTION OF SURFACE STIPULATIONS

Table A3-1 shows resources of concern and stipulations including exceptions, modifications, and waivers. 

Three surface stipulations could be applied to land use authorizations: (1) no surface occupancy (NSO), 

(2) timing limitations (TL), and (3) controlled surface use (CSU). 

Areas identified as NSO (major constraints) would be closed to surface disturbing activities. NSO areas 

would be avoidance areas for rights-of-way (ROW) and where necessary would be recommended for 

withdrawal from operations under the mining laws (locatable minerals) to prevent unacceptable resource 

impacts. An NSO stipulation cannot be applied to locatable minerals without a withdrawal. A withdrawal 

is not a land use planning decision because it must be approved by the Secretary of the Interior. 

Areas identified as TL (moderate constraints) would be closed to surface disturbing activities during 

identified time frames. TL areas would be open to operational and maintenance activities, including 

associated vehicle travel, during the closed period unless otherwise specified in the stipulation. 

Areas identified as CSU (moderate constraints) would require proposals to be authorized only according 

to the controls or constraints specified. The controls would be applicable to all surface disturbing 

activities. 

EXCEPTIONS, MODIFICATIONS, AND WAIVERS

Surface stipulations could be excepted, modified, or waived by the authorized officer. An exception 

exempts the holder of the land use authorization document from the stipulation on a one-time basis. A 

modification changes the language or provisions of a surface stipulation, either temporarily or 
Appendix 3 Proposed RMP and Final EIS 

A3-2 Kanab RMP 

permanently. A waiver permanently exempts the surface stipulation. The environmental analysis 

document prepared for site-specific proposals such as oil and gas development (i.e., applications for 

permit to drill [APD] or sundry notices) also would need to address proposals to exempt, modify, or 

waive a surface stipulation. To exempt, modify, or waive a stipulation, the environmental analysis 

document would have to show that (1) the circumstances or relative resource values in the area had 

changed following issuance of the lease, (2) less restrictive requirements could be developed to protect 

the resource of concern, and (3) operations could be conducted without causing unacceptable impacts. 

STANDARD TERMS AND CONDITIONS

All surface disturbing activities are subject to standard terms and conditions. These include the 

stipulations that are required for proposed actions in order to comply with the Endangered Species Act 

(ESA). Standard terms and conditions for oil and gas leasing provide for relocation of proposed 

operations up to 200 meters and for prohibiting surface disturbing operations for a period not to exceed 60 

days. The stipulations addressed in Table A3-1 that are within the parameters of 200 meters and 60 days 

are considered open to oil and gas leasing subject to standard terms and conditions. 

CLOSED AREAS

Areas identified as closed are not available for oil and gas leasing. Areas where restrictions apply to all 

surface disturbing activities are noted with an asterisk. 
Proposed RMP and Final EIS Appendix 3 

Kanab RMP A3-3 

Table A3-1. Proposed RMP Surface Stipulations and Exception, Modification, and Waiver Criteria 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

Closed Recreation 

Paria Special Recreation Management Area (SRMA) – Canyon Recreation Management Zone (RMZ) and Uplands RMZ 

The Paria SRMA (Canyon RMZ and Uplands RMZ) is in the Paria Canyon Wilderness Area, which is closed to oil and gas leasing. Purpose: To protect recreational values such as world-class wilderness trekking, adventure, viewing deeply entrenched slickrock canyon, and associated slot canyon features. Exception: None Modification: None Waiver: None 

Closed Recreation Moquith Mountain SRMA – Dunes RMZ 

The Moquith Mountain SRMA – Dunes RMZ would be closed to oil and gas leasing. Purpose: To protect unique, scenic, and expansive sand dunes OHV opportunities. Exception: None Modification: None Waiver: None 

Closed Recreation North Fork Virgin River SRMA 

The North Fork Virgin River SRMA would be closed to oil and gas leasing. Purpose: To protect spectacular, primitive riparian canyon travel with abundant geologic formations and diverse flora and fauna. Exception: None Modification: None Waiver: None 

Closed Recreation Orderville Canyon SRMA 

The Orderville Canyon SRMA is entirely within the WSA and would be closed to leasing. 

Purpose: To protect spectacular, primitive riparian canyon travel with abundant geologic formations and diverse flora and fauna. Exception: None Modification: None Waiver: None 

Closed 

Wild and Scenic Rivers 

Suitable “wild” river corridors 

Manage river segments found suitable and classified as “wild” as closed to oil and gas leasing within 1⁄4 mile of each side of the river or the viewshed from the river, whichever is less. Purpose: To protect the tentative classification and outstandingly remarkable values (ORV). Exception: None Modification: None Waiver: None 
Appendix 3 Proposed RMP and Final EIS 

A3-4 Kanab RMP 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

Closed Wilderness 

area 

Paria Canyon–Vermilion Cliffs Wilderness area 

The designated Paria Canyon Wilderness area is closed to oil and gas leasing. Purpose: To protect wilderness values. Exception: None Modification: None Waiver: None 

Closed 

Wilderness Study Area (WSA) 

North Fork Virgin River Orderville Canyon Parunuweap Canyon Canaan Mountain Moquith Mountain 

Areas within WSAs are closed to oil and gas leasing. Purpose: To protect wilderness values. Exception: None Modification: None Waiver: None 

Major (NSO) ACEC Cottonwood Canyon ACEC 

The Cottonwood Canyon ACEC, which includes the existing Water Canyon/South Fork Indian Canyon ACEC, would be open to leasing subject to major constraints (NSO). Purpose: To protect relevant and important (R&I) values, including scenic and cultural values and the Fredonia water supply. Exception: An exception could be authorized if the use is consistent and compatible with protection or enhancement of the resource values or would provide suitable opportunities for public enjoyment of these resources. Modification: None Waiver: None 

Major (NSO) Cultural Resources Sites listed on the National Register of Historic Places 

Sites listed on the National Register of Historic Places would be open to leasing subject to major constraints (NSO). Purpose: To protect sites listed on the National Register of Historic Places for the purposes for which they were listed. Exception: An exception could be authorized if the use is consistent and compatible with protection or enhancement of the resource values or would provide suitable opportunities for public enjoyment of these resources. Modification: None Waiver: None 

Major (NSO) Cultural Resources* 

Within 1⁄4 mile or within the visual horizon, whichever is closer, of cultural sites where the landscape features are important in understanding the property or sites where setting 

Cultural sites within 1⁄4 mile or within the visual horizon, whichever is closer, would be open to leasing subject to major constraints (NSO). Purpose: To protect cultural sites where the landscape features are important in understanding 

the property or sites where the setting directly contributes to the significance of the property. Exception: An exception could be authorized if the use is consistent and compatible with protection or enhancement of the resource values or would provide suitable opportunities for 
Proposed RMP and Final EIS Appendix 3 

Kanab RMP A3-5 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

directly contributes to the significance of the property 

public enjoyment of these resources. Modification: None Waiver: None 

Major (NSO) Fish and Wildlife Within 1 mile of condor nest sites 

Preclude placement of permanent structures or roads within 1 mile of condor nest sites. Purpose: To protect condor nest sites. Exception: An exception could be granted if surveys determine that California condor communal roosting or nesting areas are not occupied. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include habitat or are outside the current defined area, as determined by the 

BLM. Waiver: A waiver may be granted if it is determined the habitat no longer exists or has been 

destroyed. 

Major (NSO) Lands and Realty R&PP Leases 

The areas with Recreation and Public Purposes (R&PP) leases would be open to leasing 

subject to major constraints (NSO). Purpose: To protect the purposes for which the R&PP leases were established. Exception: An exception could be authorized if the use is consistent and compatible with protection or enhancement of the resource values or would provide suitable opportunities for public enjoyment of these resources. Modification: None Waiver: None 

Major (NSO) Lands and Realty Cemeteries 

Cemeteries would be open to leasing subject to major constraints (NSO). Purpose: To protect cemeteries for the purposes they were established and to eliminate 

potential safety issues and surface use conflicts. Exception: An exception could be authorized if the use is consistent and compatible with protection or enhancement of the resource values or would provide suitable opportunities for public enjoyment of these resources. Modification: None Waiver: None 

Major (NSO) Lands and Realty Landfills (existing and closed) 

Existing and closed landfills would be open to leasing subject to major constraints (NSO). Purpose: To eliminate potential safety issues and surface use conflicts. Exception: An exception could be granted if it can be demonstrated that the action would not result in any surface use conflicts. Modification: None Waiver: None 
Appendix 3 Proposed RMP and Final EIS 

A3-6 Kanab RMP 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

Major (NSO) Lands and Realty Incorporated Municipalities 

Incorporated municipalities would be open to leasing subject to major constraints (NSO). Purpose: To eliminate potential safety issues and surface use conflicts. Exception: An exception could be granted if it can be demonstrated that the action would not result in any surface use conflicts. Modification: None Waiver: None 

Major (NSO) Lands and Realty Airports 

Airports would be open to leasing subject to major constraints (NSO). Purpose: To eliminate potential safety issues and surface use conflicts. Exception: An exception could be granted if it can be demonstrated that the action would not result in any surface use conflicts. Modification: None Waiver: None 

Major (NSO) Minerals and Energy Federal facilities 

Federal facilities would be open to leasing subject to major constraints (NSO). Purpose: To protect federal investment in facilities and to eliminate potential safety issues and surface use conflicts. Exception: An exception could be granted if it can be demonstrated that the action would not result in any surface use conflicts. Modification: None Waiver: None 

Major (NSO) Recreation Developed recreation sites 

Developed recreation sites would be open to leasing subject to major constraints (NSO). Purpose: To protect federal investment in facilities, provide for recreational use, and protect the 

viewshed from the facility. Exception: An exception could be granted if a viewshed analysis indicates there would be no impairment of the visual resources from the recreation site. Also, an exception could be authorized if the use is consistent and compatible with protection or enhancement of the 

resource values or would provide suitable opportunities for public enjoyment of the applicable 

resources. Modification: None Waiver: None 

Major (NSO) Recreation Kanab Community SRMA – OHV RMZ 

The Kanab Community SRMA – OHV RMZ would be open to leasing subject to major constraints (NSO). Purpose: To protect close-to-town OHV travel in an exceptionally scenic setting with a variety of trails for different skill levels. Exception: An exception could be authorized if the use is consistent and compatible with 
Proposed RMP and Final EIS Appendix 3 

Kanab RMP A3-7 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

protection or enhancement of the resource values, would provide a public benefit, or would provide suitable opportunities for public enjoyment of the resources. Modification: None Waiver: None 

Major (NSO) Recreation Kanab Community SRMA – Non-Motorized RMZ 

The Kanab Community SRMA – Non-Motorized RMZ would be open to leasing subject to major constraints (NSO). Purpose: To protect town-accessible hiking and an equestrian trail network offering outstanding views and varied terrain. Exception: An exception could be authorized if the use is consistent and compatible with protection or enhancement of the resource values, would provide a public benefit, or would provide suitable opportunities for public enjoyment of the resources. 

Modification: None Waiver: None 

Major (NSO) Recreation 

Moquith Mountain SRMA – Non-Dunes Wooded RMZ – OUTSIDE WSA

The Moquith Mountain SRMA – Non-Dunes Wooded RMZ (outside the WSA) would be open to 

leasing subject to major constraints (NSO). Purpose: To protect a scenic and extensive OHV trail network accessing vistas, overlooks, flora and fauna, and cultural sites. Exception: An exception could be authorized if the use is consistent and compatible with protection or enhancement of the resource values, would provide a public benefit, or would provide suitable opportunities for public enjoyment of the resources. 

Modification: None Waiver: None 

Major (NSO) 

Special Status Species 

Within 1⁄2 mile radius of a Greater sage-grouse lek site 

Manage oil and gas leasing as open subject to major constraints (NSO) within 1⁄2 mile of a Greater sage-grouse lek site. Purpose: To protect occupied lek sites within Greater sage-grouse habitat. Exception: An exception may be granted by the Field Manager if the operator submits a plan that demonstrates that impacts from the proposed action can be adequately mitigated. Modification: The Field Manager may modify the boundaries of the stipulation area if (1) portions of the area do not include lek sites, (2) the lek site(s) have been completely abandoned 

or destroyed, or (3) occupied lek site(s) occur outside the current defined area, as determined by the BLM. Waiver: A waiver may be granted if there are no active lek site(s) in the leasehold and it is determined the site(s) have been completely abandoned or destroyed or occur outside current defined area, as determined by the BLM. 

Major (NSO) Special Within 1⁄2 mile of active Areas within 1⁄2 mile of active bald eagle nest sites would be managed as open to leasing 
Appendix 3 Proposed RMP and Final EIS 

A3-8 Kanab RMP 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

Status Species* 

bald eagle nest sites yearround subject to major constraints (NSO). Purpose: To protect active bald eagle nest sites. 

Exception: An exception may be granted by the Field Manager if authorization is obtained from USFWS (through applicable provisions of the ESA). The Field Manager may also grant an exception if an environmental analysis indicates that the nature of the conduct of the actions, as 

proposed or conditioned, would not impair the primary constituent element determined necessary for the survival and recovery of the bald eagles and USFWS concurs with this determination. Modification: The Field Manager may modify the boundaries of the stipulation area if an environmental analysis indicates and USFWS determines (through applicable provisions of the ESA) that a portion of the area is not being used as bald eagle nesting territory. Waiver: May be granted if bald eagles are de-listed and if USFWS determines it is not 

necessary to protect nesting territories according to the ESA and the Bald Eagle Protection Act 

or if there is no reasonable likelihood of site occupancy over a minimum 10-year period. 

Major (NSO) 

Special Status Species* 

Within 1⁄2 mile of active, suitable, or potential reintroduction Utah prairie dog habitats/sites 

Areas within 1⁄2 mile of active, suitable, or potential reintroduction Utah prairie dog habitats/sites would be managed as open to leasing subject to major constraints (NSO). Purpose: To protect active, suitable, or potential reintroduction Utah prairie dog habitats/sites. 

Exception: An exception may be granted if the applicant submits a plan that indicates that impacts of the proposed action can be adequately mitigated, or, if due to the size of the town 

there is no reasonable location to develop a lease and avoid colonies, the Field Manager will allow for loss of prairie dog colonies and/or habitat to satisfy terms and conditions of the lease. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include prairie dog habitat or active colonies are found outside current defined 

area, as determined by the BLM. Waiver: A waiver may be granted if in the leasehold it is determined that habitat no longer exists or has been destroyed. 

Major (NSO) 

Special Status Species* 

Within 1⁄2 mile around Mexican spotted owl nests 

Areas within 1⁄2 mile around Mexican spotted owl (MSO) nests would be managed as open to leasing subject to major constraints (NSO). Purpose: To protect MSO nests. Exception: An exception may be granted by the Field Manager if concurrence is obtained from USFWS (through applicable provisions of the ESA). The Field Manager may also grant an exception if an environmental analysis indicates that the nature or conduct of the actions would not impair the primary constituent element determined necessary for the survival and recovery of the MSO and USFWS concurs with this determination. Modification: The Field Manager may modify the boundaries of the stipulation area if an environmental analysis indicates and USFWS determines (through applicable provisions of the ESA) that a portion of the area is not being used as critical habitat. 
Proposed RMP and Final EIS Appendix 3 

Kanab RMP A3-9 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

Waiver: A waiver may be granted if the MSO is de-listed and the critical habitat is determined by USFWS as not necessary for the survival and recovery of the MSO. 

Major (NSO) Vegetation 

Relict Vegetation (Diana’s Throne and Elephant Butte) 

Restrict surface occupancy (NSO) for surface disturbing activities to protect relict vegetation at Diana’s Throne and Elephant Butte. Purpose: To protect relict vegetation at Diana’s Throne and Elephant Butte. Exception: Exceptions could be allowed if the use is consistent and compatible with protection or enhancement of the resource values or would provide suitable opportunities for public enjoyment of these resources. Modification: None Waiver: None 

Major (NSO) Water* Within 330 feet of riparian areas 

Do not allow new surface disturbing activities within 330 feet of riparian/wetland areas. Purpose: To protect riparian areas. Exception: An exception could be authorized if (a) there are no practical alternatives, (b) all long-term impacts could be fully mitigated, or (c) the activity would benefit and enhance the riparian area. Modification: None Waiver: None 

Major (NSO) 

Wild and Scenic Rivers 

Suitable “scenic” river corridors 

Manage oil and gas leasing as open subject to major constraints (NSO) in the East Fork Virgin River segment 37-40a suitable “scenic” river segment (within 1⁄4 mile of each side of the river or the viewshed from river, whichever is less). Purpose: To protect the tentative classification and ORVs. Exception: An exception could be authorized if the activity would benefit and enhance the tentative classification and ORVs. Modification: None Waiver: None 

Major (NSO) 

Wild and Scenic Rivers 

Suitable wild and scenic river “recreational” segment East Fork Virgin River (segment 36-37) – OUTSIDE THE WSA 

Manage oil and gas leasing as open subject to major constraints (NSO) in the East Fork Virgin River segment 36-37 suitable “recreational” river segment (within 1⁄4 mile of each side of the river or the viewshed from river, whichever is less). Purpose: To protect the tentative classification and ORVs. Exception: An exception could be authorized if the activity would benefit and enhance the tentative classification and ORVs. Modification: None Waiver: None 

Moderate Soil Fragile soils areas Develop and implement site-specific restrictions and/or mitigations for activities proposed in 
Appendix 3 Proposed RMP and Final EIS 

A3-10 Kanab RMP 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

(CSU) fragile soil areas on a case-by-case basis. The BLM must approve surface disturbing activities 

before construction and maintenance would be authorized. Allow surface disturbance in fragile soil areas as long as impacts would be mitigated or disturbance would be beneficial to rangeland health. Purpose: To protect fragile soil resources. Exception: An exception could be authorized if the use is consistent and compatible with longterm protection or enhancement of soil resource values. Modification: None Waiver: None 

Moderate (CSU) 

Special Status Species 

Federally listed and candidate plant species occupied and suitable habitat 

Manage oil and gas leasing as open subject to moderate constraints (CSU) in federally listed and candidate plant species-occupied and suitable habitat. In these areas, well placement would be located to not adversely affect the species or its habitat. Purpose: To protect federally listed and candidate plant species-occupied and suitable habitat. Exception: None Modification: If federally listed and candidate plant species are not identified in the habitat, development could occur, but site-specific mitigation requirements could be included in the application for permit to drill. Waiver: None 

Moderate (CSU) 

Visual Resources VRM Class II areas 

Surface disturbing activities must meet the objectives of Visual Resource Management (VRM) Class II. Purpose: To protect high-quality visual resources. Exception: The level of change to the landscape should be low; management activities may be seen, but should not attract the attention of the casual observer. Any change to the landscape 

must repeat the basic elements of form, line, color, and texture found in the predominant natural 

features of the characteristic landscape. Surface disturbing activities that are determined to be compatible and consistent with the protection or enhancement of the resource values are exempted. Also, recognized utility corridors are exempted only for utility projects, which would be managed according to VRM Class III objectives. Modification: None Waiver: None

Moderate (CSU) Water 

Culinary water supply in the following areas: T 42 S R 6 W Sections 19, 31 T 42 S R 7 W Sections 23, 24, 25, 26, 27, 34, 35 

Manage oil and gas leasing as open to leasing subject to moderate constraints to protect culinary water supply as directed by the Land Use Agreement for Kanab City Existing Wells in the following sections: T 42 S R 6 W Sections 19, 31 T 42 S R 7 W Sections 23, 24, 25, 26, 27, 34, 35 In these areas (1) well placement would be located to eliminate potential contamination sources or pollution sources and/or (2) design standards would be implemented to prevent 
Proposed RMP and Final EIS Appendix 3 

Kanab RMP A3-11 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

contaminated discharges to ground water. Purpose: To protect culinary water supply as directed by the Land Use Agreement for Kanab City Existing Wells. Exception: If federally listed and candidate plant species are not identified in the habitat, there 

would be no restrictions. Modification: None Waiver: None 

Moderate (TL) Fish and Wildlife 

Identified big game migration and transitional ranges from October 1 to November 15 

Preclude oil and gas development and ROW construction/reconstruction in identified big game migration and transitional ranges from October 1 to November 15. Purpose: To minimize disturbance within identified big game migration and transitional ranges. Exception: The Field Manager may grant an exception if the operator submits a plan that demonstrates that impacts from the proposed action can be adequately mitigated. Modification: The Field Manager may modify the boundaries of the stipulation area if a portion of the area is (1) not being used as big game migration and transitional ranges and (2) if habitat is being used outside of stipulation boundaries for big game migration and transitional ranges and needs to be protected. Waiver: A waiver may be granted if the habitat is determined to be unsuitable for big game migration and transitional ranges and there is no reasonable likelihood of future use as big game migration and transitional ranges. 

Moderate (TL) Fish and Wildlife* Crucial mule deer and elk winter range from November 15 to April 15 

Preclude surface disturbing activities in crucial mule deer and elk winter range from November 15 to April 15 unless the activity would improve mule deer or elk habitat. Purpose: To minimize stress and disturbance to deer and elk during critical winter months. Exception: This stipulation does not apply to the maintenance and operation of existing and ongoing facilities. An exception may be granted by the Field Manager if the operator submits a plan that demonstrates that impacts from the proposed action can be adequately mitigated or it 

is determined the habitat is not being used during the winter period for any given year. Modification: The Field Manager may modify the boundaries of the stipulation area if (1) a 

portion of the area is not being used as crucial winter range by deer/elk, (2) habitat outside of stipulation boundaries is being used as crucial winter range and needs to be protected, or (3) 

the migration patterns have changed causing a difference in the season of use. Waiver: A waiver may be granted if the winter range habitat is unsuitable or unoccupied during winter months by deer/elk and there is no reasonable likelihood of future winter range use. 

Moderate (TL) Fish and Wildlife* 

Crucial Desert bighorn sheep habitat from April 15 to June 15 during lambing season 

Preclude surface disturbing activities in crucial Desert bighorn sheep habitat during lambing season (April 15 through June 15). Purpose: To minimize disturbance within crucial Desert bighorn sheep habitat during lambing season. 
Appendix 3 Proposed RMP and Final EIS 

A3-12 Kanab RMP 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

Exception: The Field Manager may grant an exception if the operator submits a plan that demonstrates that impacts from the proposed action can be adequately mitigated. Modification: The Field Manager may modify the boundaries of the stipulation area (1) if a portion of the area is not being used as crucial Desert bighorn sheep habitat during lambing season or (2) if habitat outside of stipulation boundaries is being used for crucial Desert bighorn sheep habitat and needs to be protected. Waiver: A waiver may be granted if the habitat is determined to be unsuitable for crucial Desert bighorn sheep habitat and there is no reasonable likelihood of future use as crucial Desert bighorn sheep habitat. 

Moderate (TL) Fish and Wildlife* Crucial pronghorn habitat from May 15 to June 15 during fawning season 

Preclude surface disturbing activities in crucial pronghorn habitat from May 15 through June 15 during fawning season. Purpose: To minimize disturbance within crucial pronghorn habitat during fawning season. Exception: The Field Manager may grant an exception if the operator submits a plan that 

demonstrates that impacts from the proposed action can be adequately mitigated. Modification: The Field Manager may modify the boundaries of the stipulation area (1) if a portion of the area is not being used as crucial pronghorn habitat during fawning season or (2) if habitat outside of stipulation boundaries is being used for crucial pronghorn habitat and needs to be protected. Waiver: A waiver may be granted if the habitat is determined as unsuitable for crucial pronghorn habitat and there is no reasonable likelihood of future use as crucial pronghorn habitat. 

Moderate (TL) Fish and Wildlife* 

Prohibit disruptive activities within 1 mile of Peregrine falcon nest sites from February 1 to August 31 

Prohibit disruptive activities within 1 mile of Peregrine falcon nest sites from February 1 to 

August 31. Purpose: To protect Peregrine falcon nest sites. Exception: An exception could be granted if surveys determine that nesting sites are not occupied. During years when a nest site is unoccupied before May 30, the seasonal limitation may be suspended. It may also be suspended once young have fledged and dispersed from the nest. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include habitat or are outside the current defined area, as determined by the BLM. Dates could be adjusted by local Utah Division of Wildlife Resources (UDWR) and BLM biologists based on local knowledge of nesting chronology of raptors. Waiver: A waiver may be granted if it is determined that the habitat no longer exists, has been destroyed, or there is no reasonable likelihood of future use. 

Moderate (TL) Fish and Wildlife* 

Prohibit disruptive activities to nesting raptors within 1⁄2 mile of a raptor nest for the protection of 

Prohibit disruptive activities to nesting raptors within 1⁄2 mile of a raptor nest during the following time periods for the protection of raptor nesting areas: Jan 1–Aug 31: golden eagle 
Proposed RMP and Final EIS Appendix 3 

Kanab RMP A3-13 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

raptor nesting areas Mar 15–Aug 15: red-tailed hawk 

Mar 15–Aug 31: Cooper’s hawk, sharp-shinned hawk Mar 1–Aug 31: Swainson’s hawk Apr 1–Aug 15: Northern harrier Apr 1–Aug 31: merlin, osprey May 1–Aug 15: Turkey vulture Purpose: To protect raptor nesting areas. Exception: An exception could be granted if surveys determine that nesting sites are not occupied. During years when a nest site is unoccupied before May 30, the seasonal limitation may be suspended. It may also be suspended once young have fledged and dispersed from the nest. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include habitat or are outside the current defined area, as determined by the 

BLM. Dates could be adjusted by local UDWR and BLM biologists based on local knowledge of nesting chronology of raptors. Waiver: A waiver may be granted if it is determined that the habitat no longer exists, has been destroyed, or there is no reasonable likelihood of future use. 

Moderate (TL) Fish and Wildlife* 

Prohibit disruptive activities to nesting raptors within 1⁄4 mile of a raptor nest for the protection of raptor nesting areas 

Prohibit disruptive activities to nesting raptors within 1⁄4 mile of a raptor nest during the following time periods for the protection of raptor nesting areas: Dec 1–Sep 31: Great horned owl Feb 1–Jul 31: Boreal owl Feb 1–Aug 15: Long-eared owl Mar 1–Aug 15: W. Screech owl Mar 1–Aug 31: N. saw-whet owl Apr 1–Aug 1: N. Pygmy owl Apr 1–Aug 31: Prairie falcon Apr 1–Sep 30: Flammulated owl Purpose: To protect raptor nesting areas. Exception: An exception could be granted if surveys determine that nesting sites are not occupied. During years when a nest site is unoccupied before May 30, the seasonal limitation may be suspended. It may also be suspended once young have fledged and dispersed from the nest. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include habitat or are outside the current defined area, as determined by the 

BLM. Dates could be adjusted by local UDWR and BLM biologists based on local knowledge of 
Appendix 3 Proposed RMP and Final EIS 

A3-14 Kanab RMP 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

nesting chronology of raptors. Waiver: A waiver may be granted if it is determined that the habitat no longer exists, has been destroyed, or there is no reasonable likelihood of future use. 

Moderate (TL) Recreation 

Escalante SRMA – Close seasonally from May 1 to September 30 

Open to leasing subject to moderate constraints (timing limitation stipulation from May 1 to 

September 30). Purpose: To protect town-accessible hiking/equestrian trail network offering outstanding views and varied terrain. Exception: An exception could be authorized if the use is consistent and compatible with 

protection or enhancement of the resource values or would provide a public benefit or suitable opportunities for public enjoyment of the resources. Modification: None Waiver: None 

Moderate (TL) 

Special Status Species 

Preclude disruptive activities within 1 mile of a California condor nest site during breeding season 

Preclude disruptive activities within 1 mile of a California condor nest site during the breeding season. Preclude placement of permanent structures or roads within 1 mile of condor nest sites. Purpose: To protect California condor communal roosting or nesting areas. Exception: An exception could be granted if surveys determine that California condor communal roosting or nesting areas are not occupied. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include habitat or are outside the current defined area, as determined by the 

BLM. Waiver: A waiver may be granted if it is determined that the habitat no longer exists or has 

been destroyed. 

Moderate (TL) 

Special Status Species* 

Restrict activities or habitat alterations that may disturb nesting bald eagles from January 1 to August 31 within 1 mile of bald eagle nest sites 

Restrict activities or habitat alterations that may disturb nesting bald eagles from January 1 to August 31 within 1 mile of bald eagle nest sites. Purpose: To protect active bald eagle nest sites. Exception: An exception may be granted by the Field Manager if authorization is obtained from USFWS (through applicable provisions of the ESA). The Field Manager may also grant an exception if an environmental analysis indicates that the nature of the conduct of the actions, as 

proposed or conditioned, would not impair the primary constituent element determined necessary for the survival and recovery of the bald eagles and USFWS concurs with this determination. An exception may be granted by the Field Manager where no nesting behavior is 

initiated prior to June 1. Modification: The Field Manager may modify the boundaries of the stipulation area if an environmental analysis indicates and USFWS determines (through applicable provisions of the ESA) that a portion of the area is not being used as bald eagle nesting territories. Waiver: A waiver may be granted if bald eagles are de-listed and if USFWS determines it is not 
Proposed RMP and Final EIS Appendix 3 

Kanab RMP A3-15 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

necessary to protect nesting territories according to the ESA and the Bald Eagle Protection Act or if there is no reasonable likelihood of site occupancy over a minimum 10-year period. 

Moderate (TL) 

Special Status Species* 

Restrict activities or habitat alterations that may disturb bald eagles within 1⁄2 mile of known winter concentration areas from November 1 to March 31 

Restrict activities or habitat alterations that may disturb bald eagles within 1⁄2 mile of known winter concentration areas from November 1 to March 31. In addition, where daily activities must occur within these spatial buffers, and are approved through subsequent consultation with USFWS, activities should be scheduled to occur after 9 a.m. and terminate at least 1 hour before official sunset to ensure that bald eagles using these roosts are allowed the opportunity to vacate their roost in the morning and return undisturbed in the evening. Purpose: To protect active bald eagle winter concentration areas. Exception: An exception may be granted by the Field Manager if authorization is obtained from USFWS (through applicable provisions of the ESA). The Field Manager may also grant an exception if an environmental analysis indicates that the nature of the conduct of the actions, as 

proposed or conditioned, would not impair the primary constituent element determined necessary for the survival and recovery of the bald eagles and USFWS concurs with this determination. Modification: The Field Manager may modify the boundaries of the stipulation area if an environmental analysis indicates and USFWS determines (through applicable provisions of the ESA) that a portion of the area is not being used as bald eagle winter concentration area. Waiver: A waiver may be granted if bald eagles are de-listed and if USFWS determines it is not necessary to protect nesting territories according to the ESA and the Bald Eagle Protection Act or if there is no reasonable likelihood of site occupancy over a minimum 10-year period.

Moderate (TL) 

Special Status Species* 

Prohibit surface disturbing activities within 1⁄2 mile around special status raptor species nest sites Prohibit surface disturbing activities within 1⁄4 mile around special status raptor species nest sites 

Prohibit surface disturbing activities within 1⁄2 mile around special status raptor species nest sites during the following time periods: Mar 1–Aug 1: Ferruginous hawk Mar 1–Aug 15: N. Goshawk Prohibit surface disturbing activities within 1⁄4 mile around special status raptor species nest sites during the following time periods: Mar 1–Aug 1: Short-eared owl Mar 1–Aug 31: Burrowing owl Purpose: To protect raptor habitat. Exception: An exception could be granted if surveys determine that nesting sites are not occupied. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include habitat or are outside the current defined area, as determined by the 

BLM. Waiver: A waiver may be granted if it is determined the habitat no longer exists or has been 
Appendix 3 Proposed RMP and Final EIS 

A3-16 Kanab RMP 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

destroyed. 

Moderate (TL) 

Special Status Species* 

Permit no surface disturbing activities from March 1 to August 31 in Mexican spotted owl protected activity centers (PAC), breeding habitats, or designated critical habitat 

Permit no surface disturbing activities or surface occupancy within 1⁄2 mile around MSO nests to protect the species from disturbance. Permit no surface disturbing activities from March 1 to August 31 in PACs, breeding habitats, or designated critical habitat to avoid disturbance to breeding MSOs. If the action occurs entirely outside of the MSO breeding season (March 1 to August 31) and leaves no permanent structure or permanent habitat disturbance, the action may proceed without an occupancy survey. If action would occur during the season restriction (March 1 to August 31), surveys according to USFWS protocol for MSO would be required prior to commencement of activities, and if owls are detected, the BLM would reinitiate Section 7 consultation with USFWS. Purpose: To protect MSO nests. Exception: An exception could be granted if surveys determine that MSO nest areas are not occupied. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include habitat or are outside the current defined area, as determined by the 

BLM. Waiver: A waiver may be granted if it is determined the habitat no longer exists or has been 

destroyed. 

Moderate (TL) 

Special Status Species* 

Prohibit surface disturbing activities within 1⁄4 mile of occupied Southwestern willow flycatcher breeding habitat from May 1 through August 15 

Prohibit surface disturbing activities within 1⁄4 mile of occupied Southwestern willow flycatcher breeding habitat from May 1 to August 15. Purpose: To protect Southwestern willow flycatcher breeding habitat. Exception: An exception could be granted if surveys determine that the Southwestern willow flycatcher breeding habitat is not occupied. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include habitat or are outside the current defined area, as determined by the 

BLM. Waiver: A waiver may be granted if it is determined the habitat no longer exists or has been 

destroyed. 

Moderate (TL) 

Special Status Species* 

Prohibit surface disturbing activities within 2 miles of a Greater sage-grouse lek in the nesting and broodrearing habitat from March 15 to July 15 

Allow no surface disturbing or otherwise disruptive activities (e.g., construction and maintenance) within 2 miles of a Greater sage-grouse lek in nesting and brood-rearing habitat 

from March 15 to July 15. Purpose: To protect Greater sage-grouse lek in nesting and brood-rearing habitat. 

Exception: An exception could be granted if surveys determine that the Greater sage-grouse lek in nesting and brood-rearing habitat is not occupied. An exception may also be granted by the 

Field Manager if the operator submits a plan that demonstrates that impacts from the proposed action can be adequately mitigated or it is determined the lek sites are not active. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of 
Proposed RMP and Final EIS Appendix 3 

Kanab RMP A3-17 

Stipulation 

Code 

Resource 

of Concern Applicable Area Stipulation Description 

the area do not include habitat or are outside the current defined area, as determined by the BLM. Waiver: A waiver may be granted if it is determined the habitat no longer exists or has been 

destroyed. 

Moderate (TL) 

Special Status Species* 

Prohibit surface disturbing activities within Greater sage-grouse winter habitat from December 1 to March 14 

Allow no surface disturbing or otherwise disruptive activities in Greater sage-grouse winter habitat from December 1 to March 14. Purpose: To protect Greater sage-grouse wintering habitat. Exception: An exception could be granted if surveys determine that the Greater sage-grouse lek in winter habitat is not occupied, and that snow depths in the area allow continued sage-grouse use. An exception may also be granted by the Field Manager if the operator submits a plan that 

demonstrates that impacts from the proposed action can be avoided, sufficiently minimized, or adequately mitigated. Modification: The Field Manager may modify the boundaries of the stipulation area if portions of the area do not include habitat or are outside the current defined area, as determined by the 

BLM. Waiver: A waiver may be granted if it is determined the habitat no longer exists or has been 

destroyed. 
Appendix 3 Proposed RMP and Final EIS 

A3-18 Kanab RMP 

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Proposed RMP and Final EIS Appendix 4 

Kanab RMP A4-1 

APPENDIX 4—RECREATION MANAGEMENT FOR 

SPECIAL RECREATION MANAGEMENT AREAS 

AND THE KANAB EXTENSIVE RECREATION 

MANAGEMENT AREA 

KANAB COMMUNITY SPECIAL RECREATION MANAGEMENT AREA 

(SRMA)—OFF-HIGHWAY VEHICLE (OHV) RECREATION 

MANAGEMENT ZONE (RMZ) 

Recreation Niche: Close-to-town OHV travel in an exceptionally scenic setting with a variety of trails 

for different skill levels. 

Recreation Management Objectives: By the year 2012, manage this zone to provide opportunities for 

community residents and regional visitors to engage in sustainable, easy-to-access, primarily day-use 

motorized recreation, providing no less than 75 percent of responding visitors and affected community 

residents at least a “moderate” realization of these benefits (i.e., 3.0 on a probability scale, where 1 = not 

at all, 2 = somewhat, 3 = moderate, 4 = total realization). 

Primary Activities: Driving OHVs, viewing scenery and wildlife, photography, spending time with 

friends and family, participating in and/or viewing organized events. 

Experiences: Savoring the sensory experience of an outdoor setting, relishing group togetherness, 

enjoying risk-taking adventures, appreciating nature, escaping everyday stress and boredom, enjoying 

easy and convenient access. 

Benefits: 

• Personal—Improved OHV skills, bonding with family and friends, stress relief, enhanced 

awareness and appreciation of natural resources, greater self-reliance, renewed human spirit. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding. 

• Economic—Enhanced local economy via purchases (gas, groceries, lodging, OHV/outdoor 

equipment, etc.). 

• Environmental—Increased awareness and protection of natural landscapes. 

Setting Characteristics: 

• Physical—Mostly middle country, but back country and primitive away from designated routes, 

with regard to naturalness and facilities. 

• Social—Front country along trails with regard to group sizes and contacts, but back country away 

from trails. 

• Administrative—Front country along trails and staging areas at entry portals; back country away 

from trails. 
Appendix 4 Proposed RMP and Final EIS 

A4-2 Kanab RMP 

KANAB COMMUNITY SRMA—NON-MOTORIZED TRAILS RMZ 

Recreation Niche: Town-accessible hiking trail network offering outstanding views and varied terrain. 

Recreation Management Objectives: By the year 2012, manage this zone to provide opportunities for 

community residents and regional visitors to engage in sustainable, easy-to-access, primarily day-use nonmotorized recreation, providing no less than 75 percent of responding visitors and affected community 

residents at least a “moderate” realization of these benefits (i.e., 3.0 on a probability scale, where 1 = not 

at all, 2 = somewhat, 3 = moderate, 4 = total realization). 

Primary Activities: Hiking, rock scrambling and climbing, viewing scenery and wildlife, photography, 

equestrian, spending time with friends and family, participating in and/or viewing organized events. 

Experiences: Savoring the sensory experience of an outdoor setting, relishing group togetherness, 

enjoying risk-taking adventures, appreciating nature, escaping everyday stress and boredom, enjoying 

easy and convenient access. 

Benefits: 

• Personal—Bonding with family and friends, stress relief, enhanced awareness and appreciation of 

natural resources, greater self-reliance, renewed human spirit. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding. 

• Economic—Enhanced local economy via purchases (gas, groceries, lodging, outdoor equipment, 

etc.). 

• Environmental—Increased awareness and protection of natural landscapes. 

Setting Characteristics: 

• Physical—Mostly back country along trails, with primitive away from trails, routes, and 

community. 

• Social—Middle country to back country along trails depending on trail traffic; primitive and back 

country off trail. 

• Administrative—Front country at trailheads; middle country along trails; back country and 

primitive away from trails. 

MOQUITH SRMA—DUNES RMZ 

Recreation Niche: OHV and non-motorized opportunities on unique, scenic, and expansive sand dunes. 

Recreation Management Objectives: By the year 2012, manage this zone to provide opportunities for 

community residents and regional visitors to engage in sustainable, easy-to-access, day-use and multi-day 

motorized recreation, providing no less than 75 percent of responding visitors and affected community 

residents at least a “moderate” realization of these benefits (i.e., 3.0 on a probability scale, where 1 = not 

at all, 2 = somewhat, 3 = moderate, 4 = total realization). 

Primary Activities: Driving among sand dunes, camping along dune fringes, photography, spending time 

with friends and family. 
Proposed RMP and Final EIS Appendix 4 

Kanab RMP A4-3 

Experiences: Savoring the sensory experience of an outdoor setting, relishing group togetherness, 

enjoying risk-taking adventures, appreciating nature, escaping everyday stress and boredom, enjoying 

easy and convenient access, learning about sand dune ecosystems. 

Benefits: 

• Personal—Improved OHV skills, bonding with family and friends, stress relief, enhanced 

awareness and appreciation of natural resources, greater self-reliance, renewed human spirit. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding. 

• Economic—Enhance local economy via purchases (gas, groceries, lodging, OHV/outdoor 

equipment, etc.). 

• Environmental—Increased awareness and protection of natural landscapes. 

Setting Characteristics:

• Physical—Mostly front country and middle country with regard to naturalness and facilities. 

• Social—Rural around campgrounds and staging areas; front country and middle country among 

dunes. 

• Administrative—Front country at campgrounds and staging areas; middle country and back 

country among dunes. 

MOQUITH SRMA—NON-DUNES WOODED RMZ 

Recreation Niche: Scenic and extensive OHV trail network accessing vistas, overlooks, flora and fauna, 

and cultural sites. 

Recreation Management Objectives: By the year 2012, manage this zone to provide opportunities for 

community residents and regional visitors to engage in sustainable, easy-to-access, day-use and multi-day 

motorized and non-motorized recreation, providing no less than 75 percent of responding visitors and 

affected community residents at least a “moderate” realization of these benefits (i.e., 3.0 on a probability 

scale, where 1 = not at all, 2 = somewhat, 3 = moderate, 4 = total realization). 

Primary Activities: Driving OHVs; viewing flora and fauna, geology, and cultural sites; hiking; 

equestrian; camping; hunting; photography; spending time with friends and family. 

Experiences: Savoring the sensory experience of an outdoor setting, relishing group togetherness, 

enjoying risk-taking adventures, appreciating nature, escaping everyday stress and boredom. 

Benefits: 

• Personal—Improved OHV skills, bonding with family and friends, stress relief, enhanced 

awareness and appreciation of natural resources, greater self-reliance, renewed human spirit. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding. 

• Economic—Enhanced local economy via purchases (gas, groceries, lodging, OHV/outdoor 

equipment, etc.). 

• Environmental—Increased awareness and protection of natural landscapes. 
Appendix 4 Proposed RMP and Final EIS 

A4-4 Kanab RMP 

Setting Characteristics: 

• Physical—Mostly front country and middle country with regard to naturalness and facilities. 

• Social—Rural around campground and staging areas; front country and middle country along 

trails; back country and primitive off trails. 

• Administrative—Front country at campgrounds and staging areas; middle country and back 

country along trails; primitive off trails. 

PARIA SRMA—CANYON RMZ 

Recreation Niche: World-class wilderness trekking adventure offering deeply entrenched slickrock 

canyons and associated slot canyon features. 

Recreation Management Objectives: By the year 2012, manage this zone to provide opportunities for 

community residents and regional visitors to engage in world-class, long-distance wilderness trekking in a 

spectacular geologic showcase of colorful deep canyons, cliffs, and narrow slots while preserving its 

wilderness character, providing no less than 75 percent of responding visitors and affected community 

residents at least a “moderate” realization of these benefits (i.e., 3.0 on a probability scale, where 1 = not 

at all, 2 = somewhat, 3 = moderate, 4 = total realization). Other management objectives would continue to 

be established through the Paria Canyon–Vermilion Cliffs Wilderness Management Plan. 

Primary Activities: Hiking, rock scrambling and climbing, backpacking, canyoneering, photography, 

camping, viewing scenic vistas, viewing cultural sites, wilderness exploration. 

Experiences: Exploring artistic expression, contemplating and shaping spiritual values, savoring the 

sensory experience of a natural landscape, testing endurance, developing outdoor skills and abilities, 

enjoying solo exploring and risk-taking adventures, savoring group/family affiliation and bonding, 

enjoying physical exercise, escaping everyday stress and boredom, feeling good about how natural 

resources are being managed. 

Benefits: 

• Personal—Improved physical fitness and health, improved outdoor knowledge and skills, stress 

relief, enhanced awareness and appreciation of nature, greater self-reliance, closer relationship 

with nature, renewed human spirit. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding. 

• Economic—Contributions to local/regional economy through equipment purchases/rentals and 

guiding operations. 

• Environmental—Increased awareness and protection of natural landscapes; reduced human 

impacts such as litter, vegetation trampling, and unplanned trails. 

Setting Characteristics: 

• Physical—Mostly back country, but primitive away from trails, with regard to naturalness and 

facilities. 

• Social—Mostly back country and primitive with regard to group encounters and evidence of use. 

• Administrative—Mostly primitive with regard to mechanized/motorized use and visitor services, 

but back country with regard to management controls. 
Proposed RMP and Final EIS Appendix 4 

Kanab RMP A4-5 

PARIA SRMA—UPLANDS RMZ 

Recreation Niche: Unique, world-class primitive and back country adventure recreation offering unique 

upland geologic features. 

Recreation Management Objectives: By the year 2012, manage this zone to provide opportunities for 

visitors to engage in world-class wilderness hiking in a spectacular geologic showcase of colorful cliffs 

and eroded formations while preserving its wilderness character, providing no less than 75 percent of 

responding visitors and affected community residents at least a “moderate” realization of these benefits 

(i.e., 3.0 on a probability scale, where 1 = not at all, 2 = somewhat, 3 = moderate, 4 = total realization). 

Other management objectives would continue to be established through the Paria Canyon–Vermilion 

Cliffs Wilderness Management Plan. 

Primary Activities: Hiking, rock scrambling and climbing, photography, viewing wildlife and scenic 

vistas, wilderness exploration, equestrian. 

Experiences: Exploring artistic expression, contemplating and shaping spiritual values, savoring the 

sensory experience of a natural landscape, testing endurance, developing outdoor skills and abilities, 

enjoying solo exploring and risk-taking adventures, savoring group/family affiliation and bonding, 

enjoying physical exercise, escaping everyday stress and boredom, feeling good about how natural 

resources are being managed. 

Benefits: 

• Personal—Improved physical fitness and health, improved outdoor knowledge and skills, stress 

relief, enhanced awareness and appreciation of nature, greater self-reliance, closer relationship 

with nature, renewed human spirit. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding. 

• Economic—Contributions to local/regional economy through equipment purchases/rentals and 

guiding operations. 

• Environmental—Increased awareness and protection of natural landscapes; reduced human 

impacts such as litter, vegetation trampling, and unplanned trails. 

Setting Characteristics:

• Physical—Mostly back country, but primitive away from trails, with regard to naturalness and 

facilities. 

• Social—Mostly back country and primitive with regard to group encounters and evidence of use. 

• Administrative—Mostly primitive with regard to mechanized/motorized use and visitor services, 

but back country with regard to management controls. 

ORDERVILLE CANYON SRMA

Recreation Niche: Spectacular, primitive riparian canyon travel with abundant geologic formations and 

diverse flora and fauna. 

Recreation Management Objectives: By the year 2012, manage this area to provide opportunities for 

community residents and regional visitors to engage in sustainable, easy-to-access, primarily multi-day 

non-motorized canyon-oriented recreation, providing no less than 75 percent of responding visitors and 
Appendix 4 Proposed RMP and Final EIS 

A4-6 Kanab RMP 

affected community residents at least a “moderate” realization of these benefits (i.e., 3.0 on a probability 

scale, where 1 = not at all, 2 = somewhat, 3 = moderate, 4 = total realization). 

Primary Activities: Canyoneering, rock scrambling and climbing, hiking, backpacking, hunting, 

camping, photography, viewing nature and wildlife, equestrian, studying geology. 

Experiences: Contemplating and shaping spiritual values, savoring the total sensory experience of a 

natural landscape, testing endurance, developing outdoor skills and abilities, enjoying solo exploring and 

risk-taking adventures, savoring group/family affiliation and bonding, enjoying physical exercise, 

escaping everyday stress and boredom, feeling good about how natural resources are being managed. 

Benefits: 

• Personal—Improved physical fitness and health, improved outdoor knowledge and skills, stress 

relief, enhanced awareness and appreciation of nature, greater self-reliance, closer relationship 

with nature, renewed human spirit. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding. 

• Economic—Contributions to local/regional economy through equipment purchases/rentals and 

guiding operations. 

• Environmental—Increased awareness and protection of natural landscapes; reduced human 

impacts such as litter, vegetation trampling, and unplanned trails. 

Setting Characteristics: 

• Physical—Mostly primitive away from trails with regard to naturalness and facilities. 

• Social—Mostly back country and primitive with regard to group encounters and evidence of use. 

• Administrative—Mostly primitive with regard to mechanized/motorized use and visitor services, 

but back country with regard to management controls. 

NORTH FORK VIRGIN RIVER SRMA 

Recreation Niche: Spectacular, primitive riparian canyon travel with abundant geologic formations and 

diverse flora and fauna. 

Recreation Management Objectives: By the year 2012, manage this area to provide opportunities for 

community residents and regional visitors to engage in sustainable, easy-to-access, primarily multi-day 

non-motorized canyon-oriented recreation, providing no less than 75 percent of responding visitors and 

affected community residents at least a “moderate” realization of these benefits (i.e., 3.0 on a probability 

scale, where 1 = not at all, 2 = somewhat, 3 = moderate, 4 = total realization). 

Primary Activities: Canyoneering, rock scrambling and climbing, hiking, backpacking, hunting, 

camping, photography, viewing nature and wildlife, equestrian, studying geology. 

Experiences: Contemplating and shaping spiritual values, savoring the sensory experience of a natural 

landscape, testing endurance, developing outdoor skills and abilities, enjoying solo exploring and risktaking adventures, savoring group/family affiliation and bonding, enjoying physical exercise, escaping 

everyday stress and boredom, feeling good about how natural resources are being managed. 
Proposed RMP and Final EIS Appendix 4 

Kanab RMP A4-7 

Benefits: 

• Personal—Improved physical fitness and health, improved outdoor knowledge and skills, stress 

relief, enhanced awareness and appreciation of nature, greater self-reliance, closer relationship 

with nature, renewed human spirit. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding. 

• Economic—Contributions to local/regional economy through equipment purchases/rentals and 

guiding operations. 

• Environmental—Increased awareness and protection of natural landscapes; reduced human 

impacts such as litter, vegetation trampling, and unplanned trails. 

Setting Characteristics: 

• Physical—Mostly primitive away from trails with regard to naturalness and facilities. 

• Social—Mostly back country and primitive with regard to group encounters and evidence of use. 

• Administrative—Mostly primitive with regard to mechanized/motorized use and visitor services, 

but back country with regard to management controls. 

ESCALANTE SRMA

Recreation Niche: Town-accessible hiking/equestrian trail network offering outstanding views and 

varied terrain. 

Recreation Management Objectives: By the year 2012, manage this area to provide opportunities for 

community residents and regional visitors to engage in sustainable, easy-to-access, primarily day-use nonmotorized recreation, providing no less than 75 percent of responding visitors and affected community 

residents at least a “moderate” realization of these benefits (i.e., 3.0 on a probability scale, where 1 = not 

at all, 2 = somewhat, 3 = moderate, 4 = total realization). 

Primary Activities: Hiking, rock scrambling and climbing, viewing scenery and wildlife, photography, 

equestrian, spending time with friends and family, participating in and/or viewing organized events. 

Experiences: Savoring the sensory experience of an outdoor setting; relishing group togetherness; 

enjoying risk-taking adventures; appreciating nature; escaping everyday stress and boredom; enjoying 

easy and convenient access; exercising in a healthy, aesthetically pleasing environment. 

Benefits: 

• Personal—Improved outdoor knowledge and skills; bonding with family and friends; stress relief; 

enhanced awareness and appreciation of natural resources; greater self-reliance; renewed human 

spirit; exercising in a healthy, aesthetically pleasing environment. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding, healthier lifestyles. 

• Economic—Decreased burden on community heath care system from healthier lifestyles. 

• Environmental—Increased awareness and protection of natural landscapes. 

Setting Characteristics:

• Physical—Mostly backcountry along trails, with primitive away from trails and community. 
Appendix 4 Proposed RMP and Final EIS 

A4-8 Kanab RMP 

• Social—Middle country to back country along trails depending on trail traffic; primitive and back 

country off trail. 

• Administrative—Front country at trailheads; middle country along trails; back country and 

primitive away from trails. 

KANAB FIELD OFFICE ERMA

Recreation Management Objectives: Manage this Extensive RMA (ERMA) to provide opportunities 

for a wide variety of motorized, mechanized, non-motorized, and non-mechanized recreational activities 

largely free from heavily restrictive regulations and management constraints in a variety of settings 

ranging from open, gently rolling sand dunes to precipitous sandstone canyons and steep, rocky slopes. 

Route designations would allow visitors to access most terrain by motorized vehicle, while leaving large 

expanses of undeveloped back country in which to “lose oneself.” 

Primary Activities: OHV touring; hiking; picnicking; backpacking; hunting; fishing; camping; 

equestrian; photography; viewing geologic features, nature, and wildlife; participating in and/or viewing 

organized events. 

Experiences: Contemplating and shaping spiritual values, savoring the sensory experience of a natural 

landscape, testing endurance, developing outdoor skills and abilities, enjoying OHV and 4x4 touring, 

enjoying solo exploring and risk-taking adventures, savoring group/family affiliation and bonding, 

enjoying physical exercise, escaping everyday stress and boredom, feeling good about how natural 

resources are being managed. 

Benefits: 

• Personal—Improved outdoor knowledge and skills, bonding with family and friends, stress relief, 

enhanced awareness and appreciation of natural resources, greater self-reliance, renewed human 

spirit. 

• Community—Stronger sense of community dependency on public lands, greater family/group 

bonding. 

• Economic—Enhanced local economy via purchases (gas, groceries, lodging, OHV/outdoor 

equipment, etc.). 

• Environmental—Increased awareness and protection of natural landscapes. 

Setting Characteristics: 

• Physical—Broad range from primitive to rural. 

• Social—Entire spectrum from primitive to rural with regard to group encounters and evidence of 

use. 

• Administrative—Mostly primitive and back country with regard to visitor services and 

management controls. 
Proposed RMP and Final EIS Appendix 5 

Kanab RMP A5-1 

APPENDIX 5—LANDS DESIGNATED FOR POTENTIAL 

DISPOSAL VIA FEDERAL LAND POLICY AND 

MANAGEMENT ACT SECTION 203 SALE 

Below is a list of the lands designated for potential disposal via Federal Land Policy and Management Act 

Section 203 sale. 

Legal Descriptions:

• T. 31 S., R. 3 W., Sec. 17, E1⁄2E1⁄2 

• T. 33 S., R. 4 E., Sec. 35, SW1⁄4SW1⁄4 

• T. 33 S., R. 4 E., Sec. 36, W1⁄2NW1⁄4NE1⁄4NE1⁄4 

• T. 34 S., R. 2 W., Sec. 22 (all public lands within Widtsoe Township) 

• T. 34 S., R. 2 E., Sec. 34 

• T. 34 S., R. 2 E., Sec. 35 

• T. 34 S., R. 5 W., Sec. 22, W1⁄2NE1⁄4SE1⁄4, NW1⁄4SE1⁄4SE1⁄4,S1⁄2SE1⁄4SE1⁄4 

• T. 34 S., R. 5 W., Sec. 23, SW1⁄4SW1⁄4SW1⁄4E1⁄2SW1⁄4SW1⁄4, E1⁄2SW1⁄4 

• T. 34 S., R. 5 W., Sec. 27, E1⁄2NE1⁄4 

• T. 35 S., R. 1 E., Sec. 33, SW1⁄4SE1⁄4 

• T. 35 S., R. 2 E., Sec. 3 

• T. 35 S., R. 2 E., Sec. 11, a portion of NW1⁄4S1⁄2SE1⁄4 (all public land outside Grand Staircase–

Escalante National Monument [GSENM]) 

• T. 35 S., R. 2 E., Sec. 15, a portion of N1⁄2NE1⁄4NE1⁄4 (all public land outside GSENM) 

• T. 35 S., R. 2 E., Sec. 17, a portion of NW1⁄4NW1⁄4SE1⁄4SE1⁄4 (all public land outside GSENM) 

• T. 35 S., R. 2 E., Sec. 20, a portion of W1⁄2SW1⁄4SE1⁄4 (all public land outside GSENM) 

• T. 35 S., R. 3 E., Sec. 5 (beginning at a Utah State Park aluminum pipe and cap monument, said 

point being N89o49’37”W 450.67 feet along the Section Line [Basis of Bearing] from the South 

Quarter Corner of Section 5, Township 35 South, Range 3 East, Salt Lake Base and Meridian; 

thence N89o49’37”W 1086.66 feet along said Section Line to PK nail and washer in the top of a 

sandstone ridge; thence N0o00’22”E 205.28 feet to a metal fence post; thence S89o49’37”E 

1086.66 feet parallel with said Section Line to a Utah State Park aluminum pipe and cap 

monument; thence S0o00’22”W 205.28 feet to a Utah State Park monument and the point of 

beginning) 

• T. 35 S., R. 3 E., Sec. 18, W1⁄2W1⁄2 

• T. 35 S., R. 3 E., Sec. 19, NW1⁄4NW1⁄4 

• T. 35 S., R. 3 E., Sec. 19, W1⁄2SE1⁄4, S1⁄2SW1⁄4, NE1⁄4SW1⁄4 

• T. 36 S., R. 1 E., Sec. 4, Lots 1, 2, SW1⁄4NE1⁄4, NW1⁄4SE1⁄4 

• T. 36 S., R. 3 E., Sec. 4, S1⁄2NW1⁄4, W1⁄2SW1⁄4, SE1⁄4SW1⁄4 

• T. 36 S., R. 3 E., Sec. 9, S1⁄2NE1⁄4, NW1⁄4, SW1⁄4, SE1⁄4 

• T. 36 S., R. 3 E., Sec. 10, NE1⁄4NE1⁄4 

• T. 36 S., R. 3 E., Sec. 10, S1⁄2SW1⁄4 

• T. 36 S., R. 3 E., Sec. 11, N1⁄2NW1⁄4 

• T. 36 S., R. 3 E., Sec. 11, SE1⁄4SW1⁄4, W1⁄2SE1⁄4 

• T. 36 S., R. 3 E., Sec. 14, E1⁄2, E1⁄2W1⁄2, NW1⁄4 NW1⁄4 

• T. 36 S., R. 3 E., Sec. 15, E1⁄2NE1⁄4, SW1⁄4NE1⁄4 

• T. 36 S., R. 3 E., Sec. 15, N1⁄2NW1⁄4 

• T. 36 S., R. 3 E., Sec. 15, SW1⁄4SW1⁄4 

• T. 36 S., R. 3 W., Sec. 7, W1⁄2NW1⁄4 

• T. 37 S., R. 2 W., Sec. 21, N1⁄2SE1⁄4, NE1⁄4SW1⁄4 
Appendix 5 Proposed RMP and Final EIS 

A5-2 Kanab RMP 

• T. 37 S., R. 2 W., Sec. 22, SE1⁄4SE1⁄4 

• T. 37 S., R. 2 W., Sec. 27, E1⁄2NE1⁄4, NE1⁄4SE1⁄4 

• T. 37 S., R. 2 W., Sec. 29, N1⁄2 NW1⁄4, SW1⁄4NW1⁄4 

• T. 37 S., R. 2 W., Sec. 29, NE1⁄4NE1⁄4 

• T. 37 S., R. 2 W., Sec. 30, S1⁄2NE1⁄4 

• T. 37 S., R. 2 W., Sec. 31, SE1⁄4NE1⁄4 

• T. 37 S., R. 2 W., Sec. 31, NW1⁄4NW1⁄4

• T. 37 S., R. 2 W., Sec. 31, SE1⁄4SE1⁄4 

• T. 38 S., R. 1 W., Sec. 5, SW1⁄4SE1⁄4 

• T. 38 S., R. 1 W., Sec. 8, W1⁄2W1⁄2, NE1⁄4SW1⁄4 

• T. 38 S., R. 2 W., Sec. 6, Lot 2 

• T. 38 S., R. 2 W., Sec. 11, SE1⁄4NE1⁄4, SW1⁄4NW1⁄4, S1⁄2 

• T. 38 S., R. 2 W., Sec. 12, W1⁄2NW1⁄4, SE1⁄4SW1⁄4, S1⁄2SE1⁄4 

• T. 38 S., R. 2 W., Sec. 13, N1⁄2 N1⁄2 

• T. 38 S., R. 2 W., Sec. 14 (all public land outside GSENM) 

• T. 38 S., R. 2 W., Sec. 15 (all public land outside GSENM) 

• T. 38 S., R. 3 W., Sec. 1, Lots 3 and 4, SW1⁄4NE1⁄4, SE1⁄4NW1⁄4, NE1⁄4SW1⁄4, NW1⁄4SE1⁄4 

• T. 39 S., R. 41⁄2 W., Sec. 27, NW1⁄4NE1⁄4, NE1⁄4NW1⁄4, SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 

• T. 39 S., R. 41⁄2 W., Sec. 34, Lot 4 

• T. 39 S., R. 41⁄2 W., Sec. 35, W1⁄2NE1⁄4, SW1⁄4 

• T. 39 S., R. 5 W., Sec. 21, SE1⁄4SW1⁄4 

• T. 39 S., R. 5 W., Sec. 35, SE1⁄4NE1⁄4, E1⁄2SE1⁄4 

• T. 39 S., R. 6 W., Sec. 23, N1⁄2SE1⁄4 

• T. 39 S., R. 6 W., Sec. 24, N1⁄2SW1⁄4 

• T. 39 S., R. 7 W., Sec. 25, SW1⁄4NE1⁄4, SW1⁄4, W1⁄2SE1⁄4 

• T. 39 S., R. 7 W., Sec. 28, SW1⁄4SE1⁄4 

• T. 39 S., R. 7 W., Sec. 30, SW1⁄4NE1⁄4 

• T. 39 S., R. 7 W., Sec. 30, SE1⁄4SE1⁄4 

• T. 39 S., R. 7 W., Sec. 31, E1⁄2NE1⁄4, NW1⁄4NE1⁄4, NE1⁄4SE1⁄4 

• T. 39 S., R. 7 W., Sec. 34, S1⁄2N1⁄2 

• T. 39 S., R. 7 W., Sec. 35, NE1⁄4NW1⁄4 

• T. 39 S., R. 7 W., Sec. 35, S1⁄2NE1⁄4 

• T. 39 S., R. 8 W., Sec. 4, SE1⁄4SW1⁄4, SW1⁄4SE1⁄4 

• T. 39 S., R. 8 W., Sec. 7, NE1⁄4NE1⁄4, S1⁄2N1⁄2 

• T. 39 S., R. 8 W., Sec. 8, SE1⁄4SE1⁄4 

• T. 39 S., R. 8 W., Sec. 9, NW1⁄4NE1⁄4, SW1⁄4SW1⁄4 

• T. 39 S., R. 8 W., Sec. 17, N1⁄2NE1⁄4 

• T. 39 S., R. 8 W., Sec. 18, SE1⁄4SE1⁄4 

• T. 39 S., R. 8 W., Sec. 34, S1⁄2NW1⁄4, NW1⁄4SE1⁄4 

• T. 39 S., R. 9 W., Sec. 1, Lot 3, SE1⁄4NW1⁄4 

• T. 39 S., R. 9 W., Sec. 12, NW1⁄4NW1⁄4, 

• T. 39 S., R. 9 W., Sec. 14, NE1⁄4NE1⁄4, 

• T. 39 S., R. 9 W., Sec. 29, W1⁄2SE1⁄4 

• T. 40 S., R. 4 W., Sec. 3, S1⁄2SW1⁄4 

• T. 40 S., R. 4 W., Sec. 4, SE1⁄4SE1⁄4 

• T. 40 S., R. 4 W., Sec. 9, E1⁄2NE1⁄4 

• T. 40 S., R. 4 W., Sec. 10, N1⁄2NW1⁄4, SW1⁄4NW1⁄4 

• T. 40 S., R. 4 W., Sec. 15, NW1⁄4NE1⁄4 

• T. 40 S., R. 6 W., Sec. 29, SW1⁄4 

• T. 40 S., R. 7 W., Sec. 1, Lot 3, SW1⁄4NE1⁄4, SE1⁄4NW1⁄4 

• T. 40 S., R. 8 W., Sec. 1, Lot 3 
Proposed RMP and Final EIS Appendix 5 

Kanab RMP A5-3 

• T. 40 S., R. 7 W., Sec. 5, Lots 1, 5, SW1⁄4SW1⁄4 

• T. 40 S., R. 8 W., Sec. 3, SE1⁄4NW1⁄4, NE1⁄4SE1⁄4 

• T. 40 S., R. 8 W., Sec. 4, Lots 1, 2, 3, 4 

• T. 40 S., R. 8 W., Sec. 5, SE1⁄4NE1⁄4, E1⁄2SE1⁄4 

• T. 40 S., R. 8 W., Sec. 8, N1⁄2NE1⁄4 

• T. 40 S., R. 8 W., Sec. 11, NW1⁄4NE1⁄4 

• T. 40 S., R. 8 W., Sec. 20, NW1⁄4SW1⁄4 

• T. 40 S., R. 8 W., Sec. 30, SW1⁄4SE1⁄4 

• T. 40 S., R. 8 W., Sec. 31, W1⁄2NE1⁄4 

• T. 40 S., R. 9 W., Sec. 5, SE1⁄4NE1⁄4 

• T. 40 S., R. 9 W., Sec. 22, NE1⁄4SE1⁄4 

• T. 40 S., R. 9 W., Sec. 23, E1⁄2NW1⁄4 

• T. 40 S., R. 9 W., Sec. 25, SE1⁄4SE1⁄4 

• T. 41 S., R. 7 W., Sec. 8, SE1⁄4SE1⁄4 

• T. 41 S., R. 7 W., Sec. 9, Lots 1 through 8, E1⁄2E1⁄2, S1⁄2SW1⁄4 

• T. 42 S., R. 5 W., Sec. 27, S1⁄2SE1⁄2 

• T. 42 S., R. 5 W., Sec. 34, NE1⁄4, NE1⁄4NW1⁄4, S1⁄2NW1⁄4 

• T. 42 S., R. 6 W., Sec. 31, NE1⁄4, SE1⁄4NW1⁄4, NE1⁄4SE1⁄4 

• T. 42 S., R. 7 W., Sec. 23 (lands south of Hancock Road) 

• T. 42 S., R. 7 W., Sec. 24 (lands south of Hancock Road) 

• T. 42 S., R. 7 W., Sec. 25, W1⁄2NE1⁄4, NW1⁄4SE1⁄4 

• T. 42 S., R. 7 W., Sec. 26 (lands south and east of Hancock Road) 

• T. 43 S., R. 41⁄2 W., Sec. 30 (the southernmost portion of Sec. 30, which lies south of the old 

highway—too small to show up on maps) 

• T. 44 S., R. 5 W., Sec. 1, Lot 4, SW1⁄4NW1⁄4 

• T. 44 S., R. 5 W., Sec. 4, SW1⁄4SW1⁄4 

• T. 44 S., R. 6 W., Sec. 6, Lots 3, 4, 5, SE1⁄4NW1⁄4 

• T. 44 S., R. 6 W., Sec. 8, NW1⁄4NW1⁄4 

• T. 44 S., R. 7 W., Sec. 1, Lots 1, 2, 3, 4, N1⁄2S1⁄2, SW1⁄4, NW1⁄4SE1⁄4 

• T. 44 S., R. 7 W., Sec. 11, N1⁄2NE1⁄4, NE1⁄4NW1⁄4 

• T. 44 S., R. 7 W., Sec. 12, NW1⁄4NW1⁄4 

• T. 44 S., R. 8 W., Sec. 3, S1⁄2 (areas outside the Moquith Mountain WSA) 

• T. 44 S., R. 8 W., Sec. 4, W1⁄2NE1⁄4, NW1⁄4, S1⁄2 (areas outside the Moquith Mountain WSA) 

• T. 44 S., R. 8 W., Sec. 5 

• T. 44 S., R. 8 W., Sec. 6, Lots 1 through 4, E1⁄2, E1⁄2W1⁄2 

• T. 44 S., R. 8 W., Sec. 7, Lots 1 through 5, N1⁄2NE1⁄4, NE1⁄4NW1⁄4 

• T. 44 S., R. 8 W., Sec. 8, Lots 1 through 4, N1⁄2N1⁄2 

• T. 44 S., R. 8 W., Sec. 9, Lots 1 through 4, N1⁄2N1⁄2 

• T. 44 S., R. 8 W., Sec. 10, Lots 1 through 4, N1⁄2N1⁄2 (areas outside the Moquith Mountain WSA) 

• T. 44 S., R. 9 W., Sec. 1 

• T. 44 S., R. 9 W., Sec. 3 

• T. 44 S., R. 9 W., Sec. 4 

• T. 44 S., R. 9 W., Sec. 9, Lots 1 through 4, N1⁄2,N1⁄2 

• T. 44 S., R. 9 W., Sec. 10, Lots 1 through 4, N1⁄2,N1⁄2 

• T. 44 S., R. 9 W., Sec. 11, Lots 1 through 4, N1⁄2,N1⁄2 

• T. 44 S., R. 9 W., Sec. 12, Lots 1 through 4, N1⁄2, N1⁄2 
Appendix 5 Proposed RMP and Final EIS 

A5-4 Kanab RMP 

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Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-1 

APPENDIX 6—KANAB FIELD OFFICE: COAL 

UNSUITABILITY REPORT 

INTRODUCTION 

Bureau of Land Management (BLM) regulations regarding coal management on public lands are found in 

Title 43 of the Code of Federal Regulations (CFR), Part 3400. During land use planning, BLM is required 

to review federal lands and assess whether there are areas unsuitable for all coal mining or for certain 

stipulated methods of coal mining. This report addresses the 20 criteria of coal unsuitability as defined in 

43 CFR 3461.5 and applies these criteria to the known recoverable coal resource areas (KRCRA) for the 

Alton, Kaiparowits, and Kolob coal fields. Unsuitability decisions were based on these criteria and 

applied to federally owned coal estates within the Kanab Field Office (KFO) Planning Area (KPA). 

Currently there are no active coal leases within the KPA, but one lease application is currently being 

processed/analyzed in the Alton Amphitheater. 

GEOLOGIC SETTING 

KPA coals are located within Late Cretaceous sedimentary strata of the Dakota and Straight Cliffs 

formations. The Alton and Kolob coal fields are in the Dakota Formation and the Kaiparowits coal field is 

in the John Henry Member of the Straight Cliffs Formation. The depositional environment for both the 

Dakota and Straight Cliffs coals was a coastal plain setting along the Western Interior Seaway. The 

Dakota coals were deposited approximately 95 million years ago during the onset (transgression) of the 

Western Interior Seaway. Kaiparowits coals were deposited approximately 85 million years ago as the 

Western Interior Seaway regressed from the area. Rivers originating along the Sevier Mountain belt and 

Mogollon highlands provided a steady supply of sediment for burial of the rich coastal mires. 

LANDS CONSIDERED 

The recoverable coal resources within the KPA cross a number of surface ownership boundaries, 

including BLM, U.S. Forest Service (USFS), National Park Service (NPS), State of Utah, and private 

lands, and are located within Kane and Garfield counties. This report considers suitability for 

approximately 246,879 acres of federally owned coal within the KRCRA (Map 1). 

COAL RESOURCES 

The Kanab Field Office Mineral Potential Report (BLM/Utah Geological Survey 2006) identifies an inground coal resource for the KPA of approximately 10 billion tons. Approximately 200 million tons have 

been identified as surface minable in the Alton coal field. Generally, Dakota Formation coals range from 

a subbituminous B rank in the Alton coal field to subbituminous A rank in the Kolob coal field. The 

sulfur content varies, but averages about 1.2 percent. The ash content generally ranges between 10 percent 

and 15 percent. Heat content for Dakota Formation coals varies from about 7,500 to 9,500 BTU/lb. In the 

Kaiparowits field, the coal rank decreases from high-volatile C bituminous to subbituminous from south 

to north in the KPA. The ash and sulfur levels of the Straight Cliffs coals average about 10 percent and 

0.7 percent, respectively. The heat content of Kaiparowits coal ranges from about 7,420 to 10,300 BTU/lb 

(BLM/UGS 2006).
Appendix 6 Proposed RMP and Final EIS 

A6-2 Kanab RMP 

Table A6-1 through Table A6-3 identify the coal resources based on the depth of cover and the mapped 

quadrangle. Shallower depths of cover, which have the potential for surface mining, are presented in 

Table A6-1. 

Table A6-1. Alton Coal Field 

Depth of Cover Quadrangle 0–200 ft 200–1000 ft 1000–2000 ft 2000–3000 ft TOTAL 

Alton 95.3 212.1 114.3 98.9 520.6 

Bald Knoll 52.7 152.9 48.8 42.3 296.7 

Orderville NE-SE 38.3 96.9 0.0 0.0 135.2 

Skutumpah Creek 16.9 183.4 107.4 17.8 325.5 

TOTAL 203.2 645.3 270.5 159.0 1,278.0 

PERCENT 15.9% 50.5% 21.2% 12.4% 100.0% 

Identified coal resource for the Alton coal field within the KPA by depth of cover and quadrangle (in millions of tons; from 

BLM/UGS 2006)

Table A6-2. Kolob Coal Field 

Depth of Cover Quadrangle 0–1000 ft 1000–2000 ft 2000–3000 ft TOTAL 

Orderville Canyon NE 62.4 305.6 193.2 561.2

Orderville Canyon SE 258.7 143.0 0.0 401.7

Orderville SW 132.2 257.0 8.4 397.6

TOTAL 453.3 705.6 201.6 1,360.5 

PERCENT 33.3% 51.9% 14.8% 100.0% 

Identified coal resource for the Kolob coal field within the KPA by depth of cover and quadrangle (in millions of tons; from 

BLM/UGS 2006) 

Table A6-3. Kaiparowits Coal Field 

Depth of Cover 

Minable Deep Township/ 

Range 

0–1000 ft 1000–2000 ft 2000–3000 ft 3000–6000 ft > 6000 ft 

TOTAL 

33S, 2W 0.0 0.0 0.0 0.0 0.0 0.0 

33S, 1W 0.0 0.0 0.0 0.0 0.0 0.0 

33S, 1E 0.0 94.9 655.4 1,046.6 0.0 1,796.9 

33S, 2E 10.5 48.8 93.3 7.3 0.0 159.9 

34S, 2W 7.5 121.2 113.1 74.4 0.0 316.2 

34S, 1W 0.0 0.0 45.3 49.9 0.0 95.2 

34S, 1E 33.2 589.7 284.5 278.9 0.0 1,186.3 

34S, 2E 1.4 45.0 0.0 0.0 0.0 46.4 
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-3 

Depth of Cover 

Minable Deep Township/ 

Range 

0–1000 ft 1000–2000 ft 2000–3000 ft 3000–6000 ft > 6000 ft 

TOTAL 

35S, 2W 111.3 150.2 165.6 249.0 0.0 676.1 

35S, 1W 0.0 0.0 0.0 405.7 54.4 460.1 

35S, 1E 20.0 190.5 188.9 356.4 6.9 762.7 

36S, 2W 

(N1⁄2) 65.5 42.6 7.9 0.1 0.0 116.1 

36S, 1W 

(N1⁄2) 9.7 22.5 101.8 151.8 7.4 293.2 

36S, 1E 104.2 217.8 189.5 948.8 0.0 1,460.3 

TOTAL 363.3 1,523.2 1,845.3 3,568.9 68.7 7,369.4 

PERCENT 4.9% 20.7% 25.0% 48.4% 0.9% 100.0% 

Identified coal resource for the Kaiparowits Plateau coal field within the KPA by depth of cover and township (in millions of tons; 

from BLM/UGS 2006) 

EVALUATION OF THE COAL UNSUITABILITY CRITERIA 

This report assesses KPA coal resources for suitability based on the 20 criteria outlined in 43 CFR 

3461.5. Underground mining of coal deposits is exempt from the criteria, where there would be no 

surface coal mining operations as stated at 3461.1.1(a). Surface mining operations include surface 

operations and surface impacts incident to an underground mine as stated in 43 CFR 3400.0-5(mm). In 

addition, where underground mining would include surface operations and surface impacts on federal 

lands to which a criterion applies, the lands shall be assessed as unsuitable unless an exception or 

exemption applies (43 CFR 3461.1(b)). Each criterion is subject to exceptions and/or exemptions as 

prescribed in the regulations. 

Criterion Number 1 

All Federal lands included in the following land systems or categories shall be considered unsuitable: 

National Park System; National Wildlife Refuge System; National System of Trails; National Wilderness 

Preservation System; National Wild and Scenic Rivers System; National Recreation Areas; lands 

acquired with money derived from the Land and Water Conservation Fund; National Forests; and 

Federal lands in incorporated cities, towns, and villages. 

• Exceptions. (i) A lease may be issued within the boundaries of any National Forest if the 

Secretary finds no significant recreational, timber, economic or other values which may be 

incompatible with the lease; and (A) surface operations and impacts are incident to an 

underground coal mine, or (B) where the Secretary of Agriculture determines, with respect to 

lands which do not have significant forest cover within those National Forests west of the 100th 

Meridian, that surface mining may be in compliance with the Multiple-Use Sustained-Yield Act of 

1960, the Federal Coal Leasing Amendments Act of 1976 and the Surface Mining Control and 

Reclamation Act of 1977. (ii) A lease may be issued within the Custer National Forest with the 

consent of the Department of Agriculture as long as no surface coal mining operations are 

permitted. 
Appendix 6 Proposed RMP and Final EIS 

A6-4 Kanab RMP 

• Exemptions. The application of this criterion to lands within the listed land systems and 

categories is subject to valid existing rights, and does not apply to surface coal mining operations 

existing on August 3, 1977. 

A number of land systems specified in Criterion 1 are applicable under the unsuitability criteria. 

National Forests 

All National Forest lands are considered unsuitable for surface coal mining operations. An exception to 

this criterion would allow surface operations based on the specific criteria outlined above. The Dixie 

National Forest prepared a Coal Unsuitability Study in 1983, and found that only 10 acres met the 

conditions of the exception. The study was based on areas identified as high- and moderate-potential coal 

lands that did not have significant forest cover. The Dixie National Forest Coal Unsuitability Study 

results are carried forward in this report. Therefore, approximately 93,425 acres of National Forest lands 

within the KRCRA are determined to be unsuitable for surface coal mining and for surface impacts 

incident to underground mining. There are an additional 1,587 acres of Bankhead-Jones lands under 

USFS administration in the KRCRA for surface coal mining and surface impacts incident to underground 

mining. 

National Recreation Areas 

There are about 2,120 acres of federal coal in the Kaiparowits coal field that underlie the Glen Canyon 

National Recreation Area. This federal coal is unsuitable for further consideration for leasing because it is 

within the National Park System. 

National Wild and Scenic Rivers System 

There are about 230 acres of lands that are eligible for inclusion in the National Wild and Scenic Rivers 

System. If these lands obtain such status, they will be determined to be unsuitable. 

Incorporated Cities, Towns, and Villages 

Approximately 3,000 acres of federal coal in the Alton and Kolob coal fields within the KRCRA underlie 

the towns of Alton, Orderville, and Glendale. Because of possible damage to private property caused by 

subsidence and surface mining, these areas are determined to be unsuitable and will not be further 

considered for future leasing. The breakdown of the number of acres within each town is as follows: 

Alton 101 acres 

Glendale 1,742 acres 

Orderville 1,162 acres 

Exemptions for valid existing rights do not apply. 

Summary: Criterion 1—Approximately 100,137 acres are determined to be unsuitable based on the 

conditions set forth in this criterion. 
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-5 

Criterion Number 2 

Federal lands that are within rights-of-way or easements or within surface leases for residential, 

commercial, industrial, or other public purposes, on federally owned surface shall be considered 

unsuitable. 

• Exceptions. A lease may be issued, and mining operations approved, in such areas if the surface 

management agency determines that: (i) All or certain types of coal development (e.g., 

underground mining) will not interfere with the purpose of the right-of-way or easement; or (ii) 

The right-of-way or easement was granted for mining purposes; or (iii) The right-of-way or 

easement was issued for a purpose for which it is not being used; (iv) The parties involved in the 

right-of-way or easement agree, in writing, to leasing; or (v) It is impractical to exclude such 

areas due to the location of coal and method of mining and such areas or uses can be protected 

through appropriate stipulations. 

• Exemptions. This criterion does not apply to lands: To which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued.

There are only 17 recorded rights-of-way (ROW), totaling approximately 30 acres of land, within the 

KRCRA. The exception (parts (i), (iv), and (v)) of this criterion offers protection for the ROWs and their 

improvements from the potential adverse effects of mining or associated surface facilities and, therefore, 

will not be considered unsuitable. 

There are a large number of roads that will be evaluated in the future for Revised Statute (RS) 2477 

standing. This could greatly affect the number of ROWs within the KRCRA. It is likely that the criterion 

exception would also apply in these cases. 

Summary: Criterion 2—No acres are determined to be unsuitable based on the conditions set forth in 

this criterion. 

Criterion Number 3 

The terms used in this criterion have the meaning set out in the Office of Surface Mining Reclamation and 

Enforcement regulations at Chapter VII of Title 30 of the Code of Federal Regulations. Federal lands 

affected by section 522(e) (4) and (5) of the Surface Mining Control and Reclamation Act of 1977 shall be 

considered unsuitable. This includes lands within 100 feet of the outside line of the right-of-way of a 

public road or within 100 feet of a cemetery, or within 300 feet of any public building, school, church, 

community or institutional building or public park or within 300 feet of an occupied dwelling. 

• Exceptions. A lease may be issued for lands: (i) Used as mine access roads or haulage roads that 

join the right-of-way for a public road; (ii) For which the Office of Surface Mining Reclamation 

and Enforcement has issued a permit to have public roads relocated; (iii) If after public notice 

and opportunity for public hearing in the locality, a written finding is made by the authorized 

officer that the interests of the public and the landowners affected by mining within 100 feet of a 

public road will be protected; (iv) For which owners of occupied dwellings have given written 

permission to mine within 300 feet of their buildings. 

• Exemptions. The application of this criterion is subject to valid existing rights, and does not apply 

to surface coal mining operations existing on August 3, 1977. 
Appendix 6 Proposed RMP and Final EIS 

A6-6 Kanab RMP 

Criterion 3 identifies approximately 3,200 acres of land within the KRCRA that have been found to be 

unsuitable. Data was not available to ascertain the location of all public buildings, community or 

institutional buildings, or occupied dwellings. Therefore, municipality boundaries were used to identify 

the areas of unsuitability. There are still a number of homes and summer cabins on private lands outside 

of these boundaries that are underlain by federal coal in the Alton and Kolob fields. A survey of the exact 

locations was not conducted. Because many of these structures are located in areas that would be mined 

primarily by underground methods, the underground exemption could possibly be applied. If the 

exemption could not be applied, mining would not be allowed within 300 feet of any such dwelling. A 

survey of existing dwellings would be made if leasing of federal coal is considered. The owners of the 

dwellings would be given the opportunity to give written permission for mining. If permission is not 

obtained, the area would then be designated unsuitable and the exact acreage calculated. Until that time, 

the area will be considered suitable. 

The Alton Cemetery is underlain by surface minable coal. This area is unsuitable because surface mining 

is prohibited within 100 feet of a cemetery. This involves only about 1 acre. 

As mentioned above in Criterion 2, the total acreage determined to be unsuitable could increase 

significantly based on administrative determinations regarding RS 2477 road assertions.

The exemptions for valid existing rights do not apply because there are presently no authorized coal 

leases within the KRCRA. 

Summary: Criterion 3—Approximately 3,200 acres are determined to be unsuitable for surface coal 

mining and surface impacts incident to underground mining based on the conditions set forth in this 

criterion. 

Criterion Number 4 

Federal lands designated as wilderness study areas shall be considered unsuitable while under review by 

the Administration and the Congress for possible wilderness designation. For any Federal land which is 

to be leased or mined prior to completion of the wilderness inventory by the surface management agency, 

the environmental assessment or impact statement on the lease sale or mine plan shall consider whether 

the land possesses the characteristics of a wilderness study area. If the finding is affirmative, the land 

shall be considered unsuitable, unless issuance of noncompetitive coal leases and mining on leases is 

authorized under the Wilderness Act and the Federal Land Policy and Management Act of 1976. 

• Exemptions. The application of this criterion to lands for which the Bureau of Land Management 

is the surface management agency and lands in designated wilderness areas in National Forests 

is subject to valid existing rights. 

There is one Wilderness Study Area (WSA) that partially overlies the KRCRA. Therefore, approximately 

45 acres within the Parunuweap Canyon WSA are considered unsuitable. 

The exemptions for valid existing rights do not apply because there are presently no authorized coal 

leases within the KRCRA. 

Summary: Criterion 4—Approximately 45 acres are determined to be unsuitable for surface coal mining 

and surface impacts incident to underground mining based on the conditions set forth in this criterion. 
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-7 

Criterion Number 5 

Scenic Federal lands designated by visual resource management analysis as Class I (areas of outstanding 

scenic quality or high visual sensitivity) but not currently on the National Register of Natural Landmarks 

shall be considered unsuitable. 

• Exceptions. A lease may be issued if the surface management agency determines that surface coal 

mining operations will not significantly diminish or adversely affect the scenic quality of the 

designated area. 

• Exemptions. This criterion does not apply to lands: to which the operator has made substantial 

legal and financial commitments prior to January 4, 1977; on which surface coal mining 

operations were being conducted on August 3, 1977, or which include operations on which a 

permit has been issued.

There are presently no Visual Resource Management (VRM) Class I lands within the KRCRA. This will 

change in the future with the new KFO Resource Management Plan (RMP) based on BLM policy set 

forth in the Washington Office Instruction Memorandum 2000-096, which directs BLM to assign VRM 

Class I designations to all WSA lands. Therefore, after authorization of the new RMP, 45 acres in the 

Parunuweap Canyon WSA that fall within the KRCRA (Criterion 4) will become unsuitable for surface 

mining. 

Summary: Criterion 5—No acres are determined to be unsuitable at this time. 

Criterion Number 6 

Federal lands under permit by the surface management agency, and being used for scientific studies 

involving food or fiber production, natural resources, or technology demonstrations and experiments 

shall be considered unsuitable for the duration of the study, demonstration or experiment, except where 

mining could be conducted in such a way as to enhance or not jeopardize the purposes of the study, as 

determined by the surface management agency, or where the principal scientific user or agency gives 

written concurrence to all or certain methods of mining. 

• Exemptions. This criterion does not apply to lands: To which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued.

Southern Utah University in conjunction with the Utah Division of Wildlife Resources (UDWR) and the 

KFO BLM are studying Greater sage-grouse in the Alton area. The study incorporates approximately 

5,800 acres within the Alton Amphitheater. The purpose of the study is to determine locations and 

suitability for sage-grouse brooding and winter habitats. This study is scheduled to be complete in 2008. 

The schedule would not conflict with future mining/leasing and, therefore, the project area is considered 

suitable under this criterion. 

Summary: Criterion 6—No acres are determined to be unsuitable. 
Appendix 6 Proposed RMP and Final EIS 

A6-8 Kanab RMP 

Criterion Number 7 

All publicly or privately owned places which are included in the National Register of Historic Places 

shall be considered unsuitable. This shall include any areas that the surface management agency 

determines, after consultation with the Advisory Council on Historic Preservation and the State Historic 

Preservation Officer, are necessary to protect the inherent values of the property that made it eligible for 

listing in the National Register. 

• Exceptions. All or certain stipulated methods of coal mining may be allowed if, after consultation 

with the Advisory Council on Historic Preservation and the State Historic Preservation Officer, 

they are approved by the surface management agency, and, where appropriate, the State or local 

agency with jurisdiction over the historic site. 

• Exemptions. This criterion does not apply to lands: to which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued. 

This criterion applies to districts, sites, objects, and other items of historical, architectural, archaeological, 

or cultural significance in or eligible for inclusion in the National Register of Historic Places. Although 

no sites within the KRCRA have been included in the National Register, there are a large number of 

known and documented archaeological sites that have been determined eligible. The exception for 

stipulated coal mining methods that will not result in adverse impacts is applicable; however, mitigation 

may be required for eligible sites where adverse impacts cannot be avoided. The State Historic 

Preservation Officer has identified possible subsidence problems associated with underground mining. 

Stipulations would be necessary in any future leases to mitigate the adverse effects of subsidence. 

Summary: Criterion 7—No acres are determined to be unsuitable at this time. 

Criterion Number 8 

Federal lands designated as natural areas or as National Natural Landmarks shall be considered 

unsuitable. 

• Exceptions. A lease may be issued and mining operation approved in an area or site if the surface 

management agency determines that: (i) The use of appropriate stipulated mining technology will 

result in no significant adverse impact to the area or site; or (ii) The mining of the coal resource 

under appropriate stipulations will enhance information recovery (e.g., paleontological sites). 

• Exemptions. This criterion does not apply to lands: To which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which includes operations on which a permit has 

been issued.

There are no designated natural areas or National Natural Landmarks designated under 43 CFR 2070 

within the KRCRA. 

Summary: Criterion 8—No acres are determined to be unsuitable. 
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-9 

Criterion Number 9 

Federally designated critical habitat for listed threatened or endangered plant and animal species, and 

habitat proposed to be designated as critical for listed threatened or endangered plant and animal 

species or species proposed for listing, and habitat for Federal threatened or endangered species which 

is determined by the Fish and Wildlife Service and the surface management agency to be of essential 

value and where the presence of threatened or endangered species has been scientifically documented, 

shall be considered unsuitable. 

• Exceptions. A lease may be issued and mining operations approved if, after consultation with the 

Fish and Wildlife Service, the Service determines that the proposed activity is not likely to 

jeopardize the continued existence of the listed species and/or its critical habitat. 

• Exemptions. This criterion does not apply to lands: to which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued. 

There are approximately 33,630 acres of federally designated critical habitat for the Mexican spotted owl 

(MSO) within the boundaries of the KRCRA. In informal consultation with the U.S. Fish and Wildlife 

Service (USFWS), BLM mapped areas that contain only the primary constituent elements for MSO 

habitat, as defined by the Mexican Spotted Owl Recovery Plan (USFWS 2001, FR 8530, vol. 66 no. 22). 

These areas were identified using professional judgment and by buffering the 2000 Willey MSO habitat 

model by 1⁄2 mile. The areas identified include approximately 8,668 acres of habitat that would be 

considered unsuitable for surface coal mining or surface facilities. In the event of future leasing, BLM 

would inventory coal areas for threatened and endangered (T&E) plant and animal species in conjunction 

with a site-specific environmental impact statement (EIS) analysis. Critical habitat designations for T&E 

plant or animal species will likely change in the future, at which time the determination of suitability 

would be revised. 

Past surveys include a general reconnaissance for T&E plants in the entire southern Utah coal area by Dr. 

Stanley Welch in 1977. Moderately intensive surveys were conducted by Dr. Kent Ostler in 1979 on 

about 56,500 acres on the Utah Power and Light Company preference right lease application area, the El 

Paso Coal Company leases, and the Resources Company leases. A moderately intensive survey on about 

26,800 acres in the Alton coal field was conducted by Dr. Robert Foster in 1979. UDWR inventoried the 

coal areas of southern Utah for T&E animals in 1977 and 1978. The process included a literature search 

and field inventories. In 1979 and 1980, BLM conducted an essential habitat inventory for the Utah 

prairie dog, peregrine falcon, and bald eagle in southern Utah. Several bald eagle sightings were made on 

the Alton and Kolob coal fields, and one concentration area was located (Criterion 12). No peregrine 

falcons or Utah prairie dogs were identified closer than 10 miles from the KRCRA (Escalante and Zion 

Unit Resource Analyses; Johnson 1979; UDWR 1977; USFWS 1978, 44 FR 7096, December 10, 1979). 

The exception in this criterion could allow for surface mining and surface facilities within these areas 

only after the USFWS determined that the proposed activity is not likely to jeopardize the continued 

existence of the MSO or other listed species in the future and/or their critical habitats. 

The exemption for substantial legal and financial commitments and ongoing mining operations does not 

apply because there are no active leases or operations within the planning area. 
Appendix 6 Proposed RMP and Final EIS 

A6-10 Kanab RMP 

Summary: Criterion 9—Approximately 8,668 acres are determined to be unsuitable for surface coal 

mining and surface impacts incident to underground mining. The exception in this criterion may be 

applicable subject to site-specific analysis and consultation with USFWS. 

Criterion Number 10 

Federal lands containing habitat determined to be critical or essential for plant or animal species listed 

by a state pursuant to state law as endangered or threatened shall be considered unsuitable. 

• Exceptions. A lease may be issued and mining operations approved if, after consultation with the 

state, the surface management agency determines that the species will not be adversely affected 

by all or certain stipulated methods of coal mining. 

• Exemptions. This criterion does not apply to lands: To which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued.

The State of Utah does not maintain an official state T&E species list; therefore, no state-listed T&E plant 

or animal species or critical habitat exists for this criterion. 

Summary: Criterion 10—No acres are determined to be unsuitable. 

Criterion Number 11 

A bald or golden eagle nest or site on Federal lands that is determined to be active and an appropriate 

buffer zone of land around the nest site shall be considered unsuitable. Consideration of availability of 

habitat for prey species and of terrain shall be included in the determination of buffer zones. Buffer zones 

shall be determined in consultation with the Fish and Wildlife Service. 

• Exceptions. A lease may be issued if: (i) It can be conditioned in such a way, either in manner or 

period of operation, that eagles will not be disturbed during breeding season; or (ii) The surface 

management agency, with the concurrence of the Fish and Wildlife Service, determines that the 

golden eagle nest(s) will be moved. (iii) Buffer zones may be decreased if the surface 

management agency determines that the active eagle nests will not be adversely affected. 

• Exemptions. This criterion does not apply to lands: to which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued.

In 2003, UDWR identified an active bald eagle nest within the KPA adjacent to the KRCRA. When 

including a 1-mile buffer zone, a portion of the KRCRA is intersected. Nests are considered active for a 

period of 7 years after discovery of a nest in use. Exercising (iii) of the exception above, the buffer has 

been modified because the natural topography provides adequate protection for the nest site. 

Approximately 20 acres of land remain unsuitable after the readjustment. Leasing may be feasible within 

the area determined to be unsuitable if the condition of exceptions (i and ii) are met. The underground 

exemption could also be applied on possible future leasing. Future leases would stipulate that no surface 

facilities could be built within a 1-mile radius of an active nest site and that surface operations could be 

conducted only between September 1 and December 31 of each year (Utah Field Office Guidelines for 

Raptor Protection From Human and Land Use Disturbances [USFWS 1999]). Future inventories by 
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-11 

UDWR and BLM may identify additional eagle nests within the coal areas that would render the nest and 

buffer areas unsuitable. 

The exemption for substantial legal and financial commitments and ongoing mining operations does not 

apply because there are no active leases or operations within the planning area. 

Summary: Criterion 11—Approximately 20 acres are determined to be unsuitable for surface coal 

mining and surface impacts incident to underground mining. The exception in this criterion may be 

applicable subject to site-specific analysis and consultation with USFWS. 

Criterion Number 12 

Bald and golden eagle roost and concentration areas on Federal lands used during migration and 

wintering shall be considered unsuitable. 

• Exceptions. A lease may be issued if the surface management agency determines that all or 

certain stipulated methods of coal mining can be conducted in such a way, and during such 

periods of time, to ensure that eagles shall not be adversely disturbed. 

• Exemptions. This criterion does not apply to lands: to which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued.

BLM and UDWR inventories have identified a bald eagle winter concentration area of approximately 

1,160 acres on Table Bench along the North Fork of the Virgin River. The wintering area is used from 

about November 1 to March 15 each year. The rough surface topography and the deep coals have led to 

the determination that only underground methods would be used to mine this area. The exception and 

underground exemption could be applied to possible future leases and surface facilities to restrict 

activities that could adversely disturb the eagles during the winter concentration period. Future 

inventories by BLM and UDWR may identify other bald eagle concentration areas within the coal areas, 

which could affect suitability (BLM 1978 and 1979, Zion Unit Analysis; UDWR 1977; Johnson 1979). 

The exemption for substantial legal and financial commitments and ongoing mining operations does not 

apply because there are no active leases or operations within the planning area. 

Summary: Criterion 12—Approximately 1,160 acres are determined to be unsuitable for surface coal 

mining and surface impacts incident to underground mining. The exception in this criterion may be 

applicable subject to site-specific analysis. 

Criterion Number 13 

Federal lands containing a falcon (excluding kestrel) cliff nesting site with an active nest and a buffer 

zone of Federal land around the nest site shall be considered unsuitable. Consideration of availability of 

habitat for prey species and of terrain shall be included in the determination of buffer zones. Buffer zones 

shall be determined in consultation with the Fish and Wildlife Service. 

• Exceptions. A lease may be issued where the surface management agency, after consultation with 

the Fish and Wildlife Service, determines that all or certain stipulated methods of coal mining 
Appendix 6 Proposed RMP and Final EIS 

A6-12 Kanab RMP 

will not adversely affect the falcon habitat during the periods when such habitat is used by the 

falcons. 

• Exemptions. This criterion does not apply to lands: to which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued.

BLM and UDWR inventories conducted in the late 1970s and early 1980s identified several prairie falcon 

nesting sites within the KPA, two of which were located within the KRCRA (BLM 1978, 1979 Zion and 

Escalante Unit Resource Analyses; UDWR 1977, 1978; Hoffman 1978; Johnson 1979; BLM field 

inventories 1976, 1977, 1978, and 1980). No recent surveys have been conducted to verify this data. 

Because of the amount of time that has passed since the data was collected and the likelihood of a change 

of status, no lands are designated as unsuitable under this criterion. A more thorough analysis would be 

required at the time of coal leasing to adequately address this criterion. Future inventories by UDWR and 

BLM or site-specific lease analysis may identify new falcon nests within coal areas. At that time the lands 

would be designated unsuitable unless the exception could be applied. 

Summary: Criterion 13—No acres are determined to be unsuitable. 

Criterion Number 14 

Federal lands which are high priority habitat for migratory bird species of high Federal interest on a 

regional or national basis, as determined jointly by the surface management agency and the Fish and 

Wildlife Service, shall be considered unsuitable. 

• Exceptions. A lease may be issued where the surface management agency, after consultation with 

the Fish and Wildlife Service, determines that all or certain stipulated methods of coal mining 

will not adversely affect the migratory bird habitat during the periods when such habitat is used 

by the species. 

• Exemptions. This criterion does not apply to lands: to which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued. 

Several Bird Habitat Conservation Areas have been identified by the Intermountain West Joint Venture 

(IWJV) along the East Fork of the Virgin River, East Fork of the Sevier River (Parker Mountain), and 

Escalante River in and adjacent to the KRCRA. In consultation with USFWS, BLM determined that highpriority habitats for migratory birds exist along these corridors, defined as a 1⁄2-mile buffer zone from the 

outer edge of the bank. Approximately 11,900 acres of the KRCRA would be affected and considered 

unsuitable. Future leasing within these areas could occur if site-specific consultation with USFWS 

determined that such operations would not adversely affect the migratory bird habitat during the periods 

of use. 

The underground exemption does not apply in this criterion because of the potential to affect hydrologic 

systems and riparian habitat. 

The exemption for substantial legal and financial commitments and ongoing mining operations does not 

apply because there are no active leases or operations within the planning area. 
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-13 

Summary: Criterion 14—Approximately 11,900 acres are determined to be unsuitable for surface coal 

mining and surface impacts incident to underground mining. The exception in this criterion may be 

applicable subject to site-specific analysis and consultation with USFWS. 

Criterion Number 15 

Federal lands which the surface management agency and the state jointly agree are habitat for resident 

species of fish, wildlife and plants of high interest to the state and which are essential for maintaining 

these priority wildlife and plant species shall be considered unsuitable. Examples of such lands which 

serve a critical function for the species involved include: (i) Active dancing and strutting grounds for 

Greater sage-grouse, sharp-tailed grouse, and prairie chicken; (ii) Winter ranges crucial for deer, 

antelope, and elk; (iii) Migration corridor for elk; and (iv) Extremes of range for plant species. 

• Exceptions. A lease may be issued if, after consultation with the state, the surface management 

agency determines that all or certain stipulated methods of coal mining will not have a significant 

long-term impact on the species being protected. 

• Exemptions. This criterion does not apply to lands: To which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued. 

There are approximately 18,330 acres of crucial elk winter range; 12,780 acres of crucial mule deer 

winter range; 8,735 acres of Greater sage-grouse breeding, nesting, and brood-rearing habitat; and 12 

acres classified as leks on federal coal lands within the KRCRA. The State of Utah and BLM agree that 

elk, mule deer, and sage-grouse habitats should remain suitable because site-specific analyses would 

occur before coal field leasing. Presently there is an EIS underway as part of a coal leasing application in 

the Alton Amphitheater. High-interest habitat issues will be addressed in this EIS. 

Table A6-4. State Sensitive Species Habitat 

State Sensitive Species Habitat 

(acres of habitat by ownership) USFS BLM State Surface 

Private 

Surface 

Elk 17,015 1,235 80 

Mule Deer 8,445 2,530 680 1,125 

Sage-Grouse Breeding, Nesting, and 

Brood-Rearing 5,735 1,940 1,060 

Sage-Grouse Lek 12 

Neither the BLM nor the State of Utah has high-interest plant species of concern within the KRCRA. 

The first exception and underground exemption in this criterion would apply. 

The exemption for substantial legal and financial commitments and ongoing mining operations does not 

apply because there are no active leases or operations within the planning area. 

Summary: Criterion 15—No acres are determined to be unsuitable. 
Appendix 6 Proposed RMP and Final EIS 

A6-14 Kanab RMP 

Criterion Number 16 

Federal lands in riverine, coastal and special floodplains (100-year recurrence interval) on which the 

surface management agency determines that mining could not be undertaken without substantial threat of 

loss of life or property shall be considered unsuitable for all or certain stipulated methods of coal mining. 

• Exemptions. This criterion does not apply to lands: To which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued. 

Data for this criterion is not presently available to adequately delineate riverine and special floodplains. 

Limited 100-year flood hazard maps are available from the U.S. Department of Housing and Urban 

Development, but the data is not adequate to determine the threat assessment. A more thorough analysis 

will be required at the time of coal leasing to adequately address this criterion. 

Summary: Criterion 16—No acres are determined to be unsuitable. 

Criterion Number 17 

Federal lands which have been committed by the surface management agency to use as municipal 

watersheds shall be considered unsuitable. 

• Exceptions. A lease may be issued where the surface management agency in consultation with the 

municipality (incorporated entity) or the responsible governmental unit determines, as a result of 

studies, that all or certain stipulated methods of coal mining will not adversely affect the 

watershed to any significant degree. 

• Exemptions. This criterion does not apply to lands: To which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued.

No lands within the KRCRA have been committed for use as municipal watersheds. 

Summary: Criterion 17—No acres are determined to be unsuitable. 

Criterion Number 18 

Federal lands with National Resource Waters, as identified by states in their water quality management 

plans, and a buffer zone of Federal lands 1⁄4 mile from the outer edge of the far banks of the water, shall 

be unsuitable. 

• Exceptions. The buffer zone may be eliminated or reduced in size where the surface management 

agency determines that it is not necessary to protect the National Resource Waters. 

• Exemptions. This criterion does not apply to lands: To which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued.
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-15 

In the State of Utah, the designation “High Quality Waters” is the equivalent of National Resource 

Waters, and therefore waters with this designation receive additional regulatory protection. 

Within the KPA, the State of Utah has designated Category 1 High Quality Waters in the following 

drainages: 

1. North Fork of the Virgin River and tributaries, from the confluence with the East Fork of the 

Virgin River to its headwaters 

2. East Fork of the Virgin River and tributaries, from the confluence with the North Fork of the 

Virgin River to its headwaters 

3. East Fork of the Sevier River and tributaries, from the Kingston diversion to its headwaters 

4. Kanab Creek and tributaries, from the irrigation diversion at the confluence with Reservoir 

Canyon to its headwaters (Utah Administrative Code R317-2-12). 

Consistent with Criterion 18 and state rules, BLM has determined that protection of High Quality Waters 

can be achieved through the use of the unsuitability designation, best management practices (BMP), and 

the state permitting process. Buffers were established for springs and perennial and intermittent streams, 

as follows: 

• Perennial streams: 1⁄4 mile (1,320 feet; 402 meters) slope distance from the outer edge of the bank 

• Intermittent streams: 330 feet (100 meters) slope distance from the outer edge of the bank 

• Springs: 330 feet (100 meters) slope distance from the edge of the saturated area. 

The locations of springs and perennial and intermittent stream reaches were determined based on 

interviews with employees of the BLM KFO and NPS (Sharrow, personal communication) as well as 

with a local landowner who has extensive knowledge of the area (Esplin, personal communication). Their 

input was used to edit the U.S. Geological Survey (USGS) digital line graphs dataset that covers the KPA. 

Stream segments that would be perennial or intermittent if it were not for irrigation diversions were 

classified according to their potential condition rather than their altered condition. 

Approximately 13,760 acres are determined to be unsuitable because of proximity to National Resource 

Waters. It is likely that additional perennial/intermittent streams and springs are present that were not 

mapped. If such waterways are determined to exist after the publication of this report, they would be 

buffered and protected as described above. 

The exemption for substantial legal and financial commitments and ongoing mining operations does not 

apply because there are no active leases or operations within the planning area. 

Summary: Criterion 18—Approximately 13,760 acres are determined to be unsuitable for surface coal 

mining and surface impacts incident to underground mining. 

Criterion Number 19 

Federal lands identified by the surface management agency, in consultation with the state in which they 

are located, as alluvial valley floors according to the definition in §3400.0—5(a) of this title, the 

standards in 30 CFR Part 822, the final alluvial valley floor guidelines of the Office of Surface Mining 

Reclamation and Enforcement when published, and approved state programs under the Surface Mining 

Control and Reclamation Act of 1977, where mining would interrupt, discontinue, or preclude farming, 

shall be considered unsuitable. Additionally, when mining Federal land outside an alluvial valley floor 
Appendix 6 Proposed RMP and Final EIS 

A6-16 Kanab RMP 

would materially damage the quantity or quality of water in surface or underground water systems that 

would supply alluvial valley floors, the land shall be considered unsuitable. 

• Exemptions. This criterion does not apply to surface coal mining operations which produced coal 

in commercial quantities in the year preceding August 3, 1977, or which had obtained a permit to 

conduct surface coal mining operations.

There is insufficient data at this time to determine either suitability or unsuitability of any area for coal 

development under this criterion. Identification of alluvial valley floors (AVF) is accomplished by the 

surface management agency in consultation with the state according to the definition in the Surface 

Mining Control and Reclamation Act of 1977 (SMCRA) (PL 95-87), the standards in 30 CFR 822, the 

Office of Surface Mining (OSM) AVF guidelines, and approved state programs under SMCRA. 

The AVF guidelines provide a sequential procedure for identifying AVFs. The first phase is a 

reconnaissance investigation that identifies probable AVFs using available regional or generalized data. 

The second phase is more detailed, and involves test drilling and mapping of geologic, vegetation, and 

soils data, leading to a determination that an area meets the criteria outlined in the regulations (30 CFR 78 

19(c)(2)). The third phase requires more detailed descriptions of the AVFs identified in phase two, and 

involves water monitoring for a sufficient period of time to be able to describe seasonal fluctuations. 

In response to a petition to designate certain lands in the study area as unsuitable for surface coal mining, 

OSM completed the first phase of an AVF investigation in the Alton coal field area (OSM 1983). The 

following list represents areas identified as possible AVFs within the KRCRA, but additional analysis 

would be required before leasing: 

1. Kanab Creek, upper and lower 

2. Sink Valley Wash 

3. Unnamed tributary north of Alton and west of Kanab Creek 

4. Thompson Creek 

5. Mill, Tenny, and Skutumpah Creeks 

6. Lower Johnson Wash 

7. Yellow Creek 

8. Upper Paria drainage 

9. East Fork of the Sevier River. 

AVFs may exist within the decision area, but initial mapping of AVFs has occurred only within the Alton 

area and at a reconnaissance level. Approximately 3,850 acres were identified as possible AVFs using 

data obtained from an investigation conducted by Jack Schmidt (1980) and BLM geographic information 

system (GIS) data layers. No lands within the planning area are designated as unsuitable under this 

criterion. A more detailed investigation would be required at the time of lease analysis. 

The exemption for ongoing mining operations does not apply because there are no active leases or 

operations within the planning area. 

Summary: Criterion 19—No acres are determined to be unsuitable. 

Criterion Number 20 

Federal lands in a state to which is applicable a criterion (i) proposed by the state or Indian tribe located 

in the planning area, and (ii) adopted by rulemaking by the Secretary, shall be considered unsuitable. 
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-17 

• Exceptions. A lease may be issued when: (i) Such criterion is adopted by the Secretary less than 6 

months prior to the publication of the draft comprehensive land use plan or land use analysis, 

plan, or supplement to a comprehensive land use plan, for the area in which such land is 

included, or (ii) After consultation with the state or affected Indian tribe, the surface management 

agency determines that all or certain stipulated methods of coal mining will not adversely affect 

the value which the criterion would protect. 

• Exemptions. This criterion does not apply to lands: To which the operator made substantial legal 

and financial commitments prior to January 4, 1977; on which surface coal mining operations 

were being conducted on August 3, 1977; or which include operations on which a permit has 

been issued.

Neither the State of Utah nor Indian tribes have proposed any criteria that would affect the coal lands 

under review, although in 1980 Secretary of Interior Andrus signed a decision designating certain areas in 

the viewshed of Bryce Canyon National Park unsuitable for surface coal mining and surface impacts 

incident to underground mining. Approximately 31,620 acres fall within the KRCRA, and these are 

determined to be unsuitable. 

The exemption for substantial legal and financial commitments and ongoing mining operations does not 

apply because there are no active leases or operations within the planning area. 

Summary: Criterion 20—Approximately 31,620 acres are determined to be unsuitable for surface coal 

mining and surface impacts incident to underground mining. 

SUMMARY OF THE UNSUITABILITY EVALUATION

The coal resources with development potential within the KPA have been evaluated based on the 20 

criteria of unsuitability. Based on the criteria, the coal resources that are considered unsuitable for leasing 

are shown on Map 2. These resources have been determined to be unsuitable for leasing based on Criteria 

1, 3, 4, 9, 11, 12, 14, 15, 18, and 20. Based on the criteria, the coal resources that are considered suitable 

for further leasing consideration are shown on Map 3. 

As a result of this analysis, there are approximately 113,642 acres within the KPA that are determined to 

be suitable and 133,237 acres that are determined to be unsuitable for surface coal mining operations. 

Within the KFO decision area, there are 113,629 acres that are determined to be suitable and 37,580 acres 

that are determined to be unsuitable based on the 20 criteria. 
Appendix 6 Proposed RMP and Final EIS 

A6-18 Kanab RMP 

REFERENCES 

Bureau of Land Management. 1978 and 1979. Escalante, Paria, and Zion Unit Resource Analysis (URA) 

and Management Framework Plans (MFP), Kanab, Utah. 

Bureau of Land Management. 1979 and 1980. Essential Habitat Inventory for the Utah Prairie Dog, 

Peregrine Falcon, and the Bald Eagle, Southern Utah. 

Bureau of Land Management, Utah State Office, 1979. Wilderness Inventory—State of Utah (Map), Salt 

Lake City, Utah. 

Bureau of Land Management. 2006. Kanab Field Office Mineral Potential Report. Prepared by Utah 

Geological Survey. 

Doelling, H.H., and Graham, R.L. 1972. Southwestern Utah Coal Fields: Alton, Kaiparowits Plateau, and 

Kolb-Harmony, Utah Geological and Mineral Survey Monograph Series No. 1. 

Intermountain West Joint Venture, Utah Steering Committee. 2005. Coordinated Implementation Plan for 

Bird Conservation in Utah. 

Hoffman, S. 1978. Inventory of Nesting Raptors in the Escalante Resource Area. Unpublished final 

report. 

Ostler, K. 1980. A Survey of Proposed Endangered and Threatened Plants of the Kaiparowits Plateau 

Area, Kane and Garfield Counties, Utah. Unpublished report. BLM Cedar City District Office, 

Cedar City, Utah. 

Office of Surface Mining Reclamation and Enforcement (OSM). 1983. Alluvial Valley Floors 

Identification and Study Guidelines. 

Schmidt, J.C. 1980. Reconnaissance Determination of Alluvial Valley Floor Status and Assessment of 

Selected Geomorphic Parameters in Selected Stream Valleys of the Alton Petition Area and 

Adjoining Lands, Garfield and Kane counties, Utah. Report prepared for Office of Surface 

Mining. 

U.S. Department of Agriculture, Forest Service, Dixie National Forest. 1983. Coal Unsuitability Study. 

U.S. Department of Housing and Urban Development. FEMA 100 Year Flood Maps. 

U.S. Fish and Wildlife Service (USFWS). 1978. Ranking of Wildlife on Federal Lands, vol. 4, Utah. 

U.S. Fish and Wildlife Service (USFWS), Johnson, C., Coal Coordinator. 1979. Personal communication 

with Steve Hedges, wildlife biologist, BLM Cedar City District Office, Cedar City, Utah. 

U.S. Fish and Wildlife Service (USFWS). 1999. Utah Field Office Guidelines for Raptor Protection from 

Human and Land Use Disturbances. 

U.S. Fish and Wildlife Service (USFWS). 2001. FR 8530, vol. 66, no. 22. 
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-19 

Utah Division of Wildlife Resources (UDWR). 1977. Endangered and Unique Terrestrial Wildlife 

Species within the Coal Study Area. Final Report to Bureau of Land Management. BLM Utah 

State Office, Salt Lake City, Utah. 

Utah Steering Committee Intermountain West Joint Venture. Coordinated Implementation Plan for Bird 

Conservation in Utah, 2005. 
Appendix 6 Proposed RMP and Final EIS 

A6-20 Kanab RMP MAP 1. FEDERAL COAL OWNERSHIP WITHIN KRCRA 
Proposed RMP and Final EIS Appendix 6 

Kanab RMP A6-21 MAP 2. COAL RESOURCES CONSIDERED UNSUITABLE FOR LEASING
Appendix 6 Proposed RMP and Final EIS 

A6-22 Kanab RMP MAP 3. COAL RESOURCES CONSIDERED SUITABLE FOR LEASING
Proposed RMP and Final EIS Appendix 7 

Kanab RMP A7-1 

APPENDIX 7—TRAVEL MANAGEMENT/ROUTE 

DESIGNATION PROCESS 

The Kanab Field Office (KFO) used the following process for route designation alternatives during 

development of the Kanab Resource Management Plan (RMP) and Environmental Impact Statement 

(EIS). This process included route inventory, interdisciplinary team (ID team) assessment, and 

cooperating agency coordination. 

ROUTE INVENTORY

The KFO conducted a complete route inventory in 2005 and 2006 to develop a route baseline for use in 

the planning process. Bureau of Land Management (BLM) employees with global positioning system 

(GPS) equipment digitized the routes while traveling on off-highway vehicles (OHV) and by foot. The 

digitized route data was verified and prepared for interdisciplinary review. In addition, Garfield County 

provided route data in a geographic information system (GIS) data layer. Data from the BLM inventory 

was overlaid with the Garfield County route data, and discrepancies were identified, reviewed, and 

resolved through ground-truthing and resource specialist review. Kane County provided paper maps with 

route data. These maps were reviewed, and any additional routes were ground-truthed with GPS and 

BLM employees. Where GPS data was incomplete, recent aerial photography was inspected to complete 

GIS datagaps. While inventorying the routes, staff collected surface type and primary and secondary 

usage associated with each route. 

INTERDISCIPLINARY TEAM ASSESSMENT

Team members reviewed the route inventory during a series of ID team meetings. The team made the 

following assumptions: 

• Prohibit motorized vehicle cross-country travel, except in designated open areas 

• Close routes (permanently, seasonally, or temporarily) or relocate as appropriate to address 

resource concerns 

• Evaluate parallel, duplicative, or redundant routes for potential closure 

• Where routes, trails, or other facilities have been abandoned, provide for restoration and 

revegetation of the site

• Prohibit motorized use of designated closed routes, except for BLM administrative and 

emergency use 

• Sign and map designated routes as motorized or non-motorized; travel maps should be user 

friendly and easily accessible 

• Existing route designations may be changed pursuant to land management objectives 

• The travel management plan should be flexible about the location of new routes needed to 

provide access for new activities or to new areas or to reduce resource and/or user conflicts 

• Where and when appropriate, plan, develop, and designate (in cooperation with user groups and 

cooperating agencies) new routes and trails that enhance and expand recreational opportunities 

and encourage responsible use. 

The ID team applied the following factors to the route inventory and used other BLM inventories and 

natural and cultural resource information to identify routes for designation. The team considered the 

following: 
Appendix 7 Proposed RMP and Final EIS 

A7-2 Kanab RMP 

• Environmental sensitivity of the areas surrounding the route, including soil type/condition, 

riparian areas and their condition, wilderness study areas (WSA), and weeds 

• Wildlife habitat sensitivity of the areas surrounding the route, including designated critical 

habitat, sensitive status species habitat, or crucial habitat 

• Current and anticipated visitor use levels and travel and transportation needs and desires 

• Management objectives for the area and the potential for user and resource conflicts 

• Access needs for BLM-permitted or authorized activities (e.g., range permittees, recreation 

permittees, and mineral developments) 

• Access needs for non-BLM-administered lands 

• Cultural resources and specific sites that require protection 

• How route designation could be used to reduce existing or anticipated conflict between users 

• How route designation would affect setting, recreation activity, and experience opportunities in 

the area. 

PLAN MAINTENANCE AND CHANGES TO ROUTE DESIGNATIONS

The RMP includes indicators that guide future plan maintenance, amendments, or revisions related to 

OHV area designations or the approved road and trail system within “Limited” areas. Future conditions 

may require the designation or construction of new routes or closure of routes to better address resources 

and resource use conflicts. Actual route designations within the “Limited” category can be modified 

without completing a plan amendment, although compliance with the National Environmental Policy Act 

of 1969 (NEPA) is still required. 

As Instruction Memorandum (IM) 2004-061 notes, plan maintenance can be accomplished through 

additional analysis and land use planning (e.g., activity level planning). The BLM will collaborate with 

affected and interested parties in evaluating the designated road and trail network for suitability for active 

OHV management and envisioning potential changes in the existing system or adding new trails that 

would help meet current and future demands. In conducting such evaluations, the following factors would 

be considered: 

• Routes suitable for various categories of OHVs (e.g., motorcycles, all-terrain vehicles [ATVs], 

dune buggies, and 4-wheel-drive touring vehicles) and opportunities for joint trail use 

• Needs for parking, trailheads, informational and directional signs, mapping and profiling, and 

development of brochures or other materials for public dissemination 

• Opportunities to tie into existing or planned route networks 

• Measures needed to meet the objectives stated in the RMP (e.g., cultural resources, soil resources, 

special status species, and recreation) 

• Public land roads or trails determined to cause considerable adverse effects or to constitute a 

nuisance or threat to public safety would be considered for relocation or closure and rehabilitation 

after appropriate coordination with applicable agencies and partners 

• Those areas managed as closed will not be available for new motorized designation or 

construction. 

Regulations at 43 Code of Federal Regulations (CFR) 8342.2 require the BLM to monitor the effects of 

OHV use. Changes should be made to the Travel Plan based on the information obtained through 

monitoring. Site-specific NEPA documentation is required for changing the route designations in this 

Travel Plan. 
Proposed RMP and Final EIS Appendix 7 

Kanab RMP A7-3 

COOPERATING AGENCY COORDINATION

BLM managers and planners met with cooperating agency representatives to review the inventory and 

discuss concerns. Maps provided at each meeting were used throughout the discussions. Specifically, 

Kane County and Garfield County representatives raised concerns regarding routes they claimed under 

Revised Statute (RS) 2477. In addition, duplicative routes, routes with maintenance concerns, 

maintenance standards, and access to the counties’ resources were discussed in relation to the route 

inventory. 

IMPLEMENTATION PROCESS

Implementation decisions are actions that the BLM takes to implement land use plans (LUP) and 

generally constitute the BLM’s final approval for allowing on-the-ground actions to proceed. These types 

of decisions, which are based on site-specific planning and NEPA analyses, are subject to the 

administrative remedies set forth in the regulations that apply to each BLM resource management 

program. Implementation decisions are not subject to protest under the planning regulations; rather, they 

are subject to various administrative remedies. Where implementation decisions are made as part of the 

land use planning process, they are still subject to the appeals process or other administrative review as 

prescribed by specific resource program regulations after the BLM resolves the protests to LUP decisions 

and makes a decision to adopt or amend the RMP. 

The travel planning and implementation process includes the following: 

• Monitoring the transportation system and modifying as appropriate 

• A map of roads and trails for all travel modes 

• Notations of any limitation for specific roads and trails 

• Criteria to select or reject roads and trails in the final travel management network, add new roads 

or trails, and specify limitations 

• Guidelines for management, monitoring, and maintenance of the transportation system 

• Needed easements and rights-of-ways (to be issued to the BLM or others) to maintain the existing 

road and trail network providing public land access. 

The RMP completes the initial route designation component of the Travel Management Plan and 

implementation process. These routes would be the initial basis for signing and enforcement. The Field 

Office will prioritize additional implementation actions, resources, and geographic areas based on the 

RMP goals and objectives and in accordance with the guidelines noted above. 
Appendix 7 Proposed RMP and Final EIS 

A7-4 Kanab RMP 

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Proposed RMP and Final EIS Appendix 8 

Kanab RMP A8-1 

APPENDIX 8—WILDLAND FIRE RESOURCE 

PROTECTION MEASURES AND REASONABLE AND 

PRUDENT MEASURES, TERMS AND CONDITIONS, 

AND REPORTING REQUIREMENTS IDENTIFIED 

THROUGH SECTION 7 CONSULTATION 

The existing land use plans (LUP) that constitute Alternative A (No Action Alternative) were amended 

September 26, 2005, with the Finding of No Significant Impact and Decision Record (UT-USO-04-01) 

Utah Land Use Plan Amendment for Fire and Fuels Management. The decisions from that document 

have been brought forward in their entirety. A majority of the decisions are located in the Management 

Common to All Alternatives section of the Proposed Resource Management Plan (RMP)/Final 

Environmental Impact Statement (EIS) Chapter 2 under the Wildland Fire Ecology heading. This 

appendix contains the remainder of the decisions, in the form of resource protection measures and terms 

and conditions identified through Section 7 consultation, that were too long to be easily integrated into 

Chapter 2 of the Proposed RMP/Final EIS. 

RESOURCE PROTECTION MEASURES IDENTIFIED IN THE UTAH LAND USE PLAN 

AMENDMENT FOR FIRE AND FUELS MANAGEMENT

Applicable Fire Management Practices: 

SUP: Wildfire Suppression 

WFU: Wildland Fire Use for Resource Benefit 

RX: Prescribed Fire 

NF: Non-Fire Fuel Treatments 

ESR: Emergency Stabilization 

and Rehabilitation

Air 

A-1 Evaluate weather conditions, including wind speed and atmospheric stability, to predict impacts from smoke from 

prescribed fires and wildland fire use. Coordinate with Utah Department of Environmental Quality for prescribed fires 

and wildland fire use. (RX, WFU) 

A-2 When using chemical fuels reduction methods, follow all label requirements for herbicide application. (NF) 

Soil and Water 

SW-1 Avoid heavy equipment use on highly erosive soils (soils with low soil loss tolerance), wet or boggy soils, and 

slopes greater than 30 percent, unless otherwise analyzed and allowed under appropriate National Environmental 

Policy Act (NEPA) evaluation with implementation of additional erosion control and other soil protection mitigation 

measures. (SUP, WFU, RX, NF, ESR) 

SW-2 There may be situations where high-intensity fire will occur on sensitive and erosive soil types during wildland 

fire, wildland fire use, or prescribed fire. If significant areas of soil show evidence of high-severity fire, evaluate the 

area for soil erosion potential and downstream values at risk and implement appropriate or necessary soil 

stabilization actions such as mulching or seeding to avoid excessive wind and water erosion. (SUP, WFU, RX) 

SW-3 Complete necessary rehabilitation on firelines or other areas of direct soil disturbance, including but not limited to 

waterbarring firelines, covering and mulching firelines with slash, tilling and/or subsoiling compacted areas, 

scarification of vehicle tracks, off-highway vehicles (OHV) closures, and seeding and/or mulching for erosion 

protection. (SUP, WFU, RX) 

SW-4 When using mechanical fuels reduction treatments, limit tractor and heavy equipment use to periods of low soil 

moisture to reduce the risk of soil compaction. If this is not practical, evaluate sites post-treatment and, if necessary, 

implement appropriate remediation, such as subsoiling, as part of the operation. (NF) 
Appendix 8 Proposed RMP and Final EIS 

A8-2 Kanab RMP 

Applicable Fire Management Practices: 

SUP: Wildfire Suppression 

WFU: Wildland Fire Use for Resource Benefit 

RX: Prescribed Fire 

NF: Non-Fire Fuel Treatments 

ESR: Emergency Stabilization 

and Rehabilitation

SW-5 Treatments such as chaining, plowing, and roller chopping shall be conducted as much as practical on the 

contour to reduce soil erosion (Bureau of Land Management [BLM] Record of Decision [ROD] 13 Western States 

Vegetation Treatment EIS 1991). (NF, ESR) 

SW-6 When using chemical fuel reduction treatments follow all label directions, additional mitigations identified in 

project NEPA evaluation, and the Approved Pesticide Use Proposal. At a minimum, provide a 100-foot-wide riparian 

buffer strip for aerial application, 25 feet for vehicle application, and 10 feet for hand application. Any deviations must 

be in accordance with the label. Herbicides would be applied to individual plants within 10 feet of water where 

application is critical (BLM ROD 13 Western States Vegetation Treatment EIS 1991). (NF) 

SW-7 Avoid heavy equipment in riparian or wetland areas. During fire suppression or wildland fire use, consult a 

resource advisor before using heavy equipment in riparian or wetland areas. (SUP, WFU, RX, NF, ESR) 

SW-8 Limit ignition within native riparian or wetland areas. Allow low-intensity fire to burn into riparian areas. (RX) 

SW-9 Suppress wildfires consistently with compliance strategies for restoring or maintaining the restoration of water 

quality impaired (303(d) listed) water bodies. Do not use retardant within 300 feet of water bodies. (SUP, WFU) 

SW-10 Plan and implement projects consistent with compliance strategies for restoring or maintaining the restoration of 

water quality impaired (303(d) listed) water bodies. Planned activities shall take into account the potential impacts on 

water quality, including increased water yields that can threaten fisheries and aquatic habitat; improvements at 

channel crossings; channel stability; and downstream values. Of special concern are small headwaters of moderate 

to steep watersheds, erosive or saline soils, multiple channel crossings, at-risk fisheries, and downstream residents. 

(RX, NF, ESR) 

Vegetation 

V-1 When restoring or rehabilitating disturbed rangelands, non-intrusive, non-native plant species are appropriate for 

use when native species: (1) are not available; (2) are not economically feasible; (3) cannot achieve ecological 

objectives as well as non-native species; and/or (4) cannot compete with already established native species (Noxious 

Weeds Executive Order 13112 2/3/1999; BLM Manual 9015; BLM ROD 13 Western States Vegetation Treatment 

EIS 1991). (RX, NF, ESR) 

V-2 In areas known to have weed infestations, aggressive action will be taken in rehabilitating firelines, seeding and 

follow-up monitoring, and treatment to reduce the spread of noxious weeds. Monitor burned areas and treat as 

necessary. All seed used will be tested for purity and for noxious weeds. Seed with noxious weeds will be rejected 

(ROD 13 Western States Vegetation Treatment EIS 1991). (SUP, WFU, RX, NF, ESR) 

Special Status Species 

SSS-1 Initiate emergency Section 7 consultation with United States Fish and Wildlife Service (USFWS) upon the 

determination that wildfire suppression may pose a potential threat to any listed threatened or endangered species or 

adverse modification of designated critical habitat. (SUP) 

SSS-3 Prior to planned fire management actions, survey for listed threatened and endangered and non-listed sensitive 

species. Initiate Section 7 consultation with USFWS as necessary if proposed project may affect any listed species. 

Review appropriate management, conservation, and recovery plans and include recovery plan direction into project 

proposals. For non-listed special status plant and animal species, follow the direction contained in the BLM 6840 

Manual. Ensure that any proposed project conserves non-listed sensitive species and their habitats and ensure that 

any action authorized, funded, or carried out by the BLM does not contribute to the need for any species to become 

listed. (RX, NF, ESR) 

SSS-4 Follow terms and conditions identified in the Biological Opinion (see section below). (SUP, WFU, RX, NF, ESR) 

Fish and Wildlife 

FW-1 Avoid treatments during nesting, fawning, spawning, or other critical periods for wildlife or fish. (RX, NF, ESR) 

FW-2 Avoid if possible or limit the size of wildland fires in important wildlife habitats such as mule deer winter range 

and riparian and occupied Greater sage-grouse habitat. Use resource advisors to help prioritize resources and 

develop Wildland Fire Situation Analyses and Wildland Fire Implementation Plans when important habitats may be 

impacted. (SUP, WFU) 
Proposed RMP and Final EIS Appendix 8 

Kanab RMP A8-3 

Applicable Fire Management Practices: 

SUP: Wildfire Suppression 

WFU: Wildland Fire Use for Resource Benefit 

RX: Prescribed Fire 

NF: Non-Fire Fuel Treatments 

ESR: Emergency Stabilization 

and Rehabilitation

FW-3 Minimize wildfire size and frequency in sagebrush communities where sage-grouse habitat objectives will not be 

met if a fire occurs. Prioritize wildfire suppression in sagebrush habitat with an understory of invasive, annual 

species. Retain unburned islands and patches of sagebrush unless there are compelling safety, private property, and 

resource protection or control objectives at risk. Minimize burnout operations (to minimize burned acres) in occupied 

sage-grouse habitats when there are no threats to human life and/or important resources. (SUP) 

FW-4 Establish fuel treatment projects at strategic locations to minimize size of wildfires and to limit further loss of 

sagebrush. Fuel treatments may include greenstripping to help reduce the spread of wildfires into sagebrush 

communities. (RX, NF) 

FW-5 Use wildland fire to meet wildlife objectives. Evaluate impacts on sage-grouse habitat in areas where wildland fire 

use for resource benefit may be implemented. (WFU, RX) 

FW-6 Create small openings in continuous or dense sagebrush (more than 30 percent canopy cover) to create a 

mosaic of multiple-age classes and associated understory diversity across the landscape to benefit sagebrushdependent species. (WFU, RX, NF) 

FW-7 On sites that are currently occupied by forests or woodlands, but historically supported sagebrush communities, 

implement treatments (fire, cutting, chaining, seeding, etc.) to reestablish sagebrush communities. (RX, NF) 

FW-8 Evaluate and monitor burned areas and continue management restrictions until the recovering and/or seeded 

plant community reflect the desired condition. (SUP, WFU, RX, ESR) 

FW-9 Use the ESR program to apply appropriate post-fire treatments within crucial wildlife habitats, including sagegrouse habitats. Minimize seeding with non-native species that may create a continuous perennial grass cover and 

restrict establishment of native vegetation. Seed mixtures shall be designed to reestablish important seasonal habitat 

components for sage-grouse. Leks shall not be reseeded with plants that change the vegetation height previously 

found on the lek. Forbs shall be stressed in early and late brood-rearing habitats. In situations of limited funds for 

ESR actions, prioritize rehabilitation of sage-grouse habitats. (ESR) 

Cultural Resources 

CR-1 Cultural resource advisors shall be contacted when fires occur in areas containing sensitive cultural resources. 

(SUP) 

CR-2 Wildland fire use is discouraged in areas containing sensitive cultural resources. A programmatic agreement is 

being prepared to cover the finding of adverse effects on cultural resources associated with wildland fire use. (WFU) 

CR-3 Potential impacts of proposed treatment shall be evaluated for compliance with the National Historic Preservation 

Act (NHPA) and the Utah Statewide Protocol. This shall be conducted prior to the proposed treatment. (RX, NF, 

ESR) 

Paleontology 

P-1 Planned projects shall be consistent with BLM Manual and Handbook H-8270-1, Chapter III (A) and III (B), to avoid 

areas where significant fossils are known or predicted to occur or to provide for other mitigation of possible adverse 

effects. (RX, NF, ESR) 

P-2 In the event that paleontological resources are discovered in the course of surface fire management activities, 

including fires suppression, efforts shall be made to protect these resources. (SUP, WFU, RX, NF, ESR) 

Forestry 

F-1 Planned projects shall be consistent with Healthy Forest Restoration Act Section 102(e)(2) to maintain or contribute 

to the restoration of old-growth stands to a pre-fire-suppression condition and to retain large trees contributing to oldgrowth structure. (SUP, WFU, RX, NF) 

F-2 During planning, evaluate opportunities to use forest and woodland products prior to implementing prescribed fire 

activities. Include opportunities to use forest and woodland product sales to accomplish non-fire fuel treatments. In 

forest and woodland stands, consider developing silvicultural prescriptions concurrently with fuel treatment 

prescriptions. (RX, NF) 
Appendix 8 Proposed RMP and Final EIS 

A8-4 Kanab RMP 

Applicable Fire Management Practices: 

SUP: Wildfire Suppression 

WFU: Wildland Fire Use for Resource Benefit 

RX: Prescribed Fire 

NF: Non-Fire Fuel Treatments 

ESR: Emergency Stabilization 

and Rehabilitation

Livestock Grazing 

LG-1 Coordinate with permittees regarding the requirements for non-use or rest of treated areas. (SUP, WFU, RX, NF, 

ESR) 

LG-2 Rangelands that have been burned by wildfire, prescribed fire, or wildland fire use will be ungrazed for a minimum 

of one complete growing season following the burn. (SUP, WFU, RX) 

LG-3 Rangelands that have been reseeded or otherwise treated to alter vegetative composition, chemically or 

mechanically, will be ungrazed for a minimum of two complete growing seasons. (RX, NF, ESR) 

Recreation and Visitor Services 

Rec-1 Wildland fire suppression efforts will preferentially protect Special Recreation Management Areas and recreation 

site infrastructure in line with fire management goals and objectives. (SUP) 

Rec-2 Vehicle tracks created off established routes will be obliterated after fire management actions in order to reduce 

unauthorized OHV travel. (SUP, WFU, RX, NF, ESR) 

Lands and Realty 

LR-1 Fire management practices will be designed to avoid or otherwise ensure the protection of authorized rights-ofway (ROW) and other facilities located on the public lands, including coordination with holders of major ROW 

systems within ROW corridors and communication sites. (WFU, RX, NF, ESR) 

LR-2 Fire management actions must not destroy, deface, change, or remove to another place any monument or 

witness tree of the Public Land Survey System. (SUP, WFU, RX, NF, ESR) 

Hazardous Waste 

HW-1 Recognize hazardous wastes and move fire personnel to a safe distance from dumped chemicals, unexploded 

ordnance, drug labs, wire burn sites, or any other hazardous wastes. Immediately notify the BLM Field Office 

HAZMAT coordinator or state HAZMAT coordinator upon discovery of any hazardous materials, following the BLM 

hazardous materials contingency plan. (SUP, WFU, RX, NF, ESR) 

Mineral Resources 

M-1 A safety buffer shall be maintained between fire management activities and at-risk facilities. (SUP, WFU, RX) 

Wilderness and Wilderness Study Areas 

Wild-1 The use of earth-moving equipment must be authorized by the Field Office manager. (SUP, WFU, RX, ESR) 

Wild-2 Fire management actions will rely on the most effective methods of suppression that are least damaging to 

wilderness values, other resources, and the environment, while requiring the least expenditure of public funds. (SUP, 

WFU) 

Wild-3 A resource advisor shall be consulted when fire occurs in Wilderness Areas and Wilderness Study Areas 

(WSA). (SUP, WFU) 

U. S. FISH AND WILDLIFE SERVICE INCIDENTAL TAKE STATEMENT, INCLUDING 

REASONABLE AND PRUDENT MEASURES, TERMS AND CONDITIONS, AND 

REPORTING REQUIREMENTS FOR ESA SPECIES OF THE BIOLOGICAL OPINION

The USFWS has completed a biological opinion on the Proposed Action alternative and terms and 

conditions have been identified as part of that opinion. Together, the resource protection measures and the 

terms and conditions were incorporated into the Proposed Action to reduce resource conflicts. Species 

that were addressed in the complete statement contained in the Finding of No Significant Impact and 
Proposed RMP and Final EIS Appendix 8 

Kanab RMP A8-5 

Decision Record (UT-USO-04-01) Utah Land Use Plan Amendment for Fire and Fuels Management that 

do not occur within the decision area or are not affected by management in the EIS alternatives are not 

include in the Incidental Take Statement below. 

Incidental Take Statement 

Section 9 of the ESA, as amended, prohibits take (harass, harm, pursue, hunt, shoot, wound, kill, trap, 

capture, or collect or attempt to engage in any such conduct) of listed species of fish or wildlife without a 

special exemption. “Harm” is further defined to include significant habitat modification or degradation 

that results in death or injury to listed species by significantly impairing behavioral patterns such as 

breeding, feeding, or sheltering (50 CFR 173). “Harass” is defined as actions that create the likelihood of 

injury to listed species to such an extent as to significantly disrupt normal behavior patterns, which 

include but are not limited to breeding, feeding, or sheltering (50 CFR 17.3).

No exemption from Section 9 of the Act is granted in this biological opinion. The Bureau of Land 

Management’s (BLM) implementation of the Land Use Plan Amendment and Five Fire Management 

Plans is likely to adversely affect listed species. The likelihood of incidental take, and the identification of 

reasonable and prudent measures (RPM) and terms and conditions to minimize such take, will be 

addressed in project-level and possibly programmatic-level consultations. Any incidental take and 

measures to reduce such take cannot be effectively identified at the level of proposed action because of 

the uncertainty of wildland fire, broad geographic scope, and the lack of site-specific information. Rather, 

incidental take and RPMs may be identified adequately through subsequent actions subject to Section 7 

consultations at the project and/or programmatic scale. 

Even though actual take levels are unquantifiable, take will occur through harm and harassment. 

Therefore, we are providing the following RPMs and terms and conditions to minimize overall take. 

Implementation of these RPMs and terms and conditions during project planning will also expedite sitespecific Section 7 consultation. 

Reasonable and Prudent Measures 

The USFWS believes that the following RPMs are necessary and appropriate to minimize impacts of 

incidental take on Utah prairie dog, Southwestern willow flycatcher, California condor, bald eagle, 

Mexican spotted owl (MSO), and Siler pincushion cactus: 

1. The BLM shall implement measures to minimize mortality or injury of federally listed species 

due to proposed project activities without placing firefighter personnel at risk. The species that 

were determined likely to be adversely affected by project activities included Utah prairie dog, 

Southwestern willow flycatcher, California condor, bald eagle, MSO, and Siler pincushion cactus. 

2. The BLM shall implement measures to minimize harm to federally listed species through 

destruction of their suitable or designated critical habitats without placing firefighter personnel at 

risk. The species’ habitats that were determined likely to be adversely affected by project 

activities included Utah prairie dog, Southwestern willow flycatcher, California condor, bald 

eagle, MSO, and Siler pincushion cactus. 

Terms and Conditions 

To be exempt from the prohibitions of Section 9 of the Act, the BLM must comply with the following 

terms and conditions, which implement the RPMs described above and outline reporting/monitoring 

requirements. These terms and conditions are non-discretionary. The following terms and conditions 
Appendix 8 Proposed RMP and Final EIS 

A8-6 Kanab RMP 

apply to all species covered under this biological opinion and are to be implemented in addition to the 

Applicant Committed Measures described in the Proposed Action. 

General Terms and Conditions 

1. To implement RPM 1: 

a. Before the beginning of each fire season, a threatened and endangered species education 

program will be presented to all personnel anticipated to be within federally listed species 

habitats during suppression activities. This program will contain information concerning 

the biology and distribution of listed species throughout the Fire Management Plan 

Planning Area, their legal status, fire suppression goals, and restrictions within suitable and 

critical habitat. Following training, each individual will sign a completion sheet to be 

placed on file at the local BLM office. 

b. All project employees (including fire fighting personnel) shall be informed as to the 

definition of “take,” the potential penalties (up to $200,000 in fines and 1 year in prison) 

for taking a species listed under the ESA, and the terms and conditions provided in this 

biological opinion. 

c. A qualified resource advisor will be assigned to each wildfire that occurs in or threatens 

listed species habitat. The resource advisor’s role is to help define goals and objectives for 

fire suppression efforts and to inform the Incident Commander (IC) of any restrictions, but 

he or she does not get involved in specific suppression tactics. Resource advisors shall 

oversee fire suppression and suppression rehabilitation activities in order to ensure that 

protective measures endorsed by the IC are implemented. 

d. For pre-planned projects, the authorized officer shall designate an individual as a contact 

representative who will be responsible for overseeing compliance with the Applicant 

Committed Measures and terms and conditions contained in this biological opinion, and 

providing coordination with USFWS. The representative will have the authority to halt 

activities that may be in violation of these conditions, unless human health and safety or 

structures are at risk. 

e. Project-related personnel shall not be permitted to have pets accompany them to the project 

site. 

f. If available, maps shall be provided to local dispatch centers showing general locations of 

listed species. Local BLM or Utah Division of Wildlife Resources (UDWR) biologists shall 

be consulted for specific locations if fires occur within or near the general locations 

delineated on the map. 

g. In occupied habitat, pre- and post-monitoring of federally listed species’ responses to the 

pre-planned treatments will be conducted. 

2. To implement RPM 2: 

a. Fingers or patches of unburned vegetation within burned areas shall not be burned out as a 

fire suppression measure unless required for safety concerns or due to high reburn 

potential. 

b. Emergency stabilization and rehabilitation efforts must focus on areas where there is a 

potential of non-native species to spread, particularly within suitable habitat for federally 

listed species. 

c. The specific seed mix and areas to be seeded within suitable habitat for federally listed and 

sensitive species will be determined through coordination and Section 7 consultation with 

the USFWS. 

d. In occupied habitat burned by wildland fire, the recovery of vegetation shall be monitored, 

including establishment and monitoring of paired plots, inside and outside of the burned 

area unless the BLM and the USFWS concur that monitoring is not required. 
Proposed RMP and Final EIS Appendix 8 

Kanab RMP A8-7 

e. Site-specific projects under the Land Use Plan Amendment and Fire Management Plans 

will maintain, protect, or enhance the primary constituent elements of designated critical 

habitat in all implementation activities. 

f. The effectiveness of suppression activities and threatened and endangered species 

conservation measures shall be evaluated after a fire in coordination with the USFWS. 

Procedures shall be revised as needed. 

g. In occupied habitat, pre- and post-monitoring of federally listed species’ habitat responses 

to the pre-planned treatments will be conducted. 

h. Temporarily close burned areas to off-highway vehicles (OHV) within occupied habitat 

after a wildland fire event until vegetation and soils recover. Consultation with the USFWS 

may determine that an area may remain open if there is no threat to the species or habitat. 

i. Consult with the USFWS to determine the need to obscure decommissioned trails and roads 

and illegal OHV trails within occupied habitat after a wildland fire event to prevent the 

trails and roads from re-opening. 

Utah Prairie Dog 

The following terms and conditions are in addition to the general terms and conditions listed above and 

apply to the Utah prairie dog: 

1. To implement RPMs 1 and 2: 

a. Wildfires will be suppressed before they reach a prairie dog colony (“prairie dog colony” 

refers to any occupied Utah prairie dog colony) or after they exit a colony. Active 

suppression efforts will not occur within a colony unless human health and safety or 

structures are at risk. 

b. Only hand lines will be authorized within colonies. 

c. Normally, only water shall be used on fires that occur within prairie dog colonies. If the fire 

IC decides that the situation requires use of chemical retardants to protect life and property, 

they may be used. The chemical composition will be supplied to the USFWS during 

emergency consultation. 

d. All vehicles shall stay on existing roads within colonies except as stated in (e). Storage of 

equipment and materials shall not occur within 1⁄4 mile of colonies. Vehicle maintenance 

shall not occur within these areas. 

e. The resource advisor, biologist, or biological monitor (someone who is either qualified with 

a biological background or has been trained by the resource advisor) ensures that prairie 

dogs and their burrows are protected or avoided by walking in front of engines, tracked 

vehicles, or other firefighting-related vehicles within occupied prairie dog colonies. 

f. Vehicles shall not exceed a speed of 10 miles per hour (cross-country) in occupied Utah 

prairie dog colonies unless a higher speed is determined to be prudent for safety reasons. 

g. Within colonies, precautions shall be taken to ensure that contamination of the site by fuels, 

motor oils, grease, etc. does not occur and that such materials are contained and properly 

disposed of off site. Inadvertent spills of petroleum-based or other toxic materials shall be 

cleaned up and removed immediately unless they occur during an emergency event 

(wildfire suppression). In which case the spill shall be cleaned up as soon as practical after 

the emergency situation is controlled. 

h. Camps associated with fire suppression activities shall be situated outside occupied habitat. 

i. If a dead or injured Utah prairie dog is located, initial notification must be made to the 

USFWS Division of Law Enforcement, Cedar City, Utah at telephone 435-865-0861 or to 

the Cedar City office of the UDWR at telephone number 435-865-6100. Instruction for 

proper handling and disposition of such specimens will be issued by the Division of Law 

Enforcement. Care must be taken in handling sick or injured animals to ensure effective 
Appendix 8 Proposed RMP and Final EIS 

A8-8 Kanab RMP 

treatment and care and in handling dead specimens to preserve biological material in the 

best possible state. 

Southwestern Willow Flycatcher 

The following terms and conditions are in addition to the general terms and conditions listed above and 

apply to the Southwestern willow flycatcher: 

1. To implement the RPM 1: 

a. Prior to planned project activities, potentially affected habitat will be surveyed according to 

USFWS protocol (A Southwestern Willow Flycatcher Natural History Summary and 

Survey Protocol; Technical Report NPS/NAUCPRS/NRTR-97/12). 

b. Except where fires are active in occupied habitat, minimize unnecessary low-level 

helicopter flights during the breeding season (April 1 to September 30). If safety allows, 

approach bucket dip sites at a 90-degree direction to rivers to minimize flight time over the 

river corridor and occupied riparian habitats. Locate landing sites for helicopters at least 1⁄4 

mile from occupied flycatcher habitat unless human safety or property dictates otherwise. 

c. Minimize use of chainsaws or bulldozers to construct firelines through occupied or suitable 

habitat except where necessary to reduce the overall acreage of occupied habitat or other 

important habitat areas that would otherwise be burned. 

d. Implement activities to reduce hazardous fuels or improve riparian habitats (prescribed 

burning or vegetation treatments) within occupied or unsurveyed suitable habitat for 

Southwestern willow flycatchers only during the non-breeding season (October 1 to March 

31). 

2. To implement RPM 2: 

a. Riparian fuel reduction actions shall be considered as experimental and initially conducted 

only in unoccupied habitats until the success and ramifications are better understood. 

Efficacy of these actions as a fire management tool, and effects on bird habitat quality, shall 

be tested in a scientifically explicit, controlled fashion (Appendix L in USFWS 2002). 

b. In occupied or suitable flycatcher habitat, creation of firebreaks might render the habitat 

unsuitable (Appendix L in USFWS 2002). As long as human safety and property allows, 

firebreaks shall be conducted in unoccupied sites, outside of proposed critical habitat, or 

within proposed critical habitat under the following situations: 

i. The habitat does not meet the Primary Constituent Elements of the proposed critical 

habitat as listed in 69 FR 60706-60786, October 12, 2004. 

ii. The firebreak is a minimal fireline necessary to prevent unacceptable losses of 

occupied habitat. 

iii. The firebreak is between fuel concentrations and flycatcher breeding sites to prevent 

fires from spreading into breeding sites (Appendix L in USFWS 2002). 

c. Prescribed fire shall be avoided in occupied habitat and considered only as experimental 

management techniques if dealing with suitable unoccupied habitat (Appendix L in 

USFWS 2002). 

d. Fires in occupied habitat and adjacent buffer zones shall be rapidly suppressed if safety 

allows. 

California Condor and Bald Eagle 

The following terms and conditions are in addition to the general terms and conditions listed above and 

apply to the California condor and bald eagle: 

1. To implement RPM 1: 
Proposed RMP and Final EIS Appendix 8 

Kanab RMP A8-9 

a. If California condors or bald eagles are found inhabiting (nesting) within the action area of 

a pre-planned project, a buffer of 1 mile surrounding the nesting area will be designated as 

non-treatment zones (Romin and Muck 2002). 

b. If California condors are observed within 1⁄4 mile of an open water source, such as an 

inflatable storage tank or “pumpkin,” the water storage tank will be covered when not in 

use. 

Mexican Spotted Owl 

The following terms and conditions are in addition to the general terms and conditions listed above and 

apply to the MSO: 

1. To implement RPM 1: 

a. Pre-planned fuels reduction projects within MSO designated critical habitat shall be 

designed to enhance habitat requirements for the MSO as well as for the valuable prey 

species they rely upon. 

2. To implement RPM 2: 

a. Fire suppression shall be considered for wildfires in designated critical habitat. 

Threatened or Endangered Plants 

The following terms and conditions are in addition to the general terms and conditions listed above and 

apply to the federally listed plants: 

1. To implement RPM 1: 

a. Do not allow wildland fire use within occupied habitat unless agreed to by the BLM and 

the USFWS. 

b. When feasible (and human life or property are not put at risk) firebreaks shall be 

constructed down-slope of plants and populations; if firebreaks must be sited up-slope, 

buffers of 100 feet minimum between surface disturbances and plants and populations will 

be incorporated. 

2. To implement RPM 2: 

a. Do not allow wildland fire use within occupied habitat unless agreed to by the BLM and 

the USFWS. 

b. For pre-planned projects within known or potential habitat, site inventories shall be 

conducted to determine habitat suitability prior to initiation of project activities at a time 

when the plant can be detected. 

c. For riparian/wetland-associated species, avoid loss or disturbance of riparian habitats. 

d. Limit disturbances to and within suitable habitat by staying on designated routes where 

feasible. 

e. Limit new access routes created by the project. 

f. Following a wildland fire event, place signing to limit all-terrain vehicle (ATV) travel in 

sensitive burned areas. 

Siler Pincushion Cactus 

The following terms and conditions are in addition to the general terms and conditions listed above as 

well as the terms and conditions for threatened and endangered plant species. These terms and conditions 

apply specifically to the Siler pincushion cactus: 

1. To implement RPMs 1 and 2: 
Appendix 8 Proposed RMP and Final EIS 

A8-10 Kanab RMP 

a. Follow and implement the restrictions on pesticide use within suitable Siler pincushion 

cactus habitat developed by the Environmental Protection Agency (EPA). These limitations 

were excerpted from the EPA’s Pesticides: Endangered Species Protection Program 

(http://www.epa.gov/oppfead l/endanger/arizona/cocon.htm#brady): 

i. If the active ingredient is 2,4-D (all forms), ATRAZINE, CLOPYRALID, 

DICAMBA (all forms), DICHLORPROP (2,4-DP), HEXAZINONE, MCPA (all 

forms), PARAQUAT, PICLORAM (all forms), or TEBUTHIURON, do not apply 

this pesticide in the species habitat. For ground applications do not apply within 20 

yards of the habitat, or within 100 yards for aerial applications. 

ii. If the active ingredient is OXYFLUORFEN (granular or non-granular), do not apply 

this pesticide in the species habitat. For ground applications do not apply within 100 

yards of the habitat, or within 1⁄4 mile for aerial applications. 

iii. If the active ingredient is either METRIBUZIN or SULFOMETURON METHYL, 

do not apply this pesticide on rights-of-way in the species habitat. 

Closing 

The USFWS believes that an unquantifiable amount of incidental take will occur in the form of harm and 

harassment as a result of the proposed actions. The RPMs, with their implementing terms and conditions, 

are designed to minimize the impact of incidental take that might otherwise result from the proposed 

actions. The BLM must immediately provide an explanation of the causes of the taking and review with the 

USFWS the need for possible modification of the RPMs. 

Reporting Requirements 

Upon locating dead, injured, or sick listed species, immediate notification must be made to the USFWS 

Salt Lake City Field Office at 801-975-3330 and the USFWS Division of Law Enforcement, Ogden, 

Utah, at 801-625-5570. Pertinent information including the date, time, location, and possible cause of 

injury or mortality of each species shall be recorded and provided to the USFWS. Instructions for proper 

care, handling, transport, and disposition of such specimens will be issued by the USFWS Division of 

Law Enforcement. Care must be taken in handling sick or injured animals to ensure effective treatment 

and care and in handling dead specimens to preserve biological material in the best possible state. 

The BLM shall submit a report to the USFWS on or before December 1 of each year in which fire 

management activities occurred within occupied habitat. For the listed and candidate species covered under 

this consultation, the report shall include (1) the amount of potential and/or occupied habitat affected by 

wildfire (i.e., stream miles burned, percentage of drainage burned, and fire severity map); (2) to the extent 

possible, the number of individuals killed from direct and indirect effects of wildfire; (3) any habitat and/or 

population monitoring efforts from past wildfire events; (4) a copy of the burned area emergency 

stabilization and rehabilitation plan; (5) implementation and effectiveness monitoring of burned area 

emergency stabilization and rehabilitation treatments; (6) implementation and effectiveness monitoring of 

the standard operating procedures (SOP); (7) recommendations for enhancing the effectiveness of the 

SOPs; and (8) any recommendations for additional SOPs. The first report shall be due to the USFWS on 

December 1, 2005. The address for the Utah Fish and Wildlife Office is: 

Field Supervisor, U.S. Fish and Wildlife Service 

2369 West Orton Circle, Suite 50 

West Valley City, Utah 84119 

Telephone: 801-975-3330 
Proposed RMP and Final EIS Appendix 8 

Kanab RMP A8-11 

ADDITIONAL RESOURCE PROTECTION MEASURES DEVELOPED BY THE BLM AND 

THE USFWS 

In addition to the resource protection measures listed in the LUP amendment, the following conservation 

measures were developed through the Section 7 consultation process. These resource protection measures 

were identified in the USFWS Biological Opinion (page 42). That document states that “the BLM has 

incorporated these measures ... by reference to their [Biological Assessment].” Species that were 

addressed in these measures that do not occur within the decision area or are not affected by management 

in the EIS alternatives are not included. Additional resource protection measures are as follows: 

• Manage natural and prescribed fire regimes to protect or improve Utah prairie dog habitat. 

• Within Utah prairie dog habitat, reseeding would be implemented according to the Utah Prairie Dog 

Recovery Plan. 

• Manage prescribed fire and wildland fire use within MSO protected activity centers (PAC) to ensure 

protection of nesting, roosting, and foraging habitats. 

• Wildland fire suppression would be prioritized for use in MSO PACs. When feasible, fire camps 

associated with suppression efforts would be built outside of the PACs and nest protection areas. 

• For treatments within suitable habitat for listed species, pre- and post-monitoring would take place 

as determined on a case-by-case basis. 

• Incorporate the standards and guidelines recommended by the Inland Native Fish Strategy (USFS 

1995). 

• As per the decision of the resource advisor, avoid construction of firelines using mechanized 

equipment across the stream channel. If used, the mechanized equipment would terminate at and not 

cross the stream channel. 

• Avoid transferring water from one watershed into another for the purpose of water drops because 

this could aid in the spread of waterborne diseases such as whirling disease. 

• Avoid retardant use in any riparian wetland communities. 

• Restricted use of mechanical treatments and hand tools. 

• Per-burn acreage limitations of 5 to 100 acres, as long as human life or property are not threatened. 

• Prior to planned fire management actions, survey for listed threatened and endangered and nonlisted sensitive species. Review appropriate management, conservation, and recovery plans and 

include recovery plan direction into project proposals, if listed. Ensure that any proposed project 

conserves non-listed sensitive species and their habitats and ensure that any action authorized, 

funded, or carried out by the BLM does not contribute to the need for any species to become listed. 
Appendix 8 Proposed RMP and Final EIS 

A8-12 Kanab RMP 

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Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-1 

APPENDIX 9—CONSERVATION MEASURES, OIL AND 

GAS LEASE NOTICES, AND RECOVERY PLANS 

FOR THREATENED AND ENDANGERED SPECIES 

SPECIFIC THREATENED/ENDANGERED SPECIES CONSERVATION MEASURES

The Utah Bureau of Land Management (BLM) is committed to the conservation of federally listed 

species. Pursuant to the Endangered Species Act (ESA), this means that that the BLM will use methods 

and procedures necessary for improving the status of federally listed species and their habitats to a point 

at which the provisions of the ESA are no longer necessary. This effort includes ensuring that BLM 

actions requiring permit or approval are consistent with the objectives of approved recovery plans for 

listed species. 

This list of conservation measures is part of the programmatic Section 7 consultation effort concerning 

existing land use plans (LUP) (Alternative A) in the decision area. To address the potential impacts of 

common land uses and to minimize the potential for their occurrence, the BLM, in coordination with the 

U.S. Fish and Wildlife Service (USFWS), has developed the following list of species-specific 

conservation measures for all future proposed actions involving BLM Utah. 

Future implementation proposals that are determined to have potential for impacts on these listed species 

should incorporate these conservation measures where applicable and appropriate. Where these measures 

are incorporated into future proposals, there is a greater likelihood that the BLM will meet the standard of 

“may affect, but not likely to adversely affect” species listed under the ESA. Where the BLM determines 

that deviation, modification, or waiver of these conservation measures would be prudent or necessary, 

early coordination and Section 7 consultation with USFWS would be necessary. The BLM will reinitiate 

Section 7 consultation at the project level as necessary to ensure proper management of listed species. 

Bald Eagle (Haliaeetus leucocephalus) 

The following list of measures provides species-specific guidance, intended to avoid, minimize, or reduce 

potential adverse impacts from implementation of BLM actions under the authority of current Utah BLM 

LUPs on the bald eagle. This list is not comprehensive. Additional conservation measures or other 

modified versions of these measures may be applied for any given BLM-authorized activity upon further 

analysis, review, coordination efforts, and/or appropriate levels of Section 7 consultation with the 

USFWS: 

1. The BLM will place restrictions on all authorized (i.e., permitted) activities that may adversely 

impact bald eagles, their breeding habitat, roosting sites, and known winter concentration areas in 

order to avoid or minimize potential impacts: 

– Measures have been adapted from guidance published in the Utah Field Office Guidelines for 

Raptor Protection from Human and Land Use Disturbances (Romin & Muck 2002), as well 

as coordination between the BLM and USFWS. Measures include, but may not be limited to 

seasonal/daily timing limitations and/or spatial buffers as follows: 
Appendix 9 Proposed RMP and Final EIS 

A9-2 Kanab RMP 

 Temporary activities1 or habitat alterations that may disturb nesting bald eagles will be 

restricted from January 1 to August 31 within 1 mile of bald eagle nest sites. Exceptions 

may be granted where no nesting behavior is initiated prior to June 1. 

 Temporary activities or habitat alterations that may disturb bald eagles will be restricted 

within 1⁄2 mile of known winter concentration areas from November 1 to March 31. 

Where daily activities must occur within these spatial buffers and are approved through 

subsequent consultation, activities should also be properly scheduled to occur after 9 a.m. 

and terminate at least 1 hour before official sunset to ensure that bald eagles using these 

roosts are allowed the opportunity to vacate their roost in the morning and return 

undisturbed in the evening. 

 No permanent2

 infrastructure will be placed within 1 mile of bald eagle nest sites or 

within 1⁄2 mile of bald eagle winter concentration areas. 

 Where activities are authorized within breeding habitats or known winter concentration 

areas, monitoring efforts would document what, if any, impacts occur during project 

implementation, and to what extent the species was affected. The results of these 

monitoring efforts would be carried forward in the design and implementation of future 

projects as part of the adaptive management process. 

2. For all project-related survey and monitoring actions: 

– Reports must be provided to affected field offices within 15 days of completion of survey or 

monitoring efforts. Reports must follow field office guidance for BLM-specified formats for 

written and automated databases. 

– Any detection of bald eagle presence during survey or monitoring efforts must be reported to 

the authorized officer within 48 hours of detection. 

3. Appropriately timed surveys in suitable bald eagle nesting habitat or identified concentration 

areas shall be conducted in accordance with approved protocols prior to any activities that may 

disturb bald eagles. Surveys would be conducted only by BLM-approved individuals or 

personnel. 

4. BLM shall, in coordination with cooperating agencies and/or partners (e.g., Utah Division of 

Wildlife Resources [UDWR] and USFWS), verify annual status (active versus inactive) of all 

known bald eagle nests and other identified concentration areas on BLM-administered lands. 

5. When project proposals that may affect threatened and endangered species are received, the BLM 

will coordinate with the USFWS at the earliest possible date so that the USFWS can provide 

necessary information to minimize or avoid the need to redesign projects at a later date to include 

conservation measures that may be determined as appropriate by the USFWS. 

6. BLM-administered lands within 1 mile of bald eagle nests, or identified communal winter roosts, 

should not be exchanged or sold. If it is imperative that these lands be transferred out of BLM 

ownership, then every effort should be made to include conservation easements or voluntary 

conservation restrictions to protect the bald eagles and support their conservation. 

7. Proponents of BLM-authorized actions will be advised that roadside carrion can attract foraging 

bald eagles and potentially increase the risk of vehicle collisions with individual bald eagles 

feeding on carrion. When carrion occurs on the road, appropriate officials will be notified for 

necessary removal. 

8. Power lines will be built to standards and guidelines identified in the Avian Protection Plan

(APP). 

 

1 Temporary activities are defined as those that are completed prior to the start of the following raptor breeding season, leaving 

no permanent structures, and resulting in no permanent habitat loss. 

2 Permanent activities continue for more than one breeding season and/or cause a loss of habitat or displace individuals through

disturbances (e.g., creation of a permanent structure including, but not limited to, well pads, roads, pipelines, and electrical 

power lines). 
Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-3 

9. The BLM will make educational information available to project proponents and the general 

public pertaining to the following topics: 

– Appropriate vehicle speeds and the associated benefit of reduced vehicle collisions with 

wildlife 

– Use of lead shot (particularly over water bodies) 

– Use of lead fishing weights 

– General ecological awareness of habitat disturbance 

10. Because bald eagles are often dependent on aquatic species as prey items, the BLM will 

periodically review existing water quality records (e.g., Utah Department of Environmental 

Quality [UDEQ], UDWR, and U.S. Geological Survey [USGS]) from monitoring stations on or 

near important bald eagle habitats (i.e., nests, roosts, and concentration areas) on BLM lands for 

any conditions that could adversely affect bald eagles or their prey. If water quality problems are 

identified, the BLM will contact the appropriate jurisdictional entity to cooperatively monitor the 

condition and/or take corrective action. 

Mexican Spotted Owl (Strix occidentalis lucida) 

The following list of measures provides species-specific guidance intended to avoid, minimize, or reduce 

potential adverse impacts from implementation of BLM actions under the authority of current Utah BLM 

LUPs on the Mexican spotted owl (MSO). This list is not comprehensive. Additional conservation 

measures or other modified versions of these measures may be applied for any given BLM-authorized 

activity upon further analysis, review, coordination efforts, and/or appropriate levels of Section 7 

consultation with the USFWS: 

1. The BLM will place restrictions on all authorized (permitted) activities that may adversely affect 

the MSO in identified protected activity centers (PAC), breeding habitat, or designated critical 

habitat in order to reduce the potential for adverse impacts to the species: 

– Restrictions and procedures have been adapted from guidance published in the Utah Field 

Office Guidelines for Raptor Protection from Human and Land Use Disturbances (Romin & 

Muck 2002), as well as coordination between the BLM and USFWS. Measures include: 

 Surveys, according to USFWS protocol, will be required prior to any disturbance-related 

activities that have been identified to have the potential to impact MSO, unless current 

species occupancy and distribution information is complete and available. All surveys 

must be conducted by USFWS-certified individuals and approved by the BLM authorized 

officer: 

◊ Assess habitat suitability for nesting and foraging using accepted habitat models in 

conjunction with field reviews. Apply the appropriate conservation measures below if 

project activities occur within 1⁄2 mile of suitable owl habitat, dependent in part on 

whether the action is temporary3 or permanent4: 

• For all temporary actions that may impact owls or suitable habitat: 

o If action occurs entirely outside of the owl breeding season and leaves no 

permanent structure or permanent habitat disturbance, action can proceed 

without an occupancy survey. 

 

3 Temporary activities are defined as those that are completed prior to the start of the following raptor breeding season, leaving 

no permanent structures, and resulting in no permanent habitat loss. 

4 Permanent activities continue for more than one breeding season and/or cause a loss of owl habitat or displace owls through 

disturbances (e.g., creation of a permanent structure including but not limited to well pads, roads, pipelines, and electrical 

powerlines). 
Appendix 9 Proposed RMP and Final EIS 

A9-4 Kanab RMP 

o If action will occur during a breeding season, survey for owls prior to 

commencing activity. If owls are found, activity should be delayed until 

outside of the breeding season. 

o Eliminate access routes created by a project through such means as raking 

out scars, revegetation, and gating access points. 

• For all permanent actions that may impact owls or suitable habitat: 

o Survey two consecutive years for owls according to established protocol 

prior to commencing activity. 

a. If owls are found, no actions will occur within 1⁄2 mile of identified nest 

site. If nest site is unknown, no activity will occur within the designated 

PACs. 

b. Avoid placing permanent structures within 1⁄2 mile of suitable habitat 

unless surveyed and not occupied. 

c. Reduce noise emissions (e.g., use hospital-grade mufflers) to 45 dBA at 

1⁄2 mile from suitable habitat, including canyon rims (Delaney et al. 

1997). Placement of permanent noise-generating facilities should be 

determined by a noise analysis to ensure noise does not encroach upon a 

1⁄2-mile buffer for suitable habitat, including canyon rims. 

d. Limit disturbances to and within suitable owl habitat by staying on 

designated routes. 

e. Limit new access routes created by the project. 

2. The BLM will, as a condition of approval (COA) on any project proposed within identified PACs 

and designated critical habitat or within spatial buffers for MSO nests (1⁄2 mile), ensure that 

project proponents are notified as to their responsibilities for rehabilitation of temporary access 

routes and other temporary surface disturbances created by their project according to individual 

BLM field office standards and procedures or those determined in the project-specific Section 7 

consultation. 

3. The BLM will require monitoring of activities in designated critical habitat, identified PACs, or 

breeding habitats wherein it has been determined that there is a potential for take. If any adverse 

impacts are observed to occur in a manner or to an extent that was not considered in the projectspecific Section 7 consultation, then consultation must be reinitiated: 

– Monitoring results should document what, if any, impacts on individuals or habitat occur 

during project construction/implementation. In addition, monitoring should document 

successes or failures of any impact minimization or mitigation measures. Monitoring results 

would be considered an opportunity for adaptive management, and as such would be carried 

forward in the design and implementation of future projects. 

4. For all survey and monitoring actions: 

– Provide reports to the affected field offices within 15 days of completion of survey or 

monitoring efforts. 

– Report any detection of MSO during survey or monitoring activities to the authorized officer 

within 48 hours. 

5. The BLM will, in areas of designated critical habitat, ensure that any physical or biological 

factors (i.e., the primary constituent elements), as identified in determining and designating such 

habitat, remain intact during implementation of any BLM-authorized activity. 

6. For all BLM actions that “may adversely affect” the primary constituent elements in any suitable 

MSO habitat, the BLM will implement measures as appropriate to minimize habitat loss or 

fragmentation, including rehabilitation of access routes created by the project through such means 

as raking out scars, revegetation, and gating access points. 

7. Where technically and economically feasible, use directional drilling from single drilling pads to 

reduce surface disturbance, and minimize or eliminate need to drill in canyon habitats suitable for 

MSO nesting. 
Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-5 

8. Prior to surface disturbing activities in MSO PACs, breeding habitats, or designated critical 

habitat, specific principles should be considered to control erosion. These principles include: 

– Conduct long-range transportation planning for large areas to ensure that roads will serve 

future needs. This will result in less total surface disturbance. 

– Avoid surface disturbance in areas with high erosion hazards to the extent possible. Avoid 

mid-slope locations, headwalls at the source of tributary drainages, inner valley gorges, and 

excessively wet slopes such as those near springs. In addition, areas where large cuts and fills 

would be required should be avoided. 

– Locate roads to minimize roadway drainage areas and to avoid modifying the natural 

drainage areas of small streams. 

9. Project developments should be designed and located to avoid direct or indirect loss or 

modification of MSO nesting and/or identified roosting habitats. 

10. Water production associated with BLM-authorized actions should be managed to ensure 

maintenance or enhancement of riparian habitats. 

Utah Prairie Dog (Cynomys parvidens) 

The following list of measures provides species-specific guidance intended to avoid, minimize, or reduce 

potential adverse impacts from implementation of BLM actions under the authority of current Utah BLM 

LUPs on the Utah prairie dog. This list is not comprehensive. Additional conservation measures or other 

modified versions of these measures may be applied for any given BLM-authorized activity upon further 

analysis, review, coordination efforts, and/or appropriate levels of Section 7 consultation with the 

USFWS: 

1. Surveys according to approved protocols and procedures will be required prior to surface 

disturbance unless species occupancy and distribution information is complete, current, and 

available. Surveys would be conducted by BLM-approved biologists. In the event species 

occurrence is verified, the project proponent may be required to modify operational plans, at the 

discretion of the authorized officer, to include additional, appropriate protection measures or 

practices for the minimization of impacts on the Utah prairie dog and its habitat. 

2. The BLM will restrict surface disturbing activities within 1⁄2 mile of active Utah prairie dog 

colonies when and where necessary, upon the recommendation of BLM Field Office (FO) staff 

biologists to BLM management and as necessary in coordination or consultation with USFWS. 

3. No permanent surface disturbance or facility will be allowed within 1⁄2 mile of potentially suitable 

Utah prairie dog habitat, as identified and mapped by the BLM or UDWR since 1976. 

4. Unavoidable surface disturbing activities in Utah prairie dog habitat should be conducted between 

April 1 and September 30 (the period when prairie dogs are most likely to be found above 

ground). BLM projects will be designed to avoid direct disturbance to Utah prairie dog 

populations and habitat wherever possible. Designs should consider flow of water, slope, buffers, 

possible fencing, and pre-activity flagging of critical areas for avoidance. 

5. Reclamation and restoration efforts in Utah prairie dog habitat will be conducted using native 

seed unless otherwise specified in coordination with USFWS. 

6. As funding allows, the BLM should complete a comprehensive assessment locating and mapping 

off-highway vehicle (OHV) use areas that interface with Utah prairie dog populations. 

Comparison of geographic information system (GIS) layers for Utah prairie dog populations and 

OHV use should give BLM personnel another tool to manage and/or minimize impacts from 

OHV use near known Utah prairie dog populations and habitat. Based on the information that is 

developed via GIS applications, appropriate actions should be taken to prevent OHV use in 

occupied territories. 

7. The BLM will consider emergency OHV closure or additional restrictions to protect, conserve, 

and recover the species. 
Appendix 9 Proposed RMP and Final EIS 

A9-6 Kanab RMP 

8. Where technically and economically feasible, the use of directional drilling or drilling of multiple 

wells from a single pad will be required to reduce surface disturbance in Utah prairie dog habitat.

9. For existing facilities, BLM and facility operators will consider if fencing infrastructure on well 

pads (e.g., drill pads, tank batteries, and compressors) would be needed to protect equipment from 

burrowing activities. In addition, BLM and project proponents should consider if future surface 

disturbing activities would be required at the site. 

10. The BLM will provide educational information for project proponents and the general public 

pertaining to appropriate vehicle speeds and the associated benefit of reduced vehicle collisions 

with wildlife, and to improve general ecological awareness of habitat disturbance. 

11. Project-related vehicle maintenance activities will be conducted in maintenance facilities. Should 

it become necessary to perform vehicle or equipment maintenance on site, these activities will not 

be conducted on identified Utah prairie dog colonies or within a 350-foot distance from colonies. 

Precautions shall be taken to ensure that contamination of maintenance sites by fuels, motor oils, 

grease, etc. does not occur and such materials are contained and properly disposed of off site. 

Inadvertent spills of petroleum-based or other toxic materials shall be cleaned up and removed 

immediately. 

12. The BLM will coordinate with interested private and governmental agencies and landowners to 

identify voluntary opportunities to modify current land stewardship practices that may have 

detrimental impacts on the Utah prairie dog and its habitat. 

13. BLM-authorized equipment and vehicles planned for use within Utah prairie dog habitat will be 

cleaned to minimize the spread of noxious weeds or other undesirable vegetation types. 

Southwestern Willow Flycatcher (Empidonax trailii extimus) 

The following list of measures provides species-specific guidance intended to avoid, minimize, or reduce 

potential adverse impacts from implementation of BLM actions under the authority of current Utah BLM 

LUPs on the Southwestern willow flycatcher. This list is not comprehensive. Additional conservation 

measures or other modified versions of these measures may be applied for any given BLM-authorized 

activity upon further analysis, review, coordination efforts, and/or appropriate levels of Section 7 

consultation with the USFWS: 

1. Surveys will be required prior to operations that “may adversely affect” Southwestern willow 

flycatcher unless species occupancy data and distribution information is complete and available. 

Surveys will be conducted only by BLM-approved personnel. In the event species occurrence is 

verified, project proponents may be required to modify operational plans at the discretion of the 

authorized officer. Modifications may include appropriate measures for minimization of adverse 

effects on Southwestern willow flycatcher and habitat. 

2. The BLM will monitor and restrict, when and where necessary, authorized or casual use activities 

that “may adversely affect” Southwestern willow flycatcher, including but not limited to 

recreation, mining, and oil and gas activities. Monitoring results should be considered in the 

design and implementation of future projects. 

3. To monitor the impacts of BLM-authorized projects determined “likely to adversely affect”

Southwestern willow flycatcher, the BLM should prepare a short report describing progress, 

including success of implementation of all associated mitigation. Reports shall be submitted 

annually to the USFWS Utah Field Office by March 1 beginning 1 full year from date of 

implementation of the proposed action. The report shall list and describe the following items: 

– Any unforeseen adverse effects resulting from activities of each site-specific project (may 

also require reinitiation of formal consultation) 

– If and when any level of anticipated incidental take is approached (as allowed by separate 

Incidental Take Statements of site-specific Formal Section 7 consultation efforts) 
Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-7 

– If and when the level of anticipated take (as allowed by separate Incidental Take Statements 

from site-specific formal consultations) is exceeded 

– Results of annual, periodic monitoring that evaluates the effectiveness of the reasonable and 

prudent measures or terms and conditions of the site-specific consultation. 

4. The BLM should avoid granting activity permits or authorizing development actions in 

Southwestern willow flycatcher habitat. Unoccupied potential habitat should be protected in order 

to preserve them for future management actions associated with the recovery of the Southwestern 

willow flycatcher. 

5. The BLM will ensure that the project design incorporates measures to avoid direct disturbance to 

populations and suitable habitats where possible. At a minimum, project designs should include 

consideration of water flows, slope, seasonal and spatial buffers, possible fencing, and preactivity flagging of critical areas for avoidance. 

6. The BLM will continue to address illegal and unauthorized OHV use and activity upon BLMadministered lands. To protect, conserve, and recover the Southwestern willow flycatcher in areas 

of heavy unauthorized use, temporary closures or use restrictions beyond those which are already 

in place may be imposed. As funding allows, the BLM should complete a comprehensive 

assessment of all OHV use areas that interface with Southwestern willow flycatcher populations. 

Comparison of Southwestern willow flycatcher populations and OHV use areas using GIS would 

give BLM personnel another tool to manage and/or minimize impacts. 

7. All surface disturbing activities should be restricted within a 1⁄4 mile buffer from suitable riparian 

habitats, and permanent surface disturbances should be avoided within 1⁄2 mile of suitable 

Southwestern willow flycatcher habitat: 

– Unavoidable ground disturbing activities in occupied Southwestern willow flycatcher habitat 

should be conducted only when preceded by current year survey, should only occur between 

August 16 and April 30 (the period when Southwestern willow flycatchers are not likely to be 

breeding), and should be monitored to ensure that adverse impacts on Southwestern willow 

flycatcher are minimized or avoided and to document the success of project-specific 

mitigation/protection measures. As monitoring is relatively undefined, project-specific 

requirements must be identified. 

8. The BLM will properly consider nesting periods for Southwestern willow flycatcher when 

conducting horse-gathering operations in the vicinity of habitat. 

9. The BLM will ensure that plans for water extraction and disposal are designed to avoid changes 

in the hydrologic regime that would be likely to result in loss or undue degradation of riparian 

habitat. 

10. Native species will be preferred over non-native for revegetation of habitat in disturbed areas. 

11. The BLM will coordinate with other agencies and private landowners to identify voluntary 

opportunities to modify current land stewardship practices that may impact the Southwestern 

willow flycatcher and its habitats. 

12. Limit disturbances to within suitable habitat by staying on designated routes. 

13. Ground disturbing activities will require monitoring throughout the duration of the project to 

ensure that adverse impacts on Southwestern willow flycatcher are avoided. Monitoring results 

should document what if any impacts on individuals or habitat occur during project 

construction/implementation. In addition, monitoring should document the successes or failures 

of any impact minimization or mitigation measures. Monitoring results would be considered an 

opportunity for adaptive management and as such would be carried forward in the design and 

implementation of future projects. 

14. Where technically and economically feasible, use directional drilling or multiple wells from the 

same pad to reduce surface disturbance and eliminate drilling in Southwestern willow flycatcher 

habitat. 
Appendix 9 Proposed RMP and Final EIS 

A9-8 Kanab RMP 

15. Habitat disturbances (e.g., organized recreational activities requiring special use permits or 

drilling activities) will be avoided within 1⁄4 mile of suitable Southwestern willow flycatcher 

habitat from May 1 to August 15. 

16. Grazing allotments that contain habitat for the species will be managed with consideration for 

recommendations provided by the Southwestern Willow Flycatcher Recovery Plan and other 

applicable research. 

OIL AND GAS LEASE NOTICES FOR SPECIAL STATUS SPECIES HABITAT

The BLM recognizes that nondiscretionary statutes such as the ESA may require conditions of approval 

that affect lease economics or even require disapproval of certain operations. Instruction Memorandum 

(IM) 2002-174 directs all BLM State Offices to “include the [following] lease stipulation on oil and gas 

leases where threatened, endangered, or other special status species or critical habitat is known or strongly 

suspected.” Management actions in Chapter 2 include actions that would implement the following 

language: 

The lease area may now or hereafter contain plants, animals, or their habitats 

determined to be threatened, endangered, or other special status species. BLM may 

recommend modifications to exploration and development proposals to further its 

conservation and management objective to avoid BLM-approved activity that will 

contribute to a need to list such a species or their habitat. BLM may require 

modifications to or disapprove proposed activity that is likely to result in jeopardy to the 

continued existence of a proposed or listed threatened or endangered species or result in 

the destruction or adverse modification of a designated or proposed critical habitat. BLM 

will not approve any ground disturbing activity that may affect any such species or 

critical habitat until it completes its obligations under applicable requirements of the 

Endangered Species Act as amended, 16 U.S.C. 1531 et seq., including completion of any 

required procedure for conference or consultation. 

IM 2002-174 also directs State Offices to “provide a separate notification to prospective lessees 

identifying the particular special status species that are present on the lease parcel offered. This 

information is to be provided through a lease notice and not by lease stipulation (unless otherwise 

provided in current LUPs). This stipulation would now be attached to most oil and gas leases issued by 

the Bureau, including areas identified in LUPs as open to standard lease terms and conditions.” 

Utah IM-UT-2005-089 identifies interim policy for ESA Section 7 consultation procedures for the 

issuance of oil and gas lease parcels that will help ensure that Utah BLM is in compliance with ESA 

consultation requirements for this program. In December 2004, the BLM and USFWS personnel 

completed work on a set of lease notices for specific listed species that are to be attached to oil and gas 

leases offered in the state. On December 13, 2004, Section 7 consultation was initiated with the 

submission of a memorandum to the USFWS containing the lease notices. USFWS responded with a 

memorandum dated December 16, 2004, concurring with the BLM determination that use of the speciesspecific lease notices on appropriate lease parcels “may affect,” but would be “not likely to adversely 

affect” listed species in the state. The following species-specific lease notice or notices should be 

attached, as appropriate, to any oil or gas lease that may contain a listed species or its habitat prior to the 

lease being offered for sale. 
Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-9 

Lease Notice—Bald Eagle 

The lessee/operator is given notice that the lands in this parcel contain nesting/winter roost habitat for the 

bald eagle, a federally listed species. Avoidance or use restrictions may be placed on portions of the lease. 

Application of appropriate measures will depend on whether the action is temporary or permanent and 

whether it occurs within or outside the bald eagle breeding or roosting season. A temporary action is 

completed prior to the following breeding or roosting season, leaving no permanent structures and 

resulting in no permanent habitat loss. A permanent action continues for more than one breeding or 

roosting season and/or causes a loss of eagle habitat or displaces eagles through disturbances (i.e., 

creation of a permanent structure). The following avoidance and minimization measures have been 

designed to ensure activities carried out on the lease are in compliance with the ESA. Integration of and 

adherence to these measures will facilitate review and analysis of any submitted permits under the 

authority of this lease. Adhering to these measures could reduce the scope of Section 7 consultation at the 

permit stage.

Current avoidance and minimization measures include the following: 

1. Surveys will be required prior to operations unless species occupancy and distribution 

information is complete and available. All surveys must be conducted by qualified individuals 

and according to protocol. 

2. Lease activities will require monitoring throughout the duration of the project. To ensure desired 

results are being achieved, minimization measures will be evaluated and, if necessary, Section 7 

consultation reinitiated. 

3. Water production will be managed to ensure maintenance or enhancement of riparian habitat. 

4. Temporary activities within 1 mile of nest sites will not occur during the breeding season of 

January 1 to August 31 unless the area has been surveyed according to protocol and determined to 

be unoccupied. 

5. Temporary activities within 1⁄2 mile of winter roost areas (e.g., cottonwood galleries) will not 

occur during the winter roost season of November 1 to March 31 unless the area has been 

surveyed according to protocol and determined to be unoccupied. 

6. No permanent infrastructure will be placed within 1 mile of nest sites. 

7. No permanent infrastructure will be placed within 1⁄2 mile of winter roost areas. 

8. Remove big game carrion to 100 feet from lease roadways occurring within bald eagle foraging 

range. 

9. Avoid loss of or disturbance to large cottonwood gallery riparian habitats. 

10. Where technically and economically feasible, use directional drilling or multiple wells from the 

same pad to reduce surface disturbance and eliminate drilling in suitable habitat. Use directional 

drilling to avoid direct impacts on large cottonwood gallery riparian habitats. Ensure that such 

directional drilling does not intercept or degrade alluvial aquifers. 

11. All areas of surface disturbance within riparian areas and/or adjacent uplands should be 

revegetated with native species. 

Additional measures may also be employed to avoid or minimize effects on the species between the lease 

sale stage and lease development stage. These additional measures will be developed and implemented in 

consultation with the USFWS to ensure continued compliance with the ESA. 

Lease Notice—Mexican Spotted Owl 

The lessee/operator is given notice that the lands in this lease contain suitable habitat for MSO, a federally 

listed species. Insert the following if the lease contains Designated Critical Habitat: [The 
Appendix 9 Proposed RMP and Final EIS 

A9-10 Kanab RMP 

Lessee/Operator is given notice that the lands in this lease contain Designated Critical Habitat for the 

Mexican spotted owl, a federally listed species. Critical habitat was designated for the Mexican spotted 

owl on August 31, 2004 (69 FR 53181-53298).] Avoidance or use restrictions may be placed on portions 

of the lease. Application of appropriate measures will depend on whether the action is temporary or 

permanent and whether it occurs within or outside the owl nesting season. A temporary action is 

completed prior to the following breeding season, leaving no permanent structures and resulting in no 

permanent habitat loss. A permanent action continues for more than one breeding season and/or causes a 

loss of owl habitat or displaces owls through disturbances (i.e., creation of a permanent structure). The 

following avoidance and minimization measures have been designed to ensure activities carried out on the 

lease are in compliance with the ESA. Integration of and adherence to these measures will facilitate 

review and analysis of any submitted permits under the authority of this lease. Adhering to these 

measures could reduce the scope of Section 7 consultation at the permit stage.

Current avoidance and minimization measures include the following: 

1. Surveys will be required prior to operations unless species occupancy and distribution 

information is complete and available. All surveys must be conducted by qualified individuals. 

2. Assess habitat suitability for nesting and foraging using accepted habitat models in conjunction 

with field reviews. Apply the conservation measures below if project activities occur within 1⁄2 

mile of suitable owl habitat. Determine potential effects of actions on owls and their habitat: 

a. Document type of activity, acreage and location of direct habitat impacts, and type and 

extent of indirect impacts relative to location of suitable owl habitat. 

b. Document if action is temporary or permanent. 

3. Lease activities will require monitoring throughout the duration of the project. To ensure desired 

results are being achieved, minimization measures will be evaluated and, if necessary, Section 7 

consultation reinitiated. 

4. Water production will be managed to ensure riparian habitat is maintained or enhanced. 

5. Where technically and economically feasible, use directional drilling or multiple wells from the 

same pad to reduce surface disturbance and eliminate drilling in canyon habitat suitable for MSO 

nesting. 

6. For all temporary actions that may impact owls or suitable habitat: 

a. If the action occurs entirely outside the owl breeding season (March 1 to August 31) and 

leaves no permanent structure or permanent habitat disturbance, action can proceed 

without an occupancy survey. 

b. If action will occur during a breeding season, survey for owls prior to commencing 

activity. If owls are found, activity must be delayed until outside of the breeding season. 

c. Rehabilitate access routes created by the project through such means as raking out scars, 

revegetation, and gating access points. 

7. For all permanent actions that may impact owls or suitable habitat: 

a. Survey two consecutive years for owls according to accepted protocol prior to 

commencing activities. 

b. If owls are found, no actions will occur within 1⁄2 mile of identified nest site. If nest site is 

unknown, no activity will occur within the designated PAC. 

c. Avoid drilling and permanent structures within 1⁄2 mile of suitable habitat unless surveyed 

and not occupied. 

d. Reduce noise emissions (e.g., use hospital-grade mufflers) to 45 dBA at 1⁄2 mile from 

suitable habitat, including canyon rims. Placement of permanent noise-generating 

facilities should be determined by a noise analysis to ensure noise does not encroach 

upon a 1⁄2-mile buffer for suitable habitat, including canyon rims. 

e. Limit disturbances to and within suitable habitat by staying on approved routes. 

f. Limit new access routes created by the project. 
Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-11 

Additional measures to avoid or minimize effects on the species may be developed and implemented in 

consultation with the USFWS between the lease sale stage and lease development stage to ensure 

continued compliance with the ESA. 

Lease Notice—California Condor 

The Lessee/Operator is given notice that the lands located in this parcel contain potential habitat for the 

California Condor, a federally listed species. Avoidance or use restrictions may be placed on portions of 

the lease if the area is known or suspected to be used by condors. Application of appropriate measures 

will depend on whether the action is temporary or permanent, and whether it occurs within or outside 

potential habitat. A temporary action is completed prior to the following important season of use, leaving 

no permanent structures and resulting in no permanent habitat loss. This would include consideration for 

habitat functionality. A permanent action continues for more than one season of habitat use, and/or causes 

a loss of condor habitat function or displaces condors through continued disturbance (i.e. creation of a 

permanent structure requiring repetitious maintenance, or emits disruptive levels of noise). 

The following avoidance and minimization measures have been designed to ensure activities carried out 

on the lease are in compliance with the Endangered Species Act. Integration of, and adherence to these 

measures will facilitate review and analysis of any submitted permits under the authority of this lease. 

Following these measures could reduce the scope of Endangered Species Act, Section 7 consultation at 

the permit stage.

Current avoidance and minimization measures include the following: 

1. Surveys will be required prior to operations unless species occupancy and distribution 

information is complete and available. All Surveys must be conducted by qualified individual(s) 

approved by the BLM, and must be conducted according to approved protocol. 

2. If surveys result in positive identification of condor use, all lease activities will require 

monitoring throughout the duration of the project to ensure desired results of applied mitigation 

and protection. Minimization measures will be evaluated during development and, if necessary, 

Section 7 consultation may be reinitiated. 

3. Temporary activities within 1.0 mile of nest sites will not occur during the breeding season. 

4. Temporary activities within 0.5 miles of established roosting sites or areas will not occur during 

the season of use, August 1 to November 31, unless the area has been surveyed according to 

protocol and determined to be unoccupied. 

5. No permanent infrastructure will be placed within 1.0 mile of nest sites. 

6. No permanent infrastructure will be placed within 0.5 miles of established roosting sites or areas. 

7. Remove big game carrion to 100 feet from on lease roadways occurring within foraging range. 

8. Where technically and economically feasible, use directional drilling or multiple wells from the 

same pad to reduce surface disturbance and eliminate drilling in suitable habitat Utilize 

directional drilling to avoid direct impacts to large cottonwood gallery riparian habitats. Ensure 

that such directional drilling does not intercept or degrade alluvial aquifers. 

9. Reinitiation of Section 7 consultation with the Service will be sought immediately if mortality or 

disturbance to California condors is anticipated as a result of project activities. Additional sitespecific measures may also be employed to avoid or minimize effects to the species. These 

additional measures will be developed and implemented in consultation with the U.S. Fish and 

Wildlife Service to ensure continued compliance with the ESA. 

Additional measures may also be employed to avoid or minimize effects to the species between the lease 

sale and lease development stages. These additional measures will be developed and implemented in 
Appendix 9 Proposed RMP and Final EIS 

A9-12 Kanab RMP 

consultation with the U.S. Fish and Wildlife Service to ensure continued compliance with the Endangered 

Species Act. 

Lease Notice—Utah Prairie Dog 

The lessee/operator is given notice that lands in this lease may contain historic and/or occupied Utah 

prairie dog habitat, a threatened species under the ESA. Avoidance or use restrictions may be placed on 

portions of the lease. Application of appropriate measures will depend on whether the action is temporary 

or permanent and whether it occurs when prairie dogs are active or hibernating. A temporary action is 

completed prior to the following active season, leaving no permanent structures and resulting in no 

permanent habitat loss. A permanent action continues for more than one activity/hibernation season 

and/or causes a loss of Utah prairie dog habitat or displaces prairie dogs through disturbances (i.e., 

creation of a permanent structure). The following avoidance and minimization measures have been 

designed to ensure activities carried out on the lease are in compliance with the ESA. Integration of and 

adherence to these measures will facilitate review and analysis of any submitted permits under the 

authority of this lease. Adhering to these measures could reduce the scope of Section 7 consultation at the 

permit stage.

Current avoidance and minimization measures include the following: 

1. Surveys will be required prior to operations unless species occupancy and distribution 

information is complete and available. All surveys must be conducted by qualified individuals. 

2. Lease activities will require monitoring throughout the duration of the project. To ensure desired 

results are being achieved, minimization measures will be evaluated and, if necessary, Section 7 

consultation reinitiated. 

3. Where technically and economically feasible, use directional drilling or multiple wells from the 

same pad to reduce surface disturbance and eliminate drilling in prairie dog habitat. 

4. Surface occupancy or other surface disturbing activity will be avoided within 1⁄2 mile of active 

prairie dog colonies. 

5. Permanent surface disturbance or facilities will be avoided within 1⁄2 mile of potentially suitable, 

unoccupied prairie dog habitat, identified and mapped by UDWR since 1976. 

6. The lessee/operator should consider if fencing infrastructure on the well pad (e.g., drill pads, tank 

batteries, and compressors) would be needed to protect equipment from burrowing activities. The 

operator should also consider if future surface disturbing activities would be required at the site. 

7. Within occupied habitat, set a 25-mph speed limit on operator-created and -maintained roads. 

8. Limit disturbances to and within suitable habitat by staying on designated routes. 

9. Limit new access routes created by the project. 

Additional measures to avoid or minimize effects on the species may be developed and implemented in 

consultation with the USFWS between the lease sale stage and lease development stage to ensure 

continued compliance with the ESA.

Lease Notice—Southwestern Willow Flycatcher 

The lessee/operator is given notice that the lands in this parcel contain riparian habitat that falls within the 

range for Southwestern willow flycatcher, a federally listed species. Avoidance or use restrictions may be 

placed on portions of the lease. Application of appropriate measures will depend on whether the action is 

temporary or permanent, and whether it occurs within or outside the nesting season. A temporary action is 

completed prior to the following breeding season, leaving no permanent structures and resulting in no 

permanent habitat loss. A permanent action continues for more than one breeding season and/or causes a 

loss of habitat or displaces flycatchers through disturbances (e.g., creation of a permanent structure). The 
Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-13 

following avoidance and minimization measures have been designed to ensure activities carried out on the 

lease are in compliance with the ESA. Integration of and adherence to these measures will facilitate 

review and analysis of any submitted permits under the authority of this lease. Adhering to these 

measures could reduce the scope of Section 7 consultation at the permit stage. 

Current avoidance and minimization measures include the following: 

1. Surveys will be required prior to operations unless species occupancy and distribution 

information is complete and available. All surveys must be conducted by qualified individuals 

and according to protocol. 

2. Lease activities will require monitoring throughout the duration of the project. To ensure desired 

results are being achieved, minimization measures will be evaluated and, if necessary, Section 7 

consultation reinitiated. 

3. Water production will be managed to ensure maintenance or enhancement of riparian habitat. 

4. Where technically and economically feasible, use directional drilling or multiple wells from the 

same pad to reduce surface disturbance and eliminate drilling in suitable riparian habitat. Ensure 

that such directional drilling does not intercept or degrade alluvial aquifers. 

5. Drilling activities will maintain a 300-foot buffer from suitable riparian habitat year long. 

6. Drilling activities within 1⁄4 mile of occupied breeding habitat will not occur during the breeding 

season of May 1 to August 15. 

7. Ensure that water extraction or disposal practices do not result in change of hydrologic regime 

that would result in loss or degradation of riparian habitat. 

8. Revegetate with native species all areas of surface disturbance within riparian areas and/or 

adjacent uplands. 

Additional measures to avoid or minimize effects on the species may be developed and implemented in 

consultation with the USFWS between the lease sale stage and lease development stage to ensure 

continued compliance with the ESA. 

Lease Notice—Listed Plant Species 

The lessee/operator is given notice that the lands in this parcel contain suitable habitat for federally listed 

plant species under the ESA. The following avoidance and minimization measures have been developed 

to facilitate review and analysis of any submitted permits under the authority of this lease: 

1. Site inventories: 

a. Must be conducted to determine habitat suitability. 

b. Are required in known or potential habitat for all areas proposed for surface disturbance 

prior to initiation of project activities, at a time when the plant can be detected, and 

during appropriate flowering periods. 

c. Documentation should include but not be limited to individual plant locations and 

suitable habitat distributions. 

d. All surveys must be conducted by qualified individuals. 

2. Lease activities will require monitoring throughout the duration of the project. To ensure desired 

results are being achieved, minimization measures will be evaluated and, if necessary, Section 7 

consultation reinitiated. 

3. Project activities must be designed to avoid direct disturbance to populations and to individual 

plants: 

a. Designs will avoid concentrating water flows or sediments into plant occupied habitat. 
Appendix 9 Proposed RMP and Final EIS 

A9-14 Kanab RMP 

b. Construction will occur down-slope of plants and populations where feasible; if well pads 

and roads must be sited up-slope, buffers of 100 feet minimum between surface 

disturbances and plants and populations will be incorporated. 

c. Where populations occur within 200 feet of well pads, establish a buffer or fence the 

individuals or groups of individuals during and post-construction. 

d. Areas for avoidance will be visually identifiable in the field (e.g., flagging, temporary 

fencing, or rebar). 

e. For surface pipelines, use a 10-foot buffer from any plant locations: 

i. If on a slope, use stabilizing construction techniques to ensure the pipelines do 

not move toward the population. 

4. For riparian/wetland-associated species (e.g., Ute ladies-tresses), avoid loss or disturbance of 

riparian habitats: 

a. Ensure that water extraction or disposal practices do not result in change of hydrologic 

regime. 

5. Limit disturbances to and within suitable habitat by staying on designated routes. 

6. Limit new access routes created by the project. 

7. Place signing to limit all-terrain vehicle (ATV) travel in sensitive areas. 

8. Implement dust abatement practices near occupied plant habitat. 

9. All disturbed areas will be revegetated with native species composed of species indigenous to the 

area. 

10. Post-construction monitoring for invasive species will be required. 

11. Where technically and economically feasible, use directional drilling or multiple wells from the 

same pad to reduce surface disturbance and eliminate drilling in plant habitat. Ensure that such 

directional drilling does not intercept or degrade alluvial aquifers. 

12. Lease activities will require monitoring throughout the duration of the project. To ensure desired 

results are being achieved, minimization measures will be evaluated and, if necessary, Section 7 

consultation reinitiated. 

Additional measures to avoid or minimize effects on the species may be developed and implemented in 

consultation with the USFWS between the lease sale stage and lease development stage to ensure 

continued compliance with the ESA. 

Lease Notice—Welsh’s Milkweed 

In order to minimize effects to the federally threatened Welsh’s milkweed, the Bureau of Land 

Management (BLM), in coordination with the U.S. Fish and Wildlife Service (Service), has developed the 

following avoidance and minimization measures. Implementation of these measures will help ensure the 

activities carried out during oil and gas development (including but not limited to drilling, production, and 

maintenance operations) are in compliance with the Endangered Species Act (ESA). For the purposes of 

this document, the follow terms are so defined: 

• Potential habitat is defined as areas which satisfy the broad criteria of the species habitat 

description; usually determined by preliminary, in-house assessment. 

• Suitable habitat is defined as areas which contain or exhibit the specific components or constituents 

necessary for plant persistence; determined by field inspection and/or surveys; may or may not 

contain clay reed-mustard; habitat descriptions can be found in Federal Register Notice and species 

recovery plan links at http://www.fws.gov/endangered/wildlife.html. 

• Occupied habitat is defined as areas currently or historically known to support clay reed-mustard; 

synonymous with “known habitat.” 

The following avoidance and minimization measures should be included in the Plan of Development: 
Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-15 

1. Pre-project habitat assessments will be completed across 100% of the project disturbance area 

within potential habitat prior to any ground disturbing activities to determine if suitable Welsh’s 

milkweed habitat is present. 

2. Within suitable habitat, site inventories will be conducted to determine occupancy. Where 

standard surveys are technically infeasible and otherwise hazardous due to topography, slope, 

etc., suitable habitat will be assessed and mapped for avoidance (hereafter, “avoidance areas”); in 

such cases, in general, 300’ buffers will be maintained between surface disturbance and 

avoidance areas. However, site specific distances will need to be approved by FWS and BLM 

when disturbance will occur upslope of habitat. Inventories: 

a. Must be conducted by qualified individual(s) approved by BLM using accepted survey 

protocols, 

b. Will be conducted in suitable and occupied habitat for all areas proposed for surface 

disturbance prior to initiation of project activities and within the same growing season, at 

a time when the plant can be detected and during appropriate flowering periods. 

Inventories should be conducted between June 1st and August 15th, however, surveyors 

should verify that the plant is flowering by contacting a BLM or FWS botanist or 

demonstrating that the nearest known population is in flower ), 

c. Will occur within 300’ from the centerline of the proposed right-of-way for surface 

pipelines or roads; and within 300’ from the perimeter of disturbance for the proposed 

well pad including the well pad, 

d. Will include, but not be limited to, plant species lists and habitat characteristics, and is 

there more? 

3. Design project infrastructure to minimize impacts within suitable habitat: 

a. Where standard surveys are technically infeasible, infrastructure and activities will avoid 

all suitable habitat (avoidance areas) and incorporate 300’ buffers, in general; however, 

site specific distances will need to be approved by FWS and BLM when disturbance will 

occur upslope of habitat, 

b. Reduce well pad size to the minimum needed, without compromising safety, 

c. Where technically and economically feasible, use directional drilling or multiple wells 

from the same pad, 

d. Limit new access routes created by the project, 

e. Roads and utilities should share common right-of-ways where possible, 

f. Reduce the width of right-of-ways and minimize the depth of excavation needed for the 

road bed; where feasible, use the natural ground surface for the road within habitat, 

g. Place signing to limit off-road travel in sensitive areas, and 

h. Stay on designated routes and other cleared/approved areas. 

i. All disturbed areas will be revegetated with native species comprised of species 

indigenous to the area and non-native species that are not likely to invade other areas. 

4. Within occupied habitat, project infrastructure will be designed to avoid direct disturbance and 

minimize indirect impacts to populations and to individual plants: 

a. Follow the above recommendations (#3) for project design within suitable habitats, 

b. To avoid water flow and/or sedimentation into occupied habitat and avoidance areas, silt 

fences, hay bales, and similar structures or practices will be incorporated into the project 

design; appropriate placement of fill is encouraged, 

c. Construction of roads will occur such that the edge of the right of way is at least 300’ 

from any plant and 300’ from avoidance areas, 

d. Roads will be graveled within occupied habitat; the operator is encouraged to apply water 

for dust abatement to such areas from June 1st to August 15th (flowering period); dust 

abatement applications will be comprised of water only, 
Appendix 9 Proposed RMP and Final EIS 

A9-16 Kanab RMP 

e. The edge of the well pad should be located at least 300’ away from plants and avoidance 

areas, in general; however, site specific distances will need to be approved by FWS and 

BLM when disturbance will occur upslope of habitat, 

f. Surface pipelines will be laid such that a 300’ buffer exists between the edge of the right 

of way and plants and 300’ between the edge of right of way and avoidance areas; use 

stabilizing and anchoring techniques when the pipeline crosses suitable habitat to ensure 

pipelines don’t move towards the population; site specific distances will need to be 

approved by FWS and BLM when disturbance will occur upslope of habitat, 

g. Construction activities will not occur from June 1st through August 15th within occupied 

habitat, 

h. Before and during construction, areas for avoidance should be visually identifiable in the 

field, e.g., flagging, temporary fencing, rebar, etc., 

i. Place produced oil, water, or condensate tanks in centralized locations, away from 

occupied habitat, and 

j. Minimize the disturbed area of producing well locations through interim and final 

reclamation. Reclaim well pads following drilling to the smallest area possible. 

5. Occupied Welsh’s milkweed habitats within 300’ of the edge of the surface pipelines’ right-ofways, 300’ of the edge of the roads’ right-of-ways, and 300’ from the edge of the well pad shall 

be monitored for a period of three years after ground disturbing activities. Monitoring will 

include annual plant surveys to determine plant and habitat impacts relative to project facilities. 

Annual reports shall be provided to the BLM and the Service. To ensure desired results are being 

achieved, minimization measures will be evaluated and may be changed after a thorough review 

of the monitoring results and annual reports during annual meetings between the BLM and the 

Service. 

6. Reinitiation of section 7 consultation with the Service will be sought immediately if any loss of 

plants or occupied habitat for the Welsh’s milkweed is anticipated as a result of project activities. 

Additional site-specific measures may also be employed to avoid or minimize effects to the 

species. These additional measures will be developed and implemented in consultation with the 

U.S. Fish and Wildlife Service to ensure continued compliance with the ESA. 

Siler Pincushion Cactus 

In order to minimize effects to the federally threatened Siler pincushion cactus, the Bureau of Land 

Management (BLM), in coordination with the U.S. Fish and Wildlife Service (Service), has developed the 

following avoidance and minimization measures. Implementation of these measures will help ensure the 

activities carried out during oil and gas development (including but not limited to drilling, production, and 

maintenance operations) are in compliance with the Endangered Species Act (ESA). For the purposes of 

this document, the follow terms are so defined: 

• Potential habitat is defined as areas which satisfy the broad criteria of the species habitat 

description; usually determined by preliminary, in-house assessment. 

• Suitable habitat is defined as areas which contain or exhibit the specific components or constituents 

necessary for plant persistence; determined by field inspection and/or surveys; may or may not 

contain clay reed-mustard; habitat descriptions can be found in Federal Register Notice and species 

recovery plan links at http://www.fws.gov/endangered/wildlife.html. 

• Occupied habitat is defined as areas currently or historically known to support the Siler pincushion 

cactus; synonymous with “known habitat.” 

The following avoidance and minimization measures should be included in the Plan of Development: 
Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-17 

1. Pre-project habitat assessments will be completed across 100% of the project disturbance area 

within potential habitat prior to any ground disturbing activities to determine if suitable Siler 

pincushion cactus habitat is present. 

2. Within suitable habitat, site inventories will be conducted to determine occupancy. Where 

standard surveys are technically infeasible and otherwise hazardous due to topography, slope, 

etc., suitable habitat will be assessed and mapped for avoidance (hereafter, “avoidance areas”); in 

such cases, in general, 300’ buffers will be maintained between surface disturbance and 

avoidance areas. However, site specific distances will need to be approved by FWS and BLM 

when disturbance will occur upslope of habitat. Inventories: 

a. Must be conducted by qualified individual(s) approved by BLM using accepted survey 

protocols, 

i. Will be conducted in suitable and occupied habitat for all areas proposed for surface 

disturbance prior to initiation of project activities and within the same growing 

season, at a time when the plant can be detected and during appropriate flowering 

periods. Inventories should be conducted between Mrch 1st to May 15th, however, 

surveyors should verify that the plant is flowering by contacting a BLM or FWS 

botanist or demonstrating that the nearest known population is in flower, 

b. Will occur within 300’ from the centerline of the proposed right-of-way for surface 

pipelines or roads; and within 300’ from the perimeter of disturbance for the proposed 

well pad including the well pad, 

c. Will include, but not be limited to, plant species lists and habitat characteristics, and 

d. Will be valid until April 1st the following year. 

3. Design project infrastructure to minimize impacts within suitable habitat: 

a. Where standard surveys are technically infeasible, infrastructure and activities will avoid 

all suitable habitat (avoidance areas) and incorporate 300’ buffers, in general; however, 

site specific distances will need to be approved by FWS and BLM when disturbance will 

occur upslope of habitat, 

b. Reduce well pad size to the minimum needed, without compromising safety, 

c. Where technically and economically feasible, use directional drilling or multiple wells 

from the same pad, 

d. Limit new access routes created by the project, 

e. Roads and utilities should share common right-of-ways where possible, 

f. Reduce the width of right-of-ways and minimize the depth of excavation needed for the 

road bed; where feasible, use the natural ground surface for the road within habitat, 

g. Place signing to limit off-road travel in sensitive areas, and 

h. Stay on designated routes and other cleared/approved areas. 

i. All disturbed areas will be revegetated with native species comprised of species 

indigenous to the area and non-native species that are not likely to invade other areas. 

4. Within occupied habitat, project infrastructure will be designed to avoid direct disturbance and 

minimize indirect impacts to populations and to individual plants: 

a. Follow the above recommendations (#3) for project design within suitable habitats, 

b. To avoid water flow and/or sedimentation into occupied habitat and avoidance areas, silt 

fences, hay bales, and similar structures or practices will be incorporated into the project 

design; appropriate placement of fill is encouraged, 

c. Construction of roads will occur such that the edge of the right of way is at least 300’ 

from any plant and 300’ from avoidance areas, 

d. Roads will be graveled within occupied habitat; the operator is encouraged to apply water 

for dust abatement to such areas from April 1st to June 15th (flowering period); dust 

abatement applications will be comprised of water only, 
Appendix 9 Proposed RMP and Final EIS 

A9-18 Kanab RMP 

e. The edge of the well pad should be located at least 300’ away from plants and avoidance 

areas, in general; however, site specific distances will need to be approved by FWS and 

BLM when disturbance will occur upslope of habitat, 

f. Surface pipelines will be laid such that a 300’ buffer exists between the edge of the right 

of way and plants and 300’ between the edge of right of way and avoidance areas; use 

stabilizing and anchoring techniques when the pipeline crosses suitable habitat to ensure 

pipelines don’t move towards the population; site specific distances will need to be 

approved by FWS and BLM when disturbance will occur upslope of habitat, 

g. Construction activities will not occur from April 1st through June 15th within occupied 

habitat, 

h. Before and during construction, areas for avoidance should be visually identifiable in the 

field, e.g., flagging, temporary fencing, rebar, etc., 

i. Place produced oil, water, or condensate tanks in centralized locations, away from 

occupied habitat, and 

j. Minimize the disturbed area of producing well locations through interim and final 

reclamation. Reclaim well pads following drilling to the smallest area possible. 

5. Occupied Siler pincushion cactus habitats within 300’ of the edge of the surface pipelines’ rightof-ways, 300’ of the edge of the roads’ right-of-ways, and 300’ from the edge of the well pad 

shall be monitored for a period of three years after ground disturbing activities. Monitoring will 

include annual plant surveys to determine plant and habitat impacts relative to project facilities. 

Annual reports shall be provided to the BLM and the Service. To ensure desired results are being 

achieved, minimization measures will be evaluated and may be changed after a thorough review 

of the monitoring results and annual reports during annual meetings between the BLM and the 

Service. 

6. Reinitiation of section 7 consultation with the Service will be sought immediately if any loss of 

plants or occupied habitat for the Siler pincushion cactus is anticipated as a result of project 

activities. Additional site-specific measures may also be employed to avoid or minimize effects to 

the species. These additional measures will be developed and implemented in consultation. 

ENDANGERED SPECIES RECOVERY PLANS AND CONSERVATION AGREEMENTS

In addition to the conservation measures and lease notices discussed above, documents such as speciesspecific recovery plans and conservation strategies, agreements, and plans contain management plans and 

strategies to protect special status species. These documents are developed using the most current science, 

but as monitoring and current scientific findings provide further information, they are subject to revision, 

amendment, or update. As such, the list of documents applicable for the decision area could be increased 

or decreased based on species listing, condition, distribution, and so forth. Documents for species within 

the decision area include, but are not limited to, the following: 

• Mexican Spotted Owl Recovery Plan, 1995 

• Northern States Bald Eagle Recovery Plan, 1983 

• American Peregrine Falcon Recovery Plan, 1984 

• Utah Prairie Dog Recovery Plan, 1991 

• Utah Prairie Dog Interim Conservation Strategy, 1997 

• Welsh’s Milkweed Recovery Plan, 1992 

• Siler Pincushion Cactus Recovery Plan, 1986 

• Autumn Buttercup Recovery Plan, 1991 

• Northern Goshawk Conservation Agreement, 1998

• Conservation Agreement and Strategy for the Coral Pink Sand Dunes Tiger Beetle, 1997
Proposed RMP and Final EIS Appendix 9 

Kanab RMP A9-19 

• Range-Wide Conservation Agreement for Roundtail Chub, Bluehead Sucker, and Flannelmouth 

Sucker, 2004 

• Recovery Plan for the California Condor, 1996 

• Final Recovery Plan for the Southwestern Willow Flycatcher, 2002 

• Interim Conservation Plan for Ambersnails of the Southwestern United States (DRAFT), Year 

Unknown. 
Appendix 9 Proposed RMP and Final EIS 

A9-20 Kanab RMP 

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Proposed RMP and Final EIS Appendix 10 

Kanab RMP A10-1 

APPENDIX 10—UTAH PUBLIC LANDS STUDY: KEY 

SOCIAL SURVEY FINDINGS FOR GARFIELD AND 

KANE COUNTIES 

A statewide social survey was conducted by Utah State University in 2007 to assess the ways in which 

Utah residents use and value public land resources and to ascertain their views about public land 

management. Random samples of residential households were selected in each of the state’s 29 counties. 

Sampled households were contacted by mail, and a randomly selected adult from the household was 

asked to participate in the survey. Self-completion questionnaires were distributed to potential survey 

participants using a multiple-wave survey administration procedure. The discussion that follows is 

focused on key survey results obtained for Garfield County (n = 125 survey responses) and for Kane 

County (n = 132 survey responses). 

ECONOMIC LINKAGES TO PUBLIC LANDS

One major focus of the survey questionnaire involved assessment of the various ways in which Utahans 

may engage in economic activities that are linked directly or indirectly to public land resources in the 

state. 

Permit-Based Economic Activities 

As indicated in Table A10-1, only a minority of survey respondents in either Garfield or Kane counties 

reported that a portion of their household income is directly linked to activities that involve permitted uses 

of lands or resources administered by the U.S. Forest Service (USFS), the Bureau of Land Management 

(BLM), other federal agencies, or the State of Utah. The percentage of respondents indicating that some 

portion of their household income is derived from such permit-based activities was uniformly higher for 

each of the agency categories in Garfield County than was the case in Kane County. In Garfield County, a 

substantial minority of respondents indicated that a portion of their household income derives from 

permitted activities that occur on public lands administered by either USFS (22.4 percent) or BLM (20.0 

percent). 

Table A10-1. Percentage of Survey Respondents Reporting that a Portion of Household 

Income Is Directly Linked to Permitted Use of Public Lands or Resources 

Agency Garfield County Kane County 

USFS 22.4% 6.9% 

BLM 20.0% 12.9% 

Other federal agency 9.6% 5.3% 

State of Utah 11.2% 8.3% 

As indicated in Table A10-2, the percentage of respondents reporting these types of permit-based 

economic linkages to public lands who indicated that 25 percent or more of their total household income 

is derived from those activities was highest among Garfield County respondents who reported use of 

other federal agency and USFS lands, and highest among Kane County respondents who reported use of 

lands administered by BLM or by other federal agencies. 
Appendix 10 Proposed RMP and Final EIS 

A10-2 Kanab RMP 

Table A10-2. Percentage of Survey Respondents Reporting Permit-Based Economic 

Activities on Public Lands Who Indicated that 25 Percent or More of Their Household 

Income Is Derived from Those Activities 

Agency Garfield County Kane County 

USFS 42.9% 9.1% 

BLM 32.0% 29.4% 

Other federal agency 66.7% 28.6% 

State of Utah 21.4% 9.1% 

Household Participation in Selected Commercial Activities 

The next series of questions asked respondents to indicate whether they or members of their households 

participate in any of a number of commercial activities that, while commonly associated with public land 

use, can involve the use of either public or private lands. Results summarized in Table A10-3 indicate that 

for any of these activities only a minority of survey respondents in either Garfield County or Kane County 

reported participation. Among Garfield County respondents, the activities reported most frequently were 

livestock grazing and related work (23.4 percent of respondents) and commercial firewood cutting (19.4 

percent). In Kane County participation was reported most frequently for livestock grazing and related 

work (15.2 percent of respondents). In both counties it is clear that involvement in commercial activities 

that involve or are related to livestock grazing is more widespread than involvement in other resourcebased commercial activities. 

Table A10-3. Percentage of Survey Respondents Reporting that They or Members of Their 

Households Participate in Selected Resource-Based Commercial Activities, on Either 

Public or Private Lands 

Economic Activity Garfield County Kane County 

Livestock grazing and related work 23.4% 15.2% 

Commercial firewood cutting 19.4% 8.3% 

Logging, post and pole cutting, or 

other timber-related work 8.9% 7.6% 

Mining of coal, uranium, or other 

solid minerals 0.8% 3.8% 

Mining of sand, gravel, or other 

construction materials 2.4% 3.0% 

Oil and gas exploration and 

development 2.4% 1.5% 

Operating an outfitting or guiding 

business 5.7% 3.8% 

Film-making/commercial 

photography 0.8% 2.3% 

Other commercial activities 5.2% 4.8% 
Proposed RMP and Final EIS Appendix 10 

Kanab RMP A10-3 

Household Involvement in Businesses Linked to Recreation/Tourism 

Survey respondents were also asked whether they or any member of their household operates or works at 

a business linked to recreation or tourism activity that is influenced by the presence of public lands and 

resources. Four out of 10 respondents from Garfield County (40.3 percent) and more than one-fourth 

(27.3 percent) of Kane County respondents said “yes” to this question. When asked to assess how 

important activities and uses linked to public lands are to the success of this business, nearly two-thirds of 

respondents in both Garfield County (64.0 percent) and Kane County (63.9 percent) who reported 

involvement in such businesses said that the influence of public lands is “extremely important.” 

Household Involvement in Businesses Linked to Commodity 

Production 

A similar question asked about the involvement of survey participants and members of their households 

in businesses that provide services and supplies to farming or ranching operations, logging firms, or other 

commercial enterprises that use or process natural resources located on public lands. The percentage of 

respondents reporting participation by a household member in such businesses was similarly low in both 

Garfield County (13.8 percent) and in Kane County (14.4 percent). 

Ownership of Property or Assets with Values Influenced by Nearby 

Public Lands 

When asked whether they own land, buildings, or other assets that they believe have a monetary value 

that is significantly influenced by the presence and condition of nearby public lands, 54.9 percent of 

Garfield County respondents and 49.2 percent of Kane County respondents said “yes.” Those who did 

perceive the existence of such a relationship were then asked to identify specific types of assets that they 

own and that they believe have a value influenced by the close proximity of public lands. Respondents in 

both counties most frequently cited their residential property (38.4 percent in Garfield County, 35.6 

percent in Kane County). The only other types of asset identified by more than 10 percent of respondents 

in either county were undeveloped non-agricultural land (10.6 percent of respondents in Kane County) 

and agricultural land (24.8 percent of respondents in Garfield County). 

PERCEIVED IMPORTANCE OF PUBLIC LANDS FOR OVERALL QUALITY 

OF LIFE

Survey participants were also asked to report how important they think 15 types of public land resources 

and resource uses are for the overall quality of life experienced by people living in their communities. 

Table A10-4 summarizes response patterns to this series of questions for Garfield and Kane counties, with 

a focus on the percentage of respondents from each county who indicated that they consider a particular 

type of resource use to be “very important” for local quality of life. 

In Garfield County 4 of the 15 types of public land resource use presented in this question were 

considered “very important” by fewer than one-half of respondents (energy resource 
Appendix 10 Proposed RMP and Final EIS 

A10-4 Kanab RMP 

Table A10-4. Percentage of Survey Respondents Indicating that Selected Public Land 

Resource Uses Are “Very Important” to the Overall Quality of Life in Their Community 

Resource Use Garfield County Kane County 

Grazing of livestock on public lands 86.3% 65.1% 

Water resources used to irrigate 

crops and pastures 96.8% 79.2% 

Water resources used to supply 

homes and businesses 94.4% 91.6% 

Water resources that provide 

important fish/wildlife habitat 70.2% 68.3% 

Energy resources such as oil, gas, 

coal, or uranium 46.6% 60.3% 

Sand, gravel, or other minerals 

used in building and construction 

industries 

40.5% 55.6% 

Forested areas that provide timber 

used by logging operations and 

lumber mills 

71.8% 58.6% 

Areas where trees or other 

vegetation provide important wildlife 

habitat 

59.7% 61.2% 

Areas that attract tourism and 

recreational activity 75.4% 70.8% 

Opportunities to enjoy off-road 

vehicles, snowmobiling, or other 

motorized recreation 

51.2% 67.4% 

Opportunities to enjoy hiking, 

backpacking, cross-country skiing, 

horseback riding, or other types of 

non-motorized recreation 

64.5% 62.6% 

Opportunities to hunt for wild game 76.6% 56.8% 

Opportunities to fish in area lakes, 

streams, and rivers 77.4% 59.1% 

Undeveloped landscapes where 

motorized access and resource 

development are restricted 

26.7% 31.5% 

Areas managed to maintain 

biodiversity and protect habitat for 

sensitive or important plants or 

wildlife 

32.2% 32.3% 

development, sand/gravel or other construction-related mineral development, undeveloped landscapes 

where motorized access and resource development are restricted, and areas managed to maintain 

biodiversity and protect habitat). At the same time, more than three-fourths of Garfield County 

respondents considered grazing of livestock on public lands; water resources used to irrigate crops and 

pastures; water resources used to supply homes and businesses; areas that attract tourism and recreation 

activity; opportunities to hunt for wild game; and opportunities to fish in area lakes, rivers, and streams to 

be “very important” to the local quality of life. 
Proposed RMP and Final EIS Appendix 10 

Kanab RMP A10-5 

In Kane County only two of these resource uses were considered “very important” by fewer than one-half 

of respondents (undeveloped landscapes where motorized access and resource development are restricted 

and areas managed to maintain biodiversity and protect habitat). Conversely, two resource uses—water 

resources used to irrigate crops and pastures and water resources used to supply homes and businesses—

were considered “very important” to the local quality of life by more than three-fourths of Kane County 

respondents. 

RECREATIONAL USES OF PUBLIC LANDS

Survey participants were also asked to report whether they had participated in any of a broad range of 

outdoor recreation activities and other non-commodity use activities on Utah public lands during the prior 

12 months. Results from this series of questions are reported in Table A10-5 and Table A10-6. These 

findings clearly indicate that there is widespread participation in many of these public land activities 

among residents of both Garfield County and Kane County. 

Table A10-5 outlines the extent of reported participation in 30 outdoor recreation activities. Among 

survey participants living in Garfield County, more than one-half reported participation in camping, 

picnicking, day hiking, wildlife viewing, hunting, fishing, visiting historical sites, all-terrain vehicle 

(ATV) riding, and driving for pleasure/sightseeing on public lands during the preceding 12 months. In 

Kane County more than half of respondents reported that they had participated in camping, picnicking, 

day hiking, wildlife viewing, fishing, visiting historical sites, ATV riding, 4-wheel driving, and driving 

for pleasure/sightseeing. 

Responses to a question focusing on participation in a variety of non-commodity use activities on public 

lands are summarized in Table A10-6. Among this list of activities, Garfield County respondents were 

most likely to report that they participate in collection of firewood for home use, cutting Christmas trees, 

gathering pinyon nuts, and collecting rocks for home landscaping. In Kane County, respondents most 

frequently reported that they collect firewood for home use; collect rocks for home landscaping; collect 

fossils, rocks, or minerals; and cut Christmas trees on public lands. 

Respondents were also asked to identify the one or two activities from the lists presented in these 

questions that they participate in most often, and to provide detail on where they engage in those 

activities. Among Garfield County respondents the first of these activities listed by respondents most 

often involved hunting (16.4 percent of responses) or fishing (14.5 percent). In Kane County the first 

listed activity most often involved either ATV riding (16.4 percent of responses) or day hiking (15.6 

percent). When asked to indicate where they participate in the first-listed of their “most frequently 

pursued” activities, 84.7 percent of Garfield County respondents and 85.2 percent of Kane County 

residents identified a location within the county where they live. 

Table A10-5. Percentage of Survey Respondents Reporting Participation in Selected 

Recreation Activities on Utah Public Lands During the Past 12 Months 

Activity Garfield County Kane County 

Camping 64.7% 59.2% 

Picnicking 72.9% 70.6% 

Backpacking 22.6% 18.2% 

Day hiking 59.1% 65.3% 

Bird watching 33.9% 31.7% 
Appendix 10 Proposed RMP and Final EIS 

A10-6 Kanab RMP 

Activity Garfield County Kane County 

Wildlife viewing 75.0% 69.9% 

Nature photography 35.1% 45.9% 

Canoeing/kayaking 3.8% 5.9% 

River rafting 3.8% 9.3% 

Motor boating 20.4% 29.2% 

Jet skiing 5.8% 6.7% 

Swimming 30.8% 29.3% 

Rock climbing 13.2% 22.5% 

Mountain climbing 11.4% 17.6% 

Hang gliding 0.0% 0.0% 

Mountain bike riding 13.2% 12.4% 

Hunting 56.4% 39.5% 

Fishing 67.5% 51.2% 

Horseback riding 40.5% 25.6% 

Orienteering/geo-caching 7.8% 12.5% 

Rock hounding 24.3% 33.1% 

Visiting historical sites 60.7% 72.0% 

Resort skiing/snowboarding 14.2% 11.9% 

Backcountry skiing/snowboarding 3.8% 1.7% 

Snowshoeing 4.8% 1.7% 

Snowmobiling 9.5% 6.8% 

ATV riding 58.1% 54.8% 

Dirt bike riding 10.7% 8.5% 

4-wheel driving/jeeping 40.0% 59.7% 

Sightseeing/pleasure driving 80.0% 90.6% 

Table A10-6. Percentage of Survey Respondents Reporting Participation in Selected NonCommodity Use Activities on Utah Public Lands During the Past 12 Months 

Activity Garfield County Kane County 

Collecting firewood for 

home use 56.1% 47.3%

Cutting Christmas trees 46.2% 27.2%

Collecting material for craft 

projects 24.5% 22.0%

Collecting rocks for home 

landscaping 30.4% 36.2%

Collecting plants for home 

landscaping 17.3% 14.3%
Proposed RMP and Final EIS Appendix 10 

Kanab RMP A10-7 

Activity Garfield County Kane County 

Gathering wild mushrooms 1.9% 1.6%

Gathering pinyon nuts 38.6% 23.0%

Gathering berries, herbs, or 

wild foods 19.1% 4.8%

Collecting fossils, rocks, or 

minerals 23.4% 32.3%

ATTITUDES AND PREFERENCES REGARDING PUBLIC LAND 

MANAGEMENT

Two similar sets of survey questions focused on respondents’ attitudes and preferences regarding the 

extent to which various natural resource use activities or management practices should be reduced or 

increased by those responsible for managing public lands in Utah. Response patterns to these questions 

are summarized in Table A10-7 and Table A10-8. 

The data presented in Table A10-7 indicates that Garfield County respondents were considerably more 

likely to prefer an increase rather than a decrease in mineral exploration and extraction, timber harvest, 

exploration for and development of oil and gas resources, protection of fish and wildlife habitat, thinning 

of forested areas to reduce wildfire risk, livestock grazing, and development of water storage and delivery 

systems on Utah public lands. They were also more likely to prefer a reduction in designation of 

wilderness areas and in protection of endangered species. Kane County respondents were more likely to 

prefer an increase rather than a decrease in mineral exploration/extraction, timber harvest, oil and gas 

development, protection of fish and wildlife habitat, thinning of forested areas to reduce wildfire risk, 

livestock grazing, and development of water storage and delivery systems. They also expressed a 

preference for a reduction in the designation of wilderness areas, and were more likely to prefer a 

reduction as opposed to an increase in protection of endangered species. 

Results summarized in Table A10-8 indicate that Garfield County respondents were more likely to prefer 

an increase rather than a reduction in provision of road access to recreation areas, provision of hunting 

opportunities, development of trails for off-highway motorized recreation, development of trails for nonmotorized recreation, regulations that restrict motorized vehicles to designated trails, and development of 

visitor facilities to increase tourism. In Kane County, respondents were far more likely to prefer an 

increase rather than a decrease in provision of road access to recreation areas, provision of hunting 

opportunities, development of trails for off-highway motorized recreation, development of trails for nonmotorized recreation, regulations that would restrict motorized vehicles to designated trails, and 

development of visitor facilities to increase tourism. 

Table A10-7. Survey Respondents’ Attitudes Regarding the Extent to Which Various 

Activities Occurring on Utah Public Land Should Be Reduced or Increaseda

Type of Garfield County Kane County 

Use/Activity Reduce Increase Reduce Increase 

Mineral 

exploration/extraction 11.9% 63.5% 14.4% 62.4%

Timber harvest 5.8% 73.6% 12.8% 71.2%
Appendix 10 Proposed RMP and Final EIS 

A10-8 Kanab RMP 

Type of Garfield County Kane County 

Use/Activity Reduce Increase Reduce Increase 

Designation of 

wilderness areas 66.7% 14.2% 52.7% 16.3%

Exploration 

for/development of 

oil and gas resources 

9.2% 70.6% 16.0% 60.0%

Protection of 

important fish and 

wildlife habitat 

13.1% 36.9% 13.2% 41.9%

Protection of 

endangered species 50.4% 20.5% 41.5% 24.4%

Use of controlled 

burns to improve 

ecological conditions 

42.9% 25.2% 42.3% 24.4%

Thinning of forested 

areas to reduce 

wildfire risk 

8.3% 70.0% 6.3% 69.1%

Livestock grazing 7.4% 52.1% 18.7% 44.7%

Designation of wild 

and scenic rivers 38.8% 20.7% 34.5% 23.6%

Developing water 

storage and delivery 

systems to meet 

needs of nearby 

communities 

3.3% 84.3% 1.6% 84.0%

a. Original response categories were “major reduction” and “moderate reduction” (combined to create “reduce”) and “major 

increase” and “minor increase” (combined to create “increase”). “Stay about the same” responses not reported here. 

Table A10-8. Survey Respondents’ Attitudes Regarding the Extent to Which the Emphasis 

Placed on Various Activities Occurring on Utah Public Land Should Be Reduced or 

Increased by Public Land Managersa

Type of Garfield County Kane County 

Use/Activity Reduce Increase Reduce Increase 

Permitting of 

commercial guiding 

or outfitter services 

14.8% 22.6% 13.1% 27.1% 

Providing road 

access to recreation 

areas 

7.4% 66.1% 3.1% 62.8% 

Providing hunting 

opportunities 7.4% 52.9% 10.1% 42.7% 

Developing trails for 

off-highway 

motorized recreation 

21.5% 53.7% 21.7% 55.8% 
Proposed RMP and Final EIS Appendix 10 

Kanab RMP A10-9 

Type of Garfield County Kane County 

Use/Activity Reduce Increase Reduce Increase 

Developing trails for 

hiking, biking, and 

other non-motorized 

recreation 

11.7% 50.0% 11.6% 57.4% 

Regulations that 

require motorized 

vehicles to stay on 

designated trails 

21.3% 48.4% 18.5% 47.7% 

Regulations that 

limit levels of noise 

and emissions from 

snowmobiles and 

ATVs 

24.4% 36.1% 20.3% 39.8% 

Developing visitor 

facilities to increase 

tourism 

12.5% 51.7% 11.6% 41.1% 

a. Original response categories were “major reduction” and “moderate reduction” (combined to create “reduce”) and “major 

increase” and “minor increase” (combined to create “increase”). “Stay about the same” responses not reported here. 
Appendix 10 Proposed RMP and Final EIS 

A10-10 Kanab RMP 

This page intentionally left blank 
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-1 

APPENDIX 11—CHANGES BETWEEN THE DRAFT 

RMP/EIS AND THE PROPOSED RMP/FINAL EIS 

This appendix details the changes between the Draft RMP/EIS and Proposed RMP/Final EIS. BLM has 

prepared this Appendix to document if changes between the Draft RMP/EIS and the Proposed RMP/Final 

EIS resulted in a significant change in circumstances or conditions, or if the Proposed RMP/Final EIS 

contains different information from that which was presented to the public in the Draft RMP/EIS. Finally, 

BLM wanted to confirm that all changes made to the Proposed RMP/Final EIS fall within the range of 

alternatives presented and analyzed in the Draft RMP/EIS. 

The regulation controlling whether or not a supplement is required is found at 40 CFR 1502.9(c), which 

provides: 

Agencies: 

Shall prepare supplements to either draft or final environmental impact statements if: 

• The agency makes substantial changes in the proposed action that are relevant to 

environmental concerns; or 

• There are significant new circumstances or information relevant to 

environmental concerns and bearing on the proposed action or its impact. 

• May also prepare supplements when the agency determines that the purposes of 

the Act will be furthered by doing so. 

• Shall adopt procedures for introducing a supplement into its formal 

administrative record, if such a record exists. 

• Shall prepare, circulate, and file a supplement to a statement in the same fashion 

(exclusive of scoping) as a draft and final statement unless alternative 

procedures are approved by the Council. 

All changes to the Kanab Field Office Draft RMP/EIS were made in response to public comment and/or 

internal review. The majority of the changes were editorial changes made to add clarity to the document. 

In some cases, alternatives presented in the Draft RMP/EIS were modified in the Proposed RMP to reflect 

technical corrections and data updates. In other cases, such as in Chapter 3, incorporation of updated 

information was necessary to refine the analysis in Chapter 4 that was incomplete or needed 

augmentation. 

None of the changes described below meet the regulatory definition for significance in 40 CFR 

1508.27(a) and (b). These regulations require an agency preparing a NEPA document to review the 

changes for significant new circumstances or information relevant to environmental concerns and bearing 

on the Proposed Plan or its impacts, using context and intensity as the trigger for significance. BLM has 

reviewed each substantive change through this regulatory standard and has determined that none of the 

changes, individually or collectively, require a supplement to this Final EIS. 

Table A11-1 describes the changes from Alternatives B of the Draft RMP/EIS to the Proposed RMP in 

Chapter 2 of this Proposed RMP/Final EIS. The section titled “Changes to the Draft RMP/EIS” that 

follows the table describes the changes and updates to the Draft RMP/EIS. 
Appendix 11 Proposed RMP and Final EIS 

A11-2 Kanab RMP 

Table A11-1. Changes from Alternative B of the Draft RMP/EIS to the Proposed RMP 

Change from Alternative B of 

Draft Reason for Change Significance 

Added additional management 

actions for air quality. 

Based on public comments 

received on the Draft RMP/EIS, 

particularly comments from the 

State of Utah 

The additions do not result in any 

changes to the impact analysis and 

are not significant. 

Added restrictions on surface 

disturbing activities in pygmy rabbit 

habitat. 

The Draft RMP/EIS addresses 

pygmy rabbit habitat; however since 

publication of the Draft RMP/EIS 

additional populations have been 

identified in the planning area. 

No change in the impact analysis. 

Mitigation would be applied on a 

case-by-case basis with additional 

NEPA required. Not a significant 

change. 

Removed several management 

actions (conservation measures) 

from the special status species 

section in Chapter 2. 

Based on BLM review and 

coordination with USFWS. This was 

due to duplication of conservation 

measures in Chapter 2 and 

Appendix M of the Draft RMP/EIS. 

No change in the impact analysis. 

This was done for clarification and 

to eliminate duplication. This is not 

a significant change. 

Manage oil and gas leasing as open 

subject to major constraints (NSO) 

in Welsh’s milkweed designated 

critical habitat. 

Changed due to comments from the 

USFWS. The majority of Welsh’s 

milkweed habitat is inside the 

Moquith Mountain WSA and is 

therefore closed to oil and gas 

leasing. This change was due to the 

sand hills area, 790 acres, not 

having a protective oil and gas 

leasing stipulation. 

The small acreage adjustment (790 

acres) makes this change not 

significant. 

Preclude surface disturbing 

activities in crucial mule deer and 

elk winter range from November 15 

to April 15 unless the activity would 

improve mule deer or elk habitat. 

This decision was included in 

Alternative B of the Draft RMP/EIS. 

However, since the publication of 

the Draft RMP/EIS, UDWR adjusted 

the habitat layers for crucial habitat. 

This caused a large shift in acres 

affected by this decision. 

The larger crucial winter habitat 

area was analyzed in the Draft 

RMP/EIS in Alternative C. 

Additionally, Appendix 3 includes 

exception, waiver, and 

modifications available for this 

stipulation. Because this information 

was taken into consideration and 

analyzed in the Draft RMP/EIS, 

these changes are not considered 

significant. 

Added two cultural sites to the 

Public Use category. 

Based on public comments 

received on the Draft RMP/EIS. 

No changes to the impact analysis. 

This change is not significant. 

Made minor adjustments to VRM II 

and VRM III acreages. 

Changed to due management of 

non-WSA lands with wilderness 

character and adjustments due to 

oil and gas leasing categories. 

Increased VRM II by 800 acres and 

decreased VRM III by 800 acres. 

This small acreage change is not 

significant. 

Added Management of five areas 

(27,700 acres) to maintain, protect 

and preserve their wilderness 

characteristics. 

Change made due to public 

comments received on the Draft 

RMP/EIS and further BLM review. 

Management of these areas was 

analyzed in Alternative C of the 

Draft RMP/EIS. 

Added language on drought and 

natural disasters. Based on BLM review. 

This change is a list of BMPs that 

address drought conditions and 

natural disaster. No change to 

impact analysis. This is not a 

significant change. 
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-3 

Change from Alternative B of 

Draft Reason for Change Significance 

Closed the Water Canyon Allotment 

to livestock grazing for the life of the 

plan. 

Based on public comment and 

coordination with the State of Utah, 

this allotment was closed to 

livestock grazing for the life of the 

plane rather than being reallocated 

to wildlife (Alternate B of the Draft 

RMP/EIS). 

No change in impact, not a 

significant change. 

Removed language about allocating 

any future AUMs (identified through 

forage surveys) to livestock for the 

following allotments: Lydia, Zion 

Park, and South Canyon. 

Based on BLM review. No change in the impact analysis. 

This is not a significant change. 

Removed the Parunuweap SRMA. Based on BLM review. 

The Parunuweap SRMA was 

located entirely inside Parunuweap 

WSA. Removing the Parunuweap 

SRMA reduced the area closed to 

OHV use by 3,900 acres. 

Alternative A of the Draft RMP/EIS 

analyzed not managing the 

Parunuweap SRMA and therefore 

this change is within the range of 

alternatives. This is not a significant 

change. 

Made adjustments to the OHV area 

designations. 

The OHV area designations were 

adjusted due to a mapping/GIS 

error in the Draft RMP/EIS. The 

BLM portion of the Coral Pink Sand 

Dunes (that is open to crosscountry travel) acreage and map 

has been adjusted. The 

Parunuweap SRMA was removed 

as described above. 

Change affected 100 acres in the 

Coral Pink Sand Dunes and 3,900 

acres in the Parunuweap SRMA. 

This is not significant change. 

Made adjustments to the total 

number of miles of routes. 

Alternative B of the Draft RMP/EIS 

listed a total of 1,505 miles of 

routes. The Proposed RMP has a 

total of 1,478 miles of routes. Due 

to GIS/data errors the total mileage 

of routes in the Draft RMP/EIS was 

overstated. Adjustments were made 

to correct this total mileage. Some 

roads were added to the GIS 

dataset that were unintentionally 

omitted from the initial inventory 

(Neuts Canyon). Based on public 

comment and BLM review, 

adjustments were made to the 

transportation network (see Map 

10). 

The difference in total miles of 

routes is 27 miles. This difference 

between miles stated in the Draft 

RMP/EIS and the Proposed 

RMP/Final EIS is a change of less 

than 2 percent of the routes in the 

planning area. This is not a 

significant change. 

Areas where ROWs would be 

avoided was increased by 27,770 

acres. 

This was due to management of 

non-WSA lands with wilderness 

characteristics (27,770 acres). 

Analyzed under Alternative C of the 

Draft RMP/EIS, not a significant 

change. 
Appendix 11 Proposed RMP and Final EIS 

A11-4 Kanab RMP 

Change from Alternative B of 

Draft Reason for Change Significance 

Added language about giving 

priority to the State of Utah in land 

exchanges and a statement about 

the Cotter Decision (access to state 

lands). 

This was the result of coordination 

with the State of Utah. 

No change to impact analysis. This 

is not a significant change. 

Adjustments were made to the oil 

and gas leasing categories. 

This adjustments to oil and gas 

leasing were due to changes in the 

big game crucial winter habitat 

mentioned above. 

The larger habitat layer was 

analyzed under Alternative C of the 

Draft RMP/EIS. This change is 

within the range of alternatives. This 

is not a significant change. 

Removed the suitability 

recommendation for the East Fork 

Virgin River – Segment 36-37 

(Recreational classification). 

This was done based on BLM 

review. 

Upon further review by the BLM, 

there were concerns about the 

manageability of this segment due 

to the physical nature of the way 

(route) (e.g., several river crossings 

that vary with changing runoff 

conditions and flood events). Not 

carrying this segment forward was 

analyzed under Alternative D of the 

Draft RMP/EIS and is not a 

significant change. 

Added language to work with the 

State of Utah, federal agencies, and 

tribal governments in taking Wild 

and Scenic River recommendations 

forward to Congress. 

This was the result of coordination 

with the State of Utah. 

No change to impact analysis. This 

is not a significant change. 

Specified by WSA, the miles of 

inventoried ways in WSAs 

designated as open to OHV use. 

Based on BLM review. 

This change was made to clarify the 

miles of inventoried ways in WSAs 

that are open to OHV use. This is 

not a significant change. 

Made adjustments to the miles of 

inventoried ways available for OHV 

use. 

Based on public comment and BLM 

review. 

Alternative B of the Draft RMP/EIS 

identified 15 miles of inventoried 

ways as open to OHV use. The 

Proposed RMP identifies 25 miles 

of inventoried ways as open to OHV 

use. This change is within the range 

of alternatives analyzed in the Draft 

RMP/EIS (Alternative D identified 

32 miles of inventoried ways). This 

is not a significant change. 

CHANGES TO THE DRAFT RMP/EIS 

This section describes the changes and updates to the Draft RMP/EIS. The page numbers that appear 

along the left margin throughout this section indicate the page of the Draft RMP/EIS on which the 

addition or correction would appear if the entire draft were reprinted. 

Chapter 1 of the Draft RMP/EIS 

Page 1-6 Insert the following at the end of the Vegetation section on page 1-6: 
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-5 

“The RMP will need to ensure that vegetation management activities and 

treatment of invasive species will follow principles of integrated pest 

management. The following documents are incorporated by reference as 

current national guidance, although they may be updated over the life of this 

plan: 

• Vegetation Treatments on BLM Lands in 17 Western States 

Programmatic Environmental Report, 2007 

• Vegetation Treatments Using Herbicides in 17 Western States 

Programmatic Environmental Impact Statement, 2007 

• Final Environmental Impact Statement Vegetation Treatment on BLM 

Lands in Thirteen Western States and Associated Records of Decision, 

1991.” 

Page 1-9 Change the first bullet under the Livestock Grazing heading to: 

“A limited number of necessary changes in the current forage allocation.” 

Chapter 2 of the Draft RMP/EIS 

Page 2-14 Following the discussion of the management of Greater sage-grouse habitat 

insert the following: 

“Management of Pygmy Rabbit Habitat 

Apply restrictions (e.g., avoidance or mitigation) to surface disturbing and 

disruptive activities on a case-by-case basis in occupied and potential pygmy 

rabbit habitat for the protection of this species and its associated habitat. Sitespecific NEPA documentation would address restrictions around pygmy rabbit 

habitat.” 

Page 2-23 Insert the following at the end of Section 2.2.1: 

“Drought and Natural Disasters 

Coordinate appropriate management responses with affected parties when 

natural resources may be affected by drought, insects, diseases, or natural 

disasters. A variety of emergency or interim actions may be necessary to 

minimize land health degradations such as reduced forage allocations, 

reductions in the number of livestock and/or wildlife, increased mitigation 

measures to ensure reclamation, and limitations on energy field activities and 

recreational uses. 

Incorporate current Utah BLM Standards for Rangeland Health, as 

appropriate, across all resource programs as a minimum. Management 

prescriptions in the form of constraints to use, terms and conditions, and 

stipulations may be needed to sustain rangeland health and viability. 

Management prescriptions will consider the following: 

• Surface disturbing activities. These will be closely monitored to ensure 

compliance with authorizations and the permit’s conditions of approval 

or terms and conditions. Actions minimizing new surface disturbance 
Appendix 11 Proposed RMP and Final EIS 

A11-6 Kanab RMP 

allowed by regulations and actions ensuring successful reclamation 

will be emphasized. During periods of drought, the BLM could require 

additional actions such as changes to standard seed mix compositions, 

amount, and/or method of application. Methods to ensure successful 

revegetation following disturbance could also include hydromulching, 

installation of drip irrigators, and fencing to exclude ungulate 

grazing/browsing. 

• Livestock grazing. During periods of prolonged drought, use will be 

allowed in both quantity and timing that will not result in a downward 

shift in rangeland health and/or production. The BLM will work 

cooperatively to effect a grazing strategy specific to a grazing 

permittee’s individual grazing allotment(s) and make changes to the 

grazing authorizations, as appropriate, in accordance with the grazing 

regulations. In the case of drought, the BLM could temporarily close 

the range, or portions of it, to livestock grazing. 

• Wildlife management. During periods of prolonged drought to the 

extent that vegetation monitoring indicates that habitat for wildlife 

ungulate populations cannot be sustained and overall animal health is 

compromised, the BLM will enter into discussions with the Utah 

Division of Wildlife Resources (UDWR) regarding herd numbers and 

overall management options to combat the effects of drought. 

• Recreation. During periods of prolonged drought, the BLM, in 

cooperation with local and state fire management agencies, will limit 

campfires to established fire rings or fully contained fires. The last 

resort will be to close the public lands to campfires of any kind. 

• OHVs. Off-highway/road vehicle use during periods of prolonged 

drought could be further restricted; or, if site-specific conditions 

warrant, closure to OHVs could be implemented to minimize vehicleinduced injury or damage to rangeland and/or woodland resources and 

to minimize the potential of spark-caused fires.” 

Page 2-26 Insert the following transportation common to all management actions: 

“BLM, in preparing its RMP designations and its implementation-level travel 

management plans, is following policy and regulation authority found at 43 

CFR 8340, 43 CFR 8364, and 43 CFR 9268. 

Where the authorized officer determines that OHVs are causing or would cause 

considerable adverse impacts, the authorized officer shall close or restrict such 

areas. Local highway authorities would be consulted as appropriate. The public 

would be notified. 

BLM could impose limitations on the types of vehicles allowed on specific 

designated routes if monitoring indicates that a particular type of vehicle is 

causing disturbance to the soil, wildlife habitat, cultural or vegetative 

resources, especially by off-road travel in an area that is limited to designated 

routes. 

As per the State of Utah v. Andrus, October 1, 1979 (Cotter Decision), BLM 

would grant the State of Utah reasonable access to state lands for economic 
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-7 

purposes on a case-by-case basis. 

Where routes would remain available for motorized use within WSAs, such 

use could continue on a conditional basis. Use of the existing routes in the 

WSAs (“ways” when located within WSAs) could continue as long as the use 

of these routes does not impair wilderness suitability, as provided by the IMP 

(BLM 1995). If Congress designates the area as wilderness, the routes will be 

closed. In the interim, if use and/or non-compliance are found through 

monitoring efforts to impair the area’s suitability for wilderness designation, 

BLM would take further action to limit use of the routes or close them. The 

continued use of these routes, therefore, is based on user compliance and nonimpairment of wilderness values.” 

Page 2-27 Insert the following in the lands and realty common to all management actions: 

“Give land exchanges with the State of Utah priority consideration to resolve 

inholdings issues. 

As per the Cotter Decision, reasonable access to state lands would be 

authorized for economic purposes.” 

Page 2-38 Revise Alternatives B and C under the general vegetation heading by adding 

the following: 

“unless site-specific management objectives for other resources dictate 

otherwise (e.g., special status species adapted to 0 percent to 25 percent of 

PNC).” 

Page 2-42 Under vegetation restoration treatments management actions (Alternatives B, 

C, and D), revise the term “wildland fire” to “wildland fire use.” 

Page 2-43 Add the following to the list of factors for Alternatives B and C: 

• “Restore special status species habitats to achieve long-term 

conservation and recovery objectives.” 

Page 2-50 Revise the Alternative C management action to read: 

“Preclude surface disturbing activities in mule deer and elk crucial winter 

range from November 15 to April 15 for protection of winter habitats.” 

The revision is necessary because UDWR has combined what was termed 

high-value and crucial habitat in the Draft RMP/EIS to be crucial habitat. The 

term high-value winter habitat is no longer used by UDWR. 

Page 2-50 Add the following reference to Alternatives B and C under management of 

bighorn sheep habitat: “(Bighorn Institute 2008).” 

Page 2-54 Under Alternative B, revise the management action to the following: 

“Close the Water Canyon Allotment to livestock grazing for the life of the plan 
Appendix 11 Proposed RMP and Final EIS 

A11-8 Kanab RMP 

in order to protect the Fredonia City Culinary water supply.” 

Pages 2-59 and 2-60 Remove the following from the list of areas managed to maintain wilderness 

characteristics under Alternative C: Black Hills, Heaps Canyon, Little Valley 

Canyon, North Escalante Canyon, and Paria/Hackberry. These lands were 

found not to have wilderness characteristics during inventory maintenance as 

identified in Chapter 3 of the Draft RMP/EIS. They were inadvertently placed 

on the table in Chapter 2. 

In addition, Jolley Gulch is included within the Orderville Canyon non-WSA 

(wilderness study area) lands with wilderness characteristics area and was 

incorrectly listed separately from Orderville Canyon. 

Pages 2-64 and 2-65 Under Alternative B, revise the management action to the following: 

“Close the Water Canyon Allotment to livestock grazing for the life of the plan 

in order to protect the Fredonia City Culinary water supply.” 

Page 2-65 Remove the following decision from the Lydia’s Canyon/Lydia Allotments 

decision: 

“AUMs identified through future forage surveys would be allocated for 

livestock.” 

Page 2-66 Remove the following decision from the Sawmill/South Canyon Allotments 

decision: 

“AUMs identified through future forage surveys would be allocated for 

livestock.” 

Page 2-69 Remove the Parunuweap SRMA from Alternative B. 

Page 2-73 Remove the last bullet under Ponderosa Grove campground in Alternative B. 

Pages 2-74 and 2-75 Remove the Parunuweap SRMA and associated management prescriptions 

from Alternative B. 

Pages 2-81 and 2-82 Revise the acreage for open to cross-country OHV use for Alternatives B and 

D to 1,000 acres. 

Page 2-84 Under seasonal limitations, insert the following sentence: 

“If no nesting behavior is initiated prior to June 1, a BLM authorized officer 

could open the route to motorized use.” 

Pages 2-87 and 2-88 Add the following to the lands and realty management action under 

Alternatives B and C: 

“The addition of new communications devices on existing towers will be 

considered where it is practical and does not present a safety or operational 

risk.” 
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-9 

Page 2-98 Under the Hazard/Safety/Public Welfare heading for Alternative B, revise the 

management action to the following: 

“Close the Water Canyon Allotment (48 AUMs) to livestock grazing in order 

to protect the Fredonia City Culinary water supply for the life of the plan.” 

Chapter 3 of the Draft RMP/EIS 

Page 3-1 Added the heading “Ambient Air Quality” following the first paragraph in

section 3.2.1 on page 3-1. 

Added the following text and figures following the second sentence of the second 

paragraph in section 3.2.1 on page 3-1. 

For ozone (O3) data have been collected at Grand Canyon National Park from

1999-2007 and Canyonlands National Park from 1996-2007. Figure 3-1 shows 

the 8 hour average concentrations for Grand Canyon. Annual average ozone 

concentrations are shown in Figure 3-2 for Canyonlands. The data indicate 

compliance with the ozone standard. Also, no data trends are noted. 

Figure 3-1. Ozone Concentrations in Grand Canyon National Park, 

Arizona. 

0.06

0.065

0.07

0.075

0.08

0.085

1999 2000 2001 2002 2003 2004 2005 2006 2007 2008

Data taken from EPA Air Data

Grand Canyon National Park station

3 year rolling average of 8 hour 4th maxima

8 hour O3 concentration (ppm)

former NAAQS

NAAQS
Appendix 11 Proposed RMP and Final EIS 

A11-10 Kanab RMP 

Figure 3-2. Mean Annual Ozone Concentrations near the Kanab 

Planning Area. 

0

10

20

30

40

50

60

70

80

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

Data taken from Clean Air Status & Trends

CASTNet Canyonlands National Park station: CAN407

O3 concentration (ppb)

Additionally, nitrogen and sulfur compounds have been measured at Canyonlands

National Park from 1995-2006. Figure 3-3 and Figure 3-4 show that the data are 

typical for rural western US locations. A slight downward trend in the data is

noted for sulfur compound. 

Figure 3-3. Mean Annual Concentrations of Nitrogen Compounds 

near the Kanab Planning Area. 

0

0.2

0.4

0.6

0.8

1

1.2

1.4

1.6

1.8

2

19951996199719981999200020012002200320042005200620072008

Dat a t ak en f r om Cle an Air S t a t us & Tr ends Ne t wor k

CAS TNe t Canyonl ands Na t iona l P a r k st a t ion: CAN40 7

Typic al conc ent r at ions f or r e mot e a r ea s:

HNO3 ( nit ric acid) : .05 - 8 ug/ m3

NH4 ( ammonium) : .2 ug/ m3

NO3 ( nit rat e) : .5 ug/ m3

Concentration (ug/m3)

HNO3

NH4

NO3
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-11 

Figure 3-4. Mean Annual Concentrations of Sulfur Compounds 

near the Kanab Planning Area. 

0

0.5

1

1.5

2

2.5

1995

1996

1997

1998

1999

2000

2001

2002

2003

2004

2005

2006

2007

2008

Data taken from Clean Air Status & Trend Network

CASTNet Canyonlands National Park station CAN407

Typical concentrations for remote areas

SO2: 2.6 - 26 ug/m3

SO4: 2.5 ug/m3

Concentration (ug/m3)

SO2

SO4

Other ambient air data are not available for the immediate area. 

Page 3-2 Replace the definitions for Class I, II and III Prevention of Significant

Deterioration (PSD) areas with the following: 

• PSD Class I Areas. Areas with pristine air quality, such as wilderness

areas, national parks, and some Indian reservations, are accorded the

strictest protection. Only very small incremental increases in 

concentration are allowed to maintain very clean air quality in these

areas. 

• PSD Class II Areas. Moderate incremental increases in concentration are

allowed, although the concentrations are not allowed to reach the

concentrations set by NAAQS. 

• PSD Class III Areas. No areas have yet been designated Class III. 

Concentrations would be allowed to increase to established NAAQS 

concentrations. 

Page 3-3 Add the following after the second paragraph of page 3-3: 

Visibility 

Regional haze is an issue of increasing concern throughout the western United

States. Regional haze causes visual impairment by obscuring the clarity, color,

texture, and form of what can be seen. As part of the Interagency Monitoring of

Protected Visual Environments (IMPROVE) network, visual air quality in Bryce 

Canyon National Park and Canyonlands National Park has been monitored from

1992–2004. Figure 3-5 and Figure 3-6 indicate that the visibility trend both in 
Appendix 11 Proposed RMP and Final EIS 

A11-12 Kanab RMP 

Bryce Canyon National Park and Canyonlands is improving on the clearest days. 

Figure 3-5. Visibility Data for Bryce National Park 

Figure 3-6. Visibility Data for Canyonlands National Park 

Atmospheric Deposition

Atmospheric deposition of air pollutants can increase the acidity of soils and

water resources. Measurements of atmospheric deposition are currently being

taken in Class I areas of Bryce Canyon National Park, and Canyonlands National

Park by the National Acid Deposition Program. Figure 3-7 shows precipitation 

pH data at Bryce national Park from 19985-2006. Recent measurements show 
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-13 

less acidity for the period 1994-2001. Available data indicate that wet deposition 

of ammonium as measured by the NADP station in Bryce Canyon National Park

has indeed increased from .2 to .8 kg/ha-year during the period from 1984 

through 2006. 

Total nitrogen and sulfur deposition are shown for Canyonlands National Park

from 1995-2004 in Figure 3-8 and Figure 3-9. The data indicate the rates of

atmospheric deposition of nitrogen and sulfur in rain are relatively low in

Canyonlands National Park. Trend analysis shows that nitrogen deposition has 

remained relatively constant and that sulfur deposition has slightly decreased.

Total nitrogen deposition from nitrogen compounds, including ammonium,

remains below the nitrogen deposition level-of-concern of 3 - 5 kg/ha-year (Fox, 

1989), with deposition ranging from 1.7 to 2.2 kg/ha-year during the period from 

1995 through 2004. 

Figure 3-7. Mean Annual Precipitation pH near the Kanab Planning 

Area. 

4

4.2

4.4

4.6

4.8

5

5.2

5.4

5.6

1985

1987

1989

1991

1993

1995

1997

1999

2001

2003

2005

2007

Data taken from National Atmospheric Deposition Program

NADP Bryce Canyon National Park - Repeater Hill station: UT99

precipitation pH
Appendix 11 Proposed RMP and Final EIS 

A11-14 Kanab RMP 

Figure 3-8. Total Nitrogen Deposition for Canyonlands National Park

Figure 3-9. Total Sulfur Deposition for Canyonlands National Park 

The lack of available data limits the forecasting trends of air quality; however,

ambient air quality is not exceeding standards, visibility is typical of clear skies 

associated with remote areas in the western United States, and atmospheric

deposition levels are below federal levels of concern. Future changes to air

quality conditions would occur according to the intensity and expansion or

reduction of activities that produce air pollutants. However, the use of air

pollution mitigation techniques can reduce emissions from sources, and in some

cases, also minimize air quality impacts. At this time, future impacts to air quality 

within the planning area from non-BLM sources (e.g., power plants and 

fireplaces) are uncertain; however, emissions from these existing sources are not

anticipated to increase. 
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-15 

Page 3-3 Add the following to the bottom of page 3-3: 

Global Climate Change

On-going scientific research has identified the potential impacts of climate

changing pollutants on global climate. These pollutants are commonly called 

“greenhouse gases” and include carbon dioxide, CO2; methane; nitrous oxide; 

water vapor; and several trace gas emissions. Through complex interactions on a 

regional and global scale, these emissions cause a net warming effect of the

atmosphere, primarily by decreasing the amount of heat energy radiated by the

Earth back into space. Although climate changing pollutant levels have varied for

millennia (along with corresponding variations in climatic conditions), recent

industrialization and burning of fossil carbon sources have caused CO2

concentrations to increase dramatically, and are likely to contribute to overall 

climatic changes, typically referred to as global warming. Increasing CO2

concentrations also lead to preferential fertilization and growth of specific plant

species. 

Global mean surface temperatures have increased nearly 1.0°C (1.8°F) from 1890 

to 2006 (Goddard Institute for Space Studies, 2007). However, observations and

predictive models indicate that average temperature changes are likely to be

greater in the Northern Hemisphere. Figure 3-10 demonstrates that northern 

latitudes (above 24° N ) have exhibited temperature increases of nearly 1.2°C

(2.1°F) since 1900, with nearly a 1.0°C (1.8°F) increase since 1970. Without

additional meteorological monitoring systems, it is difficult to determine the

spatial and temporal variability and change of climatic conditions, but increasing 

concentrations of these “greenhouse gases” are likely to accelerate the rate of

climate change. 

The Intergovernmental Panel on Climate Change (IPCC) has recently completed

a comprehensive report assessing the current state of knowledge on climate 

change, its potential impacts, and options for adaptation and mitigation. At 

printing of this PRMP/FEIS, this assessment is available on the IPCC web site at

http://www.ipcc.ch/. According to this report, global climate change may 

ultimately contribute to a rise in sea level, destruction of estuaries and coastal

wetlands, and changes in regional temperature and rainfall patterns, with major

implications to agricultural and coastal communities. The IPCC has suggested 

that the average global surface temperature could rise 1 to 4.5 degrees Fahrenheit

(°F) in the next 50 years, with significant regional variation. The National 

Academy of Sciences (2006) has confirmed these findings, but also indicated that

there are uncertainties regarding how climate change may affect different regions.

Computer models indicate that such increases in temperature will not be equally

distributed globally, but are likely to be accentuated at higher latitudes, such as in 

the Arctic, where the temperature increase may be more than double the global

average (BLM 2007b). Also, warming during the winter months is expected to be

greater than during the summer, and increases in daily minimum temperatures is

more likely than increases in daily maximum temperatures. Vulnerabilities to 

climate change depend considerably on specific geographic and social contexts.

BLM recognizes the importance of climate change and the potential effects it

may have on the natural environment. Several activities occur within the planning 
Appendix 11 Proposed RMP and Final EIS 

A11-16 Kanab RMP 

area that may generate emissions of climate changing pollutants. For example, oil 

and gas development, large fires, and recreation using combustion engines, can

potentially generate CO2 and methane. Wind erosion from disturbed areas and

fugitive dust from roads along with entrained atmospheric dust has the potential

to darken glacial surfaces and snow packs resulting in faster snowmelt. Other

activities may help sequester carbon, such as managing vegetation to favor

perennial grasses and increase vegetative cover, which may help build organic

carbon in soils and function as “carbon sinks”. 

Figure 3-10. Annual Mean Temperature Change for Northern 

Latitudes (24 - 90° N) 

Source: Goddard Institute for Space Studies (2007) 

Page 3-10 Delete the last sentence at the bottom of page 3-10 and replace it with the 

following: 

“It is now generally accepted by the Colorado River Basin Salinity Control

Forum that saline ground-water flowing through the soils to the rivers may be 

contributing as much as 85% of the salt loading from public lands in the Upper

Colorado River Basin (Warner et. al. 1985 and Westenburg 1995).” 

Page 3-12 Revise Table 3-2: 

Hydrologic Unit 

Code (HUC) Watershed Drainage Basin 

14070001 Upper Lake Powell Colorado River Basin 

14070003 Fremont Colorado River Basin 

14070005 Escalante Colorado River Basin 
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-17 

14070006 Lower Lake Powell Colorado River Basin 

14070007 Paria Colorado River Basin 

15010003 Kanab Colorado River Basin 

15010008 Upper Virgin Colorado River Basin 

15010009 Fort Pierce Wash Colorado River Basin 

16030001 Upper Sevier Great Basin 

16030002 East Fork Sevier Great Basin 

16030006 Escalante Desert Colorado River Basin 

Source: U.S. Geological Survey (USGS) 2005 

Page 3-14 The following was added to page 3-14 immediately before the Surface Water

Quantity and Quality heading: 

“TDS of surface water can be increased from saline ground-water inflow to the 

streams. In areas such as the Paria River and Kanab Creek watersheds, shallow

ground-water flow through eroded sediments from saline rock formations (Tropic

Shale for the Paria River and Chinle and Moenkopi formations for Kanab Cr)

contributes salt (mainly gypsum) to the surface water naturally.” 

Page 3-15 The following was added to the end of the first paragraph on page 3-15: 

“The Virgin River Management Plan Coordinating Committee, consisting of

local and federal agencies and interested parties, completed the Virgin River

Watershed Management Plan in 2006. The plan comprises a suite of activities

and management practices to target specific problems in the watershed. The plan 

addresses issues such as stream flow, dissolved solids, nutrients, stream bank

stabilization, native fishes, and recreation. In addition, the U.S. Army Corps of

Engineers is conducting the federally funded Virgin River Comprehensive

Watershed Analysis. The Corps is working in partnership with local and county

governments; tribal, state, and federal agencies; municipalities; landowners;

citizen groups; and the public. A goal of the analysis is to produce a watershed

plan that assists stakeholders in successful management of the Virgin River and 

tributaries and related resources.” 

Pages 3-30 and 3-31 Remove the bald eagle from Table 3-12 and the narrative discussion. The U.S. 

Fish and Wildlife Service (USFWS) has delisted this species. 

Page 3-34 Delete the third sentence under the Siler Pincushion Cactus section on page 3-34.
Appendix 11 Proposed RMP and Final EIS 

A11-18 Kanab RMP 

Page 3-34 Add the following language after the paragraph on Welsh’s Milkweed: 

“Colorado River Fish. Four fish species that occur in the Colorado River system

have been listed as either threatened or endangered. These are the bonytail chub

(Gila elegans), humpback chub (Gila cypha), pikeminnow (Ptychocheilus 

lucius), and razorback sucker (Xyrauchen texanus). No existing or potential 

habitat for any of these species occurs near or within the Kanab planning area 

boundaries. No actions that would be authorized by implementation of the new

RMP would affect existing or potential habitat for these species; therefore they

will not be discussed further in this document.” 

Page 3-35 Add the bald eagle to Table 3-13 as a BLM sensitive species and move the 

narrative discussion from pages 3-30 and 3-31 to page 3-36. 

Page 3-39 Add to the pygmy rabbit narrative the following: 

“...occurs in isolated patches in the western half of Utah with some colonies 

present in the decision area.” 

Page 3-45 Add the following before the mule deer heading on page 3-45. 

In August of 2005, the Utah Division of Wildlife Resources (UDWR) changed its

wildlife habitat classification system. Prior to 2005, the UDWR classification 

system distinguished between “critical” habitat (an area that provides for

biological and/or behavioral requisites necessary to sustain the existence and/or

perpetuation of a wildlife population) and “high value” (an area that provides for

intensive use by the species). The UDWR has been criticized for using the term 

“critical”, as the same term refers to habitat Federally designated by the U.S. Fish

and Wildlife Service as required by the Endangered Species Act (ESA). 

In previous BLM planning efforts, mitigation decisions (usually timing 

stipulations) for impacts to UDWR’s “critical” habitats have been integrated into 

the planning process. BLM rarely incorporated management decisions in its

RMPs for “high value” habitats. UDWR changed its classification system to 

include “critical” habitat with “high value” habitat, in part to accommodate the 

limitations of having classifications that were of no practical value to land

managers. The new term “crucial” habitat is defined by UDWR as “habitat on 

which the local population of a wildlife species depends for survival because

there are no alternative ranges or habitats available. Crucial habitat is essential to

the life-history requirements of a wildlife species. Degradation or loss of crucial

habitat will lead to significant declines in the wildlife population in question.” 

Crucial habitat boundaries appear larger on the wildlife maps in this Proposed

Plan because they are a combination of UDWR’s old “critical” habitat and “high

value” habitat, with some minor modifications. Timing stipulations for each of

the species now apply to the whole crucial habitat area. It is important to note 

however, that the application of waivers, exceptions and modifications, as

outlined in Appendix C, will be taken into consideration and used where/when 

applicable for all surface disturbing activities in these areas. Alternative C in the 

Draft RMP/Draft EIS considered both of UDWR’s old classifications of critical 

and high value habitat. Minor boundary modifications have been made by 
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-19 

UDWR prior to incorporating them into crucial habitat boundaries. 

Page 3-46 Revise the first sentence of the second to last paragraph to the following: 

The largest areas of identified pronghorn habitat within or adjacent to the

decision area are within the Panguitch Valley (Sage Hen Hollow and East Bench 

populations) and John’s Valley. 

Page 3-51 Replace the paragraph under the Fish Species heading with the following: 

Fisheries habitat includes perennial and intermittent streams that support fish 

through at least a portion of the year. The condition of fisheries habitat is related

to riparian habitat condition and stream channel characteristics. Previous stocking

efforts by UDWR have established many non-native fish species in streams to 

provide for sport fishing opportunities. Aquatic invertebrates and amphibians are

integral components of warm and cold fish communities. 

Page 3-58 Add the following to the end of the second paragraph on page 3-58: 

A Class II inventory of the BLM portion of the Coral Pink Sand Dunes was 

completed in summer 2008. No cultural sites were identified by the new

inventory. 

Page 3-65 Add the following to the end of the last paragraph on page 3-65: 

In addition, the secretarial decision directs that “under no circumstances should 

this decision become the only basis for protection of the values for which Bryce

Canyon National Park was established and I direct that these park values be taken

into account in future decisions by the bureaus of this Department on mining

plans and permit applications for other activities on undesignated Federal lands 

near the park.” 

Page 3-83 Add the following prior to the Off-Highway Vehicles heading on page 3-83: 

“SITLA Lands 

Throughout much of the State of Utah, the state owns and manages four isolated

sections in each 36-section township. These are generally Sections 2, 16, 32, and

36, and are ordinarily 1 mile square (640 acres). They are primarily administered

by the Utah School and Institutional Trust Lands Administration (SITLA) for the 

purpose of economic support of the state’s public schools and institutional trust

funds. Activities on state land generally are not substantially different from those

on the surrounding land administered by BLM. Many of the SITLA lands 

generate funds through grazing permits, right-of-way easements and permits, and

hydrocarbon or other mineral leases. 

Many BLM lands with management restrictions, such as WSAs, have state lands 

that are adjacent to or within their boundaries. State lands that are completely or

almost entirely surrounded by BLM lands with management restrictions, or are in

conjunction with administratively endorsed National Park Service lands, are

termed state inholdings. 
Appendix 11 Proposed RMP and Final EIS 

A11-20 Kanab RMP 

Existing access to inheld state lands varies. Some of the parcels have direct

access through cherry-stemmed or boundary roads of WSAs. Inheld parcels may 

or may not currently have access, depending upon whether or not existing vehicle

routes lead to them. BLM policy, as required by the Cotter decision, is that “the

state must be allowed access to the state school trust lands so that those lands can

be developed in a manner that will provide funds for the common school.” This 

decision confined the issue of access to situations directly involving economic

revenues generated for the school trust. For example, if a holder of a state oil and

gas lease on a parcel of state land that is completely surrounded by a WSA

requires access to develop that lease, BLM must grant the leaseholder reasonable

access with consideration given to minimize impacts on wilderness character.” 

Page 3-105 Add the following to the top of page 3-105 before the Economic Characteristics 

heading: 

“A statewide social survey was conducted by Utah State University (USU) in

2007 to assess the ways in which Utah residents use and value public land 

resources and their views about public lands management. A complete analysis of

the results had not been completed as of February 2008. “Public lands,” as 

described in the study, consist of not only BLM, but all federal and state managed

lands. Surveys were mailed to a random sample of residents of all 29 Utah

counties. According to the authors, the study and sample sizes are designed to

produce results generalizable at the statewide level, with generalization

increasingly risky as the sample area diminishes. For example, the data may lose 

much of its generalizability at the individual county level, but increase as

additional counties are aggregated into the sample. The areas sampled do not 

necessarily coincide with field office planning area boundaries, because that was 

not the focus of the study. Nonetheless, the study provides current and interesting 

results not available elsewhere, and shows the dependence of local communities

on public lands for a variety of economic and recreational pursuits. Appendix 10 

contains initial summary results for Kane and Garfield counties lying within the 

Kanab Field Office. There is nothing in the preliminary USU results that affect

the formulation of alternatives in Chapter 2 or the analysis of impacts in Chapter

4.” 

Page 3-112 Add the following prior to the Values and Attitudes heading: 

“Although not in the socioeconomic study area of Kane and Garfield counties,

Utah, the Kaibab-Paiute Tribe reservation is adjacent to the planning area along 

the Utah-Arizona border. In July 2005, the Kaibab-Paiute Tribe signed a 

memorandum of agreement (MOA) formalizing cooperating agency status with

the KFO. 

The Kaibab-Paiute Tribe reservation is within the Kaibab census-designated

place (CDP). According to Census data from 2000, more than half of the 

population in the Kaibab CDP, 54.9 percent, was American Indian, with 43.6

percent being white. Most whites, 58.2 percent, live in the community of

Moccasin, which is not on reservation lands. 

The Kaibab-Paiute Tribe also had a very high individual poverty rate at 31.6

percent, a high family poverty rate at 29.7 percent, and a low per capita income at
Proposed RMP and Final EIS Appendix 11 

Kanab RMP A11-21 

$7,951. Family size did not seem to play an important role in the tribe’s poverty

rates and low per capita income. The tribe’s average family size was 3.51, only 

slightly higher than the national average.” 

Chapter 4 of the Draft RMP/EIS 

Page 4-255 Under the Environmental Justice heading on page 4-255, replace the second 

sentence with the following:

“Although not in the socioeconomic study area of Kane and Garfield counties,

Utah, the Kaibab-Paiute Tribe reservation is adjacent to the planning area along

the Utah-Arizona border. While the Kaibab-Paiute Tribe qualifies as an 

environmental justice population, no disproportionate adverse impacts to this 

area of higher density minority populations would occur from implementation

of any of the management actions, resource programs, or objectives proposed

under any of the alternatives. ” 

Page 4-262 Add the following prior to the Livestock Grazing heading at the top of page 4-

262: 

“Due to the unknown nature of where future oil and gas development could

occur in the Kanab Field Office planning area, an additional potential impact on

state revenues is the potential loss to the Utah School and Institutional Trust

Lands Administration (SITLA) of not being able to lease or develop lands 

bordered all or in part by non-WSA lands with wilderness characteristics. The 

value of these lands for oil and gas leasing and/or development may be reduced 

if all or portions of public lands bordering these state lands are closed to new oil

and gas leasing. This in turn could reduce the monies collected by the state

(through SITLA), including royalties and severance taxes. These impacts can be 

estimated using current data and incorporating several assumptions. If one 

assumes that SITLA lands whose perimeter is more than 50 percent bounded by 

BLM acreage that is closed to new oil and gas leasing (as a result of

implementing Alternative C) would be unavailable for development, and using 

the projections of the Reasonably Foreseeable Development (RFD), one can 

project that less than one well (0.45) would not be drilled over the life of the

plan. Using data provided by the State of Utah, royalty payments to wells on 

SITLA lands averaged $57,065 as of early 2008. Severance taxes averaged 

$9,335 for all wells, regardless of land ownership. Multiplying these figures by 

the wells assumed to not be drilled, the fiscal loss to the state would total

$25,582 in royalties and $4,185 in severance taxes in any year in which these

wells would have been in operation. This amount could increase over the life of

the plan, as it is likely that some fraction of these wells would be in operation in

several (or even all) years of the plan. 

Similarly, one can compute potential spending on oil and gas activities

(including coalbed natural gas) lost to the planning area if these SITLA lands 

prove undevelopable under Alternative C. Using the assumptions outlined on

pages 4-245 and 4-246 of the Draft EIS, the loss in spending in the local area 

would be approximately $295,877 in any one year in which the wells were not

in operation.” 
Appendix 11 Proposed RMP and Final EIS 

A11-22 Kanab RMP 

Appendices 

Page AA-2 Add the following to the bulleted list at the top of page AA-2: 

BLM Vegetation Treatments Using Herbicides Final Programmatic

Environmental Impact Statement Record of Decision, September 2007. As of

April 2008, an electronic version of this document was available at

http://www.blm.gov/wo/st/en/prog/more/veg_eis.html. 

Page AB-8 Add the following to the last paragraph on page AB-8: 

If monitoring detects an impact on bird behavior, especially one that might

result in "take" the activity could be suspended or modified so that the impacts 

are avoided or removed. 

Appendix C Remove exception language from oil and gas stipulations for Moquith

Mountain, Orderville Canyon, and North Fork Virgin River SRMAs and

suitable “wild” river corridors. 

Remove oil and gas leasing stipulations for the Parunuweap SRMA under

Alternative B. 

Page AC-20 Add the following VRM Class II stipulation to Alternatives B and C: 

“Surface disturbing activities must meet the objectives of VRM Class II

objectives. 

Purpose: To protect high-quality visual resources. 

Exception: The level of change to the landscape should be low; management

activities may be seen, but should not attract the attention of the casual observer.

Any change to the landscape must repeat the basic elements of form, line, color,

and texture found in the predominant natural features of the characteristic

landscape. Surface disturbing activities that are determined to be compatible and

consistent with the protection or enhancement of the resource values are

exempted. Also, recognized utility corridors are exempted only for utility 

projects that would be managed according to VRM Class III objectives. 

Modification: None 

Waiver: None” 

Pages AF-21 and AF-22 Corrected and updated Maps 2 and 3 of the Coal Unsuitability Appendix. 

Page AG-9 Revise Table AG-2 for the North Fork Virgin River segment 46-47 under the 

wildlife heading to the following: 

“Spotted owl designated critical habitat is present; however, per BLM-M-8351 

Section .3(c) (‘Contiguous habitat conditions are such that the biological needs 

of the species are met’) the habitat in this corridor is not contiguous and does

not meet the needs of the species in this area.” 
Proposed RMP and Final EIS Appendix 12 

Kanab RMP A12-1 

APPENDIX 12—STATE OF UTAH LETTER 

ADDRESSING AIR QUALITY 
Appendix 12 Proposed RMP and Final EIS 

A12-2 Kanab RMP 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-1 

APPENDIX 13—WILD AND SCENIC RIVERS STUDY 

PROCESS 

I. INTRODUCTION

The Wild and Scenic Rivers Act (October 2, 1968, Public Law 90-542) establishes the National Wild and 

Scenic Rivers System (NWSRS), which is intended to preserve free-flowing rivers with outstandingly 

remarkable values (ORV) in their natural condition for the benefit of present and future generations, 

balancing the nation’s water resource development policies with river conservation and recreation goals. 

The Wild and Scenic Rivers Act states, “In all planning for the use and development of water and related 

land resources, consideration shall be given by all federal agencies involved to potential national wild, 

scenic and recreational river areas...” [Section 5(d) (1)]. Federal agencies consider potential rivers by 

evaluating a river’s eligibility, tentative classification, and suitability for designation under the Wild and 

Scenic Rivers Act. This study process is part of the resource management planning effort for the Kanab 

Field Office. 

Eligibility and tentative classification are determined by an inventory of existing conditions. Eligibility 

involves an evaluation of whether a river or river segment is free-flowing and possesses one or more 

ORVs. If found eligible, a river is analyzed as to its current level of development (e.g., water resources 

projects, shoreline development, and accessibility) and segmented accordingly. Each river segment is 

given one of three tentative classifications—“wild,” “scenic,” or “recreational”—based on the degree of 

development. The final procedural step, suitability, provides the basis for determining whether to 

recommend a river as part of the National Wild and Scenic Rivers System (NWSRS). 

On December 13, 1994, an interagency agreement was signed by the Bureau of Land Management 

(BLM) (Utah State Office), the U.S. Department of Agriculture (USDA) Forest Service (Intermountain 

Region), and the National Park Service (Rocky Mountain Region). The agreement calls for the three 

agencies to “work cooperatively to define common criteria and processes for use in determining the 

eligibility and suitability of Utah rivers for potential inclusion by Congress in the [national system of 

Wild and Scenic Rivers].” The product of this agreement is the Wild and Scenic River Review in the State 

of Utah: Process and Criteria for Interagency Use, also known as the Utah Wild and Scenic River “Blue 

Book,” published in June 1996. This publication supplements the Wild and Scenic Rivers Act by 

providing clear, specific criteria for identifying eligible rivers, including identification and evaluation of 

ORVs. 

Guidance used for this study is also contained in the Wild and Scenic Rivers–Policy and Program 

Direction for Identification, Evaluation, and Management, Bureau of Land Management Manual–8351. 

In June 2004, the BLM issued IM-2004-196, which clarified policy in BLM Manual–8351 with respect to 

eligibility criteria and protective management. In addition, various technical papers published by the 

Interagency Wild and Scenic Rivers Coordination Council related to the evaluation of rivers were used. 

These publications may be found at www.nps.gov/rivers/publications.html. 
Appendix 13 Proposed RMP and Final EIS 

A13-2 Kanab RMP 

II. ELIGIBILITY AND TENTATIVE CLASSIFICATION

Eligibility Determination Considerations 

For a river to be eligible for inclusion in the national system of rivers, the Wild and Scenic Rivers Act 

specifies that certain criteria (discussed below) must be met. These criteria apply not only to each 

potentially eligible river but also to their immediate environment, which is defined as a river corridor 

extending, on average, 1⁄4 mile from both sides of the high water mark. For purposes of the eligibility 

inventory, attention was not given to land ownership other than to ensure that at least some portion of a 

river segment crosses federal lands administered by the Kanab Field Office. The status of land ownership, 

however, is evaluated as a consideration in the suitability step of the study process, and is presented in 

detail in Section III of this appendix. 

Free-Flowing Character 

To be considered a free-flowing river, it must be a flowing body of water, or estuary, or section, portion, 

or tributary thereof, including rivers, streams, creeks, runs, kills, rills, and small lakes [Section 16 (a)]. A 

river can be any size or length, and does not have to be floatable or boatable. For purposes of eligibility 

determination, a river’s flow is sufficient as long as it sustains or complements the ORV for which the 

river is found to be eligible. The body of water must be existing or flowing in a natural condition without 

major modification of the waterway, such as channelization, impoundment, diversion, straightening, riprapping, or other modification. However, some minor modifications can be allowed, such as low dams, 

diversion works, and minor structures [Section 16 (b)]. The river can lie between impoundments or major 

dams. 

Outstandingly Remarkable Values 

The Wild and Scenic Rivers Act specifies that rivers “with their immediate environment, must possess 

outstandingly remarkable scenic, recreational, geologic, fish and wildlife, historic, cultural, or other 

similar value” [Section 1 (b)]. 

The “Blue Book” further describes values and characteristics of each that are used to determine which 

values are outstandingly remarkable and at least regionally significant. The following summarizes the 

characteristics of each value that would render it rare, unique, or exemplary: 

• Scenic: Diversity of view, special features, seasonal variations, and cultural features 

• Recreational: Diversity of use, experience quality, length of season, access, level of use, 

attraction, sites and facilities, and associated opportunities 

• Geologic: Feature abundance, diversity of features, and educational /scientific importance 

• Fish: Habitat quality, diversity of species, values of species, abundance of fish, natural 

reproduction, size and vigor of fish, quality of experience, cultural/historic importance, 

recreational importance, and access 

• Wildlife: Habitat quality, diversity of species, abundance of species, natural reproduction, size 

and vigor of fish, quality of experience, cultural/historic importance, recreational importance, and 

access 

• Historic: Significance, site integrity, education/interpretation, and listing in or eligibility for 

listing in the National Register of Historic Places (NRHP) 

• Cultural: Significance, current uses, number of cultures, site integrity, education/interpretation, 

and listing in or eligibility for listing in NRHP 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-3 

• Ecologic: Species diversity, ecological function, rare communities, and educational/scientific 

features. 

Because these values must be at least regionally significant to be considered outstandingly remarkable, a 

region of comparison is necessary to guide the evaluation of a value’s significance. On May 8, 2002, an 

interagency team consisting of representatives of various National Forests, National Parks, and BLM 

offices within Utah concluded that using applicable ecological sections, or combinations of these sections, 

would be the most appropriate way to delineate regions of comparison. Ecological sections are basically 

subunits of physiographic provinces such as the Colorado Plateau. 

Ecological sections provide clear parameters of major ecological systems as defined by geology, 

topography, climate, and so on, and are typically the most distinct, visible features of the landscape. They 

offer an excellent context with relative consistency of scenic, wildlife, and other values for comparison, 

and are large enough to encompass areas with similar values without forcing comparison of disparate 

values. 

Team members relied on professional expertise, personal knowledge of the river segments, and field visits 

to determine if values were outstandingly remarkable. The interdisciplinary team generally defined the 

region of comparison as the Colorado Plateau. The region of comparison is intended to guide the 

evaluation, but it can vary for different resource considerations. The interdisciplinary team included an 

archeologist, hydrologist, geologist, rangeland specialists, wildlife biologist, recreation planner, realty 

specialist, landscape architect, land use planner, and geographic information system (GIS) specialist. If a 

segment was free-flowing and had at least one ORV, it was considered eligible. The team determined that 

15 river segments were preliminarily eligible for congressional designation as Wild and Scenic Rivers. 

Tentative Classification 

Eligible rivers are given a tentative classification. The Wild and Scenic Rivers Act provides for three 

possible classifications: “wild,” “scenic,” or “recreational.” These classifications, when applied to eligible 

rivers, are based on the type and degree of human development associated with the river and adjacent 

lands present at the time of inventory. They also prescribe what management activities would be allowed 

to occur along a river, as long as no ORV is compromised. The tentative classifications are based on the 

following: 

• Wild: Rivers classified as “wild”, which is the most restrictive Wild and Scenic River 

classification, are rivers that are free of impoundments and those that are generally inaccessible 

except by trail, with watersheds or shorelines essentially primitive and waters unpolluted. 

• Scenic: Rivers classified as “scenic” are rivers that are generally free of impoundments, with 

shorelines or watersheds that are still largely primitive and shorelines that are largely 

undeveloped, but accessible in places by roads. 

• Recreational: Rivers classified as “recreational” classification, which is the least restrictive Wild 

and Scenic River classification, are rivers that are readily accessible by road or railroad, that may 

have some development along their shorelines, and that may have substantial evidence of human 

activity. 

The BLM may consider alternative tentative classifications at the time of evaluating suitability, as per 

BLM Manual 8351.33C, to resolve potential conflicts with other management objectives (whether BLM’s 

or those of another official entity), provide continuity of management prescriptions, or on the basis of 

other management considerations within the river area. Final classification of a river segment is 

determined if and when a river is designated for entry into the national system. 
Appendix 13 Proposed RMP and Final EIS 

A13-4 Kanab RMP 

Eligibility Determinations Process 

The eligibility of the Paria River segment located within the Paria Canyon–Vermilion Cliffs Wilderness 

was determined in a previous study. The segment of the Paria River in Utah was found to be eligible in 

the Final Arizona Statewide Wild and Scenic Rivers Legislative Environmental Impact Statement, 

December 1994. 

Coordination 

In November 1997, a Memorandum of Understanding (MOU) was signed between the State of Utah and 

the BLM by former governor, Mike Leavitt, and former BLM state director, William Lamb, to establish a 

cooperative effort for Wild and Scenic River study processes for BLM field offices in Utah. In addition, 

Kane County previously established a cooperative agreement with the BLM for land use planning in a 

MOU signed February 2004. Likewise, Garfield County agreed to cooperate in a similar MOU signed 

July 2004. These agreements enabled the BLM to expand the interdisciplinary team of specialists formed 

for this study process to include representatives from these governments. 

Identification of Rivers for Review 

The role of federal land management agencies is to review rivers under their jurisdictions to determine 

their eligibility, tentative classification, and suitability for congressional designation. A river means a 

flowing body of water or estuary or a section, portion, or tributary thereof, including rivers, streams, 

creeks, runs, kills, rills, and small lakes. The evaluation process began with the solicitation of public 

nominations for eligible rivers. During that process, no nominations were received from the public. The 

interdisciplinary team then considered all drainages crossing public lands within the Kanab Field Office 

decision area, as depicted on BLM 1:100,000 scale topographic maps. These drainages were reviewed to 

determine if they were (1) free-flowing and (2) contained any potential ORVs as defined in the Wild and 

Scenic Rivers Act. In addition, the BLM used information from the Utah Rivers Council and the National 

Rivers Inventory. In all, 50 drainages were reviewed. 

Rivers Studied—Not Considered Further 

The following rivers were considered potentially eligible in the initial review of the decision area. 

However, they were found to be ephemeral, not free-flowing, or void of any ORVs. As directed by IM2004-196 (Clarification of Policy in the BLM Manual Section 8351, Wild and Scenic Rivers, with Respect 

to Eligibility Criteria and Protective Management), segments “should not be ephemeral (flow lasting only 

few days out of a year).” 

• Johnson Wash—Ephemeral, not free-flowing. 

• Fisher Canyon—Ephemeral, no ORVs. 

• Robinson Creek—Ephemeral, no ORVs. 

• Sink Valley Wash—Ephemeral, no ORVs. 

• Trail Canyon—Ephemeral, no ORVs. 

• Pugh Canyon—Ephemeral, no ORVs. 

• Toms Canyon—Not free-flowing due to diversions. 

• Maranger Canyon—Ephemeral, no ORVs. 

• Willis Canyon (Complex)—Ephemeral, no ORVs. 

• Oak Canyon—Ephemeral, no ORVs. 

• Dairy Canyon—Ephemeral, no ORVs. 

• Steep Trail Spring Canyon—No ORVs. 

• Red Hollow—Not free-flowing, no ORVs. 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-5 

• Dry Wash—Ephemeral, no ORVs. 

• Lydia’s Canyon—Not free-flowing, no ORVs. 

• Smith Creek—Not free-flowing, no ORVs. 

• Limekiln Creek—No ORVs. 

• Peterson Wash—Ephemeral, no ORVs. 

• Sanford Creek—No ORVs. 

• Butler Wash—Ephemeral, no ORVs. 

• Bunting Canyon—Ephemeral, no ORVs. 

• Panguitch Creek—Mostly private, only 660 feet on BLM lands. 

• Escalante Creek—Only 2,300 feet on land outside the Grand Staircase–Escalante National 

Monument (GSENM), character not the same as what was found suitable in GSENM plan. Was 

found not eligible in GSENM planning process. 

• Buckskin Gulch—Ephemeral. 

• Wire Pass—Ephemeral. 

• Varney Griffin—No ORVs. 

Potentially Eligible Rivers Considered 

From among all of the streams identified, focus was narrowed by the interdisciplinary team to those 

identified as potentially eligible. Following the review of 50 drainages, 34 river segments were identified 

as potentially eligible or requiring further review. Table A13-1 is a list of these segments and the 

evaluation of findings. 

Table A13-1. Summary of All Potentially Eligible River Segments Considered, and 

Identification of Outstandingly Remarkable Values 

Segment Description County Drainage 

Typei 

FreeFlowingii 

Potential 

Outstandingly 

Remarkable 

Value(s) 

North Fork Virgin River—Segment 48-49 

Section 31-33 (northeast of Zion National Park 

[NP]). 

Kane Perennial Yes 

Scenic 

Geologic 

Wildlife 

Recreational 

North Fork Virgin River—Segment 46-47 

Section 34 up to private land boundary in 

northwest quarter of Section 24.

Kane Perennial Yes 

Scenic 

Wildlife 

Recreational 

East Fork Virgin River—Segment 36-41 

private property to Zion NP boundary. Kane Perennial Yes 

Scenic 

Geologic 

Wildlife 

Fish 

Historic 

Ecologic 

Recreational 

Cultural 
Appendix 13 Proposed RMP and Final EIS 

A13-6 Kanab RMP 

Segment Description County Drainage 

Typei 

FreeFlowingii 

Potential 

Outstandingly 

Remarkable 

Value(s) 

Orderville Gulch (Esplin Gulch)—Segment 44-

45 Zion NP boundary to the falls; Esplin Gulch 

Segment 45-45A.

Kane Perennial Yes 

Scenic 

Recreational 

Geologic 

Wildlife 

Ecologic 

Bob Creek (tributary of Orderville Gulch)—

Segment 42-43 from diversion to Bob Creek in 

Section 6.

Kane Perennial Yes Scenic 

Meadow Creek / Mineral Gulch—Segments 

33-35 and 35-38 south of Highway 9 to 

confluence with Mineral Gulch, then to 

confluence with East Fork Virgin River. 

Kane Perennial Yes 

Scenic 

Recreational 

Geologic 

Deep Creek—Segment 50-51 from 

Washington County line to BLM boundary in 

Section 30. 

Kane Perennial Yes Scenic 

Kanab Creek—Segment 7-8 south of Alton at 

Alton Sink Valley Road to the falls. Kane Perennial No None 

Kanab Creek—Segment 8-9 from falls to BLM 

boundary in northeast corner in Section 32. Kane Intermittent Yes 

Scenic 

Recreational 

Wildlife 

Kanab Creek—Segment 9-10 from Point 9 to 

dam north of Kanab. Kane Perennial Yes 

Scenic 

Wildlife 

Cottonwood Creek—Segment 28-29 

beginning in Section 10 at BLM boundary, 

ending at confluence with Indian Canyon.

Kane Perennial Yes 

Scenic 

Recreational 

Wildlife 

Cultural 

Cottonwood Creek—Segment 31-32 

beginning at confluence with Indian Canyon to 

BLM boundary in Section 3.

Kane Perennial No None 

Indian Canyon—Segment 26-27 from head of 

canyon to confluence with Cottonwood Creek. Kane Perennial Yes 

Scenic 

Recreational 

Geologic 

Ecologic 

South Fork Indian Canyon—Segment 22-23 

from head of South Fork Indian Canyon to 

BLM boundary in northeast corner of Section 

20.

Kane Perennial Yes 

Scenic 

Recreational 

Wildlife 

Cultural 

Ecologic 

North Branch of South Fork Indian Canyon—

Segment 23-24 from point where canyon 

deepens to BLM boundary in southeast corner 

of Section 17. 

Kane Perennial Yes 

Scenic 

Recreational 

Geologic 

Cultural 

Ecologic 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-7 

Segment Description County Drainage 

Typei 

FreeFlowingii 

Potential 

Outstandingly 

Remarkable 

Value(s) 

Water Canyon—Segment 20-21 beginning at 

head of canyon to BLM boundary in Section 

21. 

Kane Perennial Yes 

Scenic 

Recreational 

Geologic 

Ecologic 

Hell Dive Canyon—Segment 30-31 from point 

where canyon deepens to confluence with 

Cottonwood Creek. 

Kane Perennial Yes 

Scenic 

Recreational 

Geologic 

Cultural 

Ecologic 

Thompson Creek—Segment 5-6 beginning at 

BLM boundary just south of confluence with 

Birch Creek to BLM boundary at south end of 

Section 19. 

Kane Perennial Yes None 

Mill Creek (tributaries)—Segment 2-4 

beginning at BLM boundary in southeast 

corner of Section 34 to BLM boundary in 

eastern part of Section 20.

Kane Perennial Yes None 

Mill Creek (tributaries)—Segment 1-3 Mineral 

Creek from BLM property line in Section 4 to 

confluence with Mill Creek.

Kane Perennial Yes None 

Hog Canyon (tributaries)—Segment 16-19 

beginning at headwaters to TV Hill Road in 

Section 10.

Kane Intermittent Yes None 

Hog Canyon (tributaries)—Segment 17-18 

South Fork Hog Canyon, beginning at 

headwaters in Section 12 to confluence with 

main stem Hog Canyon in Section 11. 

Kane Intermittent Yes None 

Hog Canyon (tributaries)—Segment 14-15 

North Fork Hog Canyon beginning at 

Crocodile Road in Section 34 to confluence 

with main stem. 

Kane Intermittent Yes None 

Tiny Canyon—Section 10-11 beginning at 

BLM boundary in Section 6 to confluence with 

Kanab Creek. 

Kane Perennial Yes Wildlife 

Paria River—Segment 68-69 beginning at 

Wilderness/GSENM boundary to Arizona 

border; entire segment is within Paria 

Canyon–Vermilion Cliffs Wilderness. 

Kane Perennial Yes 

Scenic 

Recreational 

Geologic 

Wildlife 

Sevier River—Segment 53-55 beginning at 

BLM boundary in Section 6 north to BLM 

boundary in Section 8. 

Garfield Perennial No None 

Sevier River—Segment 52-53 from BLM 

boundary in Section 8 to BLM boundary in 

northeast part of Section 15 north of Hatch. 

Garfield Perennial No None 
Appendix 13 Proposed RMP and Final EIS 

A13-8 Kanab RMP 

Segment Description County Drainage 

Typei 

FreeFlowingii 

Potential 

Outstandingly 

Remarkable 

Value(s) 

Three Mile Creek—Segment 56-57 beginning 

at the Dixie National Forest boundary in 

Section 11 to BLM boundary in Section 7.

Garfield Perennial Yes Fish 

Sandy Creek—Segment 58-59 beginning at 

BLM boundary in Section 35 to State 

boundary in Section 35. 

Garfield Perennial Yes None 

Bear Creek—Segment 60-61 from BLM 

boundary in Section 6 to BLM boundary in 

Section 9.

Garfield Perennial No None 

Choke Cherry Creek—Segment 54-55 from 

BLM boundary in Section 11 to confluence 

with Sevier River. 

Garfield Perennial Yes None 

Birch Creek—Segment 64-65 from BLM 

boundary in Section 11 to BLM boundary in 

Section 17. 

Garfield Perennial Yes None 

North Creek (tributaries)—Segment 66-67 

from BLM boundary to BLM boundary in 

Section 9-16. 

Garfield Perennial Yes None 

Upper Valley Creek—Segment 58-59 from 

BLM boundary in Section 4 to BLM boundary 

in Section 17 just upstream of confluence with 

Birch Creek. 

Garfield Perennial No None 

Notes: 

i - Drainages were identified as one of three types: 

• Perennial—Stream that flows continuously. Perennial streams are generally associated with a water table in the localities 

through which they flow. 

• Intermittent—Stream that flows only at certain times of the year when it receives water from springs or from some surface 

source such as melting snow in mountainous areas. 

• Ephemeral—Stream that flows only in direct response to precipitation, and whose channel is above the water table at all 

times. 

ii "Free-flowing"—Means existing or flowing in a natural condition without impoundment, diversion, straightening, rip-rapping, or 

other modifications of the waterway. The existence, however, of low dams, diversion works, or other minor structures at the time 

any river is proposed for inclusion in the National Wild and Scenic River System shall not bar its consideration for such inclusion.

Identification of Outstandingly Remarkable Values 

Following interdisciplinary team review of the 34 segments, 18 segments were identified as being freeflowing, being either perennial or intermittent, and potentially possessing one or more ORVs. Table A13-

2 identifies and describes the ORV analysis of these 18 segments. 

Table A13-2. Evaluation of Outstandingly Remarkable Values 

North Fork Virgin River 

Segment 48-49 Section 31-33 (northeast of Zion 

NP). 

Eligible in Section 31-32 

Values evaluated and determined outstandingly remarkable: 

• Scenic—Entire segment is rated as Class A scenery. 

• Recreational—Used for hiking (which requires a permit to 

enter Zion NP, the Narrows). Segment is highly valued for 

hiking, backpacking, nature study, and photography in an 

exceptionally scenic, wilderness-quality setting. 

• Wildlife—Possible neotropical migratory bird habitat 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-9 

Tentative Classification: Wild (Migratory Bird Treaty Act, Executive Order 13186). Spotted 

owl (threatened species) designated critical habitat 

cooperatively managed with Zion NP. 

Value evaluated, not determined outstandingly remarkable: 

• Geologic—All exposed formations can be seen in several 

other canyons in the area, and are not rare or unique. 

North Fork Virgin River 

Segment 46-47 Section 34 up to private land 

boundary in northwest quarter of Section 24. 

Not Eligible 

Values evaluated, none determined outstandingly 

remarkable: 

• Scenic—Entire segment is rated as Class A scenery, but 

the scenery is not notable, scarce, or exemplary when 

compared with other scenery in the region. 

• Wildlife—Spotted owl designated critical habitat is present; 

however, checkerboard ownership makes management 

difficult. 

• Recreational—Not much recreational use due to large 

amounts of private property. 

East Fork Virgin River 

Segment 36-41 private land to Zion NP boundary. 

Eligible 

Tentative Classification: Wild, Scenic, and 

Recreational 

Values evaluated and determined outstandingly remarkable: 

• Scenic—Entire segment is rated as Class A scenery. 

• Cultural—Numerous cultural resource sites considered 

eligible for listing in NRHP within the river canyon, plus 

dense concentrations of Virgin Anasazi sites situated on 

benches above the canyon.

• Recreational—Segment is highly valued for hiking, 

backpacking, nature study, and photography in an 

exceptionally scenic, wilderness-quality setting. 

• Fish—Habitat and populations of sensitive fish.

• Wildlife—Possible neotropical migratory bird habitat 

(Migratory Bird Treaty Act, Executive Order 13186), 

sensitive amphibian habitat. Spotted owl designated critical 

habitat. 

• Historic—John Wesley Powell exploration in the river 

canyon in 1872. 

• Ecologic—Unique plant community (hanging gardens). 

Value evaluated, not determined outstandingly remarkable: 

• Geologic—All exposed formations can be seen in several 

other canyons in the area, and are not rare or unique. 

Orderville Gulch (Esplin Gulch) 

Segment 44-45 Zion NP boundary to the falls; 

Esplin Gulch Segment 45-45A. 

Eligible 

Tentative Classification: Wild 

Values evaluated and determined outstandingly remarkable: 

• Scenic—Entire segment is rated as Class A scenery. 

• Recreational—Segment is heavily used and highly valued 

for hiking, photography, and canyoneering. Opportunities in 

a canyon setting very similar to those in adjacent Zion NP. 

• Wildlife—Possible neotropical migratory bird habitat 

(Migratory Bird Treaty Act, Executive Order 13186). Spotted 

owl nesting habitat. 

• Ecologic—Unique plant community (hanging gardens). 

Value evaluated, not determined outstandingly remarkable: 

• Geologic—All exposed formations can be seen in several 

other canyons in the area, and are not rare or unique. 

Bob Creek (tributary of Orderville Gulch) 

Segment 42-43 from diversion to Bob Creek in 

Values evaluated, none determined outstandingly 

remarkable: 

• Scenic—Entire segment is rated as Class A scenery, but 
Appendix 13 Proposed RMP and Final EIS 

A13-10 Kanab RMP 

Section 6. 

Not Eligible 

the scenery is not notable, scarce, or exemplary when 

compared with other scenery in the region. 

Meadow Creek / Mineral Gulch 

Segments 33-35 and 35-38 south of Highway 9 to 

confluence with Mineral Gulch, then to 

confluence with East Fork Virgin River. 

Eligible 

Tentative Classification: Wild 

Values evaluated and determined outstandingly remarkable: 

• Scenic—Majority of segment is Class A scenery. Scenic 

values of sculptured slickrock and ledges untouched by 

human influence. 

• Recreational—Segment is popular with visitors seeking 

exceptionally scenic hiking, backpacking, photography, and 

nature study opportunities in a dramatic, deep canyon 

setting where solitude abounds.

Value evaluated, not determined outstandingly remarkable: 

• Geologic—All exposed formations can be seen in several 

other canyons in the area, and are not rare or unique. 

Deep Creek

Segment 50-51 from Washington County line to 

BLM boundary in Section 30. 

Eligible 

Tentative Classification: Wild 

Value evaluated and determined outstandingly remarkable: 

• Scenic—Entire segment is rated as Class A scenery; 

access is limited due to surrounding private property.

Kanab Creek 

Segment 8-9 from the falls to BLM boundary in 

northeast corner in Section 32. 

Not Eligible 

Values evaluated, none determined outstandingly 

remarkable: 

• Scenic—Deep gorge carved in Navajo Sandstone with 

mature ponderosa pine; approximately 50% of segment is in 

Class A scenery, but the scenery is not especially 

outstanding when compared with other scenery in the 

region. 

• Recreational—Most recreation use is by local residents

and is similar in nature to that occurring in several other 

similar settings near Kanab.

• Wildlife—Little riparian vegetation. No Southwestern willow 

flycatcher habitat. Within Paunsaguant deer herd 

management area. 

Kanab Creek 

Segment 9-10 from Point 9 to dam north of 

Kanab. 

Not Eligible 

Values evaluated, none determined outstandingly 

remarkable: 

• Scenic—Scenery is not notable, scarce, or exemplary when 

compared with other scenery in the region.

• Wildlife—Neotropical migratory bird habitat; however, it is 

not exemplary when compared with other habitat in the 

region.

• Recreational—Most recreation use is by local residents. 

Cottonwood Creek 

Segment 28-29 beginning in Section 10 at BLM 

boundary ending at confluence with Indian 

Canyon. 

Eligible 

Tentative Classification: Wild 

Values evaluated and determined outstandingly remarkable: 

• Recreational—Canyon offers exceptional non-motorized/ 

non-mechanized recreation opportunities in an enticing 

canyon setting. 

• Cultural—Two eligible sites within segment, but NRHPlisted site 42Ka1581 Cottonwood Canyon Cliff Dwellings 

and four nearby rock art sites, are found in a tributary 

canyon to the east. 

• Wildlife—Neotropical migratory bird habitat (Migratory Bird 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-11 

Treaty Act, Executive Order 13186). 

Value evaluated, not determined outstandingly remarkable: 

• Scenic—Class A scenery; scenery is not especially 

notable, scarce, or exemplary when compared with other 

scenery in the vicinity of Kanab. 

Indian Canyon 

Segment 26-27 from head of canyon to 

confluence with Cottonwood Creek. 

Eligible 

Tentative Classification: Wild 

Values evaluated and determined outstandingly remarkable: 

• Scenic—Deep, narrow canyon, Class A scenery. 

• Recreational—Canyon offers non-motorized/nonmechanized recreation opportunities (e.g., hiking, 

canyoneering, photography, and nature study) in a highly 

scenic and diverse canyon setting. 

• Ecologic—Unique plant community (hanging gardens). 

Value evaluated, not determined outstandingly remarkable: 

• Geologic—All exposed formations can be seen in several 

other canyons in the area, and are not rare or unique.

South Fork Indian Canyon 

Segment 22-23 from head of South Fork Indian 

Canyon to BLM boundary in northeast corner of 

Section 20. 

Eligible 

Tentative Classification: Wild 

Values evaluated and determined outstandingly remarkable: 

• Scenic—Deep, narrow canyon, Class A scenery.

• Recreational—Canyon offers exceptional non-motorized/ 

non-mechanized recreation opportunities (e.g., hiking, 

canyoneering, photography, and nature study) in a highly 

scenic and diverse canyon setting. 

• Ecologic—Unique plant community (hanging gardens). 

Value evaluated, not determined outstandingly remarkable: 

• Geologic—All exposed formations can be seen in several 

other canyons in the area, and are not rare or unique. 

North Branch of South Fork Indian Canyon 

Segment 24-25 from point where canyon 

deepens to BLM boundary in southeast corner of 

Section 17. 

Eligible 

Tentative Classification: Wild 

Values evaluated and determined outstandingly remarkable: 

• Scenic—Deep, narrow canyon, Class A scenery.

• Recreational—Canyon offers exceptional non-motorized/ 

non-mechanized recreation opportunities (e.g., hiking, 

canyoneering, photography, and nature study) in a highly 

scenic and diverse canyon setting. 

• Cultural—One recorded site, 42Ka1576 South Fork Indian 

Canyon Pictographs, eligible for listing in NRHP. 

• Ecologic—Unique plant community (hanging gardens); 

Zion jamesia (sensitive plant) is present. 

Value evaluated, not determined outstandingly remarkable: 

• Geologic—All exposed formations can be seen in several 

other canyons in the area, and are not rare or unique. 

Water Canyon 

Segment 20-21 from point where canyon 

deepens to BLM boundary in Section 21. 

Eligible 

Tentative Classification: Wild 

Values evaluated and determined outstandingly remarkable: 

• Scenic—Deep, narrow canyon, Class A scenery. 

• Recreational—Canyon offers non-motorized/mechanized 

recreation opportunities (e.g., hiking, canyoneering, 

photography, and nature study) in a highly scenic and 

diverse canyon setting. 

• Ecologic—Unique plant community (hanging gardens); 

Zion jamesia (sensitive plant) is present. 

Value evaluated, not determined outstandingly remarkable: 

• Geologic—All exposed formations can be seen in several 

other canyons in the area, and are not rare or unique. 
Appendix 13 Proposed RMP and Final EIS 

A13-12 Kanab RMP 

Hell Dive Canyon 

Segment 30-31 from point where canyon 

deepens to confluence with Cottonwood Creek. 

Eligible 

Tentative Classification: Wild 

Values evaluated and determined outstandingly remarkable: 

• Scenic—Deep, narrow canyon, Class A scenery. 

• Recreational—Canyon offers exceptional non-motorized/ 

non-mechanized recreation opportunities (e.g., hiking, 

canyoneering, photography, and nature study) in a highly 

scenic and diverse canyon setting. 

• Cultural—One recorded rockshelter/rock art/structural site, 

eligible for listing in NRHP. 

• Ecology—Unique plant community (hanging gardens); Zion 

jamesia (sensitive plant) is present.

Value evaluated, not determined outstandingly remarkable: 

• Geologic—All exposed formations can be seen in several 

other canyons in the area, and are not rare or unique.

Paria River 

Segment 68-69 beginning at Wilderness/GSENM 

boundary to Arizona border; entire segment is 

within Paria Canyon–Vermilion Cliffs Wilderness. 

Eligible 

Tentative Classification: Wild 

Value determined outstandingly remarkable: 

• Scenic—Class A scenery. 

• Wildlife—Neotropical migratory bird habitat (Migratory Bird 

Treaty Act, Executive Order 13186).

• Recreational—Wilderness hiking and backpacking; 

opportunities for primitive experience and solitude in a 

dramatic, narrow desert canyon setting. 

Three Mile Creek 

Segment 56-57 beginning at the Dixie National 

Forest boundary in Section 11 to BLM boundary 

in Section 7. 

Eligible 

Tentative Classification: Recreation 

Value evaluated and determined outstandingly remarkable: 

• Fish—Bonneville cutthroat trout (sensitive species) present. 

Summary of Rivers Determined Eligible 

Following analysis of the ORVs, 15 segments (identified in Table A13-3) were determined to be either 

perennial or intermittent, free-flowing, and possessing ORVs, judged regionally or nationally significant, 

and, therefore, declared eligible for inclusion in the NWSRS. These eligible segments are analyzed in the 

Draft RMP/EIS for their potential suitability for inclusion in the NWSRS. 

Table A13-3. Rivers Determined Eligible for Designation into the NWSRS 

Segment 

Name 

Outstandingly Remarkable 

Value(s) 

Miles in 

Decision 

Area 

River 

Corridor 

(acres) 

River 

Corridor in 

Decision 

Area (acres) 

% of River 

Corridor in 

Decision 

Area 

North Fork Virgin 

River scenic, recreational, wildlife 2.2 500 430 86 

East Fork Virgin 

River (three 

segments) 

scenic, cultural, recreational, 

fish, wildlife, historical, ecologic 13.5 2,510 2,510 100 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-13 

Segment 

Name 

Outstandingly Remarkable 

Value(s) 

Miles in 

Decision 

Area 

River 

Corridor 

(acres) 

River 

Corridor in 

Decision 

Area (acres) 

% of River 

Corridor in 

Decision 

Area 

Orderville Gulch 

(Esplin Gulch) 

scenic, recreational, wildlife, 

ecologic 3.2 640 590 92 

Meadow 

Creek/Mineral 

Gulch 

scenic, recreational 9.2 1,780 1,760 99 

Deep Creek scenic 0.7 210 130 62 

Cottonwood 

Creek recreational, cultural, wildlife 1.1 320 280 87 

Indian Canyon scenic, recreational, ecologic 0.7 160 140 88 

South Fork 

Indian Canyon scenic, recreational, ecologic 1.8 490 450 92 

North Branch of 

South Fork 

Indian Canyon 

scenic, recreational, cultural, 

ecologic 0.4 110 90 82 

Water Canyon scenic, recreational, ecologic 3.2 710 710 100 

Hell Dive Canyon scenic, recreational, cultural, 

ecologic 1.4 350 350 100 

Paria River scenic, wildlife, recreational 4.8 1,090 1,020 100 

Three Mile Creek fish 3.7 850 770 91 

Totals 45.9 9,720 9,200 95 

III. SUITABILITY

Determination of Suitability 

Rivers determined to be eligible for inclusion into the NWSRS are further evaluated to determine their 

suitability for inclusion into the national system. 

The purpose of the suitability step of the study process is to determine whether eligible rivers would be 

appropriate additions to the national system by considering tradeoffs between corridor development and 

river protection. Suitability considerations include the environmental and economic consequences of 

designation and the manageability of a river if it were designated by Congress. 

The EIS evaluates impacts that would result if the eligible rivers were determined suitable and managed 

to protect their free-flowing nature, tentative classification, and ORVs. It also addresses impacts that 

would result if the eligible rivers are determined not suitable and their values are not provided protective 

management. The range of alternatives include the no action alternative (Alternative A), which does not 

address or provide for decisions on suitability, but leaves rivers eligible, and Alternative C, which finds 

all eligible rivers suitable. Alternative D finds none of the eligible rivers suitable; Alternative B finds 

some eligible rivers suitable. Alternative tentative classifications are also evaluated. 
Appendix 13 Proposed RMP and Final EIS 

A13-14 Kanab RMP 

In addition to the impact analysis addressed by alternative, the following suitability considerations are 

applied to each eligible river: 

• Characteristics that do or do not make the area a worthy addition to the national system 

• Status of land ownership and use in the area 

• Uses, including reasonably foreseeable potential uses, of the area and related waters that would be 

enhanced, foreclosed, or curtailed if the area were included in the national system of rivers; and 

the values that could be foreclosed or diminished if the area is not protected as part of the national 

system 

• Interest by federal, tribal, state, local, and other public entities in designation or non-designation 

of a river, including the extent to which the administration of the river, including the costs 

thereof, can be shared by the above mentioned entities 

• Ability of the agency to manage and protect the values of a river area if it were designated, and 

other mechanisms to protect identified values other than Wild and Scenic Rivers designation 

• The estimated cost, if necessary, of acquiring lands, interests in lands, and administering the area 

if it were included in the national system 

• The extent to which administration costs will be shared by local and state governments. 

Coordination 

A series of interdisciplinary meetings was held from October 2005 through September 2006 during the 

suitability step of the study process. Cooperating agencies also participated in the process and attended 

the meetings. In addition to numerous internal meetings, a series of meetings and field trips were held in 

summer 2006 to review potentially eligible/suitable segments with cooperating agencies. 

Suitability Study 

Public comments received on the Draft Evaluation Report: Wild and Scenic River Eligibility Kanab 

Resource Management Plan have been used to improve the documentation of the suitability 

considerations presented below, and to document the impacts that would result from the various 

alternatives. The actual determination of whether or not each eligible river segment is suitable is a 

decision that will be made in the Record of Decision for the Kanab Resource Management Plan (RMP). 

North Fork Virgin River—Segment 48-49 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic, recreational, and wildlife values. These values 

are described in detail below. 

Scenic 

This entire segment is rated Class A scenery. The lack of man-made structures; variety of natural shapes, 

textures, and colors; and the gradual transition from a relatively open valley stream setting to a deeply 

entrenched, prominent slot canyon make the North Fork Virgin River exceptionally scenic and 

photogenic. 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-15 

Recreational 

Because the North Fork serves as the main entrance to the Zion Narrows trek within Zion National Park 

(NP), the main recreation activity involves trekkers accessing the park. The outstanding scenery and 

wilderness-like setting make the trek along the river unique and exceptionally satisfying. Day use 

activities include hiking into portions of the canyon, nature photography, wildlife viewing, and occasional 

hunting. Private land upstream of the BLM segment limits off-highway-vehicle (OHV) use to only an 

occasional authorized vehicle. There is no motorized travel allowed beyond the east boundary of the 

North Fork Virgin River Wilderness Study Area (WSA). 

Wildlife 

This segment includes possible neotropical migratory bird habitat. It is also Mexican spotted owl 

designated critical habitat. 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 86 percent federally managed public lands. 

This segment is used by recreationists to access the narrows within Zion NP. The upper reach of this 

segment, above the canyon narrows, is used for livestock grazing and dispersed recreation. Private land 

ownership upstream of the WSA limits motorized access to the river segment. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

Current recreational uses would be preserved by congressional designation, protecting the values 

associated with the non-motorized uses and perceived natural condition and scenic values. Recreational 

enhancements would be limited to increased signage and management if designated. 

The North Fork Virgin River WSA includes 46 percent of the public lands along this segment. These 

lands have been recommended by the BLM to Congress for wilderness designation. Designation of this 

stream into the NWSRS would be compatible with and would enhance wilderness use and management of 

the area. 

Congressional designation would provide permanent protection specifically for the free-flowing condition 

of the river, its water quality, and its ORVs. This would be in addition to protection already afforded by 

the WSA status. Failure to include the river segment in the NWSRS, on the other hand, would not 

necessarily diminish the values on the basis of which the river was determined eligible inasmuch as the 

area’s WSA status would continue. Furthermore, many of the other land use prescriptions (e.g., Special 

Recreation Management Area [SRMA] designation) being considered in the EIS would also preserve and 

enhance such values if implemented. Such prescriptions would be temporary, however, and could be 

changed through plan amendment or plan revision. 

Inclusion of a river into the NWSRS could preclude the construction of dams or other water-related 

projects if they would occur within the designated segment and have direct and/or adverse effects on the 

ORVs (e.g., scenic, recreational, and wildlife) or free-flowing condition. None are currently proposed. 

Other projects on federal lands within the designated river area, such as construction of roads, pipelines, 

or other structures, would not be allowed, and the lands would be closed to mineral location if Congress 

were to classify this segment as “wild.” However, considering the area’s WSA status, no such 

development is currently proposed or foreseeable within the federal portion of this segment. Water-related 

projects proposed outside the segment would be precluded only if they would invade or unreasonably 
Appendix 13 Proposed RMP and Final EIS 

A13-16 Kanab RMP 

diminish scenic, recreational, or wildlife values within the designated segment. None are currently 

proposed. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

The National Park Service (NPS) has recommended the river portion that extends within Zion NP for 

Wild and Scenic River designation. Administration of recreation resources and activities within the 

segment could be shared with Zion NP. 

Local and state agencies and water users oppose designation primarily over their concerns that current 

and potential water use of this or any eligible stream could be affected. However, there are no current or 

foreseen uses that would be affected. Some private citizens and regional and national conservation groups 

have promoted the suitability of this stream for congressional designation. The Kaibab band of the 

Southern Paiute Tribe supports any potential Wild and Scenic River designation. Kane County comments 

state, “If determined suitable the County suggests the segment begin at the WSA boundary where it 

incises into the canyon rather than at the proposed location in the valley.” 

5. Manageability of the river if designated, and other means of protecting values 

Land status and classification level would not create problems for manageability. The BLM would be 

capable of managing this segment if it were designated, particularly with adequate funding. Wild and 

Scenic River designation would increase the Utah BLM’s ability to compete for agency dollars, and with 

increased funding and focused management, the agency’s ability to deal with recreational management of 

the area would improve. Designation would promote national and public recognition of the values 

associated with this segment and further the goals and policy established by Congress in the Wild and 

Scenic Rivers Act. 

The free-flowing nature of this stream is not currently at risk, and the identified ORVs on public lands 

could be effectively managed under land use prescriptions being considered in the EIS, if designation 

does not occur and if the management prescriptions are implemented. These prescriptions would be 

associated with the North Fork Virgin River WSA. The river corridor within the WSA is managed 

according to the Interim Management Policy (IMP). Protection would also be afforded by designation of 

the North Fork Virgin River SRMA. The status of the WSA, SRMA, and other management prescriptions 

is subject to change due to congressional action or revised land use plans. Therefore, the protection these 

designations afford the river values is subject to change. However, the isolation of the stream due to the 

very limited public access and the extreme topography inevitably provides additional protection. 

6. The estimated costs of administering the river, including costs for acquiring lands 

Costs could be reduced due to shared management with the NPS. Possible costs could be incurred due to 

acquisition of a small portion of the segment currently in private ownership. However, Kane County has a 

“no net loss” policy regarding private property, and would be unsupportive of BLM attempts to acquire 

private land. There is a concern about private riparian lands in the corridor. Other costs could be related to 

a management plan, if shared management with the NPS is not feasible. 

7. The extent to which administration costs will be shared by local and state governments 

State and local governments have made it clear that they would not share management costs of designated 

streams. 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-17 

East Fork Virgin River—Segment 37-41 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic, recreational, cultural, historic, fish, wildlife, and 

ecologic values. These values are described in detail below. 

Scenic 

This entire segment is rated as Class A scenery, and is characterized by colorful sandstone canyon rims 

rising several hundred feet above the river valley floor. The river meanders frequently along a ribbon of 

riparian vegetation. Streamside cliffs and distant slopes and precipices range from light buff shades to 

dark reds and browns, all sprinkled with various greens and yellows of the many trees, shrubs, forbs, and 

grasses of Parunuweap Canyon. Spring and early summer blossoms add touches of red, orange, yellow, 

and pale blue wildflowers. Signs of human occupation or disturbance along the river segment are rare, so 

the scenery is thoroughly primitive, spectacularly wild, and wholly natural in appearance. 

Recreational 

The East Fork Virgin River flows directly into the southeastern portion of Zion NP, and the scenery is 

very similar to that portion of the park. Typical recreation use consists of backpackers conducting multiday trips from the upper reach of the river within the Parunuweap WSA to the exit route near 

Checkerboard Mesa in the park. Day hikes to various portions of the river segment are also common. Allterrain vehicle (ATV) riders occasionally reach the river shores, although motorized travel is restricted by 

WSA interim management to only one or two sites along the entire river segment. Canyoneering, wildlife 

viewing, and nature study are frequent attractions to visitors. Hunting is allowed, but is not often 

encountered along the river segment because of the lack of easy motorized access and the steep slopes 

and cliffs along the river bank the farther downstream one travels. 

Cultural 

There are numerous cultural resource sites considered eligible for listing in the NRHP within the river 

canyon, and there are dense concentrations of Virgin Anasazi sites situated on the benches above the 

canyon. Older and younger sites are present as well. These sites, especially those within the narrow 

confines of the canyon, are an important scientific resource that contributes to the ORVs of this river 

segment. 

Historic 

John Wesley Powell explored this river canyon in 1872. 

Fish 

This segment includes habitat and populations of native fish. It is also the upland watershed for sensitive 

fisheries downstream of the Zion NP boundary.

Wildlife 

This segment includes possible neotropical migratory bird habitat and sensitive amphibian habitat. It is 

also Mexican spotted owl designated critical habitat. 
Appendix 13 Proposed RMP and Final EIS 

A13-18 Kanab RMP 

Ecologic 

This segment contains unique plant communities (hanging gardens). 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 100 percent federally managed public lands. 

This segment has been used for accessing the Fat Man’s Misery portion of Zion NP; however, Zion NP 

does not permit use through its portion of Parunuweap Canyon. There are high levels of non-motorized 

recreation use on the public lands portions of the canyon. Lands associated with this segment are also 

used for livestock grazing. Kane County claims two RS-2477 rights-of-way within proximity to the river. 

Although one route is not currently used for crossing the river, the historic route of the other road crosses 

the river several times in the space of about 3 miles, just upstream from this river segment. Both routes 

are open to OHV travel according to county ordinance. 

This entire segment is within the Parunuweap WSA and is managed according to the (IMP). The IMP 

does not allow for new developments or surface-disturbing activity. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

Designation of this segment as a “wild” river segment could create conflict with use along the RS-2477 

claimed routes. 

Uses and values that would be affected by congressional designation are also addressed in the cumulative 

impacts section of the EIS. 

All of the public lands within this segment of the East Fork Virgin River are within the Parunuweap 

Canyon WSA. This portion of the WSA has been recommended by BLM to Congress for wilderness 

designation. Designation of this stream into the NWSRS would be compatible with and enhance 

wilderness use and management of the area. 

Congressional designation would provide permanent protection specifically of the free-flowing condition 

of the river, its water quality, and its ORVs. This would be in addition to the protection already afforded 

by the WSA status. Failure to include this segment of the East Fork Virgin River in the NWSRS, on the 

other hand, would not necessarily diminish the values on the basis of which the river was determined 

eligible, inasmuch as the area’s WSA status would continue and other land use prescriptions (e.g., 

Parunuweap SRMA) being considered in the Draft RMP/EIS would also preserve and enhance such 

values if implemented. Such prescriptions would be temporary, however, and could be changed. 

Inclusion of a river into the NWSRS could preclude construction of dams or other water-related projects 

if they would occur within the designated segment and would have direct and/or adverse effects on the 

ORVs or free-flowing condition. None are currently proposed. Other projects on federal lands within the 

designated river area, such as construction of roads, pipelines, or other structures, would not be allowed, 

and the lands would be closed to mineral location if Congress were to classify this segment as “wild.” 

However, considering the area’s WSA status, no such development is currently proposed or foreseeable. 

Water-related projects proposed outside the segment would be precluded only if they would invade or 

unreasonably diminish scenic, recreational, cultural, historic, fish, wildlife, or ecologic values within the 

designated segment. None are currently proposed. 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-19 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

The NPS has recommended the river portion that extends within Zion NP for WSR designation. 

Administration of recreational resources and activities within the segment could be shared with Zion NP. 

State and local governments might support congressional designation of this segment, but not upstream of 

the claimed RS-2477 roads. Kane County representatives have noted that the county would be more 

comfortable supporting designation of the lower portion of the segment where the canyon is void of roads 

or development. 

Local and state agencies and water users oppose designation primarily over their concerns that current 

and potential water use of this or any eligible segments could be affected. However, there are no current 

or foreseen uses of the river segment that would be affected. Some private citizens and regional and 

national conservation groups have promoted the suitability of this segment for congressional designation. 

The Kaibab band of the Southern Paiute Tribe supports any potential Wild and Scenic River designation. 

5. Manageability of the river if designated, and other means of protecting values 

See initial paragraph under suitability consideration #5 for North Fork Virgin River Segment 48-49 

above. The river segment would be manageable due to public land ownership, but RS-2477 assertions 

could create conflicts in management. 

The free-flowing nature of this stream is not currently at risk, and the identified ORVs on public lands 

could be effectively managed under land use prescriptions being considered in the EIS, if designation 

does not occur and if the management prescriptions are implemented. These prescriptions would be 

associated with the Parunuweap Canyon WSA. The river corridor within the WSA is managed according 

to the IMP. Protection would also be afforded river values by the proposed Parunuweap SRMA. The 

status of the WSA, SRMA, and other management prescriptions is subject to change due to congressional 

action or revised land use plans. Therefore, the protection these designations afford the river values is 

subject to change. However, the isolation of the stream due to the very limited public access and the 

extreme topography inevitably provides additional protection. 

6. The estimated costs of administering the river, including costs for acquiring lands 

The initial costs of administration for the first 3 years would involve preparing a management plan. 

Yearly administration costs thereafter would involve plan implementation, and may include additional 

studies and monitoring as well as additional BLM presence in the area. Long-term costs would be related 

primarily to enforcement. Costs could be reduced by sharing management with the NPS. Other costs 

could be related to a management plan, if shared management with the NPS is not feasible. 

7. The extent to which administration costs will be shared by local and state governments 

State and local governments have made it clear that they would not share management costs of designated 

streams. 
Appendix 13 Proposed RMP and Final EIS 

A13-20 Kanab RMP 

East Fork Virgin River—Segment 36-37 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic, recreational, cultural, historic, fish, wildlife, and 

ecologic values. These values are described in detail below. 

Scenic 

This entire segment is rated as Class A scenery, and is characterized by colorful sandstone canyon rims 

rising several hundred feet above the river valley floor. The river meanders frequently along a ribbon of 

riparian vegetation. Streamside cliffs and distant slopes and precipices range from light buff shades to 

dark reds and browns, all sprinkled with various greens and yellows of the many trees, shrubs, forbs, and 

grasses of Parunuweap Canyon. Spring and early summer blossoms add touches of red, orange, yellow, 

and pale blue wildflowers. Signs of human occupation or disturbance along the river segment are limited 

to vehicle tracks crossing the river at several locations, so the scenery is heavily primitive, wild, and 

natural in appearance. 

Recreational 

The East Fork Virgin River flows directly into the southeastern portion of Zion NP, and the scenery is 

similar to that portion of the park. Typical recreation use consists of backpackers conducting multi-day 

trips from the upper reach of the river within the Parunuweap WSA to the exit route near Checkerboard 

Mesa in the park. Day hikes to various portions of the river segment are also common. ATV riders 

traverse the stream channel along the entire river segment. Wildlife viewing and nature study are frequent 

attractions to visitors. Hunting and OHV touring are other popular activities along this segment. 

Cultural 

There are numerous cultural resource sites considered eligible for listing in the NRHP within the river 

canyon, and there are dense concentrations of Virgin Anasazi sites situated on the benches above the 

canyon. Older and younger sites are present as well. These sites, especially those within the narrow 

confines of the canyon, are an important scientific resource that contributes to the ORVs of this river 

segment. 

Historic 

John Wesley Powell explored the river canyon in 1872. 

Fish 

This segment includes habitat for and populations of sensitive fish. 

Wildlife 

This segment has possible neotropical migratory bird habitat and sensitive amphibian habitat. It is also 

Mexican spotted owl designated critical habitat. 

Ecologic 

This segment contains unique plant communities (hanging gardens). 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-21 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 100 percent federally managed public lands. The road 

within the corridor is adjacent to the river, crosses it several times, and is currently open to motorized 

recreation. The area is also popular for hunting, nature study, and horseback riding. Livestock grazing 

occurs along this segment and on adjacent lands; there are also range improvements to support livestock 

grazing. The segment is completely within the Parunuweap Canyon WSA and is managed according to 

the IMP. 

Present within or along the majority of this segment of the East Fork Virgin River is a historical OHV 

route. Thus, vehicle-based recreation occurs often on the route, except for during periods of high runoff 

during spring snowmelt or flash flood events. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

Designation as “recreational” would not diminish motorized use on the route or hunting. Uses and values 

that would be affected by congressional designation are also addressed in the cumulative impacts section 

of the EIS. 

The entire reach of this segment of the East Fork Virgin River is within the Parunuweap Canyon WSA. 

This portion of the WSA has been recommended by BLM to Congress for wilderness designation. 

Designation of this segment into the NWSRS would be compatible with and would enhance wilderness 

use and management of the area. Congressional designation would provide permanent protection 

specifically of the free-flowing condition of the river, its water quality, and its ORVs. This would be in 

addition to protection already afforded to the river corridor by the WSA status. Within the WSA, failure 

to include this segment in the NWSRS, on the other hand, would not necessarily diminish the values for 

which the segment was determined eligible, inasmuch as the area’s WSA status would continue, and other 

land use prescriptions (e.g., SRMA designation) being considered in the EIS would also preserve and 

enhance such values if implemented. Such prescriptions would be temporary, however, and could be 

changed through plan amendment or plan revision. 

Inclusion of a river into the NWSRS could preclude construction of dams or other water-related projects 

if they would occur within the designated segment and would have direct and/or adverse effects on the 

ORVs (scenic, recreational, cultural, historic, fish, wildlife, and ecologic) or free-flowing condition. 

Water-related projects proposed outside the segment would be precluded only if they would invade or 

unreasonably diminish those ORVs within the designated segment. No such projects inside or 

immediately outside of the river area are currently proposed. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

The NPS has recommended the river portion that extends within Zion NP for WSR designation. 

Local and state agencies and water users oppose designation primarily over their concerns that current 

and potential water use of this or any eligible stream could be affected. However, there are no current or 

foreseen uses of the East Fork Virgin River that would be affected. Some private citizens and regional and 

national conservation groups have promoted the suitability of this stream for congressional designation. 

The Kaibab band of the Southern Paiute Tribe supports any potential Wild and Scenic River designation. 
Appendix 13 Proposed RMP and Final EIS 

A13-22 Kanab RMP 

5. Manageability of the river if designated, and other means of protecting values 

See initial paragraph under suitability consideration #5 for North Fork Virgin River Segment 48-49 

above. The free-flowing nature of this segment is not currently at risk, and the identified ORVs could, for 

the most part, be effectively managed under land use prescriptions being considered in the EIS, if 

designation does not occur and if the management prescriptions are implemented. These prescriptions 

would be associated with visual and cultural resource management and the Parunuweap SRMA. 

Protection is also currently afforded this portion of the segment corridor by Parunuweap Canyon WSA. 

The river corridor within the WSA is managed according to the IMP. The status of the WSA, SRMA, and 

other management prescriptions is subject to change due to congressional action or revised land use plans. 

Therefore, the protection they afford the river values is subject to change. 

6. The estimated costs of administering the river, including costs for acquiring lands 

Costs would be the same as those for the lower East Fork of Virgin River Segment 48-49. 

7. The extent to which administration costs will be shared by local and state governments 

State and local governments have made it clear that they would not share management costs of designated 

streams. 

Orderville Gulch (Esplin Gulch)—Segment 44-45 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic, recreational, geologic, wildlife, and ecologic 

values. These values are described in detail below. 

Scenic 

This entire segment is rated Class A scenery. This segment is similar in scenic qualities to those of 

adjacent Zion NP. The proposed segment has a slot waterfall just less than 100 feet in height. 

Recreational 

The outstanding scenery and wilderness-like setting make the trek along the river unique and 

exceptionally satisfying. Day use activities include hiking into portions of the canyon, nature 

photography, wildlife viewing, and occasional hunting. Private land upstream of the BLM segment limits 

OHV use to only an occasional authorized vehicle. There is no motorized travel allowed beyond the east 

boundary of the Orderville Canyon WSA. The trailhead parking area is located on private property that 

will probably be developed in the future. The trail below the waterfall is very primitive and steep. The 

segment enters Zion NP at the Kanab Field Office decision area boundary. 

Wildlife 

This segment contains designated critical habitat for the Mexican spotted owl and is adjacent to the 

protected activity center (PAC) for the Mexican spotted owl. 

Ecologic 

This segment contains unique plant communities (hanging gardens). 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-23 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 92 percent federally managed public land. This 

segment is used by recreationists to access the Orderville Canyon Narrows hike in Zion NP. The upper 

reach of this segment, above the canyon narrows, is used for livestock grazing and dispersed recreation. 

Private land ownership upstream of the WSA could limit motorized access to the river segment. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

Current recreational uses would be preserved by congressional designation, protecting the values 

associated with the non-motorized uses and the perceived natural condition and scenic values. 

Recreational enhancements would be limited to increased signage and management if designated. 

The Orderville Canyon WSA includes 84 percent of the public lands along this segment. These lands 

have been recommended by BLM to Congress for wilderness designation. Designation of this stream into 

the NWSRS would be compatible with and would enhance wilderness use and management of the area. 

Congressional designation would provide permanent protection specifically of the free-flowing condition 

of the river, its water quality, and its ORVs. This would be in addition to protection already afforded to 

the lower portions of the corridor by the WSA status. Failure to include this segment of Esplin Gulch in 

the NWSRS, on the other hand, would not necessarily diminish the values for which the river was 

determined eligible, inasmuch as the area’s WSA status would continue. Furthermore, many of the other 

land use prescriptions (e.g., SRMA designation) being considered in the EIS would also preserve and 

enhance such values if implemented. Such prescriptions would be temporary, however, and could be 

changed through plan amendment or plan revision. 

See last paragraph under suitability consideration #3 for the North Fork Virgin River Segment 48-49 

above. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

The lower reaches of the Orderville Canyon drainage, of which Esplin Gulch is a tributary, extend within 

Zion NP, and the NPS has recommended for designation. Administration of recreation within the segment 

could be shared with Zion NP. 

Local and state agencies and water users oppose designation primarily over their concerns that current 

and potential water use of this or any eligible stream could be affected. However, there are no current or 

foreseen uses that would be affected. Some private citizens and regional and national conservation groups 

have promoted the suitability of this stream for congressional designation. The Kaibab band of the 

Southern Paiute Tribe supports any potential Wild and Scenic River designation. 

5. Manageability of the river if designated, and other means of protecting values 

See initial paragraph under suitability consideration #5 for North Fork Virgin River Segment 48-49 

above. 

The free-flowing nature of this stream is not currently at risk, and the identified ORVs on public lands 

could be effectively managed under land use prescriptions being considered in the EIS, if designation 

does not occur and if the management prescriptions are implemented. These prescriptions would be 

associated with the Orderville Canyon WSA. The river corridor within the WSA is managed according to 
Appendix 13 Proposed RMP and Final EIS 

A13-24 Kanab RMP 

the IMP. Protection would also be afforded by designation of the Orderville Canyon SRMA. The status of 

the WSA, SRMA, and other management prescriptions is subject to change due to congressional action or 

revised land use plans. Therefore, the protection these designations afford the river values is subject to 

change. However, the isolation of the stream due to the very limited public access and the extreme 

topography inevitably provides additional protection. 

6. The estimated costs of administering the river, including costs for acquiring lands 

See suitability consideration #6 for North Fork Virgin River Segment 48-49 above. 

7. The extent to which administration costs will be shared by local and state governments 

State and local governments have made it clear that they would not share management costs of designated 

streams. 

Meadow Creek / Mineral Gulch—Segments 33-35 and 35-38 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic and recreational values. These values are 

described in detail below. 

Scenic 

The majority of this segment is class A scenery; with sculpted slickrock and canyon ledges untouched by 

human influence. Scenic values closely resemble those of side canyons of the East Fork Virgin River, of 

which Meadow Creek / Mineral Gulch is a tributary. Steep, towering canyon walls frame the winding 

creek bottom, with no road access and no human structures anywhere along the segment. Approximately 

1 1⁄2 miles upgradient from the East Fork Virgin River is a series of slot canyons. 

Recreational 

Recreation use tends to be light because physical access is difficult. Activities and uses probably consist 

mainly of occasional hikers and backpackers and a few adventurous hunters. The wild, pristine nature of 

the canyon offers exceptional solitude and superb opportunities for photography and wildlife and nature 

study. 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 99 percent federally managed public lands. 

Current uses include primitive types of recreation. The area is located within a livestock allotment, but 

difficult accessibility results in low use levels. This river segment is within the Parunuweap Canyon WSA 

and is managed according to the IMP. The IMP does not allow for new developments or surfacedisturbing activity. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

Uses and values that would be affected by congressional designation are also addressed in the cumulative 

impacts section of the EIS. 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-25 

The area is popular for hunting. Livestock grazing occurs along this segment and on adjacent lands. There 

are range improvements to support livestock grazing. Designation could result in increased use that could 

change some recreation experiences and detract from solitude opportunities. 

The Meadow Creek / Mineral Gulch segment corridor is 89 percent within the Parunuweap Canyon WSA. 

The portion of the WSA that includes this segment has been recommended by BLM to Congress for 

wilderness designation. Designation of this stream into the NWSRS would be compatible with and 

enhance wilderness use and management of the area. 

See last two paragraphs under suitability consideration #3 for North Fork Virgin River Segment 48-49 

above. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

Zion NP has not expressed any interest in designation. The current level of use is lower than that in the 

lower East Fork Virgin River. 

State and local governments are unsupportive of congressional designation of this stream. Local and state 

agencies and water users oppose designation primarily over concerns that potential water use of this or 

any eligible stream could be affected. However, there are no current or foreseen water uses of Meadow 

Creek / Mineral Gulch that would be affected. Some private citizens and regional and national 

conservation groups have promoted the suitability of this stream for congressional designation. The 

Kaibab band of the Southern Paiute Tribe supports any potential Wild and Scenic River designation. 

5. Manageability of the river if designated, and other means of protecting values 

See initial paragraph under suitability consideration #5 for North Fork Virgin River Segment 48-49 

above. 

The BLM would be capable of managing this stream if it were designated, particularly with adequate 

funding. The BLM currently has little to no on-the-ground presence; however, the remoteness and 

difficult access have kept visitation light. Resources are fragile and could suffer degradation if visitation 

were to increase significantly with designation. Wild and Scenic River designation would increase the 

Utah BLM’s ability to compete for agency dollars. With increased funding and focused management, the 

agency’s ability to deal with recreational management of the area would improve. Designation would 

promote national and public recognition of the values associated with this stream and further the goals 

and policy established by Congress in the Wild and Scenic Rivers Act. 

The free-flowing nature of this stream is not currently at risk, and the identified ORVs could be 

effectively managed under land use prescriptions being considered in the EIS, if designation does not 

occur and if the management prescriptions are implemented. These prescriptions would be associated 

with the Parunuweap SRMA. Protection is also currently afforded river values by the Parunuweap 

Canyon WSA. The river corridor within the WSA is managed according to the IMP. The status of the 

WSA, SRMA, and other management prescriptions is subject to change due to congressional action or 

revised land use plans. Therefore, the protection they afford the river values is subject to change. 

6. The estimated costs of administering the river, including costs for acquiring lands 

The initial costs of administration for the first 3 years would involve preparing a management plan. 

Yearly administration costs thereafter would involve plan implementation, and may include additional 

studies and monitoring as well as additional BLM presence in the area. 
Appendix 13 Proposed RMP and Final EIS 

A13-26 Kanab RMP 

7. The extent to which administration costs will be shared by local and state governments 

State and local governments have made it clear that they would not share management costs of designated 

streams. 

Deep Creek—Segment 50-51 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic values. The entire segment is rated as Class A 

scenery. This segment has scenery reminiscent of the North Fork of the Virgin River, just outside of the 

Zion NP boundary. 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 62 percent federally managed public lands. 

Uses include recreation (particularly horseback riding, hunting, and hiking), livestock grazing, and 

wildlife habitat. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

Uses and values that would be affected by congressional designation are also addressed in the cumulative 

impacts section of the EIS. 

Inclusion of a river into the NWSRS could preclude construction of dams or other water-related projects 

if they would occur within the designated segment and would have direct and/or adverse effects on the 

outstandingly remarkable scenic values or free-flowing condition. Water-related projects proposed 

outside the segment would be precluded only if they would invade or unreasonably diminish scenic 

values within the designated segment. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

State and local governments are unsupportive of congressional determination of this stream. Local and 

state agencies, water users, and municipalities oppose designation primarily over their concerns that 

current and potential water use of this or any eligible stream could be affected. Some private citizens and 

regional and national conservation groups, however, have promoted the suitability of this stream for 

congressional designation. The Kaibab band of the Southern Paiute Tribe supports any potential Wild and 

Scenic River designation. 

5. Manageability of the river if designated, and other means of protecting values 

Land status and classification level would create problems for manageability because the segment is 

isolated and surrounded by private land. Although there are portions of this river upstream and 

downstream that are recommended for designation in the NWSRS, none of those are directly contiguous. 

The physical isolation and lack of legal public access would provide the greatest degree of protection to 

this area. 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-27 

6. The estimated costs of administering the river, including costs for acquiring lands 

The initial costs of administration for the first 3 years would involve preparing a management plan. 

Yearly administration costs thereafter would involve plan implementation, and may include additional 

studies and monitoring as well as a BLM presence in the area. If other portions of the river were 

designated, cost-sharing with the other agencies could reduce administrative costs. 

7. The extent to which administration costs will be shared by local and state governments 

State and local governments have made it clear that they would not share management costs of designated 

streams. 

Cottonwood Creek—Segment 28-29 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

Cottonwood Creek possesses outstandingly remarkable recreational, cultural, and wildlife values. These 

values are described in detail below. 

Recreational 

Cottonwood Creek offers exceptional non-motorized/non-mechanized recreation opportunities in a scenic, 

enticing canyon setting. The variety of topography, vegetation, geology, and wildlife create a setting that 

is highly attractive to both day use hikers and overnight campers. 

Cultural 

There are two sites eligible for listing in the NRHP within the segment. NRHP -listed site 42Ka1581 

Cottonwood Canyon Cliff Dwellings is within the segment corridor. 

Wildlife 

This segment includes neotropical migratory bird habitat; it is also a limited deer use area. 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 87 percent federally managed public lands. 

This segment is adjacent to the Moquith Mountain WSA, and 9 percent of the corridor is within the WSA, 

providing for primitive recreation. While the segment is not totally within the WSA, the corridor offers a 

scenic, solitary backcountry experience. The river segment is used for occasional recreational activities, 

including hunting, hiking, camping, wildlife viewing, and nature photography. There are no motorized 

routes along the segment. Although the area is open to livestock grazing, no use has occurred in the Water 

Canyon Allotment for several years. Fredonia has permitted water and public lands development rights 

dating to at least the 1940s. This segment corridor is used as a surface-water collection area for the 

Fredonia water source. 
Appendix 13 Proposed RMP and Final EIS 

A13-28 Kanab RMP 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

Congressional designation would provide permanent protection specifically of the free-flowing condition 

of the river, its water quality, and its ORVs. Designation of this river into the NWSRS would be 

compatible with and would enhance wilderness use and management of the Moquith Mountain WSA. 

Inclusion of a river into the NWSRS could preclude construction of dams or other water-related projects 

if they would occur within the designated segment and would have direct and/or adverse effects on the 

ORVs or free-flowing condition. This could conflict with current water use of the surface water collection 

system and would prevent or restrict future water development. Other projects on federal lands within the 

designated river area, such as construction of roads, pipelines, or other structures, would not be allowed, 

and the lands would be closed to mineral location if Congress were to classify this segment as “wild.” 

Water-related projects proposed outside the segment would be precluded only if they would invade or 

unreasonably diminish recreational, cultural, or wildlife values within the designated segment. In addition 

to limiting future water developments for the town of Fredonia, congressional designation of this segment 

would advertise the canyons to the public, creating additional visitation, which would potentially impact 

the town’s water quality. 

On the other hand, failure of Congress to include this segment in the NWSRS would not necessarily 

diminish the values on the basis of which the river was determined eligible because of the SRMA and 

Area of Critical Environmental Concern (ACEC) designations proposed for the canyon and the overlap 

and/or presence of the Moquith Mountain WSA. Likewise, the Cottonwood Canyon ACEC provides for 

the protection of certain values within the river corridor. Furthermore, the proposed Moquith Mountain 

SRMA would protect certain resources that contribute to the recreational values within the river segment. 

However, the status of the WSA, proposed SRMA, ACEC, and other management prescriptions are 

subject to change due to congressional action or future revisions to land use plans. Such prescriptions 

would be temporary, however, and could be changed through plan amendment or plan revision. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

Local and state agencies, municipalities, and water users oppose designation primarily over their concerns 

that current and potential water use of this or any eligible segment in this area could be affected. These 

organizations have expressed concerns that existing water rights and developments could be affected and 

that opportunities for future water development could be foreclosed, not only within the designated river 

segments but also upstream or downstream of these segments. Some private citizens and regional and 

national conservation groups have encouraged or promoted the suitability of this segment for 

congressional designation. The Kaibab band of the Southern Paiute Tribe supports any potential Wild and 

Scenic River designation. 

5. Manageability of the river if designated, and other means of protecting values 

The BLM would be capable of managing this segment if it were designated, particularly with adequate 

funding. Congressional designation of this segment into the NWSRS would increase the BLM’s ability to 

compete for agency dollars, and with increased funding and focused management, the agency’s ability to 

deal with recreational and other management of the area would improve. Designation would promote 

national and public recognition of the values associated with this segment and further the goals and policy 

established by Congress in the Wild and Scenic Rivers Act. 

Designation of this segment would not result in a substantial change in management of the river corridor 

from current management. Other protective management prescriptions currently in place that would 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-29 

complement NWSR management if the segment were designated are those for OHV use, fluid minerals 

leasing, SRMAs, ACECs, WSAs, riparian habitat, and visual resources. The current management would 

provide a large degree of continuity and make the adjustment into management of a “wild” and “scenic” 

area easy because current objectives are similar to those that would result from congressional designation. 

The free-flowing nature of this segment is not currently at risk, and the identified ORVs could be 

effectively managed with existing and other land use prescriptions being considered in the EIS, if 

designation does not occur and if the management prescriptions are implemented. However, the status of 

the WSA, SRMA, ACEC, and other management prescriptions are subject to change due to congressional 

action or revised land use plans. Therefore, the protection they afford the river values is subject to change. 

6. The estimated costs of administering the river, including costs for acquiring lands 

The initial costs of administration for the first 3 years would involve preparing a management plan. 

Yearly administration costs thereafter would involve plan implementation, and may include additional 

studies and monitoring as well as additional BLM presence in the area. Funding is not expected to be 

sought for acquisition of adjacent private land (given willing sellers) because it would not be necessary to 

acquire these lands to adequately manage the designated segments. 

7. The extent to which administration costs will be shared by local and state governments 

Local governments have made it clear that they would not share management costs if this segment were 

designated. 

Indian Canyon—Segment 26-27 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic, recreational, and ecologic values. These values 

are described in detail below. 

Scenic 

This canyon has Class A scenery, is picturesque, and is tightly confined in slickrock walls that are 

punctuated with enticing alcoves and dramatic amphitheaters. The lively small stream adds a water 

feature, and brilliant green vegetation winds through a landscape of colorful rimrock. 

Recreational 

Indian Canyon offers non-motorized, non-mechanized recreational opportunities in an exceptionally 

scenic canyon characterized by slickrock cliffs, ledges and pour-overs, scattered ponderosa pines, and 

many alcoves and recesses fringed with pockets of scrub oak and riparian vegetation. 

Ecologic 

This segment contains unique plant communities (hanging gardens). 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 88 percent federally managed public lands. 
Appendix 13 Proposed RMP and Final EIS 

A13-30 Kanab RMP 

This segment is adjacent to the Moquith Mountain WSA, with 17 percent of the corridor within the WSA, 

providing for primitive recreation. Although the segment is not totally within the WSA, the corridor 

offers a scenic, solitary backcountry experience. Although the area is open to livestock grazing, no use 

has occurred in the Water Canyon Allotment for several years. Fredonia has permitted water and public 

lands development rights dating to at least the 1940s. This segment corridor is used as a surface-water 

collection area for the Fredonia water source. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

See information under suitability consideration #3 for the Cottonwood Canyon segment above. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

See information under suitability consideration #4 for the Cottonwood Canyon segment above. 

5. Manageability of the river if designated, and other means of protecting values 

See information under suitability consideration #5 for the Cottonwood Canyon segment above. 

6. The estimated costs of administering the river, including costs for acquiring lands 

See information under suitability consideration #6 for the Cottonwood Canyon segment above. 

7. The extent to which administration costs will be shared by local and state governments 

See information under suitability consideration #7 for the Cottonwood Canyon segment above. 

South Fork Indian Canyon—Segment 22-23 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic, recreational, and ecologic values. These values 

are described in detail below. 

Scenic 

This canyon has Class A scenery, is picturesque, and is tightly confined in slickrock walls that are 

punctuated with enticing alcoves and dramatic amphitheaters. The lively small stream adds a water 

feature, and brilliant green vegetation winds through a landscape of colorful rimrock. 

Recreational 

The South Fork Indian Canyon offers non-motorized, non-mechanized recreational opportunities in an 

exceptionally scenic canyon characterized by slickrock cliffs, ledges and pour-overs, scattered ponderosa 

pines, and many alcoves and recesses fringed with pockets of scrub oak and riparian vegetation. 

Ecologic 

This segment contains unique plant communities (hanging gardens). 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-31 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 92 percent federally managed public lands. 

This segment corridor is 100 percent contained within the Moquith Mountain WSA and is managed 

according to the IMP, which provides for primitive recreation. Uses also include livestock grazing, 

recreation, and wildlife habitat. The existing Water Canyon/South Fork Indian Canyon ACEC also 

overlaps 9 percent of the segment corridor. Although the area is open to livestock grazing, no use has 

occurred in the Water Canyon Allotment for several years. Fredonia has permitted water and public lands 

development rights dating to at least the 1940s. This segment corridor is used as a surface-water 

collection area for the Fredonia water source. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

See information under suitability consideration #3 for the Cottonwood Canyon segment above. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

See information under suitability consideration #4 for the Cottonwood Canyon segment above. 

5. Manageability of the river if designated, and other means of protecting values 

See information under suitability consideration #5 for the Cottonwood Canyon segment above. 

6. The estimated costs of administering the river, including costs for acquiring lands 

See information under suitability consideration #6 for the Cottonwood Canyon segment above. 

7. The extent to which administration costs will be shared by local and state governments 

See information under suitability consideration #7 for the Cottonwood Canyon segment above. 

North Branch of South Fork Indian Canyon—Segment 24-25 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic, recreational, cultural, and ecologic values. 

These values are described in detail below. 

Scenic 

This canyon has Class A scenery, is picturesque, and is tightly confined in slickrock walls that are 

punctuated with enticing alcoves and dramatic amphitheaters. The lively small stream adds a water 

feature, and brilliant green vegetation winds through a landscape of colorful rimrock. 

Recreational 

The North Branch of South Fork Indian Canyon offers non-motorized, non-mechanized recreational 

opportunities in an exceptionally scenic canyon characterized by slickrock cliffs, ledges and pour-overs, 
Appendix 13 Proposed RMP and Final EIS 

A13-32 Kanab RMP 

scattered ponderosa pines, and many alcoves and recesses fringed with pockets of scrub oak and riparian 

vegetation. 

Cultural 

This segment corridor contains one recorded cultural site, 42Ka1576 South Fork Indian Canyon 

Pictographs, that is eligible for listing in the NRHP. This is a significant rock art panel and is a popular 

local attraction and cultural interpretive site. 

Ecologic 

This segment contains unique plant communities (hanging gardens). The sensitive plant species Zion 

jamesia is also present. 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 82 percent federally managed public lands. 

This segment corridor is 100 percent contained within the Moquith Mountain WSA and is managed 

according to the IMP, which provides for primitive recreation. Uses also include livestock grazing, 

recreation, and wildlife habitat. Primary recreational uses include rock art viewing, nature study, 

photography, and hiking. Local tourism boards promote this area for its prehistoric rock art and other 

cultural and historical values. 

The existing Water Canyon/South Fork Indian Canyon ACEC also overlaps 6 percent of the segment 

corridor. Although the area is open to livestock grazing, no use has occurred in the Water Canyon 

Allotment for several years. Fredonia has permitted water and public lands development rights dating to 

at least the 1940s. This segment corridor is used as a surface-water collection area for the Fredonia water 

source. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

See information under suitability consideration #3 for the Cottonwood Canyon segment above. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing. 

See information under suitability consideration #4 for the Cottonwood Canyon segment above. 

5. Manageability of the river if designated, and other means of protecting values 

See information under suitability consideration #5 for the Cottonwood Canyon segment above. 

6. The estimated costs of administering the river, including costs for acquiring lands 

See information under suitability consideration #6 for the Cottonwood Canyon segment above. 

7. The extent to which administration costs will be shared by local and state governments 

See information under suitability consideration #7 for the Cottonwood Canyon segment above. 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-33 

Water Canyon—Segment 20-21 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic, recreational, and ecologic values. These values 

are described in detail below. 

Scenic 

This canyon has Class A scenery, is picturesque, and is tightly confined in slickrock walls that are 

punctuated with enticing alcoves and dramatic amphitheaters. The lively small stream adds a water 

feature, and brilliant green vegetation winds through a landscape of colorful rimrock. 

Recreational 

The South Fork Indian Canyon offers non-motorized, non-mechanized recreational opportunities in an 

exceptionally scenic canyon characterized by slickrock cliffs, ledges and pour-overs, scattered ponderosa 

pines, and many alcoves and recesses fringed with pockets of scrub oak and riparian vegetation. 

Ecologic 

This segment contains unique plant communities (hanging gardens). The sensitive plant species Zion 

jamesia is also present. 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 100 percent federally managed public lands. 

This segment corridor is 100 percent within the Moquith Mountain WSA and is managed according to the 

IMP, which provides for primitive recreation. The IMP does not allow for new developments or surfacedisturbing activity. Uses also include livestock grazing, recreation, and wildlife habitat. Other uses 

include more primitive types of recreation, such as hiking and camping by scout groups. 

The existing Water Canyon/South Fork Indian Canyon ACEC also overlaps 17 percent of the segment 

corridor. Although the area is open to livestock grazing, no use has occurred in the Water Canyon 

Allotment for several years. Fredonia has permitted water and public lands development rights dating to 

at least the 1940s. This segment corridor is used as a surface-water collection area for the Fredonia watersource. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

See information under suitability consideration #3 for the Cottonwood Canyon segment above. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

See information under suitability consideration #4 for the Cottonwood Canyon segment above. 

5. Manageability of the river if designated, and other means of protecting values 

See information under suitability consideration #5 for the Cottonwood Canyon segment above. 
Appendix 13 Proposed RMP and Final EIS 

A13-34 Kanab RMP 

6. The estimated costs of administering the river, including costs for acquiring lands 

See information under suitability consideration #6 for the Cottonwood Canyon segment above. 

7. The extent to which administration costs will be shared by local and state governments 

See information under suitability consideration #7 for the Cottonwood Canyon segment above. 

Hell Dive Canyon—Segment 30-31 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

This segment possesses outstandingly remarkable scenic, recreational, cultural, and ecologic values. 

These values are described in detail below. 

Scenic 

This canyon has Class A scenery, is picturesque, and is tightly confined in slickrock walls that are 

punctuated with enticing alcoves and dramatic amphitheaters. The lively small stream adds a water 

feature, and brilliant green vegetation winds through a landscape of colorful rimrock. 

Recreational 

The South Fork Indian Canyon offers non-motorized, non-mechanized recreational opportunities in an 

exceptionally scenic canyon characterized by slickrock cliffs, ledges and pour-overs, scattered ponderosa 

pines, and many alcoves and recesses fringed with pockets of scrub oak and riparian vegetation. 

Cultural 

One recorded rockshelter/rock art/structural site, 42Ka1695, in this segment is considered eligible for 

listing in the NRHP. No other sites have been documented in this canyon, but there is potential for finding 

additional sites in the cliffs and overhangs in the vicinity. 

Ecologic 

This segment contains unique plant communities (hanging gardens). The sensitive plant species Zion 

jamesia is also present. 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 100 percent federally managed public lands. 

This segment corridor is 88 percent within the Moquith Mountain WSA and is managed according to the 

IMP, which provides for primitive recreation. The IMP does not allow for new developments or surfacedisturbing activity. Uses include recreation, particularly horseback riding and hiking, livestock grazing, 

and wildlife habitat. Although the area is open to livestock grazing, no use has occurred in the Water 

Canyon Allotment for several years. Fredonia has permitted water and public lands development rights 

dating to at least the 1940s. This segment corridor is used as a surface-water collection area for the 

Fredonia water-source. 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-35 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

See information under suitability consideration #3 for the Cottonwood Canyon segment above. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

See information under suitability consideration #4 for the Cottonwood Canyon segment above. 

5. Manageability of the river if designated, and other means of protecting values 

See information under suitability consideration #5 for the Cottonwood Canyon segment above. 

6. The estimated costs of administering the river, including costs for acquiring lands 

See information under suitability consideration #6 for the Cottonwood Canyon segment above. 

7. The extent to which administration costs will be shared by local and state governments 

See information under suitability consideration #7 for the Cottonwood Canyon segment above. 

Paria River—Segment 68-69 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

The Paria River possesses outstandingly remarkable scenic, recreational, and wildlife values. These 

values are described in detail below. 

Scenic 

Scenery within the Paria River canyon includes sheer, towering walls of colorful sandstone that frame 

overhead skies and a ribbon of water accented by wildflowers, intermittent scatterings of shrubs and 

grasses, and occasional cottonwood trees. Late summer thunderstorms provide contrasts in lighting, color, 

and texture. The deeply entrenched canyon wilderness also provides spectacular nighttime views through 

canyon walls reaching several hundred feet above the river bottom. 

Recreational 

The Paria River canyon offers the opportunity for spectacular hiking and backpacking in a unique, deeply 

entrenched, desert canyon far from the sights and sounds of civilization. Permits for overnight trips 

through the Paria are sought by visitors throughout the United States and overseas. The colorful, sheer 

sandstone cliffs bordering lush riparian vegetation provide exceptional photo opportunities. Wildlife 

viewing leads to frequent sightings of Desert bighorn sheep and a variety of raptors for visitors to this 

site. Day hikers can access portions of the canyon a few miles downstream from the White House 

campground and trailhead. Overnight visitors typically start their trek at White House and continue for 3 

to 5 days, hiking the 38-mile stretch that terminates at Lee’s Ferry on the Colorado River. Because the 

number of permits is regulated on a daily basis, backpackers have excellent opportunities to experience 

solitude and primitive, unconfined recreation in a unique setting. 
Appendix 13 Proposed RMP and Final EIS 

A13-36 Kanab RMP 

Wildlife 

The Paria River is important to numerous avian wildlife species, notably the peregrine falcon. The area 

also contains suitable habitat for the Mexican spotted owl, the Southwestern willow flycatcher, and the 

California condor. This river segment provides excellent nesting and roosting habitat for the Mexican 

spotted owl and the peregrine falcon, although their presence has not been confirmed to date. The river 

segment corridor is also important lambing habitat for Desert bighorn sheep. 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 100 percent federally managed public lands. This 

segment corridor is 100 percent within the Paria Canyon–Vermilion Cliffs Wilderness Area and is 

managed according to the Wilderness Act and the Wilderness Management Plan, which specify managing 

the area for naturalness and providing opportunities for primitive recreation and solitude. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

Designation of this segment into the NWSRS would be compatible with and would enhance wilderness 

use and management of the area. Congressional designation would provide permanent protection 

specifically of the free-flowing condition of the river, its water quality, and its ORVs. This would be in 

addition to protection already afforded to the segment corridor by the wilderness area. A river 

management plan would be prepared on designation. As part of that effort, current activities may be 

monitored to ensure that activities are consistent with the goals of the designation. 

Failure to include this segment in the NWSRS, on the other hand, would not necessarily diminish the 

values on the basis of which the segment was determined eligible, inasmuch as the area’s wilderness area 

status would continue, and other land use prescriptions (e.g., SRMA designation) being considered in the 

EIS would also preserve and enhance such values if implemented. Such prescriptions would be 

temporary, however, and could be changed through plan amendment or plan revision. 

Inclusion of a river in the NWSRS could preclude construction of dams or other water-related projects if 

they would occur within the designated segment and would have direct and/or adverse effects on the 

ORVs or free-flowing condition. Water-related projects proposed outside the segment would be precluded 

only if they would invade or unreasonably diminish those ORVs within the designated segment. No such 

projects inside or immediately outside of the river area are currently proposed. 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

State and local governments are unsupportive of congressional designation of this stream. Some private 

citizens and regional and national conservation groups have promoted congressional designation of this 

river. The Kaibab band of the Southern Paiute Tribe supports any potential Wild and Scenic River 

designation. 

5. Manageability of the river if designated, and other means of protecting values 

See initial paragraph under suitability consideration #5 for the North Fork Virgin River Segment 48-49 

above. 

If the eligible segment of Paria Canyon was found to be not suitable and subsequently not designated by 

Congress, the ORVs (scenic, recreational, and wildlife) for which the segment is found to be eligible 
Proposed RMP and Final EIS Appendix 13 

Kanab RMP A13-37 

would not necessarily diminish. The proposed Paria Canyon SRMA would be managed to offer a certain 

degree of protection to recreational values. Protection is also currently afforded ORVs by the existing 

wilderness designation. The wilderness, including this entire river segment, is managed according to the 

Wilderness Management Plan for Paria Canyon–Vermilion Cliffs Wilderness, which allows for no new 

permanent developments or surface-disturbing activities. The status of the SRMA and other management 

prescriptions are subject to change due to congressional action or revised land use plans. Therefore, the 

protection they afford the river values is subject to change. 

6. The estimated costs of administering the river, including costs for acquiring lands 

The initial costs of administration for the first 3 years would involve preparing a management plan. 

Yearly administration costs thereafter would involve plan implementation, and may include additional 

studies and monitoring as well as additional BLM presence in the area. Costs could be reduced if 

management were shared with the Grand Staircase-Escalante National Monument and the Arizona Strip 

Field Office, both of which manage segments upstream and downstream. 

7. The extent to which administration costs will be shared by local and state governments 

State and local governments have made it clear that they would not share management costs if the Paria 

River were designated. 

Three Mile Creek—Segment 56-57 

1. Characteristics that would or would not make it a worthy addition to the National Wild and 

Scenic Rivers System 

Three Mile Creek possesses an outstandingly remarkable fish value. Bonneville cutthroat trout (sensitive 

species) are present. 

2. Land ownership and current use 

Ownership within the eligible segment corridor is 91 percent federally managed public lands. Uses 

include ranching, livestock grazing, wildlife habitat, and occasional recreational fishing. 

3. Uses, including reasonably foreseeable uses, that would be enhanced or curtailed if 

designated; and values that would be diminished if not designated 

A primary objective for the management of species managed by the Utah Division of Wildlife Resources 

(UDWR) is to enhance streams’ coldwater fisheries habitat and populations. Designation would directly 

contribute to these objectives and also provide for protection of the other values within the stream 

corridor. 

Inclusion of this segment in the NWSRS could preclude construction of dams or other water-related 

projects within the designated segment. This would enhance the viability of the Bonneville cutthroat trout 

population and protect the free-flowing condition. Other projects on federal lands within the designated 

river area, such as construction of roads, recreational facilities, or other structures, may be allowed along 

the segment classified by Congress as “recreational.” 

Failure to include Three Mile Creek in the NWSRS, on the other hand, would not necessarily diminish the 

values for which the river was determined eligible, inasmuch as management implemented in 

coordination with the UDWR would also preserve and enhance such values. 
Appendix 13 Proposed RMP and Final EIS 

A13-38 Kanab RMP 

4. Interest of federal, public, state, tribal, local, or other public entity in designation or nondesignation, including administration sharing 

State and local governments are unsupportive of congressional designation of this stream. These 

governments oppose designation primarily over their perceptions that existing water rights could be 

affected and that opportunities for future water development could be foreclosed. The Kaibab band of the 

Southern Paiute Tribe supports any potential Wild and Scenic River designation. 

5. Manageability of the river if designated, and other means of protecting values 

See initial paragraph under suitability consideration #5 for the North Fork Virgin River Segment 48-49 

above. 

Cooperative management of Three Mile Creek by the BLM and the UDWR would be necessary if the 

stream were to be congressionally designated. This would be expected to be productive because current 

federal and state objectives for the area are consistent. The free-flowing nature of this stream is not 

currently at risk, and the identified ORVs on public lands could be effectively managed under land use 

prescriptions being considered in the EIS, if designation does not occur and if the management 

prescriptions are implemented. 

6. The estimated costs of administering the river, including costs for acquiring lands 

Initial costs of administration for the first 3 years would involve preparing a management plan. Yearly 

administration cost thereafter would involve plan implementation, and may include additional studies, 

monitoring, and additional BLM presence in the area. The BLM would make efforts to work 

cooperatively with the State of Utah to manage Three Mile Creek on designation. 

7. The extent to which administration costs will be shared by local and state governments 

Local governments have made it clear that they would not share management costs if Three Mile Creek 

were designated. Any cooperative management of Three Mile Creek between the BLM and the UDWR 

would potentially require commitments from both entities for adequate funding. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-1 

APPENDIX 14—AREAS OF CRITICAL 

ENVIRONMENTAL CONCERN 

EVALUATION REPORT 

This report documents the process used to evaluate nominations for areas of critical environmental 

concern (ACEC) considered by the Bureau of Land Management (BLM) in developing the Kanab 

Resource Management Plan (RMP). In brief, the BLM interdisciplinary team evaluated five nominations 

for ACECs, totaling 126,170 acres within the decision area. Two nominations covered the same area. Of 

these, four areas totaling 56,800 acres met the criteria for relevant and important values, resources, natural 

systems or processes, or hazards/safety/public welfare (referred to collectively as values) and were 

identified as potential ACECs. In addition, the one existing ACEC (Water Canyon/South Fork Indian 

Canyon) was reviewed and found to contain relevant and important values on areas outside the current 

ACEC boundary (totaling 3,800 acres). 

BACKGROUND

The BLM is directed by law, regulation, and policy to consider designating and protecting ACECs when 

developing land use plans. 

The Law: FLPMA 

In the development and revision of land use plans, the Secretary shall ... give priority to 

the designation and protection of areas of critical environmental concern.—Federal Land 

Policy and Management Act (FLPMA), Title II, Section 202(c)3 

The term “areas of critical environmental concern” (often referred as “ACECs”) means 

areas within the public lands where special management attention is required (when such 

areas are developed or used or where no development is required) to protect and prevent 

irreparable damage to important historic, cultural, or scenic values, fish and wildlife 

resources or other natural systems or processes, or to protect life and safety from natural 

hazards.—FLPMA, Title I, Section 103(a)

The Regulation: 43 CFR 1610.7-2 

To be a potential ACEC, both of the following criteria shall be met: 

• Relevance: There shall be present a significant historic, cultural, or scenic value; a fish or wildlife 

resource or other natural system or process; or a natural hazard. 

• Importance: The above described value, resource, system, process, or hazard shall have 

substantial significance and values. This generally requires qualities of more than local 

significance and special worth, consequence, meaning, distinctiveness, or cause for concern. 

The Policy: BLM Manual 1613 

BLM Manual 1613, Areas of Critical Environmental Concern, provides direction for identifying, 

analyzing, designating, monitoring, and managing ACECs. Key points are as follows: 
Appendix 14 Proposed RMP and Final EIS 

A14-2 Kanab RMP 

• The ACEC designation indicates to the public that the BLM recognizes that an area has 

significant values and has established special management measures to protect those values. 

• Designation of ACECs is performed only through the resource management planning process, 

either in an RMP itself or in a plan amendment. 

• To be designated as an ACEC, an area must require special management attention to protect the 

important and relevant values. 

• Potential ACECs are identified as early as possible in the planning process. 

• Existing ACECs are subject to reconsideration when plans are revised. 

• Members of the public or other agencies may nominate an area for consideration as a potential 

ACEC. BLM personnel are encouraged to recommend areas for consideration as ACECs. 

• No formal or special procedures are associated with nomination. 

• An interdisciplinary team evaluates each resource or hazard to determine if it meets the relevance 

and importance criteria. The field manager approves the relevance and importance criteria. 

• If an area is found not to meet the relevance and importance criteria, the analysis supporting that 

conclusion must be included in the RMP and associated Environmental Impact Statement (EIS). 

EVALUATION PROCESS

Existing ACEC 

One ACEC (220 acres) currently exists within the Kanab Field Office. The existing ACEC was reviewed 

as part of this EIS. It was found to continue to meet mandatory relevance and importance criteria as 

identified in Attachment 1. 

Table A14-1. Existing ACEC 

ACEC Name Public Land Acres County 

Water Canyon/South Fork Indian Canyon 220 Kane 

ACEC Nominations 

Five ACEC nominations were received during the scoping process and subsequent data requests (Map 1, 

Nominated ACECs) (Table A14-2). One area received two nominations (the BLM-administered portion 

of the Coral Pink Sand Dunes) for the same relevant and important values and is evaluated under the 

Welsh’s Milkweed Potential ACEC. Nominations were evaluated in accordance with BLM Manual 1613. 

Values meeting mandatory relevance and importance criteria were identified and are the basis for 

establishing potential ACECs for further consideration in the RMP. (Criteria used for the relevance and 

importance evaluation are included in Attachment 1.) 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-3 

Table A14-2. ACEC Nominations 

Nominated Area Public Land Acres County 

1 Welsh’s Milkweed 3,680 Kane 

2 Vermilion Cliffs 26,486 Kane 

3 White Cliffs 45,916 Kane 

4 Parunuweap Canyon 50,088 Kane 

 Total 126,170 

Potential ACECs 

Following the evaluation of identified values using the relevance and importance criteria, five areas 

(60,600 acres) were identified as potential ACECs (Map 2, Potential ACECs). Descriptions of the 

potential ACECs and suggested management are included in Attachment 2. Potential ACECs were 

delineated in two ways: 

• The potential ACECs for Welsh’s Milkweed, Vermilion Cliffs, White Cliffs, and Parunuweap 

Canyon are smaller than the nominated ACECs because the values determined relevant and 

important are found in only parts of the nominated areas. 

• The potential ACEC for the Cottonwood Canyon area is larger than the existing ACEC (Water 

Canyon/South Fork Indian Canyon) because additional relevant and important values were 

identified outside the existing boundary. 

Table A14-3. Potential ACECs 

Area Name Acreage County 

1 Welsh’s Milkweed 1,300 Kane 

2 Vermilion Cliffs 23,400 Kane 

3 White Cliffs 26,000 Kane 

4 Cottonwood Canyon 3,800 Kane 

5 Parunuweap Canyon 6,100 Kane 

Total 60,600 

ACECs Versus Wilderness 

ACECs may be designated within wilderness areas. ACEC designation shall not be used as a substitute 

for a wilderness suitability recommendation. If an ACEC is proposed within or adjacent to a Wilderness 

Study Area (WSA), the RMP ... “shall provide clear direction of the relationship of the ACEC to the 

recommendations being made for the WSA. The relationship shall be described to the level of detail 

required to avoid misunderstanding or misinterpretation by the public.”—BLM Manual 1613.33D 

“Where ACEC values and wilderness characteristics coincide, the special management associated with an 

ACEC, if designated, may also protect wilderness characteristics.”—IM-2003-275 
Appendix 14 Proposed RMP and Final EIS 

A14-4 Kanab RMP 

Consideration of Potential ACECs in the Draft RMP/EIS 

Potential ACECs are considered in the Kanab Draft RMP/EIS, as follows: 

• Alternative A: Current designation of Water Canyon/South Fork Indian Canyon ACEC (220 

acres) 

• Alternative B: Designate Cottonwood Canyon ACEC (3,800 acres) 

• Alternative C: Designate Cottonwood Canyon ACEC, Welsh’s Milkweed ACEC, Vermilion 

Cliffs ACEC, White Cliffs ACEC, and Parunuweap Canyon ACEC (60,600 acres) 

• Alternative D: Designate no ACECs. 

The environmental consequences of the proposals under each alternative, including threats of irreparable 

damage, are evaluated in Chapter 4 of the Draft RMP/EIS. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-5 

ATTACHMENT 1: RELEVANCE AND IMPORTANCE CRITERIA

THE TASK

The task of evaluating the ACEC nominations was done by the land use planning interdisciplinary team. 

The team’s job was to: 

• Identify the potentially relevant values, resources, processes, systems, and hazards/safety/public 

welfare (referred to collectively as values) 

• Evaluate the potentially relevant values to determine which, if any, meet the relevance criteria 

• Evaluate relevant values to determine which, if any, meet the importance criteria 

• Identify special management to protect and manage relevant and important values

• Map the area(s) of relevance and importance. These maps define the potential ACECs that will be 

considered in the Draft EIS 

• Consider the existing ACEC’s relevant and important values to determine if changes should be 

made during the ongoing planning effort. 

1) Identifying Potentially Relevant Values 

The team reviewed each of the five ACEC nominations to identify potentially relevant values. Only the 

values identified in the nominations were evaluated for relevance. 

2) Determining Relevance 

Potentially relevant values were evaluated based on guidance in 43 CFR 1610.7-2, Designation of Areas 

of Critical Environmental Concern, and BLM Manual 1613, Areas of Critical Environmental Concern. 

Only one of the relevance criteria had to be met for the area to be considered further for importance. 

Historical, Cultural, and Scenic Values 

A historic or cultural value was determined relevant if it: 

• Was determined significant by the staff archaeologist 

• Has been determined to be eligible for the National Register 

• Retains integrity and has research potential and/or is considered important by local Native 

American tribes. 

A scenic value was determined relevant if it was inventoried as Class A scenery by the BLM. 

Fish and Wildlife Resources 

A fish and wildlife resource (including habitat for endangered, sensitive, or threatened species or habitat 

essential for maintaining species diversity) was judged relevant if it or its habitat was documented as 

present within the nominated area. 

Sources of information: 

• Utah Natural Heritage Program Database, operated and maintained by the Utah Division of 

Wildlife Resources (UDWR) 
Appendix 14 Proposed RMP and Final EIS 

A14-6 Kanab RMP 

• UDWR habitat maps for game species 

• U.S. Fish and Wildlife Service (USFWS) habitat data maps, recovery plans, and other 

information. 

Natural Processes or Systems 

Nominated natural processes or systems (e.g., plants, riparian areas, and geologic processes) were 

considered relevant if they were present within the nominated area and included the following: 

• Endangered, sensitive, or threatened plant species (documented occurrences and/or habitat within 

nominated area) 

• Rare, endemic, or relict terrestrial, aquatic, or riparian plants or plant communities (documented 

occurrences and/or habitat within nominated area) 

• Rare geological features. 

Sources of information included the following: 

• Utah Natural Heritage Program Database operated and maintained by the UDWR 

• UDWR habitat maps for game species 

• USFWS habitat data maps 

• Riparian area inventories 

• Existing management plans 

• Wilderness inventory information 

• National Natural Landmark Areas Survey (1980) 

• U.S. Geological Survey (USGS) data. 

Natural Hazards 

A natural hazard was considered relevant if it was so determined by the interdisciplinary team after 

reviewing the information (about the hazard) on a case-by-case basis. 

3) Determining Importance 

Only relevant values were evaluated for importance. In general, the value, resource, system, process, or 

hazard described as relevant had to have substantial significance and values to meet the importance 

criteria. Only one of the importance criteria had to be met for an area to become a potential ACEC. 

Significant Qualities 

To meet the importance criteria, a relevant value had to have more than locally significant qualities that 

gave it special worth, consequence, meaning, distinctiveness, or cause for concern, especially compared 

with any similar resource. 

Historical, Cultural Values 

A relevant historic or cultural value was determined more than locally significant if it was: 

• Listed on the National Register of Historic Places 

• Eligible for listing on National Register of Historic Places 

• Otherwise judged more than locally significant as a result of federal laws, regulations, and 

national BLM policies that mandate consideration and protection of cultural resources. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-7 

Scenic Values 

A relevant scenic value was determined more than locally significant if it was: 

• A national or state scenic designation such as State Scenic Byways, National Scenic Byways, AllAmerican Roads, or BLM Backcountry Byways 

• Otherwise judged more locally significant by the interdisciplinary team. 

Fish and Wildlife Resources or Botanical Processes or Systems 

A relevant fish or wildlife resource or botanical process or system was determined more than locally 

significant if the species is protected under federal law, regulation, or BLM national policy that mandates 

the consideration and protection of species: 

• Special status species, including: 

– Federally listed threatened or endangered species 

– BLM-sensitive species 

– State of Utah species of concern 

• Endemic to nominated area. 

Riparian Systems 

Riparian areas are deemed important because they provide water, food, cover, and travel lanes for many 

aquatic and terrestrial wildlife species. Native riparian area plants and their root systems contribute to 

improved water quality and quantity by holding soils in place while filtering sediments, increasing ground 

water recharge, and protecting stream banks. In the decision area riparian resources encompass less than 

1 percent of the total acres. Because of their limited nature and relative value, all riparian areas are 

deemed important (Utah Riparian Management Policy IM UT-2005-091). 

Natural Hazard 

A relevant natural hazard was more than locally significant if it was so determined by the interdisciplinary 

team after reviewing the information about the hazard. 

Threats and Vulnerability 

The relevant value was determined to meet the importance criteria if it had qualities or circumstances in 

the nominated area that made it: 

• Fragile 

• Sensitive 

• Rare 

• Irreplaceable 

• Exemplary 

• Unique 

• Endangered 

• Threatened 

• Vulnerable to adverse change. 

Determinations of special values, threats, and vulnerability to adverse change were made by staff 

specialists and the interdisciplinary team. 
Appendix 14 Proposed RMP and Final EIS 

A14-8 Kanab RMP 

National Priority 

The relevant values were determined to meet the importance criteria if special protection was warranted 

in order to: 

• Satisfy national priority concerns 

• Carry out FLPMA mandates. 

Historic and Cultural Values—Protection of cultural resources is a national priority; therefore, any 

cultural resource identified as relevant was also determined to be important. 

Scenic Values—A relevant scenic resource that also carried a national designation such as National 

Scenic Byway, All-American Road, or BLM Backcountry Byway was determined important. 

Fish and Wildlife Resources or Botanical Processes or Systems—A relevant, federally listed threatened or 

endangered species was also determined important because of the Endangered Species Act and Executive 

Order (EO) 13186, signed in 2001. This order requires all federal agencies that might have a measurable 

negative effect on migratory birds to develop a Memorandum of Understanding with USFWS in order to 

promote the recommendations of the North America Waterfowl Management Plan, North American Bird 

Conservation Initiative, North American Bird Conservation Act, and other migratory bird programs. The 

EO further requires federal agencies to consider the effects that planned or authorized activities will have 

on migratory birds (Migratory Bird Treaty Act [MBTA] of 1918) and their habitats and to consider 

migratory birds in their land use planning efforts. 

Riparian Systems—The BLM developed the National Riparian-Wetland Initiative for the 1990s. This 

initiative established riparian areas as a national priority, developed goals and objectives for managing 

riparian-wetland resources on public lands, and included a strategy to focus management on entire 

watersheds. The Utah BLM Riparian Management Policy is tiered to this overall national strategy. 

Safety and Public Welfare 

The relevant value was determined to meet the importance criteria if it had qualities that warranted 

highlighting it to satisfy public or management concerns about safety and public welfare. 

Threat to Life and Property 

The relevant value was determined to meet the importance criteria if it poses a significant threat to human 

life and safety or property. 

4) Special Management 

Suggested special management was developed to address, mitigate, or prevent identified threats. 

5) Mapping Potential ACECs 

Values identified as having relevance and importance provided a basis for the potential ACECs. In all 

cases where nominations were reviewed, the BLM interdisciplinary team determined the boundary of the 

potential area to be smaller than the nominated area (see rationale included in Attachment 2). During 

evaluation of the existing ACEC, additional relevant and important values were identified outside of the 

ACEC, and the acreage for the potential ACEC was thus increased. All potential ACECs will be 

evaluated in the Draft RMP/EIS. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-9 

ATTACHMENT 2—EVALUATIONS OF ACEC NOMINATIONS

Welsh’s Milkweed Nominated ACEC 

Nominated by Laura Fertig. 

Area Considered Welsh’s Milkweed Nominated ACEC 

General Location About 9 miles west of Kanab, Utah. 

General Description The Coral Pink Sand Dunes area. 

Acreage 3,680 public land acres. 

Values Considered Scenic, wildlife, plants, ecologic, and geologic. 

From Nominated Area to Potential ACEC 

This area was nominated to include 3,680 acres of public land. The BLM interdisciplinary team 

determined that relevant and important values, resources, natural systems or processes, or 

hazards/safety/public welfare (referred to collectively as values) exist on approximately 1,300 acres that 

make up the potential ACEC. 

Identification Criteria 

To be considered as a potential ACEC and analyzed in RMP alternatives, an area must meet the criteria of 

relevance and importance as established and defined in 43 CFR 1610.7-2. 

Relevance 

An area meets the “relevance” criterion if it contains one or more of the following: 

Relevance Criteria Yes/No Rationale for Determination 

A significant historic, cultural, or Yes Scenic—100% of area is Class A scenery. 

scenic value (including rare or 

sensitive archaeological resources 

and religious or cultural resources 

important to Native Americans). 

No 

Cultural—area was not nominated for this value, significant 

cultural sites may be present but did not contribute to the 

nomination of this ACEC. 

Yes Bald eagle—federally listed (threatened), documented 

presence. 

Yes Coral Pink Sand Dunes tiger beetle—candidate for listing. 

Yes Raptors—MBTA. 

No Southwestern willow flycatcher—federally listed (endangered), 

no documented sightings. 

No Western red bat—BLM sensitive, no documented sightings. 

No Big free-tailed bat—BLM sensitive, no documented sightings. 

No Townsend’s big-eared bat—BLM sensitive, no documented 

sightings. 

A fish and wildlife resource 

(including habitat for endangered, 

sensitive, or threatened species or 

habitat essential for maintaining 

species diversity). 

No Mule deer—no crucial winter habitat. 
Appendix 14 Proposed RMP and Final EIS 

A14-10 Kanab RMP 

Relevance Criteria Yes/No Rationale for Determination 

Yes Welsh’s milkweed—threatened plant species. 

Yes Old growth ponderosa pine—known occurrence. 

Yes Vernal pools. 

A natural process or system 

(including endangered, sensitive, 

or threatened plant species; rare, 

endemic, or relict plants or plant 

communities that are terrestrial, 

aquatic, or riparian; or rare 

geological features). Yes Rare geologic feature—fault controlled sand dunes. 

Natural hazards (including areas 

of avalanche, dangerous flooding, 

landslides, unstable soils, and 

seismic activity, or dangerous if it 

is determined through the 

resource management planning 

process that it has become part of 

a natural process). 

No Area was not nominated for this value. None known to be 

present. 

Importance 

The value, resource, system, process, or hazard described above must have substantial significance and 

values to satisfy the “importance” criteria. This generally means that the value, resource, system, process, 

or hazard is characterized by one or more of the following: 

Importance Criteria Yes/No Rationale for Determination 

Yes Scenery—more than locally significant, Yellowjacket Road is a 

Utah Scenic Backway. 

Yes Rare geologic feature—more than locally significant and 

distinctive. 

Yes Coral Pink Sand Dunes tiger beetle. 

No Bald eagle—not a designated winter roost site. 

No Old growth ponderosa pine—not more than locally significant. 

Has more than locally significant 

qualities that give it special worth, 

consequence, meaning, 

distinctiveness, or cause for 

concern, especially compared 

with any similar resource. 

No Raptors—habitat is available in other locations. 

Yes Welsh’s milkweed—may be impacted by off-highway vehicle 

(OHV) activity. 

Yes Coral Pink Sand Dunes tiger beetle—may be impacted by OHV 

activity. 

No Bald eagle—no identified threats. 

Has qualities or circumstances 

that make it fragile, sensitive, 

rare, irreplaceable, exemplary, 

unique, endangered, threatened, 

or vulnerable to adverse change. 

No Old growth ponderosa pine—no identified threats. 

Has been recognized as 

warranting protection to satisfy 

national priority concerns or to 

carry out FLPMA mandates. 

No Bald eagle—not a designated winter roost site. 

Has qualities that warrant 

highlighting to satisfy public or 

management concerns about 

safety and public welfare. 

No Area was not nominated for these criteria. None known to be 

present. 

Poses a significant threat to 

human life and safety or to 

property. 

No Area was not nominated for these criteria. Not present. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-11 

Potential ACEC—Summary of Relevance and Importance Findings: The BLM interdisciplinary team 

determined that 1,300 acres meet the criteria of relevance and importance for scenery, rare geologic 

feature, Coral Pink Sand Dunes tiger beetle, and Welsh’s milkweed. 

Suggested Special Management 

What special management is required to protect importance values from threats? 

FLPMA Section 103(a): The term “areas of critical environmental concern” means 

areas within the public lands where special management attention is required (when such 

areas are developed or used or where no development is required) to protect and prevent 

irreparable damage to important historic, cultural, or scenic values, fish and wildlife 

resources or other natural systems or processes, or to protect life and safety from natural 

hazards. 

Relevant and Important 

Values Suggested Special Management 

Scenic 

Manage Class A scenery as Visual Resource Management (VRM) Class II. 

(WSA area is managed as VRM Class I.) 

Oil and gas leasing with major constraints (no surface occupancy). 

Recommend withdrawing from mineral entry. 

Close to mineral material disposal. 

No new rights-of-way (ROW). 

Welsh’s Milkweed Maintain existing management. 

Coral Pink Sand Dunes Tiger 

Beetle Maintain existing management under current conservation areas. 

General Prescriptions 

Continue cooperative law enforcement with State Park. 

No woodcutting (forest product sales). 

No wildling collections without a permit. 

Retain all lands and interest in land in federal ownership. 

Vermilion Cliffs Nominated ACEC 

Nominated by Citizens of Kane County. 

Area Considered Vermilion Cliffs Nominated ACEC 

General Location Located north and northeast of Kanab between Highway 89 and Johnson Canyon 

Road. 

General Description Scenic redrock cliffs that form the backdrop of Kanab. 

Acreage 26,486 public land acres. 

Values Considered Scenic, cultural, wildlife, plant, geologic, and natural processes and systems. 
Appendix 14 Proposed RMP and Final EIS 

A14-12 Kanab RMP 

From Nominated Area to Potential ACEC 

This area was nominated to include 26,486 acres of public land. The BLM interdisciplinary team 

determined that relevant and important values exist on approximately 23,400 acres that make up the 

potential ACEC. 

Identification Criteria 

To be considered as a potential ACEC and analyzed in resource management plan alternatives, an area 

must meet the criteria of relevance and importance as established and defined in 43 CFR 1610.7-2. 

Relevance 

An area meets the “relevance” criterion if it contains one or more of the following: 

Relevance Criteria Yes/No Rationale for Determination 

Yes Scenic—about 70 percent of the nominated area is Class A 

scenery. 

A significant historic, cultural, or 

scenic value (including rare or 

sensitive archaeological resources 

and religious or cultural resources 

important to Native Americans). Yes 

Cultural—area has high density of complex sites that cover the 

timespan from the Archaic period into the historic period, with 

an emphasis on pre-Puebloan archaeology. 

Yes Peregrine falcon—BLM sensitive. 

Yes Bald eagle—federally listed (threatened). 

No Mexican spotted owl—modeled habitat present in only very 

small area. 

No Greater sage-grouse—no documented presence or habitat. 

Yes Townsend’s big-eared bat—BLM sensitive; documented 

sightings. 

Yes Ferruginous hawk—BLM sensitive, documented sightings. 

Yes Northern Goshawk—BLM sensitive. 

Yes Golden eagle—MBTA. 

Yes Fringed myotis bat—BLM sensitive. 

Yes Southwestern willow flycatcher—federally listed (endangered), 

has migratory habitat. 

Yes Spotted bat—BLM sensitive. 

A fish and wildlife resource 

(including habitat for endangered, 

sensitive, or threatened species or 

habitat essential for maintaining 

species diversity). 

Yes Mule deer—high-value winter habitat. 

No 

Geologic feature—these features are common throughout the 

Colorado Plateau, few iron concretions within the nominated 

area. 

Yes Kanab thelypody—no documented occurrences, habitat 

present. 

Yes Gumbo milkvetch—no documented occurrences, habitat 

present. 

No Arizona bladderpod—not a Utah sensitive species. 

A natural process or system 

(including endangered, sensitive, 

or threatened plant species; rare, 

endemic, or relic plants or plant 

communities that are terrestrial, 

aquatic, or riparian; or rare 

geological features). 

No Virgin phacelia—not a Utah sensitive species. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-13 

Relevance Criteria Yes/No Rationale for Determination 

Yes Meager camissonia—no documented occurrences, habitat 

present. 

Yes Stella’s pepperplant—no documented occurrences, habitat 

present. 

Yes Kane breadroot—no documented occurrences, habitat 

present. 

Yes Riparian. 

Natural hazards (including areas 

of avalanche, dangerous flooding, 

landslides, unstable soils, and 

seismic activity, or dangerous if it 

is determined through the 

resource management planning 

process that it has become part of 

a natural process). 

No Area was not nominated for these criteria. None present. 

Importance 

The value, resource, system, process, or hazard described above must have substantial significance and 

values to satisfy the “importance” criteria. This generally means that the value, resource, system, process, 

or hazard is characterized by one or more of the following: 

Importance Criteria Yes/No Rationale for Determination 

Yes Scenic—Highway 89 is a Utah Scenic Byway, Johnson 

Canyon is a Utah Scenic Backway. 

Yes Cultural—majority of sites are eligible for listing on the 

National Register of Historic Places. 

Yes Townsend’s big-eared bat—BLM sensitive. 

Yes Ferruginous hawk—BLM sensitive. 

Yes Peregrine falcon—BLM sensitive. 

No Southwestern willow flycatcher—primarily migratory habitat. 

No Mule deer—not more than locally significant, habitat on the 

fringe of premium hunting area. 

Yes Bald eagle—federally listed (threatened). 

Yes Golden eagle—federally protected. 

Yes Fringed myotis bat—BLM sensitive. 

Yes Spotted bat—BLM sensitive. 

No Northern Goshawk—transitory, small, and limited habitat. 

Yes Kanab thelypody—BLM sensitive species, habitat present. 

Yes Gumbo milkvetch—BLM sensitive species, habitat present. 

Yes Meager camissonia—no documented occurrences, habitat 

present. 

Has more than locally significant 

qualities that give it special worth, 

consequence, meaning, 

distinctiveness, or cause for 

concern, especially compared with 

any similar resource. 

Yes Stella’s pepperplant—no documented occurrences, habitat 

present. 
Appendix 14 Proposed RMP and Final EIS 

A14-14 Kanab RMP 

Importance Criteria Yes/No Rationale for Determination 

Yes Kane breadroot—no documented occurrences, habitat 

present. 

Yes Scenic—may be impacted by oil and gas development, wind 

energy development, and OHV activity. 

Yes 

Cultural—sites are fragile, sensitive, irreplaceable, 

endangered, and vulnerable to adverse change. OHV and 

vandalism are the primary threats to the cultural resources in 

this area. 

No Townsend’s big-eared bat—no identified threats. 

Yes Ferruginous hawk—threatened or vulnerable to OHV use and 

oil and gas development. 

Yes Peregrine falcon—threatened or vulnerable to OHV use and 

oil and gas development. 

Yes Bald eagle—threatened or vulnerable to OHV use and oil and 

gas development. 

No Mexican spotted owl—no identified threats. 

Yes Golden eagle—threatened or vulnerable to OHV use and oil 

and gas development. 

No Fringed myotis bat—no identified threats. 

No Spotted bat—no identified threats. 

Yes Kanab thelypody—BLM Utah Sensitive species, habitat 

present, and OHV impacts. 

Yes Gumbo milkvetch—BLM Utah Sensitive species, habitat 

present, and OHV impacts. 

Yes Meager camissonia—no documented occurrences, habitat 

present, and OHV impacts. 

Yes Stella’s pepperplant—no documented occurrences, habitat 

present, and OHV impacts. 

Has qualities or circumstances 

that make it fragile, sensitive, rare, 

irreplaceable, exemplary, unique, 

endangered, threatened, or 

vulnerable to adverse change. 

Yes Kane Breadroot—no documented occurrences, habitat 

present, and OHV impacts. 

No Scenic—not identified as a national priority. 

Yes Cultural—majority of the sites are eligible to the 

National Register, but no sites are currently listed. 

Yes Bald eagle—federally listed (threatened). 

Yes Peregrine falcon—BLM sensitive. 

Yes Golden eagle—federally protected. 

Has been recognized as 

warranting protection to satisfy 

national priority concerns or to 

carry out FLPMA mandates. 

Yes Ferruginous hawk—BLM sensitive. 

Has qualities that warrant 

highlighting to satisfy public or 

management concerns about 

safety and public welfare. 

No Area was not nominated for these criteria. None known to be 

present. 

Poses a significant threat to 

human life and safety or to 

property. 

No Area was not nominated for these criteria. None present. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-15 

Potential ACEC—Summary of Relevance and Importance Findings: After evaluation of the ACEC 

proposal, the interdisciplinary team determined that 23,400 acres meet the criteria of relevance and 

importance for scenery, cultural, wildlife, and natural processes. 

Suggested Special Management 

What special management is required to protect importance values from threats? 

FLPMA Section 103(a): The term “areas of critical environmental concern” means 

areas within the public lands where special management attention is required (when such 

areas are developed or used or where no development is required) to protect and prevent 

irreparable damage to important historic, cultural, or scenic values, fish and wildlife 

resources or other natural systems or processes, or to protect life and safety from natural 

hazards. 

Relevant and Important 

Values Suggested Special Management 

Scenic 

Manage as VRM Class II or III. 

Manage OHV as limited to designated routes. 

Oil and gas leasing with minor constraints or with major constraints (no 

surface occupancy). 

Recommend withdrawing from mineral entry. 

No new ROWs (including communication sites). 

Retain ACEC in public ownership. 

Work with Utah School and Institutional Trust Lands Administration (SITLA) 

to acquire state inholdings. 

Vegetation and Wildlife 

Lease notices for flora and fauna. 

Restrict climbing within spatial and seasonal buffers surrounding raptor 

nests. 

Cultural 

Develop interpretive displays (e.g., cultural, wildlife). 

Manage OHV as limited to designated routes. 

Manage grazing activities to minimize impacts on at-risk cultural sites. 

White Cliffs Nominated ACEC 

Nominated by Citizens of Kane County. 

Area Considered White Cliffs Nominated ACEC 

General Location Approximately 15 miles north and northwest of Kanab between Highway 89 and 

Johnson Canyon Road. 

General Description Scenic white cliffs as viewed from Highway 89. 

Acreage 45,916 public land acres. 

Values Considered Scenic, cultural, wildlife, and plants. 
Appendix 14 Proposed RMP and Final EIS 

A14-16 Kanab RMP 

From Nominated Area to Potential ACEC 

This area was nominated to include 45,916 acres of public land. The BLM interdisciplinary team 

determined relevant and important values exist on 26,000 contiguous acres that make up the potential 

ACEC. 

Identification Criteria 

To be considered as a potential ACEC and analyzed in resource management plan alternatives, an area 

must meet the criteria of relevance and importance as established and defined in 43 CFR 1610.7-2. 

Relevance 

An area meets the “relevance” criterion if it contains one or more of the following: 

Relevance Criteria Yes/No Rationale for Determination 

A significant historic, cultural, or Yes Scenic—about 65% of the nominated area is Class A scenery. 

scenic value (including rare or 

sensitive archaeological resources 

and religious or cultural resources 

important to Native Americans). 

Yes Cultural—high density of complex sites that cover the 

timespan from the Archaic period into the historic period. 

Yes Peregrine falcon—BLM sensitive. 

Yes Bald eagle—federally listed (threatened). 

Yes Mexican spotted owl—Modeled habitat present. 

Yes Mule deer—transitory habitat. 

Yes Golden eagle—MBTA. 

Yes Fringed myotis bat—BLM sensitive. 

Yes Townsend’s big-eared bat—BLM sensitive. 

Yes Spotted bat—BLM sensitive. 

Yes Ferruginous hawk—BLM sensitive, habitat present. 

No Sage-grouse—no documented presence or habitat. 

No Kit fox. 

A fish and wildlife resource 

(including habitat for endangered, 

sensitive, or threatened species or 

habitat essential for maintaining 

species diversity). 

Yes Northern Goshawk—BLM sensitive. 

Yes Welsh’s milkweed—threatened species, designated critical 

habitat. 

Yes Escarpment milkvetch—BLM sensitive. 

Yes Canaan Mountain beardtongue—BLM sensitive. 

Yes Meager camissonia—habitat is present; no known individuals. 

Yes Clarion pepperplant—BLM sensitive. 

Yes Cronquist’s phacelia—BLM sensitive. 

A natural process or system 

(including endangered, sensitive, 

or threatened plant species; rare, 

endemic, or relic plants or plant 

communities that are terrestrial, 

aquatic, or riparian; or rare 

geological features). 

No Geologic—not uncommon on the Colorado Plateau. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-17 

Relevance Criteria Yes/No Rationale for Determination 

Natural hazards (including areas 

of avalanche, dangerous flooding, 

landslides, unstable soils, and 

seismic activity, or dangerous if it 

is determined through the 

resource management planning 

process that it has become part of 

a natural process). 

No Area was not nominated for these criteria. None known to be 

present. 

Importance 

The value, resource, system, process, or hazard described above must have substantial significance and 

values to satisfy the “importance” criteria. This generally means that the value, resource, system, process, 

or hazard is characterized by one or more of the following: 

Importance Criteria Yes/No Rationale for Determination 

Yes Scenic—Highway 89 is a Utah Scenic Byway, Johnson 

Canyon is a Utah Scenic Backway. 

Yes Cultural—majority of sites are eligible for listing on the National 

Register of Historic Places. 

Yes Peregrine falcon—BLM sensitive. 

Yes Bald eagle—federally listed (threatened). 

Yes Mexican spotted owl—modeled habitat. 

No Mule deer—transitory habitat. 

Yes Golden eagle—MBTA. 

Yes Fringed myotis bat—BLM sensitive. 

Yes Townsend’s big-eared bat—BLM sensitive. 

Yes Spotted bat—BLM sensitive. 

Yes Northern Goshawk—BLM sensitive, primarily winter habitat. 

Yes Ferruginous hawk—BLM sensitive, habitat present. 

Yes Welsh’s milkweed—threatened species, designated critical 

habitat. 

Yes Escarpment milkvetch—BLM sensitive. 

Yes Canaan Mountain beardtongue—BLM sensitive. 

Yes Meager camissonia—habitat is present, no known individuals. 

Yes Clarion pepperplant—BLM sensitive. 

Has more than locally significant 

qualities that give it special worth, 

consequence, meaning, 

distinctiveness, or cause for 

concern, especially compared with 

any similar resource. 

Yes Cronquist’s phacelia—BLM sensitive, habitat is present, no 

known individuals. 

Yes Scenic—may be impacted by oil and gas development, wind 

energy development, and OHV activity. 

Yes 

Cultural—sites are fragile, sensitive, irreplaceable, 

endangered, and vulnerable to adverse change. OHV and 

vandalism potentially threaten the cultural resources. 

Has qualities or circumstances 

that make it fragile, sensitive, rare, 

irreplaceable, exemplary, unique, 

endangered, threatened, or 

vulnerable to adverse change. 

Yes Peregrine falcon—threatened or vulnerable to OHV use and oil 
Appendix 14 Proposed RMP and Final EIS 

A14-18 Kanab RMP 

Importance Criteria Yes/No Rationale for Determination 

and gas development. 

No Southwestern willow flycatcher—no identified threats. 

Yes Bald eagle—threatened or vulnerable to OHV use and oil and 

gas development. 

No Mexican spotted owl—no identified threats. 

No Mule deer—no identified threats. 

Yes Golden eagle—threatened or vulnerable to OHV use and oil 

and gas development. 

No Fringed myotis bat—no identified threats. 

No Townsend’s big-eared bat—no identified threats. 

No Spotted bat—no identified threats. 

Yes Ferruginous hawk—threatened or vulnerable to OHV use and 

oil and gas development. 

Yes Welsh’s milkweed—threatened species, designated critical 

habitat, potential OHV impacts. 

Yes Escarpment milkvetch—BLM sensitive, potential OHV impacts. 

Yes Canaan Mountain beardtongue—BLM sensitive, potential OHV 

impacts. 

Yes Meager camissonia—BLM sensitive, potential OHV impacts. 

Yes Clarion pepperplant—BLM sensitive, potential OHV impacts. 

Yes Cronquist’s phacelia—BLM sensitive, habitat is present, no 

known individuals, potential OHV impacts. 

No Scenic—not identified as a national priority. 

Yes Cultural—majority of the sites are eligible to the National 

Register, but no sites are currently listed. 

Yes Bald eagle—federally listed. 

Yes Peregrine falcon—BLM sensitive. 

Yes Golden eagle—federally listed. 

Has been recognized as 

warranting protection to satisfy 

national priority concerns or to 

carry out FLPMA mandates. 

Yes Ferruginous hawk—BLM sensitive. 

Has qualities that warrant 

highlighting to satisfy public or 

management concerns about 

safety and public welfare. 

No Area was not nominated for these criteria. None known to be 

present. 

Poses a significant threat to 

human life and safety or to 

property. 

No Area was not nominated for these criteria. None present. 

Potential ACEC—Summary of Relevance and Importance Findings: After evaluation of the ACEC 

proposal, the interdisciplinary team determined that 26,000 acres meet the criteria of relevance and 

importance for scenery, cultural, wildlife, and natural processes. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-19 

Suggested Special Management 

What special management is required to protect importance values from threats? 

FLPMA Section 103(a): The term “areas of critical environmental concern” means 

areas within the public lands where special management attention is required (when such 

areas are developed or used or where no development is required) to protect and prevent 

irreparable damage to important historic, cultural, or scenic values, fish and wildlife 

resources or other natural systems or processes, or to protect life and safety from natural 

hazards. 

Relevant and Important 

Values Suggested Special Management 

Scenic 

Manage as VRM Class II. 

Oil and gas leasing with major constraints (no surface occupancy). 

Recommend withdrawal from mineral entry. 

Close to mineral material disposals. 

No new ROWs (including communications sites). 

Retain ACEC in public ownership, work to acquire state sections within the 

nominated area. 

Work with SITLA to acquire state inholdings. 

Cultural 

Develop interpretive displays (e.g., cultural, wildlife). 

Manage OHV as limited to designated routes. 

Manage grazing activities to minimize impacts to at-risk cultural sites. 

Vegetation and Wildlife 

Lease notice for flora and fauna. 

Restrict climbing within spatial and seasonal buffers surrounding raptor 

nests. 

Water and Indian Canyon Existing ACEC (Cottonwood Canyon ACEC) 

This includes re-evaluation of the existing Water and Indian Canyon ACEC and additional acreage 

identified by the interdisciplinary team. The entire area considered is called the Cottonwood Canyon 

ACEC. 

Area Considered Water and Indian Canyon ACEC 

General Location Approximately 3 miles southwest of Kanab. 

General Description Canyon complex north of the Kaibab Paiute Reservation. 

Acreage 

220 acres in the existing ACEC, but relevant and important values, resources, 

processes, and hazards/public welfare resources were identified on 3,800 public 

land acres, including the 220 acres of the existing ACEC. 

Values Considered Scenic, cultural, wildlife, natural processes, plant, geologic features, and Fredonia 

surface water watershed. 
Appendix 14 Proposed RMP and Final EIS 

A14-20 Kanab RMP 

From Existing ACEC to Potential ACEC 

Upon re-evaluation of the existing 220 acre Water and Indian Canyon ACEC the interdisciplinary team 

identified that the relevant and important values associated with the existing ACEC extended beyond the 

existing boundary. In addition, the team identified the potential for additional values that were included in 

the following evaluation. The larger evaluated area is referred to as the Cottonwood Canyon ACEC. 

Identification Criteria 

To be considered as a potential ACEC and analyzed in resource management plan alternatives, an area 

must meet the criteria of relevance and importance as established and defined in 43 CFR 1610.7-2. 

Relevance 

An area meets the “relevance” criterion if it contains one or more of the following: 

Relevance Criteria Yes/No Rationale for Determination 

A significant historic, cultural, or Yes Scenic—entire area is Class A scenery. 

scenic value (including rare or 

sensitive archaeological 

resources and religious or cultural 

resources important to Native 

Americans). 

Yes 

Cultural—high site density and complex sites covering the 

timespan from the Archaic period into the historic period, with 

an emphasis on pre-Puebloan archaeology. Contains one site 

listed on the National Register. One of the few areas in the 

region with cliff-side dwelling sites. 

Yes Mexican spotted owl—large acreage of modeled habitat. 

Yes Peregrine falcon—BLM sensitive. 

Yes Southwestern willow flycatcher—potential habitat present. 

Yes Bald eagle—federally listed (threatened). 

Yes Golden eagle—MBTA. 

Yes Fringed myotis bat—BLM sensitive. 

Yes Spotted bat—BLM sensitive. 

Yes Townsend’s big-eared bat—BLM sensitive. 

Yes Ferruginous hawk—BLM sensitive. 

Yes Northern Goshawk—BLM sensitive. 

A fish and wildlife resource 

(including habitat for endangered, 

sensitive, or threatened species or 

habitat essential for maintaining 

species diversity). 

Yes Mule deer—winter high-value and crucial habitat. 

Yes 

Geology—Navajo sandstone is an important aquifer for the 

area, and combined with the formation of the canyons this 

provides a unique riparian area. 

Yes Ecological—hanging gardens, uncommon feature on the Kanab 

Field Office. 

Yes Riparian—a large and unique riparian system functioning 

properly. 

A natural process or system 

(including endangered, sensitive, 

or threatened plant species; rare, 

endemic, or relic plants or plant 

communities that are terrestrial, 

aquatic, or riparian; or rare 

geological features). 

Yes Old growth Douglas fir—not normally found at this low 

elevation. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-21 

Relevance Criteria Yes/No Rationale for Determination 

Natural hazards (including areas 

of avalanche, dangerous flooding, 

landslides, unstable soils, and 

seismic activity, or dangerous if it 

is determined through the 

resource management planning 

process that it has become part of 

a natural process). 

Yes 

Area contains the watershed for the city of Fredonia, AZ. 

Disturbance or vandalism of water collection facilities and the 

watershed resources could affect water quantity and quality. 

Importance 

The value, resource, system, process, or hazard described above must have substantial significance and 

values to satisfy the “importance” criteria. This generally means that the value, resource, system, process, 

or hazard is characterized by one or more of the following: 

Importance Criteria Yes/No Rationale for Determination 

Yes Scenic—more than locally significant. 

Yes Cultural—majority of sites are eligible for listing on the National 

Register of Historic Places. One site currently on the register. 

Yes Mexican spotted owl—large acreage of modeled habitat. 

Yes Peregrine falcon—BLM sensitive. 

Yes Southwestern willow flycatcher—habitat present. 

Yes Bald eagle—federally listed (threatened). 

Yes Golden eagle—MBTA. 

Yes Fringed myotis bat—BLM sensitive. 

Yes Townsend’s big-eared bat—BLM sensitive. 

Yes Spotted bat—BLM sensitive. 

Yes Ferruginous hawk—BLM sensitive. 

Yes Northern Goshawk—BLM sensitive. 

Yes Mule deer—winter high-value and critical habitat. 

No Geology—not more than locally significant. 

No Riparian—not more than locally significant. 

No Old growth Douglas fir—not more than locally significant. 

Has more than locally significant 

qualities that give it special worth, 

consequence, meaning, 

distinctiveness, or cause for 

concern, especially compared with 

any similar resource. 

No Ecological—hanging gardens, not more than locally significant. 

Yes Scenic—threats include oil and gas development. 

Yes 

Cultural—sites are fragile, sensitive, irreplaceable, endangered, 

and vulnerable to adverse change. Threats include unregulated 

OHV use, grazing impacts to certain site types, and vandalism. 

Yes Mexican spotted owl—threats include rock climbing. 

Yes Peregrine falcon—threats include rock climbing. 

No Southwestern willow flycatcher—no identified threats, very 

limited access. 

Has qualities or circumstances 

that make it fragile, sensitive, rare, 

irreplaceable, exemplary, unique, 

endangered, threatened, or 

vulnerable to adverse change. 

Yes Golden eagle—MBTA. 
Appendix 14 Proposed RMP and Final EIS 

A14-22 Kanab RMP 

Importance Criteria Yes/No Rationale for Determination 

Yes Fringe myotis bat—threats include rock climbing. 

Yes Townsend’s big-eared bat—threats include rock climbing. 

Yes Spotted bat—threats include rock climbing. 

Yes Ferruginous hawk—BLM sensitive. 

No Northern Goshawk—no identified threats. 

No Mule deer—no identified threats, very limited access. 

Yes 

Geology—Navajo sandstone is an important aquifer for the 

area, and combined with the formation of the canyons this 

provides a unique riparian area. 

No Ecology—hanging gardens, no identified threats. 

Yes Riparian—threats include oil and gas development. 

No Old growth Douglas fir—no identified threats. 

Yes Cultural—has one site listed on the National Register and many 

others considered eligible to the National Register. 

Yes Bald eagle—federally listed (threatened). 

Yes Peregrine falcon—BLM sensitive. 

Yes Golden eagle—MBTA. 

Yes Ferruginous hawk—federally listed (threatened). 

Has been recognized as 

warranting protection to satisfy 

national priority concerns or to 

carry out FLPMA mandates. 

Yes Mexican spotted owl—federally listed (threatened). 

Has qualities that warrant 

highlighting to satisfy public or 

management concerns about 

safety and public welfare. 

Yes Area contains the watershed for the city of Fredonia, AZ. 

Poses a significant threat to 

human life and safety or to 

property. 

Yes 

Area contains the watershed for the city of Fredonia, AZ. 

Disturbance or vandalism of water collection facilities and the 

watershed resources could affect water quantity and quality. 

Potential ACEC—Summary of Relevance and Importance Findings: The interdisciplinary team 

determined that 3,800 acres meet the criteria of relevance and importance for scenery, cultural, wildlife, 

natural processes, and hazard/safety/public welfare. 

Suggested Special Management 

What special management is required to protect importance values from threats? 

FLPMA Section 103(a): The term “areas of critical environmental concern” means 

areas within the public lands where special management attention is required (when such 

areas are developed or used or where no development is required) to protect and prevent 

irreparable damage to important historic, cultural, or scenic values, fish and wildlife 

resources or other natural systems or processes, or to protect life and safety from natural 

hazards. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-23 

Relevant and Important 

Values Suggested Special Management 

Scenic 

Manage as VRM Class II. 

Close area to OHV use or limited to designated routes. 

Close to oil and gas leasing or lease with major constraints. 

Recommend withdrawing from mineral entry. 

Close to mineral material disposals. 

Cultural 

Manage OHV as limited to designated routes. 

Monitor specific sites on a regular basis. 

Retain all lands and interests in land in federal ownership. 

Work with SITLA to acquire state inholdings. 

Hazard/Safety/Public Welfare Do not authorize livestock grazing in the Water Canyon Allotment. 

Parunuweap Canyon Nominated ACEC 

Nominated by Southern Utah Wilderness Alliance. 

Area Considered Parunuweap Canyon Nominated ACEC 

General Location A few miles west of Highway 89 near Mt. Carmel Junction. 

General Description Parunuweap Canyon contains the East Fork Virgin River down to the Zion National 

Park boundary. 

Acreage 50,088 public land acres. 

Values Considered Scenic, cultural, wildlife, natural processes, plant, and geologic features. 

From Nominated Area to Potential ACEC 

The nominated area includes 50,088 acres of public land. The BLM interdisciplinary team determined 

relevant and important values exist on 6,100 contiguous acres that make up the potential ACEC. 

Identification Criteria 

To be considered as a potential ACEC and analyzed in resource management plan alternatives, an area 

must meet the criteria of relevance and importance as established and defined in 43 CFR 1610.7-2. 

Relevance 

An area meets the “relevance” criterion if it contains one or more of the following: 

Relevance Criteria Yes/No Rationale for Determination 

A significant historic, cultural, or Yes Scenic—100% of the nominated area is Class A scenery. 

scenic value (including rare or 

sensitive archaeological 

resources and religious or cultural 

resources important to Native 

Americans). 

Yes 

Cultural—high site density on flats and terraces above the river 

canyon, also a significant number of sites including rock art, 

granaries, and associated sites within the canyon itself. 

A fish and wildlife resource Yes Peregrine falcon—BLM sensitive. 
Appendix 14 Proposed RMP and Final EIS 

A14-24 Kanab RMP 

Relevance Criteria Yes/No Rationale for Determination 

Yes Southwestern willow flycatcher—potential habitat present. 

Yes Bald eagle—federally listed (threatened). 

Yes Mexican spotted owl—has designated critical and modeled 

habitat in very small areas. 

Yes Mule deer—has high-value winter habitat. 

Yes Golden eagle—MBTA. 

Yes Big free-tailed bat—BLM sensitive. 

Yes Townsend’s big-eared bat—BLM sensitive. 

Yes Ferruginous hawk—BLM sensitive, habitat present. 

(including habitat for endangered, 

sensitive, or threatened species or 

habitat essential for maintaining 

species diversity). 

Yes Northern Goshawk—BLM sensitive. 

No Geologic feature—these features are common throughout the 

Colorado Plateau. 

Yes Ecological—hanging gardens, uncommon feature in the Kanab 

Field Office. 

A natural process or system 

(including endangered, sensitive, 

or threatened plant species; rare, 

endemic, or relic plants or plant 

communities that are terrestrial, 

aquatic, or riparian; or rare 

geological features). No Riparian—the riparian areas in the nominated ACEC are 

operating at proper functioning condition (PFC). 

Natural hazards (including areas 

of avalanche, dangerous flooding, 

landslides, unstable soils, and 

seismic activity, or dangerous if it 

is determined through the 

resource management planning 

process that it has become part of 

a natural process). 

No Area not nominated for these criteria. 

Importance 

The value, resource, system, process, or hazard described above must have substantial significance and 

values to satisfy the “importance” criteria. This generally means that the value, resource, system, process, 

or hazard is characterized by one or more of the following: 

Importance Criteria Yes/No Rationale for Determination 

Yes Scenery is more than locally significant. 

Yes 

Cultural—majority of the sites are eligible for listing on the 

National Register of Historic Places. Sites are fragile, sensitive, 

irreplaceable, endangered, and vulnerable to adverse change. 

Yes Peregrine falcon—BLM sensitive. 

Yes Southwestern willow flycatcher—has migratory habitat and 

documented sightings in Zion National Park. 

Yes Bald eagle—federally listed (threatened). 

Yes Mexican spotted owl—has designated critical and modeled 

habitat in very small areas. 

No Mule deer—not more than locally significant. 

Has more than locally significant 

qualities that give it special worth, 

consequence, meaning, 

distinctiveness, or cause for 

concern, especially compared with 

any similar resource. 

Yes Golden eagle—federally protected. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-25 

Importance Criteria Yes/No Rationale for Determination 

Yes Big free-tailed bat—BLM sensitive. 

Yes Townsend’s big-eared bat—BLM sensitive. 

Yes Ferruginous hawk—BLM sensitive, habitat present. 

Yes Northern Goshawk—BLM sensitive. 

No Scenery. 

Yes 

Cultural—majority of the sites are eligible for listing on the 

National Register of Historic Places. Sites are fragile, sensitive, 

irreplaceable, endangered, and vulnerable to intentional (looting 

and vandalism) and unintentional (damage from rock climbing, 

camping on cultural sites, etc.) adverse change. 

No Mexican spotted owls—no identified threats. 

No Peregrine falcon—no identified threats. 

No Southwestern willow flycatcher—no identified threats, very 

limited access. 

No Bald eagle—no identified threats, very limited access. 

No Golden eagle—no identified threats, very limited access. 

No Townsend’s big-eared bat—no identified threats. 

No Ferruginous hawk—no identified threats. 

No Northern Goshawk—no identified threats, very limited access. 

No Mule deer—no identified threats, very limited access. 

Has qualities or circumstances 

that make it fragile, sensitive, rare, 

irreplaceable, exemplary, unique, 

endangered, threatened, or 

vulnerable to adverse change. 

No Hanging gardens—no identified threats. 

No Cultural. 

Yes Bald eagle—federally listed (threatened). 

Yes Peregrine falcon—BLM sensitive. 

Yes Golden eagle—federally protected. 

Yes Ferruginous hawk—BLM sensitive. 

Has been recognized as 

warranting protection to satisfy 

national priority concerns or to 

carry out FLPMA mandates. 

Yes Mexican spotted owl—federally listed. 

Has qualities that warrant 

highlighting to satisfy public or 

management concerns about 

safety and public welfare. 

No Area was not nominated for these criteria. None known to be 

present. 

Poses a significant threat to 

human life and safety or to 

property. 

No Area was not nominated for these criteria. None present. 

Potential ACEC—Summary of Relevance and Importance Findings: The interdisciplinary team 

determined that 6,100 acres meet the criteria of relevance and importance for scenery, cultural, and 

wildlife. 

Suggested Special Management 

What special management is required to protect importance values from threats? 
Appendix 14 Proposed RMP and Final EIS 

A14-26 Kanab RMP 

FLPMA Section 103(a): The term “areas of critical environmental concern” means 

areas within the public lands where special management attention is required (when such 

areas are developed or used or where no development is required) to protect and prevent 

irreparable damage to important historic, cultural, or scenic values, fish and wildlife 

resources or other natural systems or processes, or to protect life and safety from natural 

hazards. 

Relevant and Important 

Values Suggested Special Management 

Scenic 

Designate areas outside of the WSA as VRM Class II. 

Limit OHV use outside the WSA to designated routes. 

Open areas outside the WSA to oil and gas leasing with major constraints 

(NSO). 

Recommend withdrawing from mineral entry. 

Avoid new ROWs outside the WSA. 

Retain all lands and interest in lands in federal ownership. 

Cultural 

Limit camping associated with special recreation permits (SRP) to areas/sites 

identified during permitting. 

Regulate rock climbing within 300 feet of cultural sites. Climbing routes that 

impact cultural resource sites would generally not be allowed, and climbing 

routes designed to access cultural resource sites would not be allowed 

unless under permit for scientific investigation. 

Develop interpretive/education displays for relevant and important resources 

(e.g., cultural, wildlife). 

Preclude SRP tours or visitation of sites without prior consultation/clearance 

with BLM archaeologists and other specialists. 

Wildlife and Sensitive Species 

Include USFWS lease notices for threatened and endangered (T&E) flora 

and fauna. 

Restrict climbing within spatial and seasonal buffers surrounding raptor 

nests. 
Proposed RMP and Final EIS Appendix 14 

Kanab RMP A14-27 

MAP 1 NOMINATED AREAS
Appendix 14 Proposed RMP and Final EIS 

A14-28 Kanab RMP 

MAP 2 POTENTIAL ACECS
Proposed RMP and Final EIS Appendix 15 

Kanab RMP A15-1 

APPENDIX 15—REASONABLY FORESEEABLE 

DEVELOPMENT SCENARIO 

This Reasonably Foreseeable Development Scenario is based on information in the Minerals Potential 

Report (March 30, 2006) and applies to the entire planning area (i.e., federal and private estate). The 

analysis window for the Minerals Potential Report (15 years) was extended to match the 20-year planning 

horizon for the Resource Management Plan (RMP). The reasonably foreseeable development estimates 

developed in the Minerals Potential Report were adjusted based on discussions with the Minerals 

Potential Report author (Utah Geological Survey) and the minerals specialist on the ID Team. 

LEASABLE MINERALS

Oil and Gas 

Based on historic rates, drilling in the planning area during the next 20 years could be expected to involve 

90 new well sites. Approximately 70 well sites would be new exploration wells, and 20 sites would be 

new production wells. Table A15-1 summarizes the expected number of wildcat and development wells 

to be drilled for oil and gas in each play in the planning area and totals the number of wells for the next 20 

years. 

Table A15-1. Summary of Petroleum Development Potential and Expected Number of 

Wells Drilled in the Next 20 Years for Each Play in the Planning Area 

Play Name 

Occurrence 

Potential 

Development 

Potential 

New 

Wells 

Late Proterozoic/Cambrian play moderate low 10 

Devonian-Pennsylvanian play high moderate 19 

Permo-Triassic Unconformity play high high 32 

Combined Cretaceous plays moderate low 9 

Total New Exploration Wells 70

Total New Development Wells (one very small field) 20

GRAND TOTAL EXPECTED WELLS 90

Expected Disturbance From Oil and Gas 

The expected level of disturbance from the projected 90 oil and gas wells was determined using 

reasonable assumptions about a generic well site and access needs. Each well pad was estimated to 

comprise three acres, a square area roughly 361 feet per side. Based on an analysis of the network of 

existing roads, it was estimated that reaching each new well site would require an average of 5 miles of 

new road to be constructed, and the new roads would disturb a path almost 33 feet wide. Thus, each mile 

of new road would disturb 4 acres. An estimate of the total surface disturbance for all 90 new wells 

follows: 

90 oil and gas well pads at 3 acres each = 270 acres, plus 
Appendix 15 Proposed RMP and Final EIS 

A15-2 Kanab RMP 

450 miles of new roads at 4 acres/mile = 1800 acres. 

Thus, the total surface disturbance for the 90 new exploration wells is 2,070 acres, or approximately 23 

acres per well. 

Expected Disturbance From Seismic Activities 

Seismic exploration would likely occur before any projected drilling begins. Only a small amount of 

seismic exploration has been carried out in the planning area. Covering the portion of planning area that 

has high development potential for oil and gas could entail shooting and collecting up to 1,500 line miles 

of seismic data. 

The disturbance involved with shooting and collecting up to 1,500 line miles of seismic data would likely 

be split between buggy-mounted and helicopter data acquisition methods. Assuming that buggy-mounted 

drill rigs could be used to acquire half the seismic data and that the other half required heli-portable 

drilling rigs, means that there would be 750 line miles of each type of disturbance. Buggy-mounted 

seismic data acquisition generally disturbs about 1.2 acres per mile, while helicopter-acquired data 

disturbs only 0.007 acres per mile according to recent Bureau of Land Management (BLM) 

environmental assessments (i.e., Veritas and Western Geco Uinta Basin projects) for similar seismic 

projects elsewhere in Utah. Thus, acquiring 1,500 miles of seismic data in the portion of the planning area 

prospective for petroleum would entail a total disturbance of 905.5 acres of the forest surface (900 acres 

for buggy-mounted data and 5.5 acres for helicopter data). Combining the seismic disturbance with the 

drilling disturbance means that exploration and development for oil and gas in the planning area during 

the next 20 years could be expected to disturb about 2,976 acres of the surface. Because reclamation of all 

seismic disturbance and about 70 percent of exploration well disturbance is expected to occur during the 

planning period, about 2,370 acres of surface disturbance will be reclaimed during the planning horizon, 

leaving a net disturbance from oil and gas during the next 20 years of 607 acres. 

Coal 

Alton Coal Development, LLC, has announced plans to surface mine at least 40 million tons of coal from 

the Alton area of the Alton coal field within the planning area, an area of high (H) development potential. 

The Cannonville and Skutumpah areas of the Alton coal field and the portions of the Kaiparowits Plateau 

and Kolob coal fields with thicker coals are rated as having moderate (M) development potential, whereas 

all other coal-bearing areas are rated as low (L) development potential. Preliminary plans would mine the 

coal from private surface/federal subsurface (about 1,300 acres) first and then expand onto adjacent 

federal surface/federal subsurface (about 2,300 acres). The estimated total surface disturbance from 

mining of federal coal in the decision area will entail about 3,600 acres, including haul roads and surface 

facilities. The average annual surface disturbance would be approximately 180 acres, and reclamation 

would follow shortly behind mining. Federal coal lands have not been leased, a mine permit does not 

exist, and no coal sales contract has been signed, but a good chance exists that coal mining will occur in 

the Alton area. In addition to the mining of federal coal, preliminary plans would mine coal from private 

surface/fee coal (about 800 acres) for a total cumulative surface disturbance of 4,400 acres in the planning 

area. The average annual total surface disturbance would be approximately 220 acres. The operator is 

coordinating the application for mining of fee coal through the State of Utah. 

Geothermal 

No geothermal exploration or development activity is expected in the planning area in the next 20 years; 

thus, no accompanying surface disturbance will occur. Interest in geothermal resources could be affected 

if renewable energy portfolio standards and incentives are legislatively adopted. 
Proposed RMP and Final EIS Appendix 15 

Kanab RMP A15-3 

LOCATABLE MINERALS

Uranium-Vanadium 

No uranium-vanadium exploration or development activity is expected in the planning area in the next 

20 years; thus, no accompanying surface disturbance will occur. 

Antimony 

No antimony exploration or development activity is expected in the planning area in the next 20 years; 

thus, no accompanying surface disturbance will occur. 

Gypsum 

Only very small-scale gypsum exploration and development activity is expected in the planning area in 

the next 20 years. There will be limited to small-scale extraction of blocks of alabaster for use in making 

carvings, but this surface disturbance activity is considered part of the stone extraction activities discussed 

below. 

Limestone 

No limestone exploration and development activity is expected in the planning area in the next 20 years. 

Although the occurrence potential for limestone is rated as high (H/D) in some parts of the planning area, 

the area lacks good resource definition, and better defined deposits occur closer to the major Utah 

markets. Therefore, the development potential of limestone deposits in the planning area is rated low (L) 

for the foreseeable future. 

Septarian Concretions 

Continued septarian concretion development activity is expected in the planning area in the next 20 years 

at rates similar to historic activity levels. Thus, septarian concretion mining will likely disturb about 

1 acre per year, resulting in a total 20-year surface disturbance of 20 acres. Nearly all future disturbance is 

expected to take place on State lands. 

SALABLE MINERALS

Sand and Gravel 

Continued, to slightly increased, sand and gravel exploration or development activity is expected in the 

planning area in the next 20 years at rates comparable to historic activity levels. The level of disturbance 

will likely be about 20 acres per year for the first 5 years, 30 acres per year for the second 5 years, about 

35 acres per year for the third 5 years, and 40 acres per year for the last 5 years of the planning horizon. 

Sand and gravel development will result in a total 20-year surface disturbance of 625 acres, with 

approximately 70 percent on BLM lands, approximately 15 percent on Forest Service lands, and 

approximately 15 percent on State and private lands. Reclamation will occur when the mineral material 

within the site is exhausted and the site is closed. 
Appendix 15 Proposed RMP and Final EIS 

A15-4 Kanab RMP 

Stone 

Continued stone exploration or development activity is expected in the planning area in the next 20 years 

at rates that will increase slightly from historic activity levels. Thus, about 20 acres will likely be 

disturbed per year for stone, resulting in a total 20-year surface disturbance of 400 acres. About 70 

percent of the disturbance is expected to be on BLM land, 20 percent expected on State lands, and 10 

percent on U.S. Forest Service lands. Reclamation will occur when the mineral material within the site is 

exhausted and the site is closed. 

Clay 

Very limited clay exploration or development activity is expected in the planning area in the next 

20 years; thus, only 5 acres of accompanying surface disturbance will occur, mainly recurrent use at 

existing pits for use as pond lining material. 

Humate 

No humate exploration or development activity is expected in the planning area in the next 20 years; thus, 

no accompanying surface disturbance will occur. 

In summary, Table A15-2 tallies the total expected surface disturbance in the planning area from energy 

and mineral development during the next 20 years. 

Table A15-2. Total Expected Surface Disturbance in the Planning Area From Energy and 

Mineral Development During the Next 20 Years 

Activity Average Annual Disturbance Cumulative Disturbance 

Petroleum Drilling 103.5 acres 2,070 acres 

Petroleum Seismic 45.3 acres 906 acres 

Coal Mining 220.0 acres 4,400 acres 

Septarian Concretion Mining 1.0 acre 20 acres 

Sand and Gravel Mining 31.3 acres 625 acres 

Stone Mining 20.0 acres 400 acres 

Clay Mining 0.3 acres 5 acres 

Grand Total 421.4 acres 8,426 acres 

Reclaimed Oil and Gas 118.5 acres 2,370 acres 

Reclaimed Coal Mining 100.0 acres 2,000 acres 

Net Disturbance 202.9 acres 4,056 acres 
Proposed RMP and Final EIS Appendix 16 

Kanab RMP A16-1 

APPENDIX 16—SUMMARY OF COUNTY GENERAL 

PLAN PUBLIC LAND DECISIONS 

The Federal Land Policy and Management Act (FLPMA) of 1976 Section 202 (c) (9) directs that “Land 

use plans of the Secretary [of the Interior]...shall be consistent with State and local plans to the maximum 

extent he finds consistent with Federal law and purposes of this Act.” To comply with this consistency 

requirement, the Bureau of Land Management (BLM) considered state and local plans. In the case of 

Utah counties, local plans are titled “general management plans.” 

In 1992, the Utah State Legislature adopted the County Land Use Development and Management Act. 

This legislation’s purpose was to enable counties to develop comprehensive general management plans 

for their present and future needs and the growth and development of lands within their borders. Counties 

completed general management plans in the mid- to late 1990s with funding provided by the Governor’s 

Office of Planning and Budget. Public lands and resources are only one of many topics addressed in the 

plans. 

This document presents statements on public land and Resource Management Plan (RMP)-level resource 

management contained in the general management plans of the two counties encompassed by BLM’s 

Kanab Field Office. 

This document makes no judgments about the appropriateness or correctness of the counties’ statements 

but simply records them as written. All resources are listed in the sequence in which they appear in 

Appendix C of BLM’s Land Use Planning Handbook, H-1601-1. Because the county plans are organized 

differently, this sometimes required summarizing or taking county plan statements out of context. 

Consequently, a page attribution for each statement cited is included. If readers have questions, they are 

invited to check the county plans. Not every county commented on every resource, and some of the 

counties did not comment on some resources of concern to BLM. 

GENERAL MANAGEMENT PLAN STATEMENTS

Garfield 

• The small private land base cannot be effectively sustained without considering the management 

of the public lands. Therefore, county leaders will develop a cooperative working relationship 

with all government agency managers to ensure the inclusion of local perspectives and concerns 

in public land management directions. (Garfield, p. 3-2) 

• Practice has shown that attempts to manage natural resource development with a single resource 

focus fail to reflect the true scope of impacts to the natural and built environment. At the same 

time, the “ecosystem management” concept, as described by Federal agencies, tends to treat 

humans as intruders in the natural system. County leaders reject this supposition and will insist 

that natural resource management plans and/or “ecosystem” management plans for all county 

lands, public or private, consider humans as part of the system. (Garfield, p. 3-2) 

• Continue to support exploration and development of other natural resources within Garfield 

County. (Garfield, p. 5-4) 

• ...the county deems it critical that RMPs provide for range improvements, current grazing on 

public lands be preserved, county water rights be maintained, and public lands timber harvesting 

be continued and mining leases be considered and encouraged. (Garfield, p. 6-8) 
Appendix 16 Proposed RMP and Final EIS 

A16-2 Kanab RMP 

• ...it is in the county’s best interest that BLM/U.S. Forest Service (USFS) management practices 

encourage economic ecological sustainability... (Garfield, p. 6-8) 

Kane 

• Federal land management planning processes will include Kane County as an active, on-going 

partner and will be consistent with county goals and policies when not constrained by federal law. 

(Kane, p. 11)

• Land use policies and regulations will recognize and respect the constraints which natural hazards 

present to human use. The presence of sensitive lands such as important watersheds and habitat 

for wildlife and livestock will also be reflected. Most importantly, the county will recognize that 

humans have been an integral part of natural systems in the region for over 10,000 years, and 

must continue to play an active role in the functioning of natural systems. (Kane, p. 10) 

• Maintain or improve the primary landscape soil, vegetation and watershed resources in a manner 

that perpetuates and sustains a diversity of uses while fully supporting the custom, culture, 

economic stability and viability of Kane County and our individual citizens. Essentially all 

rangeland use and value is dependent upon maintenance and enhancement of the primary 

landscape soil and vegetation resource... (Kane, p. 37) 

• Continue to insist that federal land management plans which regulate public lands in Kane 

County promote the multiple use/sustained yield concept of public lands use. (Kane, p. 60) 

• Work closely with federal land managers in the preparation of Federal Resource Management 

Plans. (Kane, p. 60) 

• Reject federal attempts to impose integral vistas, Class I air attainment areas, buffer zones, critical 

habitat designation, and other means to further restrict uses of the small private land base in Kane 

County. (Kane, p. 60)

• The county will not accept any form of “ecosystem” management of federal lands if such 

planning impacts the use and enjoyment of the few private land holdings found in the county. 

(Kane, p. 61)

• All federal land management agencies in Kane County should include a full assessment of the 

social and economic impacts of management actions. (Kane, p. 61)

NATURAL, BIOLOGICAL, AND CULTURAL RESOURCES

Air 

Garfield 

• The preservation of clean air is one of the goals of Garfield County. At this time, this goal does 

not present a conflict with economic or resource development, except in a few selected areas... 

(Garfield, p. 4-2) 

Kane 

• Comply with the National Ambient Air Quality Act and State of Utah regulations and their 

standards to prevent significant deterioration of the high air quality found in Kane County. (Kane, 

p. 81)
Proposed RMP and Final EIS Appendix 16 

Kanab RMP A16-3 

Soil and Water 

Garfield 

• The county will identify and map all drinking water source protection zones in effect in the 

county and will recognize their importance in land use permit reviews and approvals. (Garfield, p. 

3-4) 

Kane 

• The county will address erosion control, salinity control, water quality impacts, and associated 

concerns when land use proposals are reviewed. (Kane, p. 37)

• Develop surface disturbance mitigation plans on soils with a high or very high erosion hazard 

rating within plans for multiple recreation use, road building, timber harvest, mechanical range 

treatments, prescribed fires, range improvements and vegetation manipulation. (Kane, p. 38)

• The BLM must comply with Utah water quality law including the processes set forth for 

achieving water quality standards. (Kane, p. 64)

• Develop management plans for multiple recreation uses in high erosion hazard watersheds, or 

watersheds where accelerated erosion is occurring, which [ensure] that planning documents 

and/or other agreements which alter multiple recreation use are formulated through coordination 

with the Kane County Resource Development Committee, which includes Off Highway 

Motorized Vehicle recreationist representative groups. (Kane, p. 64)

• Provide for the development and maintenance of water conveyance systems. (Kane, p. 65)

Vegetation 

Kane 

• Large expanses of the land base in Kane County is covered by a Pinyon-Juniper plant community 

which inhibits the growth of necessary forbs and grasses. This plant community must be managed 

so as to allow a more diverse vegetative resource. (Kane, p. 37)

• Include within fire line and site rehabilitation plans, native or exotic vegetation capable of 

supporting watershed function and habitat for wildlife and livestock. (Kane, p. 38)

• Develop and implement an aggressive juniper and shrub abatement and control plan for all sites 

where invasion is adversely affecting desirable vegetation and/or wildlife. (Kane, p. 38)

• Apply State of Utah approved noxious weed control methods through integration into all planning 

efforts to prevent the invasion of noxious weeds and to improve the ecological status of sites 

which have been invaded by weeds in coordination with the Kane County Weed Control Program 

(includes burning, mechanical, manual, biological, and chemical control methods). (Kane, pp. 

38–39)

• Maintain or improve conifer tree health, vegetation diversity, [and] wildlife and watershed values 

through active management of conifer forests in Kane County and prevent encroachment of 

Pinyon-Juniper into these communities. (Kane, p. 72)

Special Status Species 

Kane 

• The county will continue to oppose any listing of a threatened or endangered species which does 

not include an analysis of the impacts to the [county’s] economic base. (Kane, p. 61)
Appendix 16 Proposed RMP and Final EIS 

A16-4 Kanab RMP 

Fish and Wildlife 

Garfield 

• ...the county desires that wildlife resources be comprehensively managed without detriment to 

county economic interests. (Garfield, p. 6-8) 

• ...wildlife numbers must be established for designated areas within the county. It is county policy 

that introduction of any exotic plant or animal species into the county should not take place 

without formal concurrence by the county commission and that public hearings should be held in 

Garfield County prior to any such introductions. (Garfield, p. 6-10) 

• Garfield County believes watchable wildlife areas should be developed. (Garfield, p. 6-10) 

• Garfield County has organized a wildlife committee to make recommendations on wildlife 

numbers. Committee recommendations should be based on balancing economic, recreational, 

environmental, and other needs and demands. (Garfield, p. 6-10) 

Kane 

• Maintain, improve or mitigate habitat in order to sustain viable and harvestable populations of big 

game and upland game species as well as wetland/riparian habitat for waterfowl, fur bearers and a 

diversity of other game and non-game species. (Kane, p. 66)

• Consult with the Utah [Division] of Wildlife Resources, all affected land owners, lessees and 

permittees to develop...guidelines for future site specific management plans affecting upland, 

water fowl and big game habitat. (Kane, p. 66)

Fire Management 

Kane 

• Develop prescribed fire and wildfire management plans to re-establish historic fire frequencies 

for appropriate vegetation types and include in such plans livestock grazing techniques as a tool 

for fire fuel management related to both wildfires and prescribed fires. (Kane, p. 38)

Cultural Resources 

Garfield 

• The subcommittee felt that protecting the county’s traditional land uses and rural aesthetics 

should be one of the ordinance’s main objectives. (Garfield, p. 7-1) 

Kane 

• The preservation of historic resources in Kane County has been the focus of many local and 

regional organizations. Kane County will continue to partner with such organizations in historic 

preservation projects, but does not intend to become a lead agency in historic preservation. 

Conservation efforts will focus on the rehabilitation of the land base in order to improve the 

functioning of natural systems for the benefit of residents and visitors. (Kane, pp. 10–11)

• Select at least three (3) cultural resource sites for evaluation annually and track any changes in 

site characteristics such as deterioration or vandalism. Where sufficient data indicates adverse 

impacts of multiple uses occurring on a site, establish mitigation measures to reduce impacts and 

protect and conserve unique cultural resources. (Kane, p. 71)
Proposed RMP and Final EIS Appendix 16 

Kanab RMP A16-5 

• Manage the existing historic district designations in accordance with Section 110 of the National 

Historic Preservation Act of 1966. (Kane, p. 71)

• Nominate appropriate site/areas to the National Register of Historic Places only in accordance 

with the policies and procedures outlined in [the National Environmental Policy Act (NEPA)]. 

(Kane, p. 71)

• Document, record and make available to the Kane County Historical Museum Committee all data 

that details conditions found at specific cultural and paleontological sites during all site visits. 

(Kane, p. 71)

Paleontological Resources 

Kane 

• Select at least three (3) paleontological sites for evaluation annually and track any changes in site 

characteristics such as deterioration or vandalism. Where sufficient data indicates adverse impacts 

of multiple uses occurring on a site, establish mitigation measures to reduce impacts and protect 

and conserve unique paleontological resources. (Kane, p. 71)

Visual Resources 

Kane 

• Visual Resource management on federal lands cannot be allowed to impede the legal uses of 

private lands. (Kane, p. 61)

• In coordination with federal agencies and state and local government planning agencies, and in 

cooperation with interested members of the public, re-evaluate current [Visual Resource 

Management] classifications within 3 years and every 10 years thereafter. (Kane, p. 78)

RESOURCE USES

Forestry and Woodland Products 

Garfield 

• Garfield County wishes to retain its existing timber-related businesses. (Garfield, p. 5-3) 

• Continue to support the timber industry with the goal of achieving the highest long-term sustained 

production level. (Garfield, p. 5-4) 

• ...the county deems it critical that...public land timber harvesting be continued. (Garfield, p. 6-8) 

Kane 

• Plan and implement selective timber and firewood harvesting programs where dead and/or 

decadent trees need to be removed to improve forest health. (Kane, p. 72)

Livestock Grazing 

Garfield 

• Maintenance and expansion of the livestock trade should be encouraged. (Garfield, p. 5-4) 
Appendix 16 Proposed RMP and Final EIS 

A16-6 Kanab RMP 

• ...the county deems it critical that resource management plans provide for range improvements 

[and] current grazing on public land be preserved. (Garfield, p. 6-8) 

• ...the number of animal unit months (AUM) allocated within the county should be expanded to 

the full carrying capacity of the forage resource. (Garfield, p. 6-10) 

Kane 

• Develop grazing management plans following wild or prescribed fire...to provide for use of 

grazing animal management to enhance recovery. (Kane, p. 38)

• Provide for landscape vegetation maintenance and improvement which will support restoration of 

suspended AUMs [and] allocation of continuously available temporary non-renewable use as 

active preference. Current active preference and continuously available supplemental use is 

considered the established allowable use for livestock grazing. (Kane, pp. 61–62)

• Identify and implement all possible livestock distribution, forage production enhancement, and 

weed control programs before seeking changes in livestock use levels. (Kane, p. 62)

• Document all decisions or agreements resulting in changes in active preference. Determine from 

monitoring data, trend studies and seral class rangeland studies, the amount of authorized use that 

can be sustained. (Kane, p. 63)

Recreation 

Garfield 

• Recreation development occurring [on public lands] should be clustered so as not to inhibit the 

continuing use of other lands for legitimate multiple uses. (Garfield, p. 1-8) 

• The county will support efforts to establish hiking and off-highway vehicle trails across public 

lands, including a bicycle trail along Highway 12, which is a designated Scenic Byway. (Garfield, 

p. 2-6) 

• ...in an effort to strengthen its economic base, the county desires to increase its revenue 

opportunities through enhancing county recreational opportunities and developing destinationrelated activities. (Garfield, p. 5-3) 

• Garfield County supports exploring tourism and recreational opportunities in the county. 

(Garfield, p. 5-3) 

• Garfield County supports creating new attractions and recreational facilities within the county. 

(Garfield, p. 5-3) 

Kane 

• Provide for multiple recreation uses in Kane County, including federally administered lands 

located within its boundaries, ... high quality recreational opportunities and experiences at 

developed and undeveloped recreation sites, by allowing historic uses and access while 

maintaining existing amenities and by providing new recreation sites for the public’s enjoyment. 

(Kane, p. 73) 

• Pursue increased public access opportunities in both motorized and non-motorized settings 

through the acquisition of rights-of-way or easements, both public and private. (Kane, p. 73) 

• Recognize that multiple recreation uses are mandated by the multiple use concept and that 

adequate outdoor recreation resources must be provided on the BLM administered lands and

waterways. (Kane, p. 73)

• Provide for continued multiple recreation uses in special and extensive recreation management 

areas, including those areas where state, federal and/or private funds and materials were or are 

considered to be used to provide for recreational facilities. (Kane, p. 74)
Proposed RMP and Final EIS Appendix 16 

Kanab RMP A16-7 

• In compliance with applicable local, state and federal laws, identify specific areas for additional 

trailhead facilities for motorized and non-motorized access; development and/or maintenance of 

roads, trails, and waterways for both motorized and non-motorized access; [and] restoration of 

those areas formerly available for historical recreational uses (e.g., motorized and equestrian 

access for recreational and competitive events, hunting and boating). (Kane, pp. 74–75)

• Provide for adequate outdoor recreation resources by revising the designated areas to decrease or 

eliminate limitations and restrictions where the review and evaluation shows that the limitations 

and restrictions are no longer appropriate and necessary. (Kane, p. 75)

• Integrate multiple recreation uses into all planning efforts to [ensure that] they can continue to 

occur compatibly with vegetation development and soil stability. (Kane, p. 39)

• Adopt a policy of promoting all facets of destination tourism in Kane County. The policy will 

direct its major promotional efforts to those facets of tourism that benefit the maximum number 

of businesses in the county. (Kane, p. 49)

• Develop and promote a multiple use recreation and other public service facility at the Kaneplex 

site. (Kane, p. 51)

Transportation 

Garfield 

• Maintain or improve the existing roadway system within the county, including the preservation of 

[Revised Statute] 2477 access rights-of-way to Federal and state lands for mining, timber, 

grazing, etc. Such activity is authorized by state law (UCA 27-12-25). (Garfield, p. 2-5) 

• Existing public access to public land [should] be protected and all [Revised Statute] 2477 rightsof-way preserved. (Garfield, p. 6-8) 

• It is the policy of Garfield County to preserve and enhance access to public lands. (Garfield, p. 6-

11) 

Kane 

• Kane County will take the lead in providing a safe, efficient and functional transportation system 

which emphasizes the circulation of residents and visitors between communities, as well as to the 

scenic wonders found in the county. The system will stress a wide range of transportation 

methods and will be founded upon the ability of the county to utilize rights-of-way on public 

lands asserted under the authority of Revised Statute 2477. (Kane, p. 32)

• Kane County will pursue a Memorandum of Understanding with all affected federal land 

managers which allows for joint administration of a one mile wide corridor along all arterial and 

scenic routes. (Kane, pp. 32–33)

• Kane County will establish a standard which allows for the closure of county roads to the general 

public, but allows for controlled access by authorized persons. (Kane, p. 33) 

• All areas historically accessed by off-road recreational vehicles, mechanized vehicles, horses and 

boats should continue to be available for their historical uses. These historically accessed areas 

include roads, trails, sand washes, and waterways identified to the Kane County Clerk as Revised 

Statute 2477 rights-of-way. (Kane, p. 74)
Appendix 16 Proposed RMP and Final EIS 

A16-8 Kanab RMP 

Lands and Realty 

Garfield 

• Transfers of private land to Federal or state ownership should not result in a net “private land” 

acreage loss, unless they result in long-term, ongoing, economic benefits to the county. (Garfield, 

p. 6-8) 

• Garfield County supports identifying possible Federal and state land exchanges, with the 

understanding that such exchanges will not increase the net acreage of Federal lands in the 

county. (Garfield, p. 6-9) 

• Garfield County will normally, before supporting or approving any Federal-state-county 

exchanges, involve the County Natural Resource/Land Use Committee. (Garfield, p. 6-10) 

Kane 

• The county will identify BLM parcels of land needed for community development purposes. 

These parcels will be noted in the Kanab RMP. (Kane, p. 60)

• The BLM will continue to allow the use of federal lands for Recreation and Public Purposes, to 

include access roads and parking areas in locations receiving tourist visitation. (Kane, p. 60)

• There will be “No Net Increase” of federal lands in Kane County. (Kane, p. 61)

• Identify and give priority consideration to requests for exchanges or purchases from private land 

owners with fenced federal range, isolated tracts, or irregular boundary lines. (Kane, p. 68)

• Manage newly acquired lands and lands that have been returned to BLM management through 

revocation of withdrawals in accordance with existing land use plans for adjacent land. (Kane, pp. 

68–69)

Minerals and Energy 

Garfield 

• Garfield County supports aggressively pursuing coal and other mineral resource development. 

(Garfield, p. 5-3) 

• [Garfield County] deems it critical that...mining leases be considered and encouraged. (Garfield, 

p. 6-8) 

Kane 

• Facilitate environmentally responsible exploration and development based on a preponderance of 

scientific evidence for locatable mineral, oil, gas and geothermal, and common variety mineral 

resources on BLM administered lands opened to location under mining and other appropriate 

statutes. (Kane, p. 69)

• In coordination with federal agencies...develop a land management mineral classification plan to 

evaluate, classify and inventory the potential for locatable mineral, oil, gas and geothermal, and 

material mineral exploration or development in Kane County to [ensure] that lands shall remain 

open and available unless withdrawn through the NEPA process. (Kane, p. 70)
Proposed RMP and Final EIS Appendix 16 

Kanab RMP A16-9 

SPECIAL DESIGNATIONS

Areas of Critical Environmental Concern (ACEC) 

Kane 

• In order to promote multiple use and release management agencies and affected land owners from 

the burden of an added layer of management, conduct an evaluation of all existing ACEC 

designations and release those that reflect changes from conditions existing at the time of 

designation and/or [release those for which] newly acquired information and data indicate they no 

longer qualify. Conduct NEPA and FLPMA statutory review individually on each new area 

proposed for designation as Areas of Critical Environmental Concern. (Kane, p. 78)

• In compliance with the planning process set forth in FLPMA, inventory the lands in Kane 

County, identify specific Areas of Critical Environmental Concern by describing the statutory 

criteria present in the areas, and develop and implement a Management Plan for providing the 

specific management protection required. (Kane, p. 79)

• Describe the important uniqueness (one of a kind), historic, cultural or scenic value; the fish and 

wildlife resources; or other natural systems or processes in any proposed ACEC, and describe and 

document the damage which will occur to such value unless special management attention is 

given to the area, or describe and document the natural hazards of the area which will endanger 

life [and] safety unless special management attention is given. (Kane, p. 79)

• Describe and document the special management attention which is necessary to protect the 

proposed area from imminent damage to the statutory unique (one of a kind), relevance and 

importance values or to protect life and safety from natural hazards, and quantify the manner in 

which such special management attention is expected to provide the needed protection. (Kane, p. 

80)

Wild and Scenic Rivers 

Garfield 

• Garfield County will, if it deems appropriate, comment on and may develop and submit proposals 

for Wild and Scenic River designations to the appropriate Federal land management agencies. 

(Garfield, p. 6-11) 

Kane 

• In compliance with applicable local, state and federal laws, identify specific areas for national 

wild and scenic river system potential. (Kane, pp. 74–75)

• Seek immediate Congressional designation action on all Wild and Scenic River recommendations 

in Kane County to release these areas for multiple use management and in the interim prevent, 

minimize or mitigate impairment or degradation of such areas to the extent that Congressional 

actions are not pre-empted. Upon Congressional release, return management policies for the 

affected area to those consistent with land use plans and the non-wilderness full multiple use 

concept mandated by the Federal Land Policy and Management Act and Public Rangelands 

Improvement Act. (Kane, pp. 76–77)
Appendix 16 Proposed RMP and Final EIS 

A16-10 Kanab RMP 

Wilderness Study Areas 

Kane 

• Seek immediate Congressional designation action on all [Wilderness Study Area] 

recommendations in Kane County to release these areas for multiple use management and in the 

interim prevent, minimize or mitigate impairment or degradation of such areas to the extent that 

Congressional actions are not pre-empted. Upon Congressional release, return management 

policies for the affected area to those consistent with land use plans and the non-wilderness full 

multiple use concept mandated by the Federal Land Policy and Management Act and Public 

Rangelands Improvement Act. (Kane, pp. 76–77) 

Other Special Designations 

Kane 

• Protect the integrity of those portions of the Spanish Trail and associated cultural resource sites 

on BLM administered lands. (Kane, p. 71)

OTHER COUNTY ISSUES

Payment in Lieu of Taxes 

Garfield 

• Garfield County wishes to increase Payments in Lieu of Taxes (PILT). (Garfield, p. 5-3) 

• The county takes the position that it should not be penalized, through loss of Federal or state 

shared revenues such as PILT, mineral leasing, or other revenues, when Federal lands become 

state lands or when state school trust lands are exchanged. (Garfield, p. 6-9) 

Search and Rescue 

Garfield 

• ...Garfield County...supports establishing a state search and rescue fund. Monies from this fund 

would be used to reimburse counties for county-provided search and rescue services. (Garfield, p. 

4-8) 

• As a matter of economic reality, Garfield County reserves the right to establish user fees for 

search and rescue activities, based on a user pay concept. (Garfield p. 6-9) 
Public Comments and Responses - Kanab Draft RMP/EIS 

Public Comments and Respons

Kanab Draft RMP/EIS 

July 2008 

Sorted by Category Name

Category Name Commentor Comment 

Adequacy of Analysis and Alternatives 

John Veranth Both alternative B and C are major improvements over the current situation, 

Alternative A. As a general comment, I consider Alternative C to be the most appropriate of the listed alteratives and am disappointed that the BLM did not consider a true "maximum resource protection" alternative that would have been more restrictive than even alternative C. NEPA requires consideration of a full spectrum of alternatives. 

Ta

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Air Quality Laura Kamala 

Grand Canyon Trust 

There is an omission of relevant information from the planning document in the 

absence of any reference to global climate destabilization. Climate models predict that current trends of higher temperatures and reduced precipitation will continue in the Upper Colorado River Basin leading to a decrease in quantity and quality of river water and severe consequences for humans, agricultural uses, wildlife and ecosystems. The KFO planning area has already been affected by the prolonged drought. Soil disturbing activities such as cattle grazing, energy exploration and development and recreation have increased dramatically and these uses destabilize soils. Massive dust storms from soil loss deposit darkcolored dust on mountain snowpacks which absorb heat and melt too soon. Snowmelt storage in watersheds is reduced. The implications of these and other climate effects on management decisions on the public lands are not adequately 

addressed in the RMP. 

A cameetC

Air Quality National Parks 

Conservation Association 

BLM mentions the National Park Service data show an improving visibility trend for the clearlest days; it fails to mention that the visibility trend for the haziest days is worsening (2005 Annual Performance & Progress Report: Air Quality in National Parks). There is also no mention of ammonium; a component of acid precipitation which is also worsening. Additionally, no data from other national parks including Zion and Capitol Reef bordering the planning area are mentioned. There is also no mention of ozone trends showing a decline in all area parks where trend data has been collected. 

BGNi

Air Quality National Parks The BLM erroneously states that "A direct relationship between emissions and A 

1 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Conservation Association 

visibility impairment does not exist, and so the qualitative emissions analysis cannot be used to assess potential visibility impacts on nearby Class I areas from activities within the decision area." According to the National Park Service" Visibility monitoring and research by NPS and others have found fine particles less than 2.5 millionths of a meter in diameter (PM2.5) in the form of sulfates, nitrates, organics, elemental carbon, and soil particles are primarily responsible for visibility impairment." According to EPA visibility impairment or haze is caused by particulate matter emitted from sources including power plants, automobiles and other industries. 

isd

sa 

Air Quality National Parks 

Conservation Association 

BLM errs in using a "qualitative analysis" instead of using available air quality data. They have ignored their obligation to analyze the direct and indirect impacts of their management actions. BLM states "Because a quantitative relationship between the expected air emissions calculated above and the subsequent potential impacts on the air quality values of visibility, atmospheric depositon, or 

ozone are not known, it is not possible to draw any conclusions about the potential impacts expected to these air quality values." However, there is an ample air data including trend data available through a variety of sources including the National Park Service, IMPROVE, WRAP and EPA. The BLM needs to re-evaluate its finding of "no significant" impacts since it failed to utilize existing air quality data and make a meaningful analysis of current and future conditions. 

Teaa

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Air Quality National Parks 

Conservation Association 

The cumulative air analysis fails to adequately address the threats from increased energy development in the area. The Four Corners region is seeing an explosion in oil and gas development along with proposed coal fired power plant. There are also four new proposed coal fired power plants across the border in 

Nevada. Additionally, the surrounding BLM regions of Richfield and Monticellow are releasing resource management plans that were not considered but have potential impacts on the Kanab planning area. BLM needs to adquately address these impacts. 

Bapta

Air Quality SUWA The DRMP fails to adequately assess the impacts of the proposed management 

alternatives on air quality. The DRMP fails to include any quantitative information, 

analysis or models to assist the decision-maker on this issue. 

Teaa

lca

Areas of Critical Environmental Concern 

James & Lorna Sills Areas of Critical Environmental Concern (ACEC) Cottonwood Canyon ACEC is 

proposed in Alternate B. We can understand and accept this ACEC to protect the watershed, but 3800 acres seems extreme and we question whether this much acreage is needed. In addition, we strongly oppose the designation of any additional ACECs 

AeCAe

2 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Areas of Critical Environmental Concern 

Jim & Bonnie Vann Another area is the proposed Cottonwood Canyon ACEC. Although this canyon 

deserves protection primarily as a water source for the town of Fredonia, I believe its current scope is too broad and that there is no need for any additional ACEC's. 

Trbpa

Areas of Critical Environmental Concern 

Land Use Volunteers of Kane County 

We ask that the BLM implement all 5 of these ACEC areas in the final RMP. We also ask that the BLM reconsider the original nomination of the White Cliffs ACEC and reinstate the land that was originally specified for that ACEC. For some reason, the BLM had removed the upper Kanab Creek riparian corridor from the proposed ACEC area. This stream and riparian corridor needs to remain in the White Cliffs ACEC. There is no reason not to include it. Streams like Kanab Creek are very rare in our area and need protection. 

AeCta

Areas of Critical Environmental Concern 

Laura Welp In addition, all the motorized SRMPs contradict the ACECs that were proposed in 

these areas. 

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Areas of Critical Environmental Concern 

Laura Welp This is inconsistent with the preferred alternative's proposal for a motorized RMZ 

in the middle of Welsh's milkweed designated critical habitat. The Special Management Area Moquith Mountain Dunes RMZ could be disastrous for this plant. In ACEC analysis, recommendation to maintain existing management is not being followed if you put a motorized RMZ on top of the main portion ofthe 

population (see map on page 12 of attachment). The OHV's already have the Coral Pink Sand Dunes State Park for cross-country motorized recreation, and 

don't need a special management area on the BLM portion ofthe dunes, especially when it might impact a listed Threatened species. 

Tria

Areas of Critical Environmental Concern 

Margaret Stone ACEC's Five areas were nominated and found eligible to be Areas of Critical 

Environment Concern. These areas contain an approved total of 60600 ac. Since 60600 ac were found to be eligible why is the BLM recommending only 3800 ac in its preferred plan? These areas should by given priority and all should be implemented. 

Tppo

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3 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Areas of Critical Environmental Concern 

Rebecca Mann Regarding the preferred designation of Areas of Critical Environmental Concern 

(ACECs). Designating protective boundaries around currently undisturbed and high-quality wilderness areas ensures the persistence of unique, high-quality natural resources and ecological processes. All areas proposed as potential 

ACEC units should be designated as such. Many of these areas contain 

irreplaceable habitat, such as the sand dunes in which the federally threatened Welsh's Milkweed (Asclepias welshii) thrive. For this particular case, if the Coral Pink Sand Dunes area is opened for ORV use, the individuals of Welsh's Milkweed in the affected area will not have adequate reproductive opportunities, damaging the genetic diversity and overall health of this critical population. Other 

potential Areas of Critical Concern, including Cottonwood Canyon, Parunuweap Canyon, Moquith Mountain WSA, and the Vermillion and White Cliffs, share 

similar unique and special resources, and only a strict designation to protect these areas will ensure their natural values. 

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Areas of Critical Environmental Concern 

Richard Csenge Identified ACECs including the Vermillion Cliffs, Parunuweap, White Cliffs, 

Cottonwood Canyon and Welsh's Milkweed, and eligible Wild and Scenic River segments are not being given the protection they deserve in Alternatives A, B or D. If ACECs and WSRs in the Kanab District have been found to be suitable for designation, they should be included in the preferred alternative. 

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Areas of Critical Environmental Concern 

Susan Hand Areas of Critical Environmental Concern I am confused that the KFO seems to 

acknowledge that the proposed ACECs are justified, and yet Alternative B disregards staff recommendations. Since an ACEC designation is based on unique resources (ecological, biological, historical, or cultural), it seems incongruous that the BLM not designate what it has clearly identified. The Coral Pink Sand Dunes of the Moquith Mountian WSA, the Vermilion and White Cliffs, and Purunaweap Canyon are worthy of ACEC designation, but have been 

overlooked. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Areas of Critical Environmental Concern 

SUWA To rectify this, once BLM has determined that certain areas in the Kanab Field 

Office contain the requisite relevant and importance values - which the Kanab Field Office has already done - the agency must prioritize the designation ofthose 

areas as ACECs over other competing resource uses. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Areas of Critical Environmental Concern 

SUWA BLM's treatment of proposed ACECs in the DRMP/EIS does not comply with 

either FLPMA's mandate or the agency's own internal guidance. 

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Areas of Critical Environmental Concern 

SUWA BLM has improperly ignored or discounted the threats to special places from oil 

and gas development and off-road vehicle use, and thus failed to designate and/or failed to incorporate sufficient protections for proposed ACECs. 

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Areas of Critical Environmental Concern 

SUWA However, the Kanab DRMP fails to support designation of ACECs to protect 

these values. BLM has identified approximately 89,780 acres of lands with wilderness characteristics. 

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Areas of Critical Environmental Concern 

SUWA That BLM has determined that 60,600 acres meet the relevance and importance 

criteria for ACEC designation, BLM must give priority to the designation of these 

ACECs in all alternatives, not merely Alternative C. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Areas of Critical Environmental Concern 

SUWA SUWA also contends that the values found to relevant and important extend to 

acreage beyond the 6,100 in the potential ACEC. We urge the BLM to reevaluate the extent of these values and designate a larger acreage. (Parunuweap Canyon) 

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Areas of Critical Environmental Concern 

Tracy Hiscock The BLM RMP fails to implement the five Areas of Critical Environmental 

Concern (ACEC), that were nominated for the plan under the Federal Land Policy and Management Act (FLPMA), Title II, Section 202(c)3. 

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Areas of Critical Environmental Concern 

Utah Archeological Research Institute 

We suggest that all these areas be combined and placed in one ACEC, and it should include all BLM administered lands in the entire Cottonwood Canyonj drainage system from highway 89 on the east to the Coral Pink Sand Dunes on the west and the Arizona border on the south, and that it should be established for protection of archaeological resources. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Areas of Critical Environmental Concern 

Utah Rock Art Research Association 

The area proposed under alternative C should be expanded eastward to include all public lands adjacent to Kanab and should include areas west of Three Lakes Canyon. This region has significant early Basketmaker Anasazi and Pueblo III 

archeological sites including a bird-headed Basketmaker Style rock art panel that is reminiscent of rock are found in the Grand Gulch region. These cultural resources need to be proactively managed through an archeologically focused ACEC including cultural resource inventories, nominations to the Nation Register, 

interpretation and education facilities near well known sites, physical monitoring, and being closed to surface occupancy and natural resource leasing in this area. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Areas of Critical Environmental Concern 

Utah Rock Art Research Association 

We believe the region from the Arizona state line north to the East Fork of the Virgin River and from Kane County line to Yellowjacket Canyon Road should be included in the ACEC. There are rock art sites south of the Virgin River of an unusual style not found anywhere else. This is an archeologically unique area within the state of Utah and requires special attention to documentation and 

protection. 

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Areas of Critical Environmental Concern 

Walter Fertig ACEC designation: The Field Office resource staff did a good job of evaluating 

the merits of the proposed ACECs in the planning area, but oddly, their recommendations are being bypassed in the preferred alternative B. ACECs are 

valuable chiefly for drawing attention to areas of unusual biological, ecological, cultural, or historical interest. Ideally, BLM would develop management prescriptions to ensure these values are maintained, but at a bare minimum the ACEC designation identifies that such a value exists so that future actions and 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

proposals can be dealt with in ways to minimize impacts. Ignoring the assessment that all ofthe proposed areas meet ACEC requirements and the specious reasoning that the areas are already protected by other management tools makes Alternative B's dismissal ofall but the existing Cottonwood Canyon ACEC seem arbitrary and counter to the BLM's resource management mandate. Besides, if the areas are already adequately protected without the ACEC designation, no harm is done by making them ACECs! 

Consultation and Coordination 

Bryce Canyon National Park 

Stipulations for Mineral Leasing: As the resources management planning process moves forward, we would like to work with you to develop appropriate stipulations 

for mineral extraction activities near the park. The fundamental purpose of such stipulations will be to protect those values that we have identified in this letter. 

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Consultation and Coordination 

Five County Association of Governments 

The Draft RMP goes on to simply state that the preferred alternative is consistent 

with local plans to the extent possible. No analysis of how this conclusion was reached is made. This is a serious omission. The consistency section should be expanded to include such an analysis. 

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Consultation and Coordination 

Monte Chamberlin Proposed RMP plans are not in accordance with the Kane County General Plan 

or state law and federal law. The elected officials of the County were "bypassed" and/or given misinformation during the planning stage ofthe process. BLM does 

not have the authority to override or "bully" county officials or usurp the authority 

of duly elected individuals to govern. 

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Consultation and Coordination 

SUWA Recommendation: The Kanab RMP should reflect certain aspects of the GSENM 

RMP for consistency purposes as well as to provide both the Kanab planning area and the GSENM the proper protection needed to ensure long-term preservation of the outstanding values of this landscape. The RMP should also provide measurable goals, objectives, and desired future conditions that recognize the area's special virtues of ruggedness, remoteness, and wildness. 

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Consultation and Coordination 

SUWA Recommendation: The Kanab RMP should be consistent with the management 

of the National Parks in the area and should provide management objectives and 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

prescriptions that protect and do not impair the conservation values of the adjacent and nearby National Parks. This should include, but is not limited to, the air quality and visibility impairment of the Parks from actions occurring within the planning area. 

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Consultation and Coordination 

Utah Archeological Research Institute 

No roads should be closed without consultation with all Native American Tribes. The BLM's policy should be in complete compliance with the American Indian Religious Freedom Act; Executive Order 13007: Indian Sacred Sites; Executive Order 13175: Consultation and Coordination with Indian Tribal Governments and all other federal laws, regulations and executive orders that recognize the "unique 

relationship" between the federal government and Indian tribes, (see also Advisory Council on Historic Preservation Policy Statement, dated November 17, 200, regarding relationships with Indian tribes). 

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Consultation and Coordination 

Zion National Park Because of this we strongly suggest that as part of the Preferred Alternative for 

the Final Resource Management Plan (FRMP), BLM lands adjacent to the park (within 2-miles of the park boundary - refer to attached Map) be designated as Visual Resource Management (VRM) Class I. 

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Consultation and Coordination 

Zion National Park In additional we ask that these same lands be designated exclusion areas for all 

right-of-way and communication sites (e.g., cell phone towers) to protect these scenic vistas. 

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Consultation and Coordination 

Zion National Park Second, to protect the scenic integrity along the Highway 9 corridor from Mt. 

Carmel Junction to the east entrance of the park and from integral vistas within the park, it is important that the BLM designate the corridor and vistas within the view-shed from the park as VRM Class II. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Consultation and Coordination 

Zion National Park In addition to Class II VRM designation, we ask as part of the Preferred 

Alternative for the FRMP that this corridor be designated as avoidance areas for all right-of-way and communication sites (e.g., cell phone towers) to protect the scenic vistas. 

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Consultation and Coordination 

Zion National Park As part of the Preferred Alternative for the FRMP, we strongly request that BLM 

lands within 2-miles of the park be closed to OHV use. This includes closing any roads that dead-end at the park boundary (refer to attached Map). 

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Consultation and Coordination 

Zion National Park As part of the Preferred Alternative for the FRMP, we strongly request that areas 

immediately adjacent to and near the park (within 2-miles of the park boundary - refer to attached Map) be designated: • closed to oil and gas leasing - designation should apply to both Federal surface/Federal minerals and . private surface/Federal minerals (split-estate); • closed to coal leasing; • withdrawn from 

locatable mineral entry; • closed to mineral material disposal; and • closed to nonenergy mineral leasing . 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Consultation and Coordination 

Zion National Park In order to minimally protect the watersheds to help mitigate the influx of nonnative plant species into the park, we again ask as part of the Preferred 

Alternative for the FRMP that all lands, within 2-miles (at a minimum) of the park boundary be (refer to attached Map): • closed to all surface disturbing activities; and • that any restoration use only plant species native to the area. 

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Cultural Resources Christopher Lish Unlimited damage would also occur to the historical record of native cultures, 

because the BLM has not conducted any surveys to determine the location and extent of archaeological artifacts or culturally important sites, or the impact of ORVs on these irreplaceable resources, despite authorizing ongoing ORV use that could destroy them forever. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Cultural Resources Colorado Plateau 

Archaeological Alliance 

CPAA recognizes that cultural resources can be adversely impacted through the 

course of non-regulated surface-disturbing activities such as cross-country OHV travel, wildfires, collection of artifacts, vandalism and pedestrian impacts that are not typically considered through Section 106 reviews. However, such adverse impacts to cultural resources are, in many instances, the indirect consequence of regulated surface-disturbing activities that are considered during the Section 106 review process (e.g., road access to accommodate development that subsequently provides access to looters and vandals). Consequently, the Draft 

EIS must adequately consider all impacts of undertaking on National Registereligible properties that may be a consequence of the undertaking but not directly related to it. The document currently does not address this issue. 

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Cultural Resources Colorado Plateau 

Archaeological Alliance 

The Draft EIS also fails to properly consider cumulative impacts (DEIS 4-280 to 4-281). A mere acknowledgement that resource decisions resulting from the 

RMP "could produce cumulative impacts on cultural resources and resources of religious or traditional importance to Native American tribes" does not constitute a careful consideration of what those cumulative impacts would be under each of the alternatives. In fact, there is no acknowledgement that components of all alternatives increase the risk to cultural resources from looting, vandalism and other inadvertent impacts. Other Draft EISs prepared for Moab and Monticello at 

least recognize "the potential impacts from the continually increasing recreational 

visitation" and that "the substantial increase in OHV ownership and recreational use will continue to subject cultural resources in the region to heightened risk of damage, vandalism and/or looting" (see Moab DEIS 4-502). CPAA concurs with the assessment in the Moab DEIS, and recommends that the Kanab Draft EIS be 

modified to acknowledge and fully analyze the potential impacts of OHV use on such a massive scale that could result in cumulative effects to site setting and 

integrity, even if the historic properties themselves are not directly impacted (see 36 CFR 800.5(a)(2)(v)). 

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Cultural Resources Colorado Plateau 

Archaeological Alliance 

As such, the Travel Plan is fundamentally flawed on two important points: (1) The failure of the BLM to conduct adequate analysis in the past related to OHV impacts along routes currently being used by motorized vehicles was and still remains an abrogation of agency's Section 106 responsibilities, and the failure of 

the agency to recognize or correct this deficiency in the new Travel Plan appears to validate and perpetuate the agency's failure to comply with Section 106 

requirements in the past; and (2) the failure to require Class III inventories along routes prior to designation suggests the agency official has already made a determination, as per 36 CFR 800.3(a), that travel route designations in such 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

instances are not an undertaking as defined in 36 CFR 800.16(y). u

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Cultural Resources Colorado Plateau 

Archaeological Alliance 

A factual inaccuracy needs to be corrected in Section 3.2.9 Current Conditions 

(DEIS 3-58) that states Noel Morss led the pioneering archaeological 

investigations of the Claflin Emerson Expedition. Morss, a major figure in Utah archaeology, was actually a minor figure on the Claflin Emerson Expedition, which was led in 1929 and 1930 by Henry B. Roberts, and in 1931 by Donald Scott. Morss was a member of the expedition but only peripherally, conducting his own investigations in Wayne County in 1928 and 1929 (mostly in areas managed by the Richfield Field Office, Price Field Office and Capitol Reef National Park that are irrelevant to this Draft EIS). 

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Cultural Resources Colorado Plateau 

Archaeological Alliance 

As described in Areas of Importance to Native American Tribes (DEIS2-56), the BLM would "allow Native American non-commercial traditional use of vegetation and forest and woodland products for the collection of herbs, medicines, traditional use items, or items necessary for traditional, religious or ceremonial purposes, through permits" (emphasis added). The establishment of a permitting 

process to allow Native American use of items necessary for traditional, religious or ceremonial purposes would appear to contradict the spirit of the American 

Indian Religious Freedom Act (42 U.S.C. 1996) guaranteeing the freedom of 

Native Americans to worship through ceremonials and traditional rites. 

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Cultural Resources Diane Orr 

BeecherFilms 

The BLM has overall failed to provide an alternative which fulfills the BLM’s duty to protect cultural resources in the Kanab Management Area as outlined by the National Historic Preservation Act.. I am profoundly concerned that cultural resources, particularly rock art, will be damaged or completely destroyed if the BLM proceeds to allow the extensive energy development suggested in all alternatives. I have consulted with J. Claire Dean of Dean and Associates Conservation Services. Ms. Dean has over 27 years of experience in rock art and archeological conservation. Ms. Dean states that industrial traffic can damage 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

rock art in several ways. Dust accumulates on the rock surface. The natural hydrology of the rock lays down a mineral layer on the rock surface which may mix with the dust and essentially coat the rock art, reducing the visibility of the petroglyphs. The extent and amount of damage depends on the geologic and hydrologic characteristics of the rock surface. Without studying these characteristics, the BLM can not know whether or not energy development will damage or destroy world class cultural resources. Your plans do not discuss or even mention these important factors in your energy development plans. Further, without such research, no development should occur where rock art would be exposed to industrial dust. Another consideration, entirely neglected by the BLM draft management plan, is the impact of wind-blown dust on the surface of rock art. In NineMileCanyon, industrial traffic has caused 30 foot plumes of dust which have covered panels on high cliff surfaces. Ms. Dean states that wind-blown dust and sand act like an abrasive on rock surfaces. The rock art literally can be sanded off the surface with cumulative and continual sand blasting. I saw no mention of this danger in you consideration of energy development in cultural resource areas. I have discussed dust resulting from industrial traffic, but ORVs and ATVs may also cause sufficient dust to do damage to rock art. URARA recommends that no roads or trails be further designated within one quarter mile of rock art. We feel this is a conservative request without the benefit of necessary research. Without further research, BLM is putting rock art at risk in all of the alternatives provided for public comment. 

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Cultural Resources Tim Peterson Please establish and implement a schedule to completely survey your field office 

for cultural resources. In areas of known conflict, protection of cultural resources 

should take precedence over other activities including off-roading. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Cultural Resources Utah Archeological 

Research Institute 

The above statements are not meant to imply or indicate that we advocate roads leading directly to archaeological sites. We have found that where roads lead directly to archaeological sites, vandalism and loss of artifacts always occurs. We recommend that all roads end at least 1/4 mile from rock art sites and that the best measure of protection is having no roads leading to archaeological sites. 

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Cultural Resources Utah Archeological 

Research Institute 

On pages ES-11 you state "Impacts from increasing levels of cross-country OHV use would affect long-term condition of soils, water quality, and vegetation communities" you need to add something to the effect that this action also 

adversely impacts archaeological resources. On page 1-9, under recreation, you state: "In certain parts, increased visitor use is affecting soil, water, vegetation, 

and wildlife" You need or add: and is adversely impacting prehistoris archaeological resources. 

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Cultural Resources Utah Archeological 

Research Institute 

On Page 2-25 the DRMP/DEIS would "regulate rock climbing within 300 feet of cultural sites. Climbing routes that impact cultural resource sites would generally not be allowed, and climbing routes designed to access cultural resource sites would not be allowed unless under permit for scientific investigation." We request that that this distance be increased to 500 feet from rock art sites. We ask for this change because it has been determined that the rock art was placed in specific 

locations to interact with shadows created by the sun and nearby rock formations as it travels throughout the year. In one instance, a large rock appears to have been placed on a ledge to cast a shadow on a specific element or elements in a 

prehistoric panel at a specific time, or perhaps times of year, thus creating a 

clendrical function to the site. Rock climbers can intentionally or unintentionally 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

move, or even remove such a rock, which might be seen to them as an obstacle. We ask that every effort be made to keep the surroundings of rock art sites as intact as possible so research in this respect can continue without adverse impacts occurring, which would make such research impossible. 

Cultural Resources Utah Archeological 

Research Institute 

On page 2-56 it is stated under Prioritize New Field Inventories that the areas to be surveyed are 100 feet (30 meters) (depending on topography) on either side from the centerline of designated OHV routes and 100 feet (30 meters) (depending on topography) on either side from the centerline of a road. This is not acceptable and needs be modified. This assumes direct impacts, however most of the damage comes from indirect impacts where a feature that might contain an archaeological site is visible from the road or tail, like a rockshelter, a cave, a cliff face where there may be rock art, or a concentration of stones. You need to include in the survey any area or feature that is visible from the road or trail that might contain archaeological sites, because I can guarantee you that if any of these features are present, people will stop and walk over to them, even if they are more than a mile away. We know, because we do it all the time. 

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Cultural Resources Utah Archeological 

Research Institute 

Is the difference between a Class I, II and III cultural resource inventory explained in the DRMP/DEIS: If so, there should also be a reference here (page 

2-56) explaining these designations. 

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Cultural Resources Utah Archeological 

Research Institute 

We also would like to note an error on page 3-58, which states, "Archaeological investigations started with the Harvard-sponsored Claflin-Emerson expeditions in the late 1920s led by Noel DARI comments Page 6 Morss". This is not correct. The Claflin Emerson Expedition was led in 1929 & 1930 by Henry Roberts and in 1931 by Donald Scott (Gunnerson 1969) and they were sponsored by Claflin and Emerson - two businessmen. Morss was a minor participant in the ClaflinEmerson Expeditions. 

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Cultural Resources Utah Archeological 

Research Institute 

We would like to suggest that you add to this statement something to the effect that: when a new hypothesis needs to be tested, as in the case of determining the meaning and purpose of rock art, if the rock art has been removed or the 

surroundings damaged, scientific studies will likely no longer be possible. (Rock art sites must be preserved in place.) 

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Cultural Resources Utah Archeological 

Research Institute 

No discussion is present regarding the distinction between OHV and licensed passenger vehicles. Here again you combine OHVs and commercially produced licensed passenger vehicles (e.g., Ford, Toyota, Jeep, etc.) in one category. It appears that you have the belief that you cannot close an area to OHV crosscountry travel without also closing the existing roads in these areas to all motor vehicles. You need to realize that the two are separate issues and make this distinction clear in all discussions throughout the DRMP/DEIS. In addition, why can't you close an area to all OHVs and limit travel only to commercially manufactured licensed passenger vehicles? The absence of defining and 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

separating motorized vehicles into at least two classes is the most frustrating and annoying feature of the DRMP/DEIS. In addition, there are other related questions: Why can't you close an area to all cross-county motorized travel and leave all the roads open? We do not see this option in any of the alternatives. Why not? Aren't there enough alternatives? Perhaps you should have more than just four. Because of these issues, we do not believe that the Draft Resource Management Plan and Environmental Impact Statement develops a satisfactory procedure that adequately protects rock art and other archaeological sites in KFO managed lands. 

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Fire and Fuels Management 

ECOS Consulting This section is not an analysis of impacts, as it is supposed to be, it is just a 

series of statements stating the obvious. What is the extent of the direct, indirect, and cumulative impacts on these species if fire suppression and management plans are enacted? 

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Fire and Fuels Management 

U.S. Geological Survey 

Vegetation treatment actions have been well thought out in this draft RMP/EIS. Specifically, Table 2-1 (pp 2-16 to 2-19) nicely summarizes actions by major vegetation group. It is suggested that the final document add language that restricts seeding operations to microsites with the greatest probabilities of 

success. Significant time and resources have been invested in failed seeding projects on arid lands; some of these failures might have been prevented by 

better tailoring of treatment prescriptions by site quality. The public would also benefit if the final RMP/EIS discussed whether BLM plans to aggressively suppress wildfire, when possible, on sagebrush sites to minimize mortality to sage plants that had previously been subjected to frequent fire. This is important because most sage species cannot tolerate frequent, repeated fire. 

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Fire and Fuels Management 

U.S. Geological Survey 

The Fire Regime Condition Classes (FRCC's) may not be as well defined for sage biome and other arid lands as they are for coniferous forests. It would benefit the public if the final RMP/EIS identified target vegetation descriptions in 

addition to FRCC's metrics of when to implement various treatments. (p. 2-16) 

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Lands and Realty Bryant Shakespear 

Garkane Energy 

While recognizing existing "major" energy corridors the draft RMP fails to meet the planning objective of providing new utility corridors that could be utilized for needed electrical transmission projects. See pages 1-10, 2-26, 3-87, 3-88. To the extent possible the RMP should identify corridors connecting the communities 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

within the planning area. Creating such corridors would promote joint use, limit more applications and facilities to previously disturbed areas and allow utility companies to better plan upgrades and new facilities for placement in identified corridors. 

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Lands and Realty Bryant Shakespear 

Garkane Energy 

The plan fails to coordinate the placement of utility corridors with existing 

corridors identified by the current Dixie National Forest Management Plan. Specifically the existing corridor south of Wilson Peak, Township 36 S Range 4.5 W. See pages 1-10, 1-15, 1-18, 2-26. 

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Lands and Realty Bryant Shakespear 

Garkane Energy 

Alternatives B, C, D identify avoidance and exclusion areas. Most of these 

parallel US Highway-89, the Sevier River, or SR-9. As indicted on page 1-10 these areas are identified "for the goals and objectives of other resources" which certainly is important. However, the proposed avoidance and/or exclusion areas around the communities of Hatch, and Panguitch/Spry effectively cut these and other down line communities off from the existing electrical transmission backbone. Without an access route/corridor to these existing electrical 

transmission facilities Garkane will be unable to serve the current and future power needs of Hatch, Spry, Long Valley, Cedar Mountain, and Alton. See pages 4-193 to 4-197 and maps 2-20 to 2-22. 

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Lands and Realty Bryant Shakespear 

Garkane Energy 

Specifically Garkane has applied to construct a 138 kV transmission line from Tropic to Hatch, and a 69 kV upgradeable to 138 kV transmission line from Hatch to Long Valley Junction. Our porposed routes and several possible alternatives will cross the lands identified for avoidance or exclusion. If Garkane is unable to obtain ROW for these and future projects local citizens will likely experience more outages and will be become increasingly dependant on mobile diesel generation to meet peak power demands. Garkane would also be forced to take measures to reduce peak and base loads in these areas be establishing new service hookup moratoriums, load shedding (rolling black outs), and increased electrical rates. The lack of sufficient power would substantially constrain local economic development contrary to the statement on page 4-260 of the draft RMP. 

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Lands and Realty Bryant Shakespear 

Garkane Energy 

Alternative B requires that consideration be given to burying new and reconstructed utility lines up to 34.5 kV. Alternative C requires burying new and 

reconstructed utility lines up to 34.5 kV. These requirements create unsafe working conditions and the potential for electrical flash over. See page 2-89. 

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Lands and Realty Bryant Shakespear 

Garkane Energy 

It is our opinion that these requirements should be modified to include voltages up to 24 kV for burial rather than the proposed 34.5 kV in order to provide safe working conditions. Please review the enclosed article. 

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Lands and Realty Bryant Shakespear 

Garkane Energy 

The cost increase of burying lines is significant. Based on current material prices and trenching rates Garkane estimates it will costs a project proponent 300 percent more to construct an underground distribution line opposed to an overhead line. The maintenance costs are also increased and reliability of lines 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

decreased with underground distribution line construction. The burial requirement of Alternative C is arbitrary and does not consider the effected resources, location, and environment of a proposed line. Underground distribution linjes should only be considered when overhead lines cannot meet other resource objects. See pages 2-89. 

Lands and Realty Carl Albrecht 

Garkane Energy 

1. While recognizing existing "major" energy corridors, the Draft RMP fails to meet the planning objective of providing new utility corridors that could be utilized 

for needed electrical transmission projects. See Pages 1-10, 2-26, 3-87, 3-88. To the extent possible, the RMP should identify corridors connecting the communities within the planning area. Creating such corridors would promote joint use, limit more applications and facilities to previously disturbed areas, and allow utility companies to better plan upgrades and new facilities for placement in identified corridors. 

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Lands and Realty Carl Albrecht 

Garkane Energy 

2. The plan fails to coordinate the placement of utility corridors with existing corridors identified by the current Dixie National Forest Management Plan. Specifically the existing corridor south of Wilson Peak, Township 36 S Range, 4.5 W. See Pages 1-10, 1-15, 1-18, 2-26. 

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Lands and Realty Carl Albrecht 

Garkane Energy 

4. Alternatives B, C, and D identify avoidance and exclusion areas. Most of these 

parallel Highway 89, the Sevier River; or SR-9. As indicated on Page 1-10, these areas are identified "for the goals and objectives of other resources" which certainly is important, However, the proposed avoidance and/or exclusion areas around the communities of Hatch, and the Panguitch/Spry Area effectively cut these and other down line communities off from the existing electrical transmission backbone. Without an access route/corridor to these exisiting electrical transmission facilities, Garkane will be unable to serve the current and future power needs of Hatch, Spry, Long Valley, Cedar Mountain, and Alton. See Page 4-193 to 4-197 and Maps 2-20 to 2-22. 

Anlattu

Lands and Realty Carl Albrecht 

Garkane Energy 

Garkane has two pending applications for new transmission lines that will cross these areas. Addditional distribution lines will be needed in the Hatch and 

Panguitch areas as these locations continue to develop and grow. The Avoidance and/or Exclusion Zone boundaries need to be moved so that the east boundaries are west of the existing power lines. 

Anlattu

Lands and Realty Carl Albrecht 

Garkane Energy 

Our proposed routes and several possible alternatives will cross the lands idenified for avoidance or exclusion. If Gakane is unable to obtain a ROW for these and future projects, local citizens will likely experience unacceptable power service and will become increasingly dependent on diesel generation to meet 

peak power demdns. Garkane would also be forced to take measures to reduce peak and base loads in these areas by establishing new service hoop-up 

Anlatt

23 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

moratoriums, load shedding (rolling black outs), and increased electrical rates. The lack of sufficient power would substantially constrain local economic development, contrary to the statement on Page 4-260 of the Draft RMP. 

u

Lands and Realty Carl Albrecht 

Garkane Energy 

Alternative C requires burying new and reconstructed utilities lines up to 34.5 kV. 

These requirements create unsafe working conditions and the potential for electrical flash over. See Page 2-89. 

T

Lands and Realty Carl Albrecht 

Garkane Energy 

Alternative B, C, and D require the use of non-reflective wire (non-specular 

conductor). Projects using non-specular conductor have had a marked increase of avian collision with the conductor and its use may be counterproductive to the avian protection lmeasures inxluded as part of the Draft RMP. 

Tl

Lands and Realty Carl Albrecht 

Garkane Energy 

It is our opinion that these requirements should be modified to include voltages up to 25 kV for burial, rather than the proposed 34.5 kV in order to provide safe working conditions. Please review the ennclosed articles and information (Enclosure). 

T

Lands and Realty Carl Albrecht 

Garkane Energy 

The cost increase of burying lines is significant. Based on current material prices and trenching rates, Garkane estimates it will cost a project proponent 300 perecent more to construct an underground distribution line opposed to an 

overhead line. The maintenance costs are also increased and reliability of lines 

decreased with underground distribution line construction. The burial requirement of Alternative C is arbitrary and does not consider the effected resources, location, and environment of a proposed line. Underground distribution lines should only be considered when overhead lines cannot meet other resources objects. See Pages 2-89. 

A 

w

Lands and Realty Dirk Clayson Future right of ways and easements should not be restricted in the plan in large 

geographical areas. All easements for access, water right, fence maintenance, etc should be evaluated on their own merits and not restricted without evaluation. 

R2c

Lands and Realty ECOS Consulting The width and extent of "Right-of Ways" and "Easements" proposed in the 

alternatives are too large and expansive to maintain functional ecosystems, viable unfragmented wildlife populations, natural vegetation communities, intact 

soil structure, and prevent widespread wind (dust) and soil erosion. 

To

iu

Lands and Realty ECOS Consulting In order to protect the ecological integrity of the Kanab Decision Area, it is 

recommended that all "rights-of-ways" and "easements" are limited to a maximum width of 100 meters or less, and that the total number be minimized. 

T

oiu

Lands and Realty ECOS Consulting The BLM is being irresponsible in the future planning of ROW's when it 

recommends that 72% of the Decision Area be open to the cumulative potential of all these adverse impacts, that's almost 400,000 acres out of a total of 520,000 acres. This is not reasonable, and is another example of mismanagement by not dealing directly with the issues. 

Wnacoa

24 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Lands and Realty ECOS Consulting The BLM must limit all "right-of-ways" and "easements" to no more than 100 

meters in width. The unlimited extent of "Right-ofWays" and "Easements" planned over 72% of the Decision Area in the preferred alternative is too large to maintain functional ecosystems, viable unfragmented wildlife populations, natural 

vegetation communities, intact soil structure, and prevent widespread wind (dust) and soil erosion. 

To

i

u

Lands and Realty ECOS Consulting If the authorization of ROW's would have potential direct, indirect, and cumulative 

short- and long-term adverse impacts on wildlife, then there should be an indepth analysis of these impacts on wildlife and an estimate of locations and 

extent of these impacts and what wildlife would be most impacted and how these impacts affect BLM species population goals. 

Pia

Lands and Realty Jana Hassett The plan proposed alternative does not recognize the City of Escalante Water 

System and existing ROW's for the water mains currently crossing BLM lands within the management area. solution - These ROW's need to be added and acknowledged within the plan and recognize the need for vehicle access to all segments of the ROW for maintenance. 

Te

Lands and Realty Keith Robinson 

Kanab City Public Works 

After looking over the Kanab Field Office Draft Resource Management Plan and Draft Environmental Impact Statement I would like to see the shaded area of the 

attached map designated as open for water development by Kanab City. Roads to the wells, water lines and power lines should also be allowed in this area. The BLM has worked with Kanab City over the years in helping developing our culinary water sources. Some of the above area is already within a Land Use Agreement to protect the Kanab City watershed. 

I

at

Lands and Realty Norman McKee 2 – 26: The BLM should take a very pro-active approach to make land trades with 

SITLA. Without trades, WSA’s are in jeopardy, crucial wildlife habitat is compromised, and new roads and utility corridors are required as trust lands are privatized and developed within BLM lands. 

TCc

Lands and Realty PacifiCorp Such activities (pole replacement, conductor and/or insulator replacement, etc.) 

would presumably occur within the company's existing transmission right-of way. However, the company must retain the right to service our existing power line(s) if maintenance is required within the restricted area(s) represented on the map. 

Mn

Lands and Realty PacifiCorp The Executive Summary (Pg. ES-I0) recommends limiting OHV use to 

"designated routes". Rocky Mountain Power generally concurs with this policy insofar as protecting natural and cultural resources. However, we also maintain an interest in reserving access to electrical facilities where needed to accommodate ongoing repair/maintenance and inspection needs. 

Mn

Lands and Realty PacifiCorp PacifiCorp recommends that BLM designate energy corridors in areas where 

PacifiCorp has submitted proposed corridors as part of the West-Wide Energy 

Corridor PElS . We have attached a map that shows the locations of the proposed utility corridors contained in the draft EIS as compared to the locations of the proposed energy corridors that were submitted by PacifiCorp to the 

Tf

25 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Department of Energy for consideration as part of the PElS. It should be noted that PacifiCorp's proposed energy corridors depicted on the map simply connect two end points of energy resource areas and areas of energy demand. We did not apply engineering design or environmental analysis when developing these options. An electronic version of this map is contained on the enclosed CD. PacifiCorp supports the establishment of energy corridors throughout the Kanab BLM Resource Area. 

Lands and Realty PacifiCorp Communication facilities may be adversely affected by siting additional 

communication facilities in close proximity. Recommended Revision!Action PacifiCorp recommends that the following statement be added to all of the 

alternatives, "The addition of new communications devices on existing towers will be considered where it is practical and does not present a safety or operational 

risk." 

Tac

Lands and Realty PacifiCorp There are two places in the report that state to bury distribution power lines 

including Appendix A, Page 3, Mineral Exploration and Development, Bbullet 10 and Page 4 Reducing Impacts to Visual Resource Management Class II and III Areas, Bullet 1. PacifiCorp believes that these statements are overly restrictive and need to be qualified. 

Td

r

ma

Lands and Realty PacifiCorp Timing Limitations are detailed for a variety of Resources of Concern in Table 

AC-l. PacifiCorp requires access to existing electric lines without restriction to perform emergency maintenance and repairs that may include rebuilding of structures within the line. 

Mn

Lands and Realty PacifiCorp Solar and wind powered renewal resources are becoming an increasingly 

important source of electric generation. No discussion of the potential for this development is included in this section. 

Ta

Lands and Realty PacifiCorp PacifiCorp recommends that the EIS and final RMP include a specific provision 

within the EIS and RMP stating that ROW facilities will not be placed adjacent to 

each other if issues with safety or incompatibility or resource conflicts are identified. The Western Electric Coordinating Council (WECC), a regional coordinating council for western utility groups, also supports this approach. 

Tac

Lands and Realty PacifiCorp PacifiCorp recommends that the EIS and final RMP include a specific provision 

within the EIS and RMP stating that ROW facilities will not be placed adjacent to 

each other if issues with safety or incompatibility or resource conflicts are identified. The Western Electric Coordinating Council (WECC), a regional coordinating council for western utility groups, also supports this approach. 

Tac

Lands and Realty PacifiCorp PacifiCorp is concerned that the EIS does not address electrical emergency 

situations. In an electrical emergency situation, PacifiCorp must be able to enter onto and conduct repairs or adjustments within a rights-of-way area governed by 

a ROW grant at any time. 

Mn

Lands and Realty Shirley Fujimoto Thus the BLM should prepare a Final EIS and revised RMP to encourage and P

26 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

McDermott, Will & Emery 

facilitate the siting of this infrastructure on federal lands in the Kanab Resource Area. 

pc

Lands and Realty Shirley Fujimoto 

McDermott, Will & Emery 

By contrast, the BLM should not adopt Alternative C. The BLM should also not 

adopt the proposal under Alternatives B and D to require communication site plans for all existing communications sites before any new type os uses or new facilities would be authorized on these sites. 

Tc

Livestock Grazing Dirk Clayson Cross county motorized travel should not be eliminated for cattle maintenance 

and fence repairs. There may be a number of other items as well that require this access such as cedar post, mining, engineering, survey work, re-seeding, etc. 

AimN

Livestock Grazing ECOS Consulting The DRMP does not analyze the serious short- and long-term adverse impacts 

from livestock grazing in desert environments. 

N

a(a

Livestock Grazing ECOS Consulting Page 4-17, 3r d Paragraph: Actions that allow livestock trampling ofbiological soil 

crusts are not short-term and localized, as stated in this paragraph. It is well 

documented in the scientific literature that BSC's are easily destroyed by livestock trampling and that recovery time for BSC's can take from up to 300 years, depending on micro-site characteristics. With the loss ofBSC's from the 

trampling of livestock grazing the ecosystem would suffer the loss of many positive ecological functions. Thus the impacts are severe and long-term. 

T

t

a

Livestock Grazing ECOS Consulting Page 4-25, 5th Paragraph: The BLM must show how livestock grazing according 

to BLM Standards and Guidelines would eliminate long-term impacts. What specifically will the Standards and Guidelines direct the BLM to do in order to 

mitigate the effects of erosion from compacted soil, from the destruction of biological soil crusts, from vegetation loss, from the invasion of exotic species, from stream bank failure due to vegetation loss and erosion, and from direct fecal matter input into surface water? 

TTlt

Livestock Grazing ECOS Consulting If the BLM can, it must show the documentation that these conditions are indeed 

improving, and why they are improving. Or at least, the BLM must summarize this information in this DRMP/EIS, or provide a list of allotments or areas and their conditions and trends. There is a total lack of any of this kind of information in this DRMP/EIS. How is the public able to determine if the BLM is managing the range properly if there are no results, analyses, recommendations, or feedback from over 12 years of commitment to the Standards and Guidelines? There are a number of areas in the Decision Area that clearly do not meet the current BLM standards. What are the plans for those areas? 

Tcactfad

ag

Livestock Grazing ECOS Consulting The Kanab DRMP/DEIS fails to adequately address the negative direct, indirect, 

and cumulative effects of livestock grazing on the soils, vegetation, water quality, and stream functions within riparian areas. 

N

a(

27 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

a

Livestock Grazing ECOS Consulting The DRMP should state what actions will be taken based on various drought 

conditions. 

Cd

Livestock Grazing Hal Hamblin As the lessee for the Kinne Kernie (?) Springs alotment, I would to have the 

active AUM's available for use be looked into & possibly re-evaluated. 

Md

Livestock Grazing Jeff, Kendalee, 

Mccrae, Buster and Maddie Cox C-4 Ranch 

We have recently signed a long term lease agreement with the Barracks Ranch and are in the middle of leasing the poverty allotment, which places us smack dab in the middle of two proposed road closurs. The Poeverty and Steep Train 

roads are the only way to access water on these permits. As you well know, the watering hole is the focal point of cattle permits. We need the access to make frequent visits to make sure the cows are watering, and to monitor and maintain riparian areas. 

Tdr

Livestock Grazing John Keeler 

Utah Farm Bureau Federation 

Yet in Section 2-55 (Fish and Wildlife Management Actions) and 2-64 (Livestock Grazing Management Actions) you plan to reallocate AUMs from livestock to wildlife which is not consistent with the Taylor Grazing Act either. In fact, you mention that you are going to suspend 88 livestock AUMs and reallocate them to 

wildlife into the Water Canyon, Sawmill and Lower Northfork allotments under the various alternatives. Not only do we feel this action would be inconsistent but it may very well be a violation of the Act. We realize these are a very few number of AUMs but we feel it unwise for you to pursue the course of reallocating 

livestock AUMs to wildlife. These reallocations are also mentioned in Sections 4-113, 4-169 and 4-171 under "Cultural Impacts" and other places in the document. 

Tgauehaphloto

w

Livestock Grazing Laura Kamala 

Grand Canyon Trust 

We strongly urge BLM to keep livestock out of riparian areas to assure properly functioning conditions of these areas and especially during times when an already arid environment is stressed by drought. 

Irw

iatcHe

Livestock Grazing Laura Welp I suggest that you include a plan for dealing with drought in the RMP. Drought is 

such a constant in this area that grazing management must have a plan to prepare for it, yet many field offices don't have a formal method in place. 

Cd

Livestock Grazing Merlin Esplin Page ES-7, and other places discuss the idea of reallocating 48 animal unit 

months (AUM's) from livestock to wildlife. I am strongly opposed to this move and believe it is in direct conflict with the earlier agreements between resource 

Tto

28 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

managers, ranchers, and wildlife managers. Wildlife AUM's were allocated early on. There is no need for reallocations of this sort now or ever. Are the AUM's for wildlife on table 3-24, new allocations or existing? Wording in the text below table 3-24 indicates AUM's are over allocated - if this is the case they should not be transferred to wildlife. Once the range recovers from drought AUM's could be reallocated to livestock as per the intent of the Taylor Grazing Act. 

Sl

Livestock Grazing Merlin Esplin Secondly, there is a statement about combining allotments. I believe this 

statement is out of place in the RMP, at least until affected permittees have had 

the opportunity to respond (which they have not in this case). If the allotments are held by the same permittee this may not be much of an issue, however if the allotments are held by different people it may be a very serious issue . Does this action even need to be included in the RMP? 

Tpa

q

Livestock Grazing Merlin Esplin On page 2-67 I have great concerns about the language consistent with all action 

alternatives under Grazing Management Practices. Under "Allocation of Relinquished Preference for Livestock Forage" the language is confusing and appears to favor a permittee desiring to sell to a non-bonified livestock operator, because he may choose to relinquish all or part for no reason at all. It looks like a loop hole to get around the intent of the Taylor Grazing Act, and could possible be used as another tool to remove livestock from the public lands. Please review the wording very carefully and ensure BLM's meaning is clearly stated and consistent with law and policy. 

Ti

Livestock Grazing Randy Parker 

Utah Farm Bureau Federation 

Allocation of resources for wildlife was previously addressed. Farm Bureau opposes reallocation of livestock AUM's to wildlife. 

Tgauehaphlotow

Livestock Grazing Randy Parker 

Utah Farm Bureau Federation 

Suggestions within the RMP that reduced grazing decreases erosion is contrary to science. Most of the soils are heavy clay, resisting water infiltration. Grazing 

disturbs the surface crust, allowing moisture into the soil and fertilizer perpetuating plant germination. 

PDceil

29 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Livestock Grazing Rebecca Mann Rangeland assessment. Science-based ecological assessments, using 

standardized data collection methods such the Rangeland Health Indicator system, should be regularly conducted to determine if allotments are being properly managed and not overgrazed. Unfortunately, I haven't looked into current methods being used, but wish to express my concern that the assessments be standardized, regularly conducted, and that the data collected is 

regularly analyzed with results utilized in an adaptive management program. Rangeland that is not properly maintained and is over-exposed to grazing, risks undergoing an irreversible transition to a degraded state, creating ecological problems such as erosion and top soil loss, loss of plant, animal, and microbial biodiversity, exotic weed invasion, and altered fire regimes. To best ensure the long-term viability of rangelands, regular ecological assessments should be a part of an adaptive management program. 

It

wiatcHe

Livestock Grazing Western Watersheds 

Project, Inc. 

BLM has provided no science to show that livestock grazing reduces spread or severity of fire . To the contrary, if BLM had troubled itself to look, livestock grazing increasesfire severity. Where is the science to support the myth that grazing cheatgrass reduces cheatgrass? 

BdaC

Livestock Grazing Western Watersheds 

Project, Inc. 

The Kanab FO should conduct a capability analysis to determine the areas that might be available for livestock grazing, excluding steep slopes >30%, low forage production <200 lbs/areas, ecosystems converted by wildfire or invasive weeds, and the ability of sensitive soils to respond following impacts (arid elevations, reclamation, soil chemistry, drought). 

ARc

cpimM

m

Livestock Grazing Western Watersheds 

Project, Inc. 

The DEIS does not present an allotment by allotment summary of current monitoring information that describes the trend or condition as compared to the existing RMP. 

Tca

ctfad

ag

Maps Barry Clarkson 

Clarkson Draper & Beckstrom, LLC 

Finally upon my review of the maps included it has become apparent that there 

are errors in the maps as to which land falls under the RMP and in fact which land is public. For example, Map 2-16 shows that the BLM Property extends to 

the Arizona border between the Kanab City area and property owned by my client. This is incorrect. There is a strip of land along the Arizona border which is 

private and belongs to my client and his successors in interest. I have attached a 

TAR

30 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

set of maps which clearly show this to be true. 

Maps BLM - Arizona Strip 

Field Office 

Map 2-44, General Surface Disturbance Restrictions, Alternative B Why is the Paria Canyon-Vermilion Cliffs Wilderness indicated on this map with "seasonal restrictions" for surface disturbance restrictions? Is this to accommodate fire use? 

Why would the wilderness not be classified as "no surface disturbing actions?" 

ToRndttlbs

Maps Capital Trail Vehical 

Association 

The maps and figures are not easily understood. There are no identifiable or named features and no road and trail numbers on the maps. It is very difficult for the public to orient themselves and to interpret the proposed action for each 

specific road and trail. Therefore, the public cannot adequately evaluate the proposal and cannot develop comments with reference to specific roads and trails. 

T

csf

wOiv

Maps John Veranth For the record, I will state that the RMP maps available online were inadequate to 

allow proper public comment. The scale of the map, the lack of background 

transportation and culture information, and the resolution of the file preclude figuring out where the proposed designated route is in many cases even when 

viewed at 800%. For Example In Alt B, the OHV route on private land east of 

Escalante appears to be the start of the Boulder Mail Trail, but could also be 

another route farther west or could be one of the vehicle tracks heading from Hwy 12 to the monument boundary. Likewise, to the west of Escalante it appears that one route is the Middle Canyon Road, but it could be something else. Since one cannot tell the exact route alignment, it is impossible to comment on the impact this route would have on the adjacent Federal land. The combination of low and high resolution maps as was used in the Moab RMP was a much better approach. 

TcsfwO

iv

Maps Laura Welp The boundary in the nominated map is not the same as the map I submitted (see 

map on page 11 of attachment). My original boundary is much closer to the boundary you determined was eligible for ACEC designation. 

Tia t(tdA

Maps National Parks With the exception of Map 1-01 Landownership, the maps do not show the T

31 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Conservation Association 

national park boundaries for parks within or adjacent to the planning area. Without this information it is impossible to evaluate the impacts on the affected national parks and their resources. BLM must provide adequate mapping so that the impacts of their alternatives may be analyzed by the public. 

oo

Minerals and Energy Bryce Canyon 

National Park 

"Under no circumstances should this decision become the only basis for protection of the values for which Bryce Canyon National Park was established and I direct that these park values be taken into account in future decisions by the bureaus of this Department on mining plans, permit applications for other activities on undesignated Federal lands near the park." (Emphasis added). We 

believe that the intent and specifics of the Secretarial Order should be noted in the Resources Management Plan. 

T

Minerals and Energy Mark Sterkel BLM should provide in the RMP for a buffer zone around Zion, Bryce, and Grand 

Staircase Natl Parks. I mile should be considered a minimum, where no locatable or leasable energy or mineral drilling or mining should be allowed. The DRMP affords the Springdale/Virgin watershead far less protection than it does for it's own Kanab watershed. 

AG

TopTtpcciw

dSwcatrcp

Minerals and Energy SUWA The BLM must more fully quantify this risk, as well as the potential for mineral 

recovery (and the likely amounts to be recovered) and compare them to the gains to the environment from the most well-balanced alternative, Alternative C. 

Ts

itUvoan

32 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

m

Minerals and Energy SUWA However, the Kanab Draft RMP evaluates an unjustifiably inflated reasonably 

foreseeable development scenario of ninety wells over a twenty-year period - or 4.5 wells per year. Id at 3-90, 4-198. This rate is nearly four times the historic average for the Kanab Field Office, including surface lands managed by the U.S. Forest Service. Although oil and gas development may be subject to fluctuations, the reasonably foreseeable development scenario significantly exceeds the historical reality ofthe planning area. 

Trn

et

Minerals and Energy SUWA One shortcoming common to every alternative analyzed in the Kanab Draft RMP 

is that the BLM has not endeavored to match oil and gas leasing stipulations with actual known geologic reserves of oil and gas and areas of historical development. 

Brp

Minerals and Energy SUWA The BLM provides no justification for this figure. Inexplicably, the RFD actually 

excludes the past twenty years from its calculations, seemingly for no other reason than because recent figures have been low. 

T

rnet

Minerals and Energy SUWA Kanab Draft RMP at 3-90, 4-198. This RFD scenario is arbitrary, capricious, and 

unrealistic. No twenty-year period in the history of the planning area has ever seen such a high rate of development. 

Trnet

Minerals and Energy SUWA The BLM must develop a new reasonably foreseeable development scenario that 

is historically accurate and actually tied to productive oil and gas fields. The present method completely ignores historical trends and declining production. None of the alternatives close certain. environmentally sensitive areas that should be closed, which hold little or no oil and gas production potential and are mostly unleased. 

Trnet

Minerals and Energy SUWA The BLM has never had before it the possibility of totally abandoning oil and gas 

leasing in the Kanab planning area, something it is required to do. See Bob 

Marshall Alliance, 852 F.2d at 1228. 

Cn

Minerals and Energy SUWA The BLM must take a hard look at whether any actual trade off exists between 

the preferred alternative and the additional protections of an alternative that include all of the closures and stipulations found in Alternative C as well as the additional closures and stipulations recommended above. The Kanab Draft RMP already states that none of the current alternatives would result in any changes to the RFD. 

Aid

Minerals and Energy SUWA The BLM should modify the alternatives, particularly Alternative C, so that they 

will close additional environmentally sensitive areas to leasing - or to surface occupancysince such closures are unlikely to limit feasible oil and gas production 

TMP

33 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

in the planning area. The BLM should either close to leasing or impose no surface occupancy restrictions on the entire area south of U.S. 9 and west of U.S. 89. Though no current leases exist in this area, it is an extremely environmentally sensitive and deserving of protection from these damaging activities. The area contains the following important resources: three WSAs and additional non-WSA lands with wilderness characteristics, an area of relict vegetation, critical habitat of the Mexican spotted owl, crucial and high value mule deer habitat, elk habitat, crucial desert bighorn sheep habitat, and numerous proposed ACECs. Kanab Draft RMP at Maps 2-39,3-4,3-8,3-10,3-11,3-12,3-15,318. Furthermore, the National Park Service has expressed concern that leasing in this area could damage the Navajo Aquifer; the BLM should not offer for lease any lands overlying the Navajo Aquifer because ofthe resulting degradation that could occur in Zion National Park. See Letter from Martin C. Ott, Superintendent, Zion National Park, National Park Service, to Barbara Sharrow, Acting Field Office Manager, Kanab Field Office (Jan. 4, 2002) (attached as Attachment RR). The BLM should also close to leasing or place no surface occupancy restrictions on all lands east of U.S. 89 and south ofthe road running from Glendale to the Skutampah road. No current leases exist in this area, it contains non-WSA lands with wilderness characteristics, is home to areas ofrelict vegetation and fragile soils, contains crucial and high value mule deer habitat, contains elk habitat, and has numerous proposed ACECs. Kanab Draft RMP at Maps 2-39,3-4,3-10,3-11,3-15,3-18. In addition, all lands containing critical habitat for the Mexican spotted owl on the western edge ofthe planning area should either be closed to leasing or restricted to no surface occupancy (T39-43S R8-9W). See id. at Map 3-8. Furthermore, the BLM should either close to leasing or place no surface occupancy stipulations on greater sage-grouse brooding areas and winter range. See id. at Map 3-9. 

lhWPUvoanm

Minerals and Energy – Leaseable 

PacifiCorp Section 4.2.11 discusses the allowed development of Oil and Gas and mineral 

exploration and production but does not discuss the connected action of electric 

transmission right-of-way (ROW) to serve these developments. 

Tde

Minerals and Energy – Leaseable 

Theodore Roosevelt Conservation Partnership 

Given the nature of leasing and the need for upfront comprehensive planning) it needs to be known during the RMP process how the Kanab Field Office will establish plans for mitigation) including detailed fish and wildlife monitoring and the use of adaptive management strategies to prevent, minimize or mitigate 

impacts of oil and/or gas exploration and development for future parcels offered for leasing, 

Tamfp

Minerals and Energy – Leaseable 

Walter Fertig Oil and gas leasing: Alternative B is an improvement over the existing condition 

in which nearly all BLM lands in the immediate vicinity of Kanab are open to oil and gas leasing under standard terms and conditions. While Alternative B would impose more stringent leasing constraints (such as No Surface Occupancy), the 

preferable solution would be to close these areas to leasing entirely, as proposed in Alternative C. These areas have very low oil and gas potential and have higher 

AGTopT

34 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

significance to the local community as a watershed and for scenic values. Likewise, the Kanab FO should consider lease closure in the areas adjacent to Zion National Park (especially near the NE corner of the park) within the watershed for Springdale. Alternative B leaves much of this area open to leasing subject to moderate constraints, while Alternative C would close these areas of minor oil and gas probability to leasing. 

tpcciwdSwcatrcp

Non-WSA Lands with Wilderness Characteristics 

Bill May I do not believe that the BLM should create artificial wilderness by designating it 

As an area with Wilderness Characteristic areas ... I believe the BLM should seek Out alternate methods to manage and protect the land, without giving it a WC Designation... I believe that some WC areas such as Sheep Springs, Four Mile Creek and Kanab Creek have been improperly inventoried and should not receive Such recognition. These areas have historically used machine built roads. 

ApiB

ofi

Non-WSA Lands with Wilderness Characteristics 

Bill May Calling a new WSA by a different name does not make it legal. 2) Please 

disclose the difference in management prescriptions between "non-WSA lands with wilderness characteristics" and WSAs in the Final Environmental Impact Statement (FEIS). 3) The 1999 inventory found lands that contain extensive OHV 

trails to have "wilderness characteristics." If the presence ofOHV use did not impact the presence or absence of "wilderness characteristics," then by what rationale is the BLM proposing to significantly reduce OHV trails in these areas? 4) The Supplemental Environmental Impact Statement (SEIS) is utilizing the Utah BLM 1999 statewide wilderness re-inventory. This inventory was based on criteria that were not available for public comment and review. 

TaPr

Non-WSA Lands with Wilderness Characteristics 

Bill May I believe that some WC areas such as Sheep Springs, Four Mile Creek and 

Kanab Creek have been improperly inventoried and should not receive Such recognition. These areas have historically used machine built roads. 

Api

Bofi

Non-WSA Lands with Wilderness Characteristics 

BLM - Arizona Strip Field Office 

Page 2-4, under Alternative B, the Preferred Alternative, states "Require no prescriptions specifically to maintain WC areas." Why are there no prescriptions to maintain wilderness characteristics areas in the preferred alternative? Page 2-

Ta

35 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

23 lists the objective for management of non-WSA lands with wilderness characteristics as "Maintain wilderness characteristics (appearance of naturalness, outstanding opportunities for solitude, or primitive and unconfined recreation) of WC areas, as appropriate. Manage these primitive and backcountry landscapes for their undeveloped character and to provide opportunities for primitive recreational activities and experiences of solitude, as appropriate." How can this objective be obtained when there are no management actions in the Preferred Alternative to do this? 

Non-WSA Lands with Wilderness Characteristics 

BLM - Arizona Strip Field Office 

The discussion on pages 2-59 and 2-60 addresses management of non-WSA lands with wilderness characteristics. Several of the areas included for 

management to maintain wilderness characteristics under Alternative C are areas that were determined to not have these characteristics, such as Black Hills and Heaps Canyon. Why would these areas be managed for characteristics they do not possess? In addition, the Alternative C text should make it clear that only portions of other wilderness characteristics areas (those parts determined to have wilderness characteristics) would be managed to maintain those characteristics. 

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Non-WSA Lands with Wilderness Characteristics 

BLM - Arizona Strip Field Office 

There is a contradiction in decisions in Chapter 2. Page 2-91 states that Alternatives B, C, and D would "Retain non-WSA lands with wilderness 

characteristics in federal ownership." However, pages 2-59 and 2-60 indicate this is only true for Alternative C since alternatives B and D would "Require no prescriptions specifically to maintain wilderness characteristics areas." 

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Non-WSA Lands with Wilderness Characteristics 

Capital Trail Vehicle Association 

There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Once the "603 Process" was completed, the agency was done with its Wilderness review. The question of which lands should be included in the National Wilderness Preservation System is now between Congress and the American people. Other than the management of existing WSA's, the BLM should have no part in this issue. To do so is a tragic loss of management resources. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Non-WSA Lands with Wilderness Characteristics 

Dale Grange I strongly object to the creation of areas with wilderness characteristics (WCs). 

This is simply a hollow way of creating new WSAs where that authority expired in 1991! The BLM should not be creating areas that will be managed in the same ways as existing WSAs. Before BLM creates such areas, it should be necessary to explain in detail how the management of these two types of lands will differ and have public comment before the fact, not after. It is always disappointing to see how closely BLM areas for WC follow the boundaries that the more extreme environmental groups (SUWA) are proposing for wilderness. Creating these 

areas is really only one more step toward making them permanent wilderness. 

One big problem with this is that most areas being considered as having WC already have motorized travel occurring. If this type of use does not disqualify these areas from having WC, then these kinds of uses must not be so bad! 

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Non-WSA Lands with Wilderness Characteristics 

David Armbruster Regarding definition of Non-Wilderness Areas with Wilderness Characteristics, 

the U.S. District Court decided that Congress requires the U.S. Forest Service by law to maintain a balance between wilderness protection and motorized use in authorized Wilderness Study Areas. On BLM managed lands, given that Congress rightly expected continued motorized use in WSAs, there is no legal basis by which the BLM is attempting to exclude motorized use by including a new category for Non-Wilderness Areas with Wilderness Characteristics. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Non-WSA Lands with Wilderness Characteristics 

Desiree Smith I do not believe that Far Mile Creek, Kanab Creek, and Sheep Springs Road 

should not considered wilderness places because they all have roads that run through them that lead to trails. 

Api

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Non-WSA Lands with Wilderness Characteristics 

Don Black Canyon Country 4x4 Club 

Although Alternate B "Requires no prescriptions specifically to maintain WC areas." We oppose having the designation of Non WSA Lands with Wilderness Characteristics. The Map 3-15 and table 3-22 should not be included as part of this process. Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. There is 

no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Managing WC areas as shown in Alternate C to specifically maintain wilderness characteristics, does not meet the multiple use and sustain yield mandate. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

twpPpsInccBcFi§

Non-WSA Lands with Wilderness Characteristics 

Don Black U4WDA 

Although Alternative B “Requires no prescriptions specifically to maintain WC areas.” U4WDA opposes having the designation of Non WSA Lands with Wilderness Characteristics. The Map 3-15 and table 3-22 should not be included 

as part of this process. Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. There is no justification, no mandate in FLPMA and no process 

requirement for engaging in an ongoing Wilderness inventory and review. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

BcFi§

Non-WSA Lands with Wilderness Characteristics 

Five County Association of Governments 

Wilderness inventories ended pursuant to the provisions of FLPMA. BLM 

identified lands with wilderness qualities, and has forwarded these recommendations to Congress. The final RMP should limit wilderness management to formally designated wilderness areas and wilderness study areas. Subsequent inventories, especially those conducted by non-professional special interest groups should not hold any credence in management actions laid out in the final RMP. 

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Non-WSA Lands with Wilderness Characteristics 

Frank and Kaye Alleman 

We also don't think you have the authority to create areas of Wilderness Characteristics in non WSA lands. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

lsadBptcStpfp1twpPpsInccBcFi§

Non-WSA Lands with Wilderness Characteristics 

Geno Ramsey Canyon Country 4x4 

I do not believe that the BLM should create artificial wilderness by designation it 

as an area with Wilderness Characteristic areas. I believe the BLM should seek out alternate methods to manage and protect the land, without giving it a WC designation. I believe that some WC areas such as Sheep Springs, Four Mile Creek and Kanab Creek have been improperly inventoried and should not receive such recognition. These areas have historically used machine built roads. (NOTE: If approved as WC areas, this land would basically be locked up just like a Wilderness Study Area, without the act of Congress needed to legally make Wilderness. Naming these lands as such is one step closer to them becoming full-blown Wilderness, not necessarily a bad thing in every case, but a step that shouldn't be included in this RMP nor be performed by the BLM. 

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Non-WSA Lands with Wilderness 

James & Lorna Sills Non WSA Lands With Wilderness Characteristics (WC) Congress gave very 

specific instructions to the BLM regarding Wilderness. Those instructions are 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Characteristics contained in section 603 ofFLPMA. There is no justification, no mandate in 

FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Therefore the Map 3-15 and table 3-22 should not be included as part of this process. 

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Non-WSA Lands with Wilderness Characteristics 

Jan Kobialka Areas of wilderness character contiguous to Zion National Park should be closed 

to ORVs, because Zion visitors often hike in these areas, as our friends did on their last trip. These include Parunuweap Canyon, Canaan Mountain and Moquith Mountain. Please close the Moquith Mountain ORV loop and keep ORVs out of the Coral Pink Sand Dunes, a beautiful area that should be managed for unspoiled character. Areas near the town of Kanab also need to be closed against the growing impacts of ORVs - Vermilion Cliffs, Upper Kanab Creek, and Moquith Mountain. 

Ta

Non-WSA Lands with Wilderness Characteristics 

Jerry & Cindy Foote I believe that the BLM is establishing new wilderness areas without the authority 

to do so. To manage areas that have "wilderness characteristics" as WSAs is illegal. If these "wilderness characteristic" areas are based on the Utah BLM 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

1999 statewide wilderness re-inventory then these areas have no standing as this re-inventory was performed without public oversight, comment or review. Further, those areas claimed to have "wilderness characteristics" may not be managed as WSAs and OHV travel in these areas may not be restricted. Further still, these non-WSA "wilderness characteristic" areas are being managed and considered part of the Kane County General Plan for the citizens of Kane County. 

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Non-WSA Lands with Wilderness Characteristics 

Jimmy Page U4WDA & Wasatch Cruisers 

*3 areas that are classified w/ wilderness characters" (Sheep Springs, four mile creek, Kanabe creek) have machine created Roads! These areas are in use right 

now. 

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Non-WSA Lands with Wilderness Characteristics 

Joan Thacher The DRMP has designated this area as having Wilderness Characteristics but 

again you are giving it no special protection. Where are hikers such as myself to go close to Kanab where we can still enjoy some solitude? I used to hike in Hog Canyon, but not anymore. 

TsAr

Non-WSA Lands with Land Use Volunteers Given the wilderness quality of most of this land, it is inappropriate to place M

43 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Wilderness Characteristics 

of Kane County designated transportation routes in the area. No designated routes should be 

placed within the areas identified to be of wilderness quality by the 1999 BLM Wilderness Inventory. 

nCw

Non-WSA Lands with Wilderness Characteristics 

Laura Welp Allowing motorized use in these areas is contrary to these objectives, so the 

alternatives A, B, and D are in conflict with these objectives. 

MnCw

Non-WSA Lands with Wilderness Characteristics 

Marlin Sharp Lone Peak 4 Wheelers 

I believe that some WC areas such as Sheep Springs, Four Mile Creek and Kanab Creek have been improperly inventoried and should not receive such recognition ... These areas have historically used machine built roads. 

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Non-WSA Lands with Wilderness Characteristics 

Merlin Esplin Is BLM required by law to discuss "Non-WSA Lands with Wilderness 

Characteristics"? It looks like another defacto wilderness attempt which does not need space on paper. BLM, again, has authority to administer the kinds of uses and activities permitted on public lands. It is enough. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Non-WSA Lands with Wilderness Characteristics 

Michelle Young I do not feel the BLM has the Authority to create Wilderness Characteristic Areas. T

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Non-WSA Lands with Wilderness Characteristics 

Name not legible I do not feel the BLM has the authority to create wilderness Characteristic Areas. T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

lsadBptcStpfp1twpPpsInccBcFi§

Non-WSA Lands with Wilderness Characteristics 

Nate Delaney Please disclose the difference in management prescriptions between "non-WSA 

lands with wilderness characteristics" and WSAs in the Final Environmental Impact Statement (FEIS). 

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Non-WSA Lands with Wilderness Characteristics 

Nate Delaney The 1999 inventory found lands that contain extensive OHV trails to have the 

"wilderness characteristics." If the presence of OHV use did not impact the presence or absence of "wilderness characteristics," then by what rationale is the BLM proposing to significantly reduce OHV trails in these areas? 

TaPr

Non-WSA Lands with Wilderness Characteristics 

Ray and Sharon Wells Area with wilderness characteristics - White Cliffs area up to Glendale bench and 

down Four mile and Kanab Creek. 1. Sheep Springs road and spring area are machine built on top of the Whites T0410S -R0060W Sec. 25 2. Four mile Creek and Kanab Creek area were machine built which BLM has pictures of showing 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

this and this was a main corridor from Glendale bench down to Kanab since the late 1800’s, there are at least three signature rocks along the way with a couple of mileage markers still visible on rocks down Kanab Creek. also there are at least two lime kiln sites where lime was produced along Kanab Creek This was a main road and industrial area. How does it now qualify as a wilderness or even an area with wilderness qualities. Our ancestors would laugh at us! This area is riddled with roads and improvements (fences, springs, kilns, water tanks, etc. this area is ridden from top to bottom by trucks, jeeps, and OHV’s and has been for decades. How can it qualify for wilderness characteristics? 

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Non-WSA Lands with Wilderness Characteristics 

Russell Regentine BLM is establishing new WSAs without the authority to do so. T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Non-WSA Lands with Wilderness Characteristics 

Russell Regentine Please disclose the difference in management prescriptions between "non-WSA 

lands with wilderness characteristics" and WSAs in the Final Environmental Impact Statement (FEIS). 

T6Rwt

Non-WSA Lands with Wilderness Characteristics 

Russell Regentine The 1999 inventory found lands that contain extensive OHV trails to have 

"wilderness characteristics." If the presence of OHV use did not impact the presence or absence of "wilderness characteristics," then by what rationale is the 

BLM proposing to significantly reduce OHV trails in these areas? 

TsR

Non-WSA Lands with Wilderness Characteristics 

Seth Bowers U4WDA 

3) Sheep Spring, four Mile Creek, and Kanab Creek are machine made roads that have been maintained since the late 1800's. This feat in its own negates these areas as wilderness. 

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Non-WSA Lands with Wilderness Characteristics 

SUWA Motorized routes should not be designated within lands with identified wilderness 

characteristics. 

MnCw

Non-WSA Lands with Wilderness Characteristics 

SUWA This management strategy should apply to both non-WSA lands identified as 

possessing wilderness characteristics by the BLM and non-WSA lands with wilderness characteristics included in wilderness proposals that have been introduced before Congress (i.e. the UWC ARWA proposal). 

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Non-WSA Lands with Wilderness Characteristics 

SUWA However, SUWA and others maintain that some wilderness quality lands have 

yet to be appropriately identified as possessing wilderness characteristics by the BLM. 

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Non-WSA Lands with Wilderness Characteristics 

SUWA There also remain some areas that the BLM has yet to conduct an appropriate 

on-the- ground inventory, and has instead relied on aerial photos (which tend to exaggerate impacts because vegetation patterns from old impacts are far more 

visible from the air than on the ground), where as most of these impacts cannot be found on the ground by experienced field workers, and would certainly be unnoticeable to most visitors. 

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Non-WSA Lands with Wilderness Characteristics 

SUWA Based on our review, SUWA contends that BLM has only performed a cursory 

assessment of these wilderness character units and a more complete and detailed evaluation and inventory of these units is warranted. 

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48 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Non-WSA Lands with Wilderness Characteristics 

SUWA These observation are based on on-the-ground inventories and other records. In 

sum, BLM must review the new information that SUWA has provided, and conduct on-the-ground wilderness inventories and reviews for these areas. 

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Non-WSA Lands with Wilderness Characteristics 

SUWA The recent WCR arbitrarily excludes or fails to identify many natural and 

wilderness-character- quality BLM lands contiguous with the Dixie National Forest. 

Tdca

Non-WSA Lands with Wilderness Characteristics 

SUWA The Kanab and Utah BLM bases this arbitrary exclusion on the fact that the 

Forest Service has not yet "administratively endorsed" their portion of the 

roadless area for wilderness designation, therefore, the area would have to meet the size requirements as a "stand alone unit." This arbitrary practice requires that lands within the Forest Service must be currently endorsed for wilderness designation in order for the adjacent Kanab BLM lands to meet the wilderness character and size requirement. 

Tdca

Non-WSA Lands with Wilderness Characteristics 

SUWA Therefore, the exclusion of this natural area, adjoining and contiguous with the 

larger Forest Service roadless area is not justified. 

Tdca

Non-WSA Lands with Wilderness Characteristics 

SUWA SUWA did supply the Kanab BLM with supplemental and new information for the 

Black Hills wilderness character unit previously, this information remains valid and BLM will need to correctly identify the area as retaining a wilderness character for all RMP planning purposes. 

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Non-WSA Lands with Wilderness Characteristics 

SUWA BLM needs to correct this omission and correctly include natural lands and 

identify the true extent of naturalness. 

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Non-WSA Lands with SUWA This (Heaps Canyon Wilderness Character Unit) has not been correctly identified A

49 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Wilderness Characteristics 

by the Kanab BLM. p

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Non-WSA Lands with Wilderness Characteristics 

SUWA BLM will need to correct this oversight and continue to expand its wilderness 

characteristic boundary north as shown by the supplemental map until it 

encounters a significant impact. 

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Non-WSA Lands with Wilderness Characteristics 

SUWA The submission of information did not get incorporated within the planning 

process and was not assessed during the recent WCR. SUWA's wilderness character comments remain valid and highlight the full extent of wilderness characteristics not identified by the BLM. (Orderville Canyon Wilderness Character Unit) 

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Non-WSA Lands with Wilderness Characteristics 

SUWA None of this public information has yet been addressed or have these concerns 

and situation here been properly completed during its recent WCR. The comments remain valid and highlight where the full extent of wilderness characteristics are not identified by the BLM. (Orderville) 

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Non-WSA Lands with Wilderness Characteristics 

SUWA In spite of having this information, it appears the BLM has yet to address these 

concerns during the recent WCR or within the DRMP/EIS. The comments remain valid and continue to demonstrate the full extent of wilderness characteristics not identified by the BLM. (Parunuweap Canyon) 

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Non-WSA Lands with Wilderness Characteristics 

SUWA The recent WCR is unjustified by the overly exclusion of the natural areas. 

(Parunuweap Canyon) 

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50 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Non-WSA Lands with Wilderness Characteristics 

SUWA This area exemplifies the failure of the BLM to identify wilderness values and 

characteristics -- by an outright arbitrary separation of natural areas. (Vermillion Cliffs) 

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Non-WSA Lands with Wilderness Characteristics 

Tim Rasmussen Sheep Springs Road, Four Mile Creek Road and Kanab Creek are all areas with 

existing roads. These roads are machine-made and should not be considered a wilderness area. 

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Non-WSA Lands with Wilderness Characteristics 

Utah Archeological Research Institute 

Therefore, there are no nonwilderness study lands with wilderness characteristics. They do not exist. The land was already studied and determined to be lacking in wilderness characteristics. Therefore, we ask that this section be 

deleted because the determination has already been made. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

BcFi§

Other Darren Brinkerhoff I have listed several reasons below why the BLMshould open up the land instead 

of close it down: 1) The Americans with disabilities Act (ADA) prohibits discrimination on the basis of disability by public entities. Subtitle A protects 

qualified individuals with disabilities from discrimination on the basis of disability in the services, programs, or activities of all State and local governments. It 

extends the prohibition of discrimination in federally assisted programs. 

Taprap

Process and Procedures 

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

My client has access to his property ONLY through the affected lands subject to the RMP. The applicable statute requires, "A list of individuals and groups known to be interested in or affected by a resource management plan shall be maintained by the District Manager and those on the list shall be notified of public 

participation activities" 43 CFR 1610.2(d). It is clear that my client has a direct 

interest in, and is affected by the proposed RMP and yet he has not been notified of any change. 

TIrKpatbpR

Process and Procedures 

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

Issue No.1; Failure to Cooperate with Local Government Agencies. As you know the RMP was prepared as a requirement of NEPA as well as FLPMA. NEPA requires that local and state governments be consulted prior to taking action. In the present case no report or input was included or considered from either the 

involved counties or affected cities. Failure to include a report from a local government seems to violate NEPA and the cooperative principals upon which it is based. In the event there has been some report or suggestions from local governments or officials, said information should be included in the report and identified as such. 

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Process and Procedures 

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

In the present case no individual from the community has been included in any advisory committee thus depriving the decision making process of any local 

flavor or information which related to historical or socio-economic impacts to the proposed changes. 

BiDr

Process and Procedures 

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

It is impossible to respond in sufficient detail on the proposed RMP given the time before public comment is closed. 

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52 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

aCgcf

Process and Procedures 

Bryant Shakespear Garkane Energy 

Cummulative Impact Analysis fails to include Garkane Energy proposed Tropic to Hatch 138 kV Transmission Line, application submitted to Kanab Field Office 

April of 2007. See pages 4-276, 4-285, 4-286. 

Ct

Process and Procedures 

Capital Trail Vehical Association 

The project has a critical flaw which is the lack of a true "pro-recreation alternative that adequately addresses motorized recreation. All of the alternatives developed for consideration represent a significant reduction in routes available 

for motorized use. Not one Alternative even sustains the current opportunity. 

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Process and Procedures 

Capital Trail Vehical Association 

Therefore, it is incumbent upon the project team to formulate at least one 

alternative that maximizes motorized recreation, or at least does not reduce motorized recreational opportunities in the planning area. Therefore, we request that the project team formulate a wide range of alternatives including at least one Alternative that maximizes motorized recreational . opportunities in the project area and addresses the following: 

At8m

Process and Procedures 

Capital Trail Vehical Association 

The cumulative effect of all motorized closures has been significant and is growing greater every day yet they have not been adequately addressed. Ignoring cumulative effects allows the agency to continue to close motorized routes unchecked because the facts are not on the table. CEQ guidance on cumulative effects was developed to prevent just this sort of blatant misuse of NEPA. 

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Process and Procedures 

Capital Trail Vehical Association 

The existing level of motorized access and recreation must not be dismissed without adequate consideration because it is only associated with the No Action Alternative. The existing level of motorized access and recreation is reasonable 

alternative and an alternative other than No Action must be built around it. 

At8m

Process and Procedures 

Capital Trail Vehical Association 

The difference between an RMP (general guidance) and the Travel Plan (implementation decision) is not clearly described in the DEIS. The FEIS should clearly articulate the difference. 

Ti

Process and Procedures 

Capital Trail Vehical Association 

We are concerned that many of the restrictions in all ofthe Action Alternatives are 

simply not justified. The FEIS should clearly draw a connection between the facts on the ground and the decision made. 

Creia

53 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

sAs

Process and Procedures 

Capital Trail Vehical Association 

The different management plans being developed by the BLM and Forest Service are using generated, estimated and inadequate data to forward an agenda ofeliminating access and motorized recreation from public lands. The economic impact ofthese closures will be devastating to small communities throughout the 

West. Models can be manipulated to predict any result Economic models such as IMPLAN should not be used when the input data is estimated and not factual or actual. Adequate effort must be exercised by the agencies to gather true on the ground data from businesses and individuals that use our public lands. We request that the economic analysis use actual local data to determine the true economic and social impact ofproposed motorized access and closures on the public. 

CreiasAs

Process and Procedures 

Capital Trail Vehical Association 

We request that these deficiencies be addressed by developing a starting 

benchmark alternative that identifies all of the existing roads and trails available to motorized recreationists including non-system routes and those falling under some undefined definition of "unusable" and those additional routes required to meet the needs of the public. 

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Process and Procedures 

Capital Trail Vehical Association 

We request that the environmental document adequately addresses the social economic, and environmental justice issues associated with multiple-use access and motorized recreation. We request that the environmental document include a 

travel management alternative for the project area that adequately responds to these issues and the needs for multiple-use access and recreation. 

T4

Process and Procedures 

Carl Albrecht Garkane Energy 

3. Cumulative Impact Analysis fails to include Garkane Energy's proposed Tropic to Hatch 138 kV Transmission Line Application submitted to Kanab Field Office in April of 2007. See Pages 4-276,4-285, 4-286. 

Ct

Process and Procedures 

Colorado Plateau Archaeological Alliance 

We emphasize that the BLM cannot properly manage cultural resources it does not know exist, and hence the absence of a statistically valid sample militates against adequate consideration of potential impacts to unknown cultural resources. 

ItS

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Process and Procedures 

Colorado Plateau Archaeological Alliance 

The primary consideration in this discussion is that OHVs allow greater public access to archaeological sites, and that this access facilitates adverse effects. 

This is casually acknowledged in the Draft EIS with the statement that "As access to an area increases, incidental damage of cultural resources adjacent to the access routes would increase. Impacts from incidental damage would be reduced as distance from the access route increases" (DEIS 4-96). As discussed above, 

damage to or destruction of archaeological sites is most prevalent along existing 

routes, usually within 200 meters of an existing route (cf. Spangler, Arnold and 

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54 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Boomgarden 2006). Hence, the limitation of OHV travel to existing or designated routes may not significantly reduce impacts to cultural resources along those routes. These data stand in decided contrast to statements in the Draft EIS, Alternatives B and D, that the designation of routes "would result in minimal additional impacts on cultural resources due to existing use on these routes. Because the designated routes currently exist, the damage to them would also be minimal" (DEIS 2-119). 

pp

Process and Procedures 

ECOS Consulting This Kanab DRMP/DEIS does not adequately address direct, indirect, and 

cumulative impacts. The purpose of the National Environmental Policy Act (NEPA) is to provide line officers and the public with full disclosure of the environmental consequences of taking action so they can make "informed" decisions. The Council on Environmental Quality regulations require that impact analyses include discussions of adverse and beneficial effects, short- and longterm effects, direct and indirect effects, and cumulative effects. The 

characterization of impacts must not only be simply an accounting of acres affected, as is the case throughout this Kanab DRMP/DEIS, but it must include descriptions of potential beneficial and adverse impacts, of impact duration, intensity or magnitude, and context (site specific, local, regional, and national effects, etc.), and there must be an analysis of direct, indirect, and cumulative impacts. In this Kanab DRMP/DEIS, many of the conclusions regarding potential impacts were presented without supporting scientific analysis, agency monitoring data or rationale, and, as such, appear arbitrary and unfounded. 

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Process and Procedures 

ECOS Consulting Many areas within the Kanab Decision Areas are adversely impacted, and have 

been for many years by activities allowed by the BLM. These impacts must be analyzed in greater detail, and BLM must provide supporting analysis and the rationale for the agency's subsequent conclusions. This is particularly evident in the sections on livestock grazing, mineral resources, and recreational and travel decisions. BLM fails to provide quantitative and/or qualitative analyses, and it fails to adequately consider the direct, indirect, and cumulative effects of the 

proposed alternatives. 

TEniSWsaaai

Process and Procedures 

ECOS Consulting BLM's Kanab DRMP/DEIS fails to include a reasonable range of Alternatives. 

Specifically, it contains no alternative that would adequately protect the scarce riparian resources of the Kanab BLM Decision Area from OHV use, livestock grazing, mineral development and associated damages from these activities. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Process and Procedures 

ECOS Consulting Reasonable alternatives that limit the number and extent of OHV routes must be 

presented. 

BDar

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Process and Procedures 

ECOS Consulting What are the direct, indirect, and cumulative impacts of these OHV routes within 

specific riparian areas? The Kanab DRMP/EIS mentions some direct impacts but fails to disclose the long-term indirect and cumulative impacts. 

Tdsrrhp

Process and Procedures 

ECOS Consulting It is highly recommended that the BLM perform these types of analyses before 

committing to 10-20 more years of management without adequate background baseline, trend, and potential habitat extent information. 

Creias

As

Process and Procedures 

ECOS Consulting This Kanab DRMP does not present an adequate range of Alternatives for the 

proposed number and extent of open OHV routes in the Travel Plan. 

BDatbtc

Process and Procedures 

ECOS Consulting BLM does not provide an adequate range of alternatives for the number and 

extent of OHV routes allowed. BLM ignores the seriousness of the impacts. 

BarbaoDa

Process and Procedures 

ECOS Consulting It is recommended that the BLM analyze the direct, indirect, and cumulative 

effects of roads, throughout the 524,000 acres of the Kanab Decision Area that will contribute to the fragmentation of wildlife habitat. 

I

Is

Process and ECOS Consulting It is recommended that the BLM act wisely and in the spirit of its mandates and T

56 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Procedures commitments to maintain healthy and sustainable ecosystems, by eliminating 

and restoring many of these OHV routes. If many of these roads remain open for the next 10-20 years, the future of much wildlife habitat will continue to be at risk due to many of the adverse impacts listed above. 

r

Process and Procedures 

ECOS Consulting The DRMP's range of alternatives for livestock grazing is not adequate and must 

be expanded to include alternatives that allow little (15-25%) or no grazing (0%) or some grazing(50%), or a lot of grazing (>90%). 

Tg2sta

tabEsaptc

Process and Procedures 

ECOS Consulting Many of the impacts described in this Kanab DRMP/DEIS have been monitored 

by the BLM, but the BLM has failed to provide analyses, trends, and summary data for the information collected in the field. 

CdBtrD

Process and Procedures 

ECOS Consulting Page 4-24, 3r d Paragraph: Mitigation is mentioned here but details are not 

forthcoming. According to NEPA, planned mitigation must be described in detail. What mitigation protocols will be used to restore biological soil crusts? How long will it take for the biological soil crusts to become ecologically effectual? The mitigation described briefly in this DRMP/EIS cannot restore biological soil crusts within 5 years, thus the direct impacts are long-term. The direct loss of biological soil crusts on 8,426 acres is unacceptable when considering the indirect and cumulative effects, which can spread to a much larger adjacent area. What are the projected indirect and cumulative effects? The BLM makes no effort to analyze these. 

IiAia

Process and Procedures 

ECOS Consulting In this Draft RMP/EIS, where is the analysis of cumulative effects regarding the 

past, present, and reasonably foreseeable future actions of the impacts discussed? There is no mention of the past impacts of livestock grazing, mineral development, and OHV use, and how these have adversely affected the biological soil crusts and vegetation today, and in the future. 

TfigabA

57 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

ra

tc

Process and Procedures 

ECOS Consulting There is also no mention of the context, intensity, and duration of an impact. T

i

Process and Procedures 

ECOS Consulting In relation to Appendix A on page AA-1 – Although BMP's have been in place for 

many years, the BLM doesn't ever mention a monitoring program, or an evaluation of the success of one BMP application, nor any feedback. Are there any monitoring/ evaluation/ feedback reports on any of the projects where BMP's were used? If there are, these must be summarized in this document so that these BMP's can be judged effective or not, so that future management planning can be successful. 

Tf

sia

Process and Procedures 

ECOS Consulting National Environmental Policy Act (NEPA) court precedence states that rather 

than just listing mitigation, the Environmental Impact Statement (EIS) must analyze mitigation in detail and explain the effectiveness of the measures in terms of the resulting impacts (Northwest Indian Cemetery Protective Association v. Peterson, 795 F. 2d 288 (9th Cir. 1986)). The BLM has not done this in this DRMP/EIS for many of the issues for which it recommends mitigation. 

IiAia

Process and Procedures 

ECOS Consulting National Environmental Policy Act (NEPA) court precedence states that rather 

than just listing mitigation, the Environmental Impact Statement (EIS) must analyze mitigation in detail and explain the effectiveness of the measures in terms of the resulting impacts (Northwest Indian Cemetery Protective Association v. Peterson, 795 F. 2d 288 (9th Cir. 1986)). This discussion of acres impacted must be more thorough and not only analyze the direct impacts, but also the indirect and cumulative impacts. 

IiAia

Process and Procedures 

ECOS Consulting In this DRMP/EIS, where is the analysis of cumulative effects regarding the past, 

present, and reasonably foreseeable future actions of the impacts discussed? There is no mention of the past impacts of livestock grazing, mineral development, and OHV routes and use, and how these have adversely affected the biological soil crusts, vegetation, and water quality and quantity today, and in 

the future. 

TfigabAra

t

c

Process and Procedures 

ECOS Consulting These indirect and cumulative effects must be analyzed or estimated by the BLM 

in this document. Simply stating, as the BLM does numerous times in this DRMP/DEIS, that all actual and potential problems will be mitigated is not enough in a NEPA-based EIS. 

IiAi

58 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

a

Process and Procedures 

ECOS Consulting Page 4-41, 5th Paragraph: The magnitude of impacts would indeed decrease 

when compared to alternative A, but is that the standard that all impact analysis 

should be compared to? I don't think that is the intention of NEPA. Instead of 

comparing alternative B impacts to the worst case management scenario (alternative A), the BLM must concentrate on and describe the actual intensity and duration of direct, indirect, and cumulative impacts. 

I(

C“tRd

Process and Procedures 

ECOS Consulting The BLM's conclusions of cumulative effects in this document were presented 

without supporting scientific analysis or rationale, and, as such, appear arbitrary 

and unfounded. 

A aceor

Process and Procedures 

ECOS Consulting In planning these activities the BLM must show that it is taking every precaution 

to protect biological soil crusts and minimize surface disturbance. Has the BLM done this? If so, where is the documentation and what are the measures? 

IiAia

Process and Procedures 

ECOS Consulting The BLM lists many direct and indirect impacts but fails to adequately discuss 

intensity and duration. The biggest short-coming of this analysis is to call all of these impacts "short-term" when in fact they are long-term (last more than 5 years). 

T

i

Process and Procedures 

ECOS Consulting In this Kanab DRMP/DEIS, by not including a reasonable range of alternatives, 

and not dealing directly with the impacts of livestock grazing, OHV routes, and mineral development, the BLM is skirting the NEPA requirements that compel the agencies to concentrate on the significant issues that will seriously effect the protection, restoration, and enhancement of the human environment. Only by considering a full range of alternatives and the full direct, indirect, and cumulative impacts of these activities can the BLM make sound management decisions. 

BDatbtc

Process and Procedures 

ECOS Consulting For cumulative impacts the following questions must be answered according to 

the Judicial Review Standard: The "Fritiofson v. Alexander" Test ( Fritiofson v. Alexander, 772 F.2d 1225 (5th Cir. 1985). 

TaabIfi

Process and Procedures 

Five County Association of Governments 

The final RMP must include a description of the process employed to recognize RS2477 assertions that have gained judicial authorization, and provide county governments with a procedure to submit such assertions. 

Torw

59 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

R

Process and Procedures 

Laura Welp I think it would be judicious ofyou to increase the time available for public 

comment. 

TR1atpraCgc

f

Process and Procedures 

National Parks Conservation Association 

BLM has erred in excluding the National Park Service as cooperating agency. The have ignored the directive outline in January 30, 2002 Memorandum from James Connaughton, Council on Environmental Quality (CEQ) Chair. The exclusion of the NPS from cooperating agency status has limited the input from 

this most qualified agency on the import of effects on Bryce Canyon, Zion and Capitol Reef National Parks and on the preferred approach to managing these effects. BLM must invite the National Park Service to act as a cooperating agency for the remainder of the RMP revision, including assessment of comments and recommendations for revising the Preferred Alternative. In addition, the NPS should be given the opportunity to review the information previously provided to the other cooperating agencies, and then provide input on the analysis of effects and management recommendations pertaining to Bryce Canyon, Zion and Capitol Reef National Parks. 

WaNts

c

ikD

Process and Procedures 

Randy Parker Utah Farm Bureau Federation 

Farm Bureau is opposed to the BLM's use of the RMP process to retain federal ownership of the federal lands in violation of the equal footing doctrine of the U.S. 

Constitution and other pertinent federal law, including FLPMA. 

SUrtTRall

Process and Procedures 

Richard Csenge Designating 1385 miles of totally unplanned routes, as does Alternative B is 

unnecessary, absurdly redundant, and is neither manageable nor enforceable. Even Alternative C, with 884 miles of designated routes is far too many. Such designations do not constitute a well-designed transportation plan. No proper study or inventory process could yield such proposals. BLM KFO has not completed current assessments of existing OHV damage, nor impact studies 

BrBEp

60 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

projecting future damage. NEPA rules have not been followed in the creation of the Hog Canyon Trail System. 

T

tpcr

Process and Procedures 

Susan Hand My first suggestion is that the BLM extend the public comment period. The 

placement over the holidays, coupled with simultaneous comment periods for five 

other Utah RMP's, almost seems designed to limit public understanding and participation, which is counter to the intended purpose. Other unforeseen 

distractions have further divided the public's attention. We may well live under the final plan for decades to come, so it is critical that it be developed carefully. 

TR1a

t

p

raCgcf

Process and Procedures 

SUWA A. The Public Comment Period is Far Too Short to Allow for a Fully Informed 

Response to the Draft Plan PR.P 

TR1a

tpraCgc

f

Process and Procedures 

SUWA B. The Kanab DRMP/EIS fails to acknowledge the public will regarding land 

management preferences. 

Tpidan

Process and Procedures 

SUWA The proposed designation of only 3,800 acres of ACEC when 60,600 acres have 

been found eligible falls far short of FLPMA's mandate that BLM give "priority" to this resource. 

Tppo

pf

61 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

TompmfclSppff1btd2s3eacvBPtbmsmRaaaoot

62 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

tmr

Process and Procedures 

SUWA Certain elements of the RMP, most strikingly the travel plan and OHV 

designations, fail the UUD standard. By several measures, the proposed travel plan and OHV designations will harm natural resources by increasing cumulative dust and decreasing air quality; unnecessarily fragmenting wildlife habitat; causing unnecessary damage to riparian areas, floodplains and cultural resources; reducing naturalness in areas with identified wilderness characteristics; and, impairing Wilderness Study Areas. 

Tim

A

a 

Process and Procedures 

SUWA In the context of this RMP, the decisions made with regard to travel planning 

must more fully analyze all effects of travel planning and other planning so that all 

cumulative and site specific environmental and social impacts are adequately analyzed. 

T

cRi

Process and Procedures 

SUWA NEPA requires BLM to "rigorously explore and objectively evaluate" a range of 

alternatives to proposed federal actions, and the lack of an alternative that adequately protects natural and cultural resources is a fatal flaw to this plan. See 

40 C.F.R. §§ 1502.14(a) and 1508.25(c). 

Tra(ctp

c

Process and Procedures 

SUWA For this Draft RMP, the consideration of more environmentally protective 

alternatives consistent with FLPMA's requirement that BLM "minimize adverse impacts on the natural, environmental, scientific, cultural, and other resources 

and values (including fish and wildlife habitat) ofthe public lands involved," is lacking given the dearth of analysis, the limited range of alternatives, and the omission ofthe Vermilion Cliffs Heritage Proposal as an alternative. 43 U.S.c. 

§1732(d)(2)(a). 

TRaaa

Process and Procedures 

SUWA The Travel Plan included in this EIS is a key example of the aforementioned 

citations, with each alternative posing significant resource harms and no alternative that mitigates those harms (i.e. no alternative not designating routes within WSAs or WC areas). 

AA

Process and Procedures 

SUWA This type of analysis is wholly lacking with regard to travel planning, as well as 

many other aspects of the Kanab Draft RMP. 

T

a

Process and Procedures 

SUWA BLM's cursory dismissal ofthe Vermilion Cliffs Heritage Proposal is a clear 

indication of the BLM's refusal to entertain a responsible "opposing view" in the planning process. SUWA's comments about BLM's capricious dismissal ofthe Vermilion Cliffs Heritage Proposal are included in these comments immediately below. 

Ipppft

63 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

mDfc

Process and Procedures 

SUWA Our review of the draft RMP and EIS show that much more work must be done 

on these documents before they can be formalized. We found significant deficiencies in both the analysis of the current condition and the analysis ofthe impacts ofthe proposed alternatives. 

Ta

Process and Procedures 

SUWA One of the most obvious and consequential flaws in the document is its failure to 

assess the ongoing impact of existing ORV use in the Kanab Field Office. 

TRT

b

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haacauc

Process and Procedures 

SUWA The DRMP must include BLMs, USFWS's and the Utah Dept. of Natural 

Resources' monitoring data, trend analysis, and any other available documentation of he Welsh's milkweed and the impacts of ORV use on this 

federally listed species. This information is necessary in order for the decision maker and the public to ascertain if the requirements of the Endangered Species Act are being met if ORV use is allowed in Welsh's milkweed habitat. 

To

Process and Procedures 

SUWA Because hard information on visitation was missing from the AMS and Affected 

Environment section of the Draft RMP, the BLM has created a potentially false impression that the Kanab Field Office is a location in which ORV use is more popular than every other recreation pursuit, which contradicts information gathered by BLM, itself - for the Moquith sand dunes where motorized use appears to be heaviest - that indicates that over 90% of the visitors to the sand dunes are non-motorized users. 

T

(Dosfia 

f

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rt

64 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

TdctddtBo

Process and Procedures 

SUWA 1. We reiterate that the BLM's failure to analyze and present information about 

the impacts of existing ORV use violates its NEPA duties. 

TRT

b

be

haacauc

Process and Procedures 

SUWA 2. ORV impacts to vegetation are largely ignored. For example, Chapter 4's 

discussion of this impact is limited to two paragraphs, neither of which is 

quantitative in nature and which do not assess the probability of ORVs introducing and facilitating the spread of non-native species. However, the plan 

admits on p. 4-41 that "areas open to cross-country OHV use (1,100 acres)" would be more likely to experience surface disturbance, but fails to mention that this disturbance takes place in a WSA. 

I

trd

si

Process and Procedures 

SUWA 3. Chapter 4's discussion of soils at 4-16 to 4-24 lacks well-considered, informed 

decisions about broad-scale uses with long-term impacts - such as the designation of thousands of miles of ORV routes. 

T

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mrarlAm

65 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

fa

Process and Procedures 

SUWA The DRMP/EIS never considers or analyzes whether current or proposed ORV 

use levels are sustainable over the long term. 

Tpm

Process and Procedures 

SUWA However, the BLM never quantifies this assertion with analysis of how close 

many of the proposed routes are to known sites. Also, there is no analysis of the likelihood that route designation will harm unknown sites. 

Ccr

tnA

Process and Procedures 

SUWA Yet nowhere in the document is the estimated amount of soil lost to ORV use 

quantified. This information gap should be filled by inclusion of the best available data and methodology. 

AKi

Process and Procedures 

SUWA However wouldn't decisions to limit grazing based on riparian area destruction 

also impact ORV decisions? As would decisions to protect areas based on visual resources, or wildlife? Please provide an explanation for this approach. 

LnlR(

Process and Procedures 

SUWA The DEIS generally provides little or no discussion of cumulative impacts or the 

effects connected activities have on various resources. 

TcRi

Process and Procedures 

SUWA For example, the plan provides for high levels of both grazing and ORV use in 

canyon bottoms where riparian areas and cultural sites are also prevalent. Yet the plan does little more than acknowledge the combined effects of these two intensive uses, both of which are associated with long-term impacts such as 

decreased water quality and quantity, native plant loss, soil erosion and diminished enjoyment by non-motorized recreationists. 

TdlLraci

Process and Procedures 

SUWA There is no attempt to break dow the assessment by alternative, timeline for 

meeting PFC, or any real quantitative analysis. 

TP

Process and Procedures 

SUWA The BLM should identify the areas in which ORV use is also permitted (where 

trails would be designated) and each stream's PFC rating, and discuss the 

combined effects of grazing and ORVs on these riparian areas. 

T4aAwTi

66 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

d

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Process and Procedures 

SUWA This pre-determined approach has infected the rest of the draft plan with an 

assumption that demand for ORV use is high and impacts relatively low. It has affected the development of alternatives, as well, with a complete lack of a proposal which addresses the needs of non-motorized visitors. For example, how many routes designated in the plan are for ORVs and how many trails are proposed for hikers? 

Mp

rmimp

Process and Procedures 

SUWA The BLM avoids dealing with a range of important issues by declaring some 

beyond the scope of this plan. The issues of public education, enforcement/prosecution, vandalism and volunteer coordination are not addressed, but are critical to adequately analyzing the feasibility of implementing travel planning decisions and DRV route designations. 

T

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Process and Procedures 

SUWA Indeed, there are only 274 miles of difference between the routes designated in 

Alternatives B, C and D - not a meaningful difference in light of the 1,300+ miles of designated ORV routes and over 5000 miles of route total when combined with 

other dirt roads and trails on all lands. Thus, the DRMP/EIS violates NEPA's 

requirement that the agency provide a reasonable range of alternatives for the public to consider, and for the agency to analyze in order to make a fully informed decision. 

A 

TAc

Process and Procedures 

SUWA As discussed below, SUWA maintains that BLM has the authority and the 

responsibility pursuant to FLPMA § 202 to fully analyze and adopt an alternative that would designate new wilderness study areas. BLM's failure to fully consider and analyze such an alternative is fatal to its analysis. 

TpTc

Tts“smful(Srr

67 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Trl2ls

Process and Procedures 

SUWA The DRMP/EIS fails to provide an alternative avoiding potential environmental 

effects of designating particular routes. 

A TpKsic

d

i

R

Process and Procedures 

SUWA Although the DRMP/EIS includes a description of the various recreational 

opportunity "focus areas" for which recreation can be managed, it is impossible to decipher the acreages within the various classifications under the various alternatives as key information is omitted from the maps and charts. Based on a 

review of the maps, however, the alternatives fail to provide adequately for quality, dispersed non-motorized recreational opportunities, especially nonstructured, primitive and unconfirmed recreation which is not afforded by narrowly defined Recreational Management Zones (RMZs) that cater to specific niche recreation. 

MprmifSTwap

Process and Procedures 

SUWA The BLM has not fully considered and analyzed the Vermilion Cliffs Heritage 

Proposal or meaningfully incorporated it into any of the alternatives. 

TRaas

Process and Procedures 

SUWA Because BLM has never fully evaluated the no-leasing alternative there is no 

earlier analysis that BLM can rely upon for this analysis. BLM must therefore fully 

analyze and consider the no-leasing " alternative, which would provide for no more leasing in the Kanab Field Office - as opposed to simply the maintenance of 

the status quo of making lands available for leasing in the no-action alternative - in the EIS accompanying the Kanab RMP. 

Cn

Process and Procedures 

SUWA Further, if BLM continues to exclude designation of new WSAs from 

consideration in the DRMP/EIS, it risks violating both FLPMA and NEPA, and 

Tp

68 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

jeopardizing the validity of the entire planning process. 

TcTts“smful(SrrTrl2ls

Process and Procedures 

SUWA Contrary to its own guidance, it appears that the BLM has provided no 

"definitions and additional limitations for specific roads and trails;" no "criteria" for the selection of specific roads and trails like those described in the Guidance; provided no "guidelines" for the management, monitoring and maintenance of the trails, and lastly, there are no "indicators" to guide future planning such as the result of monitoring data or other information. Thus, the travel plan violates the BLM's own rules for designating trails. 

Asc

Process and Procedures 

SUWA 2-3 Based on our examination of the maps, DRMP/EIS and discussions with BLM 

personnel involved in the RMP and travel plan development it is clear that the 

BLM did exactly what the Guidance warned against. Instead of actively choosing routes based on sensible criteria like the need for access, desired future condition and the protection of natural and cultural resources, the BLM simply 

"inherited" roads and trails from county maps and from off-road vehicle advocates. 

At

wiA

a

Process and Procedures 

SUWA As noted above, the DRMP/EIS does not demonstrate a full range of travel types 

and modes, or other limitations sufficient to protect the resources at risk from 

ORV use. In particular, while BLM proposes to designate nearly 1,400 miles of ORV routes, there appears to be zero miles of hiking trail proposed in the DRMP. 

Mprm

69 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

And because of the obvious public safety and other conflicts present, allowing hikers to use ORV trails is not a solution. (2.3) 

i

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Process and Procedures 

SUWA To address these insufficiencies, the BLM must provide specific information on 

the purpose and need for the routes incorporated in each alternative, the potential impacts on other resources, and the potential conflicts with other users and the justification for designating the route with the proposed range of uses. The public should then have an opportunity to comment so that this input can be taken into account before issuance of a Proposed RMP/Final EIS. 

A 

T

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d

iRTJaa

Process and Procedures 

SUWA However, the preferred alternative would designate only a small fraction of 

acreage (6%) evaluated by the BLM to meet the relevance and importance criteria. This is a violation of FLPMA's mandate that "priority" be given to designation of ACECs. 

Tppo

pf

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clSppff1b

70 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

td2s3eacvBPtbmsmRaaaoottmr

Process and Procedures 

SUWA This ACEC must be designated if the BLM fulfills its FLPMA obligations to "give 

priority" to ACEC designation. The BLM well describes both the relevance and importance of this potential ACEC in Appendix H. (Vermillion Cliffs) 

Tppo

pf

To

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71 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

lSppff1btd2s3eacvBPtbmsmRaaaoottmr

Process and Procedures 

SUWA This ACEC must be designated if the BLM fulfills its FLPMA obligations to “give 

priority" to ACEC designation. The BLM well describes both the relevance and importance of this potential ACEC in Appendix H. (Welsh’s Milkweed) 

Tppo

72 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

pfTompmfclSppff1btd2s3eacvBPtbmsmRaaa

73 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

oottmr

Process and Procedures 

SUWA The BLM must take a hard look at resource damage (direct, indirect and 

cumulative) that may be incurred with each route. 

TAc

d

iR

Process and Procedures 

SUWA This ACEC must be designated ifthe BLM fulfills its FLPMA obligations to "give 

priority" to ACEC designation. The BLM well describes both the relevance and importance of this potential ACEC in Appendix H. (White Cliffs) 

Tp

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Tomp

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l

Sppff1btd2s

74 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

3eacvBPtbmsmRaaaoottmr

Process and Procedures 

SUWA BLM must take a hard look at resource damage that may be incurred with each 

route. (White Cliffs) 

TAcd

iR

Process and Procedures 

SUWA This ACEC must be designated if the BLM fulfills its FLPMA obligations to "give 

priority" to ACEC designation. The BLM well describes both the relevance and importance of this potential ACEC in Appendix H. (Parunuweap Canyon) 

Tppo

pf

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75 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

clSppff1btd2s3eacvBPtbmsmRaaaoottmr

Process and Procedures 

SUWA The BLM must take a hard look at resource damage that may be incurred with 

each route (including direct, indirect, and cumulative impacts). (Parunuweap Canyon) 

TAc

76 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

d

iR

Process and Procedures 

SUWA The BLM's reasonably foreseeable development (RFD) scenario is arbitrary and 

capricious and ignores historic development trends in the planning area. 

Trnet

Process and Procedures 

SUWA Throughout the environmental consequences section, the BLM fails to perform 

an adequate analysis for recreation management pursuant to NEPA. 

Td

Ki

Process and Procedures 

SUWA The DRMP/EIS Failed to Analyze the Impacts ofClimate Change to the 

Resources of the Kanab Field Office. This oversight amounts to a failure to take 

the necessary "hard look" at the challenge of resource management in the Kanab 

Field Office. 

A cam

eetTgBpC

Process and Procedures 

SUWA The BLM should have discussed all of these predicted effects of climate in 

Chapter 3's assessment of existing conditions and in Chapter 4's discussion ofthe impacts of the various alternatives. A strong argument can be made that 

over the life of the RMP, no other factor will affect the resources of the Kanab 

Field Office more than climate change; it must figure as a prominent aspect of the future management ofthe area and BLM must demonstrate that it has begun to 

grapple with the management challenges that climate change presents. 

A cameetTgBpC

Process and Procedures 

SUWA We have noted elsewhere that the EIS has not discussed the cumulative effects 

of various uses like ORV recreation and grazing on, for example, riparian areas. These cumulative effects should also be considered in the context of climate 

A 

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77 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

change and how these uses act synergistically to impact the resources of the Kanab Field Office. 

meetTgBpC

Process and Procedures 

SUWA NEPA requires BLM to "rigorously explore and objectively evaluate" a range of 

alternatives to proposed federal actions. See 40 C.F.R. §§ 1502.14(a) and 1508.25(c). Further, an agency violates NEPA by failing to "rigorously explore 

and objectively evaluate all reasonable alternatives" to the proposed action. City 

of Tenakee Springs v. Clough, 915 F.2d 1308, 1310 (9th Cir. 1990) (quoting 40 C.F.R. § 1502.14). This evaluation extends to considering more environmentally protective alternatives and mitigation measures. See, e.g., Kootenai Tribe of Idaho v. Veneman, 313 F.3d 1094, 1122-1123 (9th Cir. 2002) (and cases cited therein). 

Taqimdce

a

Process and Procedures 

SUWA The BLM should not designate routes open to motorized use based on the 

existence of unproven claims under R.S. 2477. 

Tc

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Process and Procedures 

Theodore Roosevelt Conservation Partnership 

Therefore, we recomment that the Kanab field office should extend the comment period for the Kanab RMP DEIS to provide the public with adequate opportunity to express their concerns and recommendations. 

TR1atpraCgc

f

Process and Procedures 

Theodore Roosevelt Conservation Partnership 

We believe that the RMP is not adhering to Executive Order 13443, issued on Aug. 16, 2007 and Instructional Memorandum No. 2008-06 issued Nov. 12, 2007. (Available at: http://www.blm.gov/nhp/efoia/wo/fy08/IM2008-006.htm) 

TIs

n

di

o

78 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

ct

Process and Procedures 

Theodore Roosevelt Conservation Partnership 

Under CEQ NEPA regulations, BLM must make use of all the best available scientific information to assess the effects of land management actions, including cumulative effects from existing, proposed, or foreseeable development projects 

in the resource management area. Referenced below are peer-reviewed scientific studies on the impacts on sage grouse, elk, and mule deer from vehicle traffic, roads, and oil and gas development. The information from these studies should be incorporated into the FEIS. 

Tacb

Process and Procedures 

Tom Grant There should be more time in this comment period to address the areas of 

extreme importance to the future of this area. 

TR1atpraCgc

f

Process and Procedures 

Tracy Hiscock Clearly, this BLM RMP does not fulfill the legal requirements of either the 

National Environmental Policy Act (NEPA) or the Federal Lands Policy and Management Act (FLPMA). 

Tl

S

Process and Procedures 

Tracy Hiscock Many of the already existing ORV routes in the area lead to or go through 

archeological sites. By allowing such routes to continue, and by failing to assess the impact of motorized vehicles driving over these irreplaceable and scientifically important cultural resources, the BLM RMP falls short of fulfilling the legal 

requirements of NEPA and FLPMA. Furthermore, the existence of such routes also tempts motorized users to violate the Archeological Resources Protection Act. 

C

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Process and Procedures 

Tracy Hiscock It is my concern that the BLM has failed in its duties under these laws. The RMP 

will be in place for many years to come. It is the duty of the agency to follow the law, responsibly managing these lands and protecting them for future generations. 

TlS

Process and Procedures 

Tyler Kokjohn The draft plan also fails to include any meaningful discussion of monitoring and 

assessment methods that would support all adaptive management efforts. Instead we are informed that implementation or activity-level decisions “could be adapted.” In addition, “future activity-level plans would follow NEPA guidelines 

and involve the public.” These are serious oversights in the draft and are not in accord with planning requirements detailed by the BLM itself. 

Ip

79 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Process and Procedures 

Utah Archeological Research Institute 

Is there some reason that there has to be four alternatives? What if there are six viable alternatives? What if there are fifteen viable alternatives? Do you combine them or just leave some out? Confining management strategies to four different 

options restricts management alternatives, and thus it is not an adequate 

approach to effectively manage our public lands. 

BDatbtc

Process and Procedures 

Utah Archeological Research Institute 

It makes no logical sense to manage public lands for activities that seldom take 

place while ignoring activities participated in by the greater number of people. We ask that management alternatives be given priority that support the interests of 

the majority of the people utilizing the BLM Lands in the Kanab Field Office area, as long as the resources can be protected, and that this information be an integral part of the final RMP/EIS. 

Tddio

Process and Procedures 

Utah Rock Art Research Association 

We are concerned about the process used to identify cultural resource management associated with this RMP. Only 10% of the area has been subjected to detailed cultural inventories. Most of this 10% survey area is based on "compliance with Section 106 of the NHPA, meaning the surveys are conducted as needed to identify cultural resources in a project-specific context 

and generally are not statistically valid samples of the region." (Page 3-60) Cultural resource decisions on the remaining 90% are the result of known sites and professional judgment (4-96) based on a small survey sample that is not statistically valid. Professional judgment in this context sounds a lot like guessing. It is our understanding that Section 106 (16 U.S.C. § 470t) obligates the BLM to consider the effects of management actions on cultural resources listed or eligible for listing to the National Register of Historic Places. Section 110 of the NHPA requires the BLM to manage and maintain those resources in a way that gives "special consideration" to preserving archaeological and cultural values. Section 110 also requires the BLM to ensure that all historic properties under the jurisdiction or control the agency are identified, evaluated, and nominated to the National Register of Historic Places. Id. § 470h-2(a)(2)(A). How can the BLM claim to be honoring their legal responsibilities when they are not using real data regarding archeological sites to make management decisions? We do not support a decision-making process which is not based on actual rock art and archeological site inventories. 

ItSipdo

Process and Procedures 

Western Watersheds Project, Inc. 

This failure must be corrected to meet the intent of NEPA and in order to provide a comparison of the impacts of livestock on riparian and upland areas, water quality, soils and wildlife under proposed stocking rates as compared to conditions in the absence of livestock. Otherwise, no true evaluation of the impacts of livestock grazing can be claimed. 

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abEsaptc

Process and Procedures 

Western Watersheds Project, Inc. 

The Preferred Alternative ignores the ecological impacts of off-road vehicles and allows their use on major portions of the RA, including thousands of miles of roads and trails. 

Barba

oDa

Process and Procedures 

Western Watersheds Project, Inc. 

The lack of an alternative that eliminates off-road vehicles and the lack of analysis of impacts of OHVs violates the intent of NEPA. 

BarbaoDa

Process and Procedures 

Western Watersheds Project, Inc. 

There is no analysis of the impacts of the hundreds of water developments for livestock, the miles of fences and their impacts on wildlife, the loss of riparian and wetland areas due to water developments nor the thousands of acres of watershed and plant community degradation that occur around livestock water developments. There is no analysis of the watershed impacts from livestock 

grazing including the degree of loss of ground cover, the accelerated rate of erosion compared to natural conditions with intact plant and biological crust communities, the loss of ground water and watershed storage or the impacts on the Colorado River System and its endangered species. The Colorado River Salinity Control Act is not addressed in regards to livestock, erosion, sedimentation and salinity. 

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Process and Procedures 

Western Watersheds Project, Inc. 

The DEIS/RMP have failed to meet the intent of FLPMA for sustainable uses that 

do not impair productivity, have failed to "accelerate restoration" and have abrogated BLM's responsibility for effectiveness monitoring that is meaningful and without bias. 

Ip

Process and Procedures 

Western Watersheds Project, Inc. 

Resource alternatives provided within the DEIS/RMP are not compliant with the BLM Land use Planning Handbook planning guidance which directs the 

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Category Name Commentor Comment 

identification and analysis of specific rmanagement actions. 

Process and Procedures 

Western Watersheds Project, Inc. 

Therefore, in lieu of adequate data and analysis, OHV activities and other surface disturbing activities such as recreation, livestock grazing, travel routes, oil/gas 

and mineral extraction, must be analyzed for elimination or significantly restricted 

use on public lands within the following sensitive areas: 

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Process and Procedures 

Western Watersheds Project, Inc. 

The Kanab FO should at a minimum, analyze alternatives including No Action (status quo), No ATVs, Dirt Bikes or Snowmobiles, or the new experimental playtoys, Personal Aerial Vehicles, and the level of use allowed in the current set of alternatives. Some of the science regarding this issue is presented in the following paragraphs. 

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Process and Procedures 

Western Watersheds Project, Inc. 

BLM must review all this information in its analysis in order to meet its obligation under NEPA to take a "hard look" at the effects of its actions. 

NotB

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Category Name Commentor Comment 

Rr

Recreation Alexander Kowalski Please include in your final RMP access possibilities for personal, noncommercial rock and fossil collecting. Restrictions on mining for commercially 

valuable minerals, and restrictions on off highway travel directly affects our ability to access remote areas and enjoy our hobby. 

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Recreation Bill May I do not believe that group sizes should be limited to 25 people under the Special 

Recreation Permit... This number in my opinion is unrealistic and makes group 

events such as family picnics or scouting events impossible... I believe the rules and authorized exceptions for these SRP's should be clarified and added to Alternative B. 

Tdl2a

Recreation Bill May "I believe the information and data collected by the BLM in Table 3-26 is faulty. 

The BLM's own report indicates that critical information was not available for this Table ... In my personal experiences I don't believe the numbers to be accurate... 

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Recreation Bill May Special Recreation Permits: I do not believe that group sizes should be limited to 

25 people under the Proposed Special Recreation Permit... This number in my opinion is unrealistic and Makes group events such as family picnics or scouting events impossible... I Believe the rules and authorized exceptions for theses SRP's should be clarified And added to Alternative B. 

Tdl2a

Recreation Bill May I believe the information and data collected by the BLM in Table 3-26 is faulty. 

The BLM’s own report indicates that critical information was not available for this Table... In my personal experiences I don’t believe the numbers to be accurate... I Do not believe that any decisions should be made based upon this faulty table 

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paAbVsu

Recreation Bill May Special Recreation Permits: I do not believe that group sizes should be limited to 

25 people under the Proposed Special Recreation Permit... This number in my opinion is unrealistic and Makes group events such as family picnics or scouting events impossible... I Believe the rules and authorized exceptions for theses 

SRP’s should be clarified And added to Alternative B 

Tdl2a

Recreation Capital Trail Vehical 

Association 

Please explain why the needs of non-motorized recreationists are provided for at a much higher level (quality and quantity) than motorized recreationists? 

Mp

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Recreation Capital Trail Vehical 

Association 

Most of the non-motorized focus areas have designated routes open to motorized vehicles] within them. If implemented as written in Alternatives B, C and D, many visitors will perceive these focus areas as establishing blanket restrictions on 

motorized use. The unintended consequences will likely result in increasing, not 

reducing actual or perceived "user conflict." 

Imiabc

Recreation Capital Trail Vehical 

Association 

Because vehicles are not permitted to travel off designated routes - for any reason - the Kanab BLM is proposing a "vehicle camping only in designated campsites" in the entire Field Office. Such a restrictive policy would be 

appropriate for National Parks or National Monuments, but for Public Lands this is truly unheard of. 

CdT

Recreation Capital Trail Vehical 

Association 

All planning projects should disclose the added benefit to non-motorized recreational resources resulting from the closure of roads by adding the miles of closed roads to the miles of existing non-motorized trails. We request that this procedure be used by this project and all future agency projects. Additionally, we request that the cumulative negative impact on motorized recreationists resulting from this lack of adequate accounting be evaluated and adequately mitigated. 

TR

Recreation Chris Bell 

U4WDA 

Not limiting group sizes under special recreation permit rules. T

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Recreation Chris Bell 

U4WDA 

Elimination of the user statistics (table 3-26) since they are clearly flawed. T

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Recreation David Armbruster Table 3-16, Recreation Visitation, is based on unreliable information and should 

not be used as planning criteria in the RMP process. Specifically this Table appears to be very biased towards a specific user group and seems to utilize badly flawed data. 

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Recreation David Fackrell I never remember seeing a hiker or back packer, which leads me to believe that 

your data shown in Table 3-26 is incorrect. I ran into an occasional hunter on foot, but never a hiker or back packer. It is inconceivable to me that so much of 

the public lands should be closed to use of so many. 

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Vsu

Recreation David Fackrell I never remember seeing a hiker or back packer, which leads me to believe that 

your data shown in Table 3-26 is incorrect. I ran into an occasional hunter on foot, but never a hiker or back packer. It is inconceivable to me that so much of 

the public lands should be closed to use of so many. 

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Recreation David Fackrell Special Recreation Permits: should not be required of groups of 25. Such a low 

number would eliminate Family Reunions, Church Groups and ORV Clubs using our public lands. Numbers over 100 is more feasible. 

Tdl2a

Recreation Desiree Smith I feel that the special use permits should not be reduced to 25 per group. T

dl2a

Recreation Don Black Making it impossible to hold these organized events by prohibitive SRP 

requirements is a step in the wrong direction. It does nothing to stop the individuals who are uninformed or disrespectful and cause damage to resources, but does restrict those that would be trying to educate against abuse of public 

lands. The SRP requirements as shown in Alternate B are unworkable as written. 

Tdl2a

Recreation Don Black 

Canyon Country 4x4 Club 

The Special Recreation Permit requirements as written in Alternate B are totally unworkable. As written, not only would organized 4x4 and ATV events be unlikely, but probably any organized events like family reunions, scout camps or even a large barbeque. Clear cut guidelines are needed for when a SRP is required. The Group size limit of 25 people is totally unrealistic. 

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Recreation Don Black 

Canyon Country 4x4 

We believe that none of the Alternates have adequately addressed the issue of Heritage Tourism. Many of the routes listed in Alternate B to be closed, go to 

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Category Name Commentor Comment 

Club areas that include historic, cultural and natural resources that have been visited 

by people for many years for thise purpose of experiencing settings that represent the past. 

c

Recreation Don Black 

Canyon Country 4x4 Club 

Table 3-26 appears to be very unreliable and slanted towards a specific user group. Anyone who has spent any time in any of the areas managed by the KFO can see how greatly flawed this table is. Some special interest groups are making grossly inaccurate statements using this table as evidence. Unless there is some data that could give some credence to the highly unbelieveable numbers on the table, we ask that this table be removed in it's entirety from the RMP documents 

as it is being misused to distort issues rather than determine how areas should be managed. Also, this table is contradicted in 4.1.6; Incomplete or Unavailable 

Information, which states; "Direct recreation visitation based on actual use and economic expenditure data associated with such use" 

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Recreation Don Black 

Canyon Country 4x4 Club 

We believe that the management action for Special Recreation Permits as shown in Alternate B is totally unreasonable. It would seem to be an arbitrary attempt to eliminate any organized group events. There have been SRP's issued to local clubs for events and I am not aware of any problems arising from these permitted events. There is no justification for these excessive restrictions. 

Tdl2a

Recreation Don Black 

Canyon Country 4x4 Club 

Just with the points I brought up here indicates the fact that the tables 3-26 Recreation Visitation were poorly done and should NOT be used to justify any decision on land use overall. 

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Recreation Don Black 

U4WDA 

The Special Recreation Permit requirements as written Alternative B are totally unworkable. As written, not only would organized 4x4 and ATV events be 

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Category Name Commentor Comment 

unlikely, but probably any organized events like family reunions, scout camps or even a large barbeque. Clear cut guidelines are needed for when a SRP is required. The Group size limit of 25 people is totally unrealistic. 

l2a

Recreation Don Black 

U4WDA 

Table 3-26 appears to be very unreliable and slanted towards a specific user group. Anyone who has spent any time in any of the areas managed by the KFO can see how greatly flawed this table is. Some special interest groups are making grossly inaccurate statements using this table as evidence. Unless there is some data that could give some credence to the highly unbelievable numbers on the table, we ask that this table be removed in it’s entirety from the RMP documents 

as it is being misused to distort issues rather than determine how areas should be managed. Also, this table is contradicted in 4.1.6; Incomplete or Unavailable 

Information, which states; “Direct recreation visitation based on actual use and economic expenditure data associated with such use.” 

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Recreation Donald Kramer SUBJECT STATISTICS CHARTED IN TABLE 3-26 RECREATION VISITATION. 

I believe the estimates in this table are extremely misleading at best and extremely slanted to support the point ofview that wants OHV use stopped or curtailed. First the idea of limiting a user day to twelve hours at the resource is ludicrous. This slants the use ofthe resource to those disciplines that require more time in the field. In order for 20.000 backpackers to get five user days they would spend 2.5 , 24 hour days at the resource. The estimate of 20,000 backpackers in the Kanab Field Office area looks awfully high especially if you 

take away those backpackers in the Wire Pass Coyote Butte area, an area where accurate statistics are available. The OHV use block appears low in the overall 

numbers and since the inaccurate way of calculating "user days needs 12 hours, it may take OHV users two or three trips to total a user day. A user day should be calculated as any day or part of a day the user visits the resource, even if it is 

only a short while. This would give a more accurate picture of land use by recreationists. Big game hunting is the worst example ofstatistics I have seen. On 

11-06-2007 I attended a Utah Dept of Wildlife Regional Advisory Committee meeting in Hurricane. At that meeting the biologist reported that Big Game 

Hunters spent an average of 4 days in the field during the " Any Weapon season". According to your "estimates" the hunters spend less than a day and a half in the field. The biologists were going to ask the Wildlife Board to extend the deer season in the Southern Region to nine days. This however was rejected by the board. Your "estimates" of32,463 Big game hunters is way off. There were 16,200 any weapon deer permits during the 2007 season and this encompasses 

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Category Name Commentor Comment 

the entire southern region. An area that encompasses 1/4 ofthe state. And 14,000 archery permits statewide. Elk permits in the subject area were 7, the antelope permits limited to 5 and the general elk hunting (no permit required) limited to the Zion unit that is mostly private land.(These numbers are from the 

2007 Utah Big Game publication). All other hunts in the region were mostly on Forest service land. Along with the fact that very few archery hunters hunt the lower sage-juniper land that makes up the lower halfofthe Kanab field office area would reduce those numbers drastically. ( during the archery season the migratory mule deer herds are up higher in the pine-aspen forest). As you can see these numbers are way off from the "estimates" in table 3-26. If accurate hunter numbers were multiplied by the documented 4 user days the hunter numbers would be lower but the user days would be higher. In addition almost all hunters use OHV access to get into the more remote hunting areas. Just with the points I brought up here indicates the fact that the tables 3-26 Recreation Visitation were poorly done and should NOT be used to justify any decision on land use overall. 

Recreation Donald Sprecher 5: An explanation why the BLM used in the resource plan the chart that showed 

usage by the various recreation groups based on estimates and not real numbers. I strongly protest using that chart as a basis of information in decisionmaking, because it is flawed. There is nothing in place for OHV users to log into any kiosk, or station, so the BLM can obtain an accurate number of users and user hours. I feel the BLM is making decisions based on unknown real numbers. 

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Recreation Duane Smith I feel that the special use permits should not be reduced to 25 veh. per group T

dl2a

Recreation Duane Smith I feel that Table 3.26 should be eliminated-that data is flawed and inaccurate T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Recreation Earl Stuker Alternative B (Preferred) has some excellent points. Some modifications I would 

like to see are the following: A. Manage three RMZs specifically for motorized uses (21, 800 acres) I think this should read 42,000 acres. B. Manage six RMZs specifically for non-motorized uses (44,900 acres) I think this should read 21000 acres. C. You do not have to close a land to study it for a prospective wilderness area. 

MprmaC

Recreation Evan Day Please include in your final RMP access possibilities for personal, noncommercial rock and fossil collecting. Restrictions on mining for commercially 

valuable minerals, and restrictions on off highway travel directly affects our ability to access remote areas and enjoy our hobby. 

Ap

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Recreation Gary Tsujimoto I think that some of the data in 3.26 is flawed and should NOT be considered. T

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Recreation Geno Ramsey 

Canyon Country 4x4 

I do not believe that group sizes should be limited to 25 people under the proposed Special Recreation Permit. This number in my opinion, is unrealistic and makes group events such as family outings or scouting events impossible. I believe the rules and authorized exceptions for these SRP'S should be clarified and added to Alternative B. 

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Recreation Geno Ramsey 

Canyon Country 4x4 

I believe the information and data collected by the BLM in Table 3-26 is faulty. The BLM's own report indicates that critical information was not available for this table. 

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Recreation Glenn Wimpee Please include in your final RMP access possibilities for personal, noncommercial rock and fossil collecting. A

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Recreation J. Capozzelli There needs to be adequate opportunities to get out of earshot of motorized 

trails. Currently the large majority of the lands BLM manages are within 1 mile of a motorized road or trail. This is not acceptable in Southern Utah, one of the most remote and unspoiled parts of the lower 48. Therefore many routes which penetrate deeply into otherwise roadless areas should be closed, in order to have a more balanced spectrum of near-road and far-from-a-road recreational 

opportunities. 

Mprm

Recreation Jacalyn & Charles 

Liebfried 

Table 3-26 is almost a complete fabrication. In logging over 6,000 off highway miles in Kane county we have encountered few vehicles and NO backpackers. Unless these hikers are raking out their tracks as they go, they simply do not exist. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Recreation Jack Christensen 1) Special Recreation Permits should be left as is not limit group size to 25. T

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Recreation Jack Christensen User statistics in Table 3.26 seem to be flawed and should not be considered 

because it shows analysis and decision towards hiking at the expense of motorized use. There are far mor 4x4's and ATVs than hikers in the Kanab area. 

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Recreation Jack Johnston 

U4WDA 

Special permit for groups over 25 means my family reunion, 32, would require a permit. Make it at least 40-50. 

Tdl2a

Recreation James & Lorna Sills Special Recreation Management Areas (SRMA) The DRMP needs to provide 

more direction on how these areas are to be managed. The "focus areas" need to be inclusive and avoid excluding other uses categorically. 

Amo

Recreation James & Lorna Sills Special Recreation Permits We do not support the Special Recreation Permit 

requirements as currently proposed in Alternate B. The group size limit of 25 

people is unacceptable. We frequently have 4 people in our vehicle alone and like to travel in groups or travel with a club. Clear-cut guidelines need to be established for when a SRP is required. 

Tdl2a

Recreation James & Lorna Sills Recreation Visitation We take exception to Table 3-26. Having visited areas 

managed by the KFO it is plain to see that this table is greatly flawed. Further, 

certain special interest groups are making grossly inaccurate statements based on this. We would like to see Table 3-26 removed completely from the RMP. 

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Recreation James Bulkeley The alternatives are also flawed in that they do not address any mitigation 

measures for loss of motorized recreational opportunities. 

B

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Recreation James McEwen Please include in your final RMP access possibilities for personal, noncommercial rock and fossil collecting. Restrictions on mining for commercially 

valuable minerals, and restrictions on off highway travel directly affects our ability to access remote areas and enjoy our hobby. 

Ap

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Recreation Jay McIlwaine Coral Pink Sand Dunes etc.. Our noninvasive hiking trips are becoming harder to 

enjoy and sadly more infrequent. Off road vehicles are quickly and effectively 

destroying our ability to be "untrammeled". 

Mp

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Recreation Jerry & Cindy Foote Table 3-26 in Chapter 3 of the Draft has obvious errors in it. Specifically: 1. The 

number of backpackers during the 05-06 year is listed as 20,000. This number is 3 times the entire population of Kane and Garfield counties. If that number was correct the influx of that many people would be highly noticeable in both parking areas of trail heads and at the grocery stores in the counties. The claim that 

these "20,000" backpackers spent on average 5 nights in the field clearly indicates that the BLM staff has not been in the field or they would have noticed that these people are not there. As one that has been in the field both hiking and ATVing it is clear that these numbers are highly inflated. 2. To indicate that the number of big game hunters in the Kane and Garfield counties during the 05-06 year is 36,726 implies that there have been hunting permits for 36,726 hunters. A quick look at the Utah Division on Wildlife Resources information shows that the permits issued during these years is only about 30% of that number. 

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Recreation Jerry & Cindy Foote We would like to comment on the Special Recreation Permit group size limitation. 

Limiting groups to less than 25 individuals is unrealistic and abridges the people's rights to access to public lands. Many times family picnics, scouting events, club 

outings would normally exceed this limit. As the present permitting process is 

very involved, lengthy and requires months of pre-planning it would not be possible to hold an event based on weather or other circumstances. With the current work load of the Field Office permits would not be available in a timely manor. 

Tdl2a

Recreation Jim & Bonnie Vann The Recreation Management Zone in Hog Canyon is a good example of 

intelligent management as it is close to town for visiting tourists, already provides ample roads to travel, and is a cooperative effort with the BLM and the Canyon Country 4x4 Club. I support this RMZ and suggest that future expansion of it be considered, or at least not excluded. I am aware that Kane County is proposing a similar SRMA for the John R. Flat area, and I support the County's efforts to that end. I also support Kane County's legal right to protect both their road rights, and our access rights to areas provided under RS-2477 Statutes. I believe that the BLM should recognize those rights for all Utah counties and should not consider 

any final road closure decisions until the validity of those claims are resolved. I 

fully intend to support any litigation that the County finds necessary with both my tax dollars and individual contribution if necessary. 

Tcea

Recreation Jim & Bonnie Vann 1.) The road out to Hell Dive is an old established road that was originally put in 

for ranching purposes and qualifies as part of Kane Counties RS-2477 road rights, and I support those rights . It currently traverses a State School Section and terminates just a short distance further at a spectacular Indian site hidden 

under the rock rims with beautiful Indian drawings on the walls, and grinding stones still in place. This area has been visited by local residents for well over 100 years and shows virtually no signs of impairment or degradation. This is a 

beautiful destination site to take people to who are unfamiliar with the Indian cultures. A short time spent in silence here conjures images of ancient native peoples working, cooking, and playing under the overhanging cliffs. This area would make an excellent interpretive site for the BLM while still allowing the 

public to visit and enjoy it. This area would lend itself to a cooperative effort between the OHV communities and the BLM as a project to fence the end of the road at its current location with a kiosk containing interpretive information for visitors as a "cultural resource" area. 

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Recreation Jim and Bonnie Vann 2.) The second road is to the west of the one just described and terminates at a 

viewpoint on the south rim of the Virgin River Gorge just east of Rock Canyon.. This is also a Kane County RS-2477 road and should remain open. Like the above described road, it is a significant "visual resource" for its view into the Virgin River Gorge and travel is not possible beyond its current end. To reach this 

spot, you would have to travel over 15 miles by OHV to the edge ofthe WSA, and then walk approximately 2 miles in soft sand to the viewpoint end. No one would 

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Category Name Commentor Comment 

do this, and you would be denying the general public the ability of enjoying this spectacular view. 

Recreation Jimmy Page 

U4WDA & Wasatch Cruisers 

*Special Recreation permits should not be limited to 25 or less. (Many clubs are >25. 

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Recreation Jimmy Page 

U4WDA & Wasatch Cruisers 

*Table 3.26 in the RMP is flawed and eliminated due to should be eliminated due to incomplete data (as stated in the RMP). 

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Recreation John Veranth Regarding parking pullouts for hiking, picnics, and car camping along open 

vehicle routes, this seem to be an issue that always gets lost between the OHV 

and Wilderness advocacy groups. The RMP should explicitly address this issue. In general, vehicle travel immediately adjacent to the designated route (for 

example 25-33 ft) for the purpose of parking should be allowed. In more sensitive areas an adequate number of informal parking areas or spur should be designated to concentrate this type of use adjacent to open routes. 

P

Recreation John Veranth Perhaps I did not read carefully enough, but mountain bikes also seem to have 

gotten lost between the OHV and Wilderness advocacy groups There seems to be no consideration of non-motorized single-track routes, but I presume some 

mountain bike groups will comment. Mountain bikes are mentioned as nonmotorized in 3.5.1 and the use statistics in Table 3-26 seem totally inconsistant with my "eyeball" observations of bike groups along Hwy 12 alone. 

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Recreation John Veranth In fact, it appears that all of Table 3-26 is badly skewed by the fact that many 

activities are hard to count and use surveys are incomplete. Counting trailers at an ORV trailhead is an easy way to estimate use. Picnicking and day hiking on BLM land are very dispersed and since on registration is required there is no efficient way to get a count beyond a sampling and extrapolation study. As a 

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specific example, I frequently hike onto nearby BLM land starting either directly from my private property or after walking a only short way on the public road. There is no way such use will be included in the visitor statistics, but it represents 

real user days, and there are many, many others who do similar informal hikes. If I drive my stock SUV to a trailhead on a county road and then start walking is this counted as "OHVs (Cars/Trucks/ Sport Utility Vehicles) and All- Terrain Vehicles" or as "Hiking/Walking/Running" or both? Further, I question whether environmental and nature study really jumped from 0 in 2004 to 3352 in 2005 - rather I suspect the prior years were really (N/M = not measured). Although the DEIS acknowledges the limitations of the data in 3-26 on page 3-77, I want to remark that management decisions based on these statistics are flawed since "direct monitoring by BLM staff ... focused on areas of greater use and conflict" is likely to overstate use at motorized play areas and motorized trail heads. Thus the BLM statement p3-80 that "More recreationists participate in OHV riding than in any other form of recreation use," is likely to be inaccurate due to systematic undercounting of hiking, wildlife watching, sightseeing, photograpy, and picnicking. 

vmDdpaAbVsu

Recreation John Veranth Regarding the "quantitiative objectives" for the recreation management zones. I 

am not sure what "75% of responding visitors" means if you ask hikers about benefits of OHV play areas (or conversly ask OHV riders about benefits of nonmotorized areas). This whole criteria discussion seems artificial and contrived. 

Tpo

Recreation Land Use Volunteers 

of Kane County 

This projection of future OHV travel and impacts on our public land needs to be completed and included in the planning process before approving a Travel Plan for the Hog Canyon and JR Flat areas. 

Tpmi

Recreation Laura Welp This SRMA should not be implemented until further studies show that the OHV 

impact to this plant would not affect its reproduction. 

T4

Recreation Lisa Rasmussen I go 4-wheeling with my rig with various clubs and often times it is with more than 

25 rigs. To break up a party for arbitrary reasons is ludicrous. 

Tdl2a

Recreation Lisa Rasmussen The RMP statistics are flawed. Please take out Table 8-26. T

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Category Name Commentor Comment 

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Recreation Liz Kolle I'd like to see KFO develop a campground for RVS, to replace the Dry Lake Bed 

as a camping area. I'd prefer the WSA there to be closed to overnight camping. 

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Recreation Marlin Sharp 

Lone Peak 4 Wheelers 

Concerning Special Recreation Permits. I do not believe that group sizes should be limited to 25 people under the proposed Special Recreation Permit. .. This number in my opinion is unrealistic and makes group events such as family picnics or scouting events impossible I believe the rules and authorized exceptions for theses SRP's should be clarified and added to Alternative B. If the 

BLM were to require permits for all "groups", and only allow each group to consist of 25 people, even a weekend club 4x4 run or family reunion would have to apply for a permit, a lengthy, expensive and troublesome process in most cases. For groups of over 25 people, that permit would have to be evaluated and authorized 

on a "case by case" situation, meaning the BLM has no set guidelines for authorizing larger groups. 

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Recreation Melissa Gardner Please do not limit the group size to 25. T

dl2a

Recreation Merlin Esplin All action alternatives propose to "prohibit OHV or mountain bike tours in... " as 

listed on page 2-81. BLM cannot enforce the restrictions currently in place. 

Please be wise and careful when considering additional restrictions. 

BDrwu

Recreation National Parks 

Conservation Association 

The BLM has completely failed to address the impact that the proposed Alton Coal Mine or increased oil and gas development would have upon the pristine night skies within the parks. 

NAdw

Recreation Richard Csenge In addition, by their very nature, motorized uses of public lands impact very large 

areas due to the speed and power, and noise ofthe machines, disturbing wildlife, 

and creating conflicts with other uses, such as non-motorized recreation. It is therefore necessary that separate recreational management zones be established and enforced for motorized and non-motorized use. Until such time as Congress decides , establishment of such zones must not violate existing wilderness, WSAs, or non-wilderness lands with wilderness characteristics, which 

Mprm

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

are specifically contained in the America's Red Rock Wilderness Act, pending in U. S. Congress. 

Recreation Richard Csenge In Alternative B and D, Maps 2-17 and 2-19, BLM appears to be designating 

open routes for motorized travel within the Parunuweap, and Moquith WSAs. Maps 2-9, and 2-11 seem to introduce motorized RMZs into WSAs. Is this not against federal law, and will not such mismanagement inevitably lead to resource impairment? Vegetation damage from OHVs is prevalent in each of these areas, which are already being impacted by a multitude of meandering routes created by motorized vehicle travel. In addition, maps 3-10 and 3-11 list these areas as crucial, high, or substantial habitat for mule deer. Frequent and increasing intrusions by OHVs over the term of the RMP may significantly reduce, if not 

eventually banish herds from these areas. One prime public interest, that of 

hunting, would surely be adversely impacted.(see enclosures #4 & #5) Such management would be contradictory to the preservation of resource values as required by law. In this regard, only alternative C, indicated by Map 2-18, provides the bare minimum of protection that wildlife deserves. 

Tpd

Recreation Russell Howe First, I believe that putting a 25 person (group size) limit is a mistake. This would 

surely limit many family activities, (reunions, events, etc.) as well as scouting events, group rides, camping parties, etc. In my own extended family we frequently visit parts of our beautiful state in large camping groups, and would no longer be able to visit this affected region. 

Tdl2a

Recreation Scott Howe 

U4WDA, TLCA 

I do not support the requirements for the special recreation permits. These requirements are unreasonable and severly limit the possibility of group events. 

Group events are a crucial part of responsible recreation where as people can 

learn from others proper off highway recreation habits & show group support for areas. Groups provide the possibility for service projects that help to manage public land. 

Tdl2a

Recreation Seth Bowers 

U4WDA 

1) The limit of special rec permits to 25 is unreasonable. My family reunions would not be allowed under this rule. 

Tdl2a

Recreation Seth Bowers 

U4WDA 

2) Table 3.26 is grossly distorted. Data collected is flawed by the BLM's own admission. The table should be removed in its entirety. 

Ti

piavmDd

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

paAbVsu

Recreation Spencer Decker I am extremely concerned with the BLM plans to open up this area to additional 

roads and ORV trails. There is plenty of space in the region to accomodate both hikers, canyoneers and ORV recreation, but they cannot effectively exist on top of each other. 

Mprm

Recreation Steven Edmunds Special recreation permits - do not reduce the size of the groups - you will be 

requiring my family to seek permits for annual family reunions. 

Tdl2a

Recreation Steven Edmunds The use statistics are wrong - these statistics in table 3-26 should be removed or 

replaced with accurate data. 

Ti

piavmDdpa

AbVs

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Recreation Susan Hand The area of the Vermilion Cliffs between Kanab and Johnson Canyon. The 

subdivisions in this area were established as equestrian developments, and many residents ride their horses on adjacent BLM lands. ATV's and horses are generally not compatible. Many property owners object to the trespass, dust 

noise, erosion, and scarring created by the proximity of motorized recreation to the subdivisions along this narrow corridor. 

Acf

Recreation Susan Hand I'm especially disappointed by the motorized activity which has been allowed on 

the Dry Lake Bed adjacent to the Coral Pink Sand Dunes. Proximity of the campground to the WSA has resulted in repeated and extensive OHV use within 

Td

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

the closed area, even though it is signed. The RMP should create a more appropriate campground and close the Dry Lake Bed. 

Recreation SUWA This DRMP/EIS does not provide equal recreational opportunities for nonmotorized uses - or even try to move toward some semblance of balance. M

p

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Recreation SUWA Under the plain language and intent of these provisions, the BLM has not 

provided a reasonable range of alternatives for the designations of SRMAs and RMZs to sufficiently address the aforementioned increasing damage caused by ORV use, including conflicts between recreationists. 

Tra(

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Recreation SUWA The Kanab Field Office has failed to take a hard look at the impacts of motorized 

uses in designated SRMAs. For example, the DRMP/EIS discusses potential 

impacts to soils from the designated SRMAs in the preferred alternative (B) 

T4

Recreation SUWA BLM should develop and choose an alternative that manages a significant portion 

of the planning area as non-motorized. BLM should also take the requisite hard look at impacts from the designated SRMAs and lack of SRMAs before moving forward. This hard look should naturally include the new alternative with more specific non-motorized use in SRMAs in order to be in compliance with NEPA, the CEQ regulations, and case law. 

UmnRU

voanm

Recreation SUWA BLM should choose Alternative C rather than the preferred alternative in order to 

better protect the planning area from damage caused by large events. The factors weighed before an SRP is issued should be further defined, with clear guidelines. The Kanab Field Office should also consider using the model provided by the Price Field Office DRMP/EIS for classification of SRPs to show what uses may be appropriate/inappropriate in what areas. 

T

Dtlos

Recreation SUWA There are several factors the BLM should always take into account before an 

SRP is issued. The DRMP/EIS for management of a particular area provides the 

ideal forum to list such factors by which each SRP should be weighed in future actions. At a minimum, the DRMP/EIS should address the following : • Duration of permit - all permits should be limited to a temporary and short term activity. SRPs should only be issued on a one-time basis and should not be extended to last for an inordinate amount of time. For example, a ten-year SRP would be an abuse of discretion on the agency's behalf. • Number of vehicles permitted -the 

TgHSlb

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

DRMP must include a limit on the number of vehicles, and description of the type of vehicles that would be considered for specific areas in which SRPs would be considered in order for the decisionmaker to assess the potential for damage to environmental and cultural resources. • Type of vehicles - the BLM should delineate these categories and the number permitted by type before an SRP is needed. Different categories of vehicles (e.g., kayaks, motorized boats, mountain bikes, dirt bikes, ATVs, high clearance jeeps ("rock crawler")) have different impacts and require different management prescriptions. However, the current DRMP/EIS does not define what constitutes a ''vehicle'' for the purpose of SRPs • Number of persons permitted - a threshold should be set for how many people within a group will trigger the need to apply for an SRP. Even without vehicles, large group activities can have a significant impact on environmental and cultural resources. Thus, management of such events will need greater attention/restrictions in order to mitigate these impacts. • Location of SRPs - the DRMP/EIS should specifically identify areas that are not appropriate for the issuance of SRPs. Such areas should include Wilderness, Wilderness Study Areas, non-wilderness study area lands with wilderness characteristics, riparian areas, and any lands that currently are being evaluated or managed for their primitiveness and sense of solitude. Conversely, there should also be locations identified where SRPs may be acceptable. This can be done through the designated of SRMAs/ERMAs, using the ROS as a baseline. • Number of permits per year - there should be a cap on how many SRPs may be issued within a specific area. This can be done through the designated of SRMAs/ERMAs, using the ROS as a baseline. Limiting the number of SRPs will help the Kanab Field Office implement its policy of better prioritizing uses associated with SRPs by only permitting activities that fit squarely with the best management of each area. 

Recreation Theodore Roosevelt 

Conservation Partnership 

Given the long-term nature of energy development, the BLM should include a plan in the FEIS for compensating hunters for the loss of big game that might 

occur as a result of energy development. 

BcRg

Recreation Thomas Forsythe Beyond that, anyone wishing to enjoy the viewpoints and landscape of the area 

below Thompson Point can do so on the one recognized Kane County road. No further motorized access is either necessary or warranted. This could be accomplished by including this area in the Kanab Community SRMA - NonMotorized Trails RMZ 

TTcea

Recreation Tim Rasmussen Do not limit group sizes to 25 vehicles. We often travel with groups larger than 

this and it would limit our enjoyment of this sport. 

Tdl2a

Recreation Tim Rasmussen Some of the statistics used for the RMP are flawed, such as Table 3-26 and 

should be eliminated. 

Ti

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

piavmDdpaAbVsu

Recreation Timothy Zimmer The SRMA proposals should not exclude any user categorically. T

trah

Recreation Timothy Zimmer I reviewed Table 3-26 and agree with the “U4WDA” group that this cannot be 

based on reality since these areas are fairly remote and not used predominately by the specific user groups it implies. I would like to see the raw data or surveys 

that supposedly generated this mythical table, especially since it was contradicted in 4.1.6. 

T

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Recreation Tobin Gardner Please don't limit the group size to 25. T

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Recreation Tobin Gardner I believe the RMP user stats are not correct. Table 3.26 should be elimited. T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

piavmDdpaAbVsu

Recreation U.S. Fish and Wildlife 

Service, Utah Field Office 

Page2-72, Section 2.4.1: We do not support Alternative B for the Moquith Mtn, Dunes RMZ. A requirement for research and monitoring of OHV impacts to both Welsh's milkweed and Coral Pink Tiger Beetle should be included in all alternatives. Research and monitoring is necessary to ensure accurate assessment of impacts, particularly from ongoing OHV use, and development and implementation of effective conservation management strategies. 

TRtB

mR

Recreation U.S. Fish and Wildlife 

Service, Utah Field Office 

Page 2-72, Section 2.4.1: Alternative A indicates that the Sand Spring area would be designated closed to OHV use. Please clarify if Alternative B would maintain or expand use at Sand Spring. Also please clarify the extent and location of the conservation areas that are referred to in Alternative B. 

Tr

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Recreation Utah Archeological 

Research Institute 

We ask that you please include a section with alternatives on target shooting. We further ask that the preferred alternative ban all target shooting with gunpowdered projectiles on public lands. 

E

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Recreation Walter Fertig Recreation management: I commend the Kanab FO for adopting "Special 

Recreation Management Areas" as a planning and management tool. This is something that should have been done a long time ago to minimize conflicts between competing (and sometimes incompatible) uses and represents what multiple use management ought to be. The trick, of course, is that delineation of the areas is fair to all and management is enforced. 

Ttra

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Recreation Western Watersheds 

Project, Inc. 

Recreation management actions within Chapter 2 pg 2-80, should change requirements of a 200' buffer in riparian areas as stipulation for recreation SRPs to require 330 in accordance with UT Riparian Policy and Utah Guidelines for Recreation Activities. 

Ttiv

103 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

oc

Recreation Western Wildlife 

Conservancy 

We categorically reject the philosophically unsophisticated idea enthroned in the federal bureaucracy that all values reduce to the varied preferences of human beings. To the contrary, we maintain that both biotic and a-biotic nature possess 

irreducible intrinsic value. In our view that human beings (including especially the employees of the Bureau of Land Management) have a moral duty to recognize and protect these values while giving proper weight to instrumental values, such as accessible mineral deposits, and various recreational values. Among these latter, those types of recreation that are most conducive to appreciation of the intrinsic values of the land, wildlife and cultural resources, which are typically least destructive to these resources and least obnoxious to quiet recreationists, ought to be accorded the highest priority. Note: This excludes ATV, ORV and OHV recreation. In our opinion, the Kanab RMP, especially under the “preferred” alternative, gives far too much weight to mineral exploration, livestock grazing and motorized recreation at the expense of intrinsic values and the experiences of quiet recreationists. It’s as if a fine acoustic guitar were given to a tribe of people who could conceive of no better use for it than firewood. 

Mprm

Recreation William Hughes First, the Hog Canyon SRMA needs to have language added that would allow for 

possible expansion of the road system in the future. This is a tool that might be valuable in the future. 

A

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Recreation William Hughes Second, an SRMA should be added for the John R. Flat area per the suggestion 

of Kane County officials. 

M

Riparian ECOS Consulting The riparian "330 foot" buffer proposed within this Kanab DRMP/DEIS is woefully 

inadequate to prevent widespread riparian long-term, direct, indirect and cumulative impacts. 

N

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Riparian ECOS Consulting For these reasons, and many more, the BLM must establish an effective buffer 

zone that protects the less than 1% of the Kanab Decision Area that riparian habitat encompasses. When there is nearby surface disturbance, the proposed BLM buffer of "100 meters" is inadequate in this dry desert environment, because ofthe ease of the spread of soil disturbance and erosion, vegetation loss, and soil and water contamination that can spread into the floodplain and riparian habitat. 

N

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Riparian ECOS Consulting The DRMP/EIS fails to provide enough information to adequately assess the 

direct, indirect, and cumulative impacts of OHV use in the riparian areas within the Kanab Decision Area. In particular, the DRMP/EIS fails to identify what specific riparian areas will be affected, how much of the total percentage of riparian areas and floodplains will contain OHV routes in the different alternatives, or what specific riparian areas will be "Closed." 

Tdsrrhp

Riparian ECOS Consulting It is recommended that the DRMP fully disclose what riparian areas will have T

104 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

OHV routes in/near them. Specifically, each riparian area should be listed as either open or closed to OHV use, with "open" being those riparian areas that have an OHV route within the riparian area and/or floodplain. The DRMP/EIS should also disclose each of the routes clearly, and address how they will be maintained. The DRMP/EIS should also address future relocation and closure due to deteriorating riparian conditions and deteriorating route conditions due to continuous wear and tear and storm events. 

dsrrhp

Riparian ECOS Consulting Thus, the BLM must manage the small percentage ofriparian habitat that is in the 

Kanab DRMP project area, less than 1% of the total area, for the maximum 

benefit of renewable resources, and for the ecological benefit of surrounding 

areas. 

Pa

Riparian ECOS Consulting These potential impacts are not addressed adequately in this Kanab 

DRMP/DEIS; this is especially relevant considering the increase in mining and oil 

and gas exploration applications and future plans of the industry. 

Rndbd

Riparian Mark Sterkel As for unique, rare, threatened riparian areas, the DRMP does not provide for 

management to protect them. Utah is the 2nd dryest state, so should not our 

vulnerable streams, wetlands, and riparian areas be treasured & protected? Why continue to ignore proper management and let them be overgrazed, and trashed by OHV's? 

Nier

Riparian Norman McKee 2 – 8: In management actions, is there consideration to include the use of beaver 

for riparian management? 

BD"ea

Riparian Norman McKee 2 – 9: To remove all exotic plants would also include Russian Olive trees. This is 

a tree that is an important winter food source for several wildlife species, notably wild turkeys. Please reconsider the proposal to removal all Russian Olive trees in occupied or potential turkey habitat. 

Tt

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Riparian U.S. Fish and Wildlife 

Service, Utah Field Office 

Page 2-38, Section 2.4.1: Management of Riparian Areas (first row): Does the BLM have a list of "small" or "isolated" riparian areas that are considered suitable for divestiture? If so, it may be appropriate to list those under consideration in the document. Riparian areas, even ones that are small and/or isolated, are 

important for many species of Utah wildlife. Divestiture of these features should not result in their loss or degredation or result in the degradation of water quality within and downstream of the riparian areas. 

T

Riparian U.S. Fish and Wildlife 

Service, Utah Field 

Page 2-38, Section 2.4.1: Management of Riparian Areas (3rd row): "As opportunities arise..." This statement implies that recovery and rehabilitation 

T"

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Office would not be considered a priority, and only occur as opportunities arise. 

Consider providing a stronger standard and commitment in the RMP toward restoration of riparian communities, particularly because of their high value to wildlife species throughout the State. 

m

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Riparian U.S. Fish and Wildlife 

Service, Utah Field Office 

Page 2-39, Section 2.4.1, 2nd row: Reword as, "Do not allow new surface disturbing activities within a minimum buffer of 330 feet..." Protection of wildlife species, particularly during nesting or breeding seasons may require a larger 

spatial buffer than 330 feet. Similar wording should be added to all alternatives, and throughout the document. 

LPfc

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Riparian U.S. Fish and Wildlife 

Service, Utah Field Office 

Page 2-40, Section 2.4.1: Management of Riparian Areas (last row): Remove the wording "to the extent possible" from the commitment to maintain sufficient water at springs. Many wildlife species rely heavily on spring habitats, and these features should always be retained. 

To

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Riparian Western Watersheds 

Project, Inc. 

Indeed the entire riparian discussion and definitions need clarification with respect to riparian and/or wetland resources. 

Ti

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Riparian Western Watersheds 

Project, Inc. 

Proper data is available through current technology regarding geographic information systems digital imagery, data sources such as the National Hydrographic Dataset (NHD) and US Geologic Survey (USGS) water resources data, as well as site-specific field assessments for Standards of Rangeland Health and Riparian Databases. 

Ti

Ow(eias

Riparian Western Watersheds 

Project, Inc. 

The DEIS/RMP needs to demonstrate through proper analysis that riparian/wetland resources and other sensitive values including dependent wildlife species habitats, are adequately identified and protected from proposed 

resource uses and impacts. 

TTudcAda

Riparian Western Watersheds Additionally, clarification needs to be provided that all riparian/wetland resources B

106 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Project, Inc. (both lotic and lentic systems) are protected by the Executive Order (EO) 11990 

(wetland protection), EO 11988 (floodplain management), and Section 404 of the 

Clean Water Act. 

Rt

Riparian Western Watersheds 

Project, Inc. 

Where is BLM's analysis showing the relationship of livestock and OHV activities to water pollution, stream damage and loss of aquatic habitat in ALL livestock or 

motorized accessible areas? 

Ta

Riparian Western Watersheds 

Project, Inc. 

Despite an improper capability and suitability analysis, the DEIS failed to quantify and analze the impacts of livestock grazing within riparian/wetland areas which are critical and sensitive ecosystems within the western landscape. 

Ta

Riparian Western Watersheds 

Project, Inc. 

Claims of streams and riparian areas in PFC ignore that PFC is a minimal classification that does not address the wildlife habitat attributes of these most important areas, water quality or instream habitat for fish. In addition, springs, 

seeps and wetlands condition and trend are not described. 

PrFl

Scope of Document Bill May In addition, I believe That the BLM should recognize the RS2477 road claims that 

are part of Kane and Garfield Counties Transportation Plans ... 

Tcea

Scope of Document Bruce Bunting 

Kane County Conservation District UACD 

Do not attempt to close roads that are part of the counties transportion plans or RS-2477 roads that are being claimed by the counties. There would be less conflict with these road areas if these routes were determined before attempts made later to close these important rights of way. The district does not believe 

the BLM has this kind of authority to over ride RS-2477 roads to begin with. 

Tcea

Scope of Document Capital Trail Vehical 

Association 

We request that this planning project include adequate research ofthe county records and adequate formal consultation and coordination with the county to get their input on RS 2477 routes. 

Ta

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3 

Scope of Document Don Black Canyon 

Country 4x4 Club 

We also consider it a mistake to attempt to close roads that are part of the Counties Transportation Plans or RS2477 roads that are being claimed by the Counties. Less conflict would arise by having the validity of these route determined before any attempt was made to close any of these roads. 

T

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Scope of Document Don Black Canyon 

Country 4x4 Club 

Due to popularity, improved equipment and technological advancements, we need to update and get prepared for future use. Attached is a list of people who have also acknowledged the need for these improvements. We ask that you 

consider this proposal and retain it in your records. We look forward to working with you regarding the following: 1) The Hog Canyon OHV area should be treated as a separate entity from the RMP due to its complexity and previous determination. 2) The Trail Patrol functions and activities should be better coordinated with land managers. 3) Have an unbiased member of land management to work with the motorized community on day to day issues. 4) All actions taken for the betterment of the system be a mutual effort between land 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

managers and users. 5) A trail be developed to the North to better access the states existing trail systems. 6) Trails on attached map be considered to make this a more adequate and complete trail system. 

Scope of Document Don Black U4WDA We also consider it a mistake to attempt to close roads that are part of the 

Counties Transportation Plans or RS2477 roads that are being claimed by the Counties. Less conflict would arise by having the validity of these route determined before any attempt was made to close any of these roads. We also feel that not having existing roads on the maps as part of the RMP process does 

not give us the opportunity to make meaningful comments on the roads shown on the maps as part of Alternate B. 

Tcea

Scope of Document Duane Smith The roads that run to, through and around Rock Canyon Spur, Poverty Flat 

Road, Virgin River Access, Hell Dive, Ed Lamb Point Rd. Verillion Routt, Willis Canyon, Black Mesa quilify under RS2477 as road that should remain open to public acess of all types. 

Tcea

Scope of Document ECOS Consulting Where monitoring programs have been developed and used, the BLM must write 

summary and trend reports so that management and the public can make determinations on the effectiveness of the management of allowed activities. 

Tr

Scope of Document ECOS Consulting In particular, we would like to see Wildlife Management Plans for mountain lions, 

bobcats, bears, foxes, and coyotes that include habitat improvements and the protection of areas large enough to support viable populations of these predators. 

WRis

Scope of Document ECOS Consulting Besides population numbers, this DRMP lacks overall goals and objectives for 

the management of fish and wildlife for the next 10-20 years. It also lacks what the basic wildlife needs are and how the BLM plans to meet any objectives. 

WRis

Scope of Document ECOS Consulting By all measures, the loss of wildlife habitat in this area would be devastating, 

immediate, and very long-term. What wildlife use this habitat? Are there any populations that would be significantly impacted by these activities? This must be thoroughly discussed in this section. 

Tqady

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Scope of Document Frank and Kaye 

Alleman 

Closing of roads that have RS2477 rights. We don't think you have the authority to do this. 

T

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Scope of Document Geno Ramsey I believe that the BLM should recognize the RS2477 road claims that are part of T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Canyon Country 4x4 Kane and Garfield Counties Transportation Plans. The validity ofthese claims 

should be determined before a final decision is made in the RMP. 

c

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Scope of Document Illegible Illegible Alternative B is preferred with reservations. I do not feel the BLM has the 

authority to implement changes to RS 2477 roads let alone any public roads and needs good reasons to close any roads whether established or not. 

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Scope of Document Jacalyn & Charles 

Liebfried 

Any and all RS 2477 roads must remain open. Litigation over these roads is paid for by the taxpayers for both sides of the issue. Avail yourselves to Kane 

County's pre 1976 aerial maps. 

Tcea

Scope of Document Jack Johnston 

U4WDA 

Was RS2477 considered when closing Sheep Springs Road and Kanab Creek Road as I know these roads are man made & maintained. 

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Scope of Document James Bulkeley I have reviewed the plans and noticed the following major flaw. The plan is flaw 

because it does not include the Grand Staircase-Escalante National Monument (GSENM) (1,900,000-acre). An adjacent land mass the size of the GSENM should be included in any regional plan. All of the proposed alternative failed to address a balance of recreational values and opportunities. 

T

MS

Tcd

Scope of Document Joan Thacher I request that any transportation plan have a sufficient strategy for enforcement. L

er

Scope of Document Josh Heaton Also I would like to voice a concern about the coal mine going in up in Alton. And 

since I live up there I really don't want it to go in. Because the trucks that will be 

hauling it out, will constantly be driving threw the town. 

Tt

Scope of Document Land Use Volunteers 

of Kane County 

The Kanab BLM needs to complete projections of future OHV use in our area for the next 20 years, then include these projections in their land use planning . What resources will be impacted by greatly increasing numbers of OHVers over time, and which of these resources need to be protected by prudent transportation 

route planning? 

Tpm

Scope of Document Land Use Volunteers 

of Kane County 

This projection of future OHV travel and impacts on our public land needs to be completed and included in the planning process before approving a Resource Management Plan that will last for 20 years. 

Tpm

Scope of Document Land Use Volunteers 

of Kane County 

Because this geographic area has been inventoried by the BLM to contain wilderness characteristics, a more extensive inventory of resources should be completed before approval of an RMP Travel Plan. The current BLM inventory is inadequate and does not include or accurately map the distribution of many of the archeological, botanical, wildlife, cultural, and ecological resources present in 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

the area that may be impacted by ORV's. This extensive inventory needs to be completed before the final version of an RMP is approved. 

Trtr

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Scope of Document Land Use Volunteers 

of Kane County 

The current BLM inventory of Moquith Mountain WSA is inadequate and does not include or accurately map the distribution of many of the archeological, botanical, 

wildlife, cultural, and ecological resources present in the area that have already been impacted by ORV's. This extensive inventory needs to be completed before 

the final version of an RMP is approved. 

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Scope of Document Land Use Volunteers 

of Kane County 

The current BLM inventory of Parunuweap WSA is inadequate and does not 

include or accurately map the distribution of many of the archeological, botanical , wildlife, cultural, and ecological resources present in the area that have already been impacted by ORV's. This extensive inventory needs to be completed before 

the final version of an RMP is approved. 

Wee

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Scope of Document Laura Welp Although this part of the trail is not on BLM land, the BLM is obviously part of the 

larger road system that is required to take OHVs from Kanab to the Hog Canyon Trailhead. 

T

Scope of Document Laura Welp A monitoring plan should be described in detail in the RMP. If impacts are 

identified, how will they be mitigated? 

At

Scope of Document Mark Sterkel 40 million tons of coal from a mine near Alton, over the next 20 years, raises 

serious questions that may be within the scope of the RMP. For the I, 430 acres 

of public land (nearly 2 1/2 sq. miles) that would be strip mined, a seperate E.I.S. seems in order how many haul trucks per day through Kanab, Panguitch, or Cedar City? Every 5 minutes, 24 hrs/day, for the next 20 years? Will the drivers 

slow down for, or even see our children? Will the drivers be on meth or crack? How many highway wrecks will be caused by the frantic rush hours to and from Alton, from Kanab, Cedar, Escalante, Kingston, or Burrville? Will the housing & 

services for all those workers change our quality of life? What about crime, air pollution, crowded govt offices & jails, our teenage daughters? BLM should study a slower approach, before we end up with traffic lights in Hatch & Orderville. 

Tt

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Scope of Document Marlin Sharp 

Lone Peak 4 Wheelers 

In addition, I believe that the BLM should recognize the RS2477 road claims that 

are part of Kane and Garfield Counties Transportation Plans. The validity of these claims should be determined before a final decision is made in this RMP. I believe Kane and Garfield counties should be consulted regarding all road decisions prior to decision. 

Tcea

Scope of Document Michelle Young Alternative B is preferred with reservations. I do not feel the BLM has the 

authority to implement closures to RS 2477 roads. And needs good reasons to close any roads whether established or not. 

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Scope of Document Monte Chamberlin 

Canyon Country Rural Alliance 

Under the proposal water rights are being threatened-rights which are already 

threatened under wild and scenic designation, wilderness characteristics management, watershed protection provisions, etc. 

Tmws

Scope of Document Robert Aiken The road to Moquith Mountain and the road to Hells Dive Canyon. Are RS 2477 

roads and should be open for the public to use. 

TIRTaT

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Scope of Document Robert Aiken On the South side of the Virgin River, you are proposing to close the Rock Creek 

accesses road. This road has been in existence for over 30 years, and is considered a RS2477 road claimed by Kane County. 

TR

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Scope of Document Sam Hamp 

Utah 4x4 Club 

first off I would like to say that I believe the following roads to be established roads and as such are covered under RS2477: Rock Canyon Spur on the map "The Barracks", The Poverty Flat Road on map "The Barraks," Virgin River Access Rd on map "The Barraks," Hell Drive on map "Moquith Mountain", Ed Lamb Point Rd on map "Moquith Mountain", Vermillion Route on map "Thomson Point", Willis Canyon on map "Thomson Point" and Black Mesa Routes on mapo "Black Mesa. 

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Scope of Document SUWA Vast tracks of BLM lands were arbitrarily and/or capriciously omitted from WSA 

designation for various reasons not in keeping with FLPMA's mandate. These 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

errors and omissions made it impossible for the BLM to fully account or the extent of the wilderness resource during its FLPMA mandated wilderness inventories. 

TcTts“smful(SrrTrl2ls

Scope of Document SUWA We are deeply troubled that BLM, by condoning trespass and impairment to our 

public wild lands, is taking the extreme position that the federal government will tolerate damage to our public lands and that those who damage our public lands can do so without fear that BLM will enforce the law. Such a position is contrary 

to law and BLM policy and must be reversed. 

Ler

Scope of Document SUWA Recommendation: We strongly urge BLM to take immediate action to enforce the 

law and remove the illegal Kane County road signs from the wilderness study areas and other public lands (this would also apply to any Garfield County signs if that county posts such signs). In addition, the RMP should state that BLM shall 

immediately remove all signs that conflict with BLM's travel management 

decisions. 

Ler

Scope of Document SUWA The BLM should adopt the approach to management set out in IM ID-2008-016, 

including creating a baseline of conditions in the WSAs, setting out a detailed monitoring program, incorporating standards for determining if use of these ways is impairing wilderness values, and committing to take measures to end any such impairment immediately, including through closure and restoration of ways. 

Tl

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Scope of Document Tracy Hiscock Adequately fund resource protection and law enforcement programs. The agency 

already fails to control ORV use in Wilderness Study Areas or wilderness quality 

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e

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Category Name Commentor Comment 

lands. r

Scope of Document Tracy Hiscock By adequately planning the ORV designated routes to avoid environmentally 

sensitive areas, • By improperly allowing construction of ORV staging areas, signs and routes without following federal rules imposed by the National Environmental Policy Act (NEPA), and • By failing to designate any areas as closed to ORV use and, consequently, primarily for hiking or equestrian use. This ignores a huge population of public land users to accommodate a smaller group of ORV users. 

Mp

rmimp

Scope of Document Utah Archeological 

Research Institute 

It would be appropriate for the BLM as part of this management plan to formally commit to getting all of the eligible archaeological sites in the KFO area listed on the NRHP. Therefore, we formally request that you please do exactly that. The Cottonwood Canyon drainage would be a good place to start. 

T

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Scope of Document Utah Archeological 

Research Institute 

Regarding section 1.4 on page 1-15 under Planning Criteria, there is no discussion about archaeological resources (field inventories, identification, 

protection). Should not the existence of archaeological resources play a significant role in these plans? See page 2-21 through 2-22, Objectives under Cultural Resources. 

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Scope of Document Western Watersheds 

Project, Inc. 

The RMP/EIS has failed to take a hard look at the issue of livestock grazing, instead, putting off decisions to some uncertain time in the future, while impacts, 

Es

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

which are massive across the Resource Area, continue. BLM has not provided for enforceable permit terms and conditions. 

bDtmppmRct

Scope of Document Western Watersheds 

Project, Inc. 

The Draft RMP/EIS failed to analyze the role and values of predators in controlling rodent populations and fulfilling their role in a healthy ecosystem. 

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Socioeconomics Capital Trail Vehical 

Association 

Additionally, we request that the cumulative negative impact resulting from 

inadequate evaluation of economic and social impacts in past actions are considered in the analysis and decision-making and that an adequate mitigation plan be included as part of this action to compensate for past cumulative 

negative impacts. 

TdTe

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Socioeconomics Melanie BooneReznick In reviewing the Kanab Resource Management Plan, there is a lack of recognition of the intrinsic values that the resources of the area provide to the 

local social and economic welfare of the surrounding communities. 

TndoAs

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Socioeconomics SUWA The range of alternatives analyzed in the RMP Draft EIS is insufficient. There's 

almost no variability among the four alternatives presented, in terms of the 

proportion of the planning area being open for both motorized recreation and for oil and gas development. The so-called protective alternative is the only one with a notable difference and even this alternative opens the majority of the planning area for oil and gas drilling and off-road motorized recreation. 

Taqimd

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Category Name Commentor Comment 

a

Socioeconomics SUWA Recommendations: The BLM must measure and account for changes in nonmarket values associated with the level of off-road motorized recreation, oil and 

gas drilling and other development proposed in this RMP. To do otherwise omits a very important socioeconomic impact that is the direct result of management actions. The BLM must assess the non-market economic impacts on the owners of the lands in the Kanab Field Office - all Americans. This analysis must include 

the passive use values of undeveloped lands such as the lands with wilderness characteristics. 

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Socioeconomics SUWA Recommendations: The BLM must collect and analyze actual data on the 

economic impacts of the alternatives, including Alternative E. Some suggested 

analyses and sources of data can be found in "Socio-Economic Framework for Public Land Management Planning: Indicators for the West's Economy" (attached). 

TdTmMsTBp

sTu

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Socioeconomics SUWA Recommendation: The BLM must collect accurate data on actual recreation use 

of the Kanab Field Office, including data on the impacts (environmental, social 

and economic) of recreation use. Until an accurate assessment of actual use and impacts can be made the BLM should err on the side of caution and restrict offroad motorized use. 

TdT(Dosfi

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Category Name Commentor Comment 

a fdartAa

Socioeconomics SUWA Recommendations: BLM must develop recreation management directives which 

reflect the proportional use of the area by non-motorized and/or non-OHV users. BLM must collect and analyze more thorough and accurate data on the costs of off-road motorized recreation in order to make an accurate assessment of the impacts of the alternatives. BLM must recognize that increasing off-road 

motorized recreation implies the need for increased restrictions, and increased 

law enforcement, not opening more land for open cross-country travel. 

TsivS

Socioeconomics SUWA The use of IMPLAN is insufficient to predict future economic impacts from the 

management of the Kanab Field Office lands. While the IMPLAN model can be useful as a tool to develop static analyses of the regional economy, the agency 

and local communities must be aware of the shortcomings and poor track record of the model as a predictive tool. IMPLAN models do not consider the impacts of 

many important variables that affect regional growth in many rural communities, especially in the West. Attributes such as natural amenities, high quality hunting, fishing and recreational opportunities, open space, scenic beauty, clean air and clean water, a sense of community, and overall high quality of life are not measured or accounted for in IMPLAN models, however these amenities are associated with attracting new migrants as well as retaining long-time residents. Many residents of Western communities (both longtime and new) earn retirement and investment income, and while it is technically possible, most IMPLAN models completely fail to consider the important economic role of retirement and 

investment income. 

I

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Socioeconomics SUWA Recommendations: The BLM must collect and analyze credible data on all 

sectors of the economy, especially investment and retirement income and recreation (including nonmotorized recreation). These sectors, along with the various sectors which depend indirectly on the protection of public lands from motorized recreation and development must then be included in a quantitative assessment of the impacts of land management decisions. 

TtfauTpama

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Category Name Commentor Comment 

Tawa

Socioeconomics Utah Archeological 

Research Institute 

Additionally, we see no evidence of a cost analysis associated with each alternative. If you or we are to choose an alternative, is not the cost an important factor? We would like to see an estimate of the costs of implementing each 

alternative 

Tdrcps1F1. peaeipe

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mTicist

Soil Resources ECOS Consulting The destruction of biological soil crusts is a "long-term" impact. The loss of 

biological soil crusts has long-term indirect and cumulative effects on soil stability and moisture, on the amount of vegetation, vegetation type, vegetation health 

and vigor, and is directly responsible for the loss of many important ecological functions within the ecosystem. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

RidaDnesetpeRcdhdadcr

Soil Resources ECOS Consulting The BLM Kanab Field Office must classify biological soil crusts as a "sensitive 

and fragile soil." BSCs are classified as such in the Moab Field Office. 

FsefRDdcTD

Soil Resources ECOS Consulting Given the scientific literature on the ecological importance of BSC's, how can this 

component not be part of the evaluation? Without this component included, the results of these evaluations cannot be seriously considered as an effective indication of the health of the land. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

aDnesetpeRcdhdadcr

Soil Resources ECOS Consulting It is recommended that the Kanab Field Office classify BSC's as sensitive soils 

and limit surface disturbance wherever they are present, and wherever they have historically occurred. 

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Soil Resources ECOS Consulting Because of the widespread occurrence of biological soil crusts in the Decision 

Area, it is essential that the BLM include the protection of these fragile and 

sensitive biological soil crusts as a fundamental part oftheir land management, and as a top priority in their best management practices (BMP's). 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

esetpeRcdhdadcr

Soil Resources ECOS Consulting Page 4-24, 2nd Paragraph: This statement is wrong. The short-term use of soil 

resources will definitely affect long-term productivity of the biological soil crusts and the vegetation that depends on it for water retention and vital minerals. Reclaiming disturbed areas, as outlined in the BMP's in Appendix A, will not be nearly as effective in this dry desert environment. Especially on soils that contain 

biological soil crusts, which is about 89% of the Decision Area. 

Aa

Soil Resources ECOS Consulting In particular, the BLM must update, develop, and maintain strict protocols or Best 

Management Practices (BMP's) that are designed to minimize damage to biological soil crusts, vegetation, water, and riparian resources during extractive industry activities. 

A

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Soil Resources ECOS Consulting Boilogical soil crusts are a significant part of a majority of vegetation types in the 

Kanab Decision Area. Desert Scrub, Sagebrush Steppe, and Pinyon-Juniper Woodland encompass approximately 90% of the Kanab Decision Area. This is why the protection, restoration, and, enhancement of the biological soil crust is so important. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

tpeRcdhdadcr

Soil Resources U.S. Fish and Wildlife 

Service, Utah Field Office 

Page 4-20, Section 4.2.2: In the Recreation (outside OHV use section), 1st sentence: replace "could result in soil compaction" with "would result in soil compaction." Simlarly, in the second sentence, replace "could" with "would." Check the entire document for similar terminology changes. 

Twa

Soil Resources U.S. Fish and Wildlife 

Service, Utah Field Office 

Page 4-20, Section 4.2.2: The RMP states: "Motorized activities in SRMAs could increase use on routes, which could indirectly protect nearby soils..." However, Alternative B indicates that the Dunes RMZ would be open use for OHV, rather 

than restricted to routes. Please provide more support of the reasoning behind this statement. 

T

Soil Resources U.S. Geological 

Survey 

Impacts on Soil Resources, pages 4-16 - 4-24 There are numerous references to soils. It would benefit the public if the final RMP/EIS identified the soils datasets that were used in the assessment. 

T

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Soil Resources Western Watersheds 

Project, Inc. 

The definition of sensitive or fragile soils must be expanded to include those soils with moderately high to high soil erosion potential from wind or water, soils with potential for biological crusts, soils on steeper slopes and soils where ground cover is below potential. 

F

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Special Status Species 

Laura Welp Welsh's milkweed The RMP does not address the best available data showing a 

potential conflict between motorized damage to plants and reduction in reproductive output. 

Tm

B

Special Status Species 

Laura Welp To sum up, this policy would have a negative effect on rare plant surveys and 

appears to be politically motivated. It should be removed from the draft. 

B

bs

Special Status Merlin Esplin Page 2-13 Welsh's Milkweed: BLM desires to close motorized use in and through T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Species islands of vegetation in designated critical habitat for Welsh's milkweed. The 

Coral Pink Sand Dunes State Park already provides education and administration in this regard, and a sizable portion of the dunes is already off limits to motorized activity. Is the 790 acres proposed for closure in addition to the area already closed? If so, current data and ongoing research does not support this action. Reports clearly show that Welsh's milkweed needs disturbance for survival. Closing the dunes creates two concerns; first, the dunes become vegetated more quickly - thus crowding out the milkweed faster, and second, it displaces OHV's to other areas where greater damage may occur to vegetation, soil, water, wildlife, livestock, and recreation. Any decision to alter the current management of the dunes may be met by unintended consequences. 

CVaaa

Special Status Species 

SUWA The Kanab draft RMP fails to address these threats adequately, therefore 

violating Endangered Species Act. requirements that federal agencies must avoid jeopardizing and promote conservation of listed species. 

Tmntcbn

Special Status Species 

SUWA The draft RMP fails to provide adequate protection for suitable Utah prairie dog 

habitat (both unoccupied and occupied) by failing to curtail land uses deleterious to prairie dogs and their habitat. The primary land uses at issue are livestock grazing, oil and gas drilling and exploration, and OHV use. 

TcFptmmscU"ifp

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-10, Section 2.2.1, 3rd bullet: "...in managing listed species and their 

habitat." Add "sensitive species" or "special status species" to this sentence. 

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-10, Section 2.2.1: Management Actions, Special Status Species Conservation and Habitat Enhancement, last line: Rewrite to read, "Apply lease notices and conservation measures to activities occurring in special status species habitat." 

T

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field 

Page 2-10 through 2-14 and Appendix M, Section 2.2.1, Special Status Species: 

Conservation measures included for the threatened, endangered, and candidate 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Office species should be the same as those included in the June 19, 2007 Biological 

Opinion for the Existing Utah BLM Resource Management Plans. It appears that Appendix M includes the correct measures. However, the wording on pp. 2-10 through 2-14 is sometimes inconsistent with Appendix M, and not as complete. This makes the document confusing upon initial reading. Recommend including either all of Appendix M up front in Chapter 2, or referring to Appendix M without attempting to include partial measures in Chapter 2. 

C

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-10 and 3-30, Section 2.2.1, Bald Eagles: The bald eagle has been delisted. However, eagles are still provided protection under the MBTA and Bald 

and Golden Eagle Act. We recommend moving the eagle discussion to the Fish and Wildlife or Migratory Bird section of the document. To ensure continued species conservation, we also recommend a commitment to the conservation measures agreed to in the aforementioned June 2007 biological opinion. 

T

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-11, Section 2.2.1, Bald Eagles: The document states that monitoring will 

occur in order to document the impacts to bald eagles in their breeding or wintering areas. The RMP should also clearly commit to avoiding or minimizing impacts that monitoring detects. 

Md

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-11, Section 2.2.1, Bald Eagles: The "Utah Field Office Guidelines for Raptor Protection from Human and Land Use Disturbances" recommends a 1.0 mile buffer around bald eagle nests between January 1 and August 31. Although a 0.5 mile buffer may be appropriate for temporary activities at other times of the 

year, the 1.0 mile buffer should be used for permanent surface disturbances and during the bald eagle nesting season. 

Tb

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Pge 2-11, Section 2.2.1, Utah Prairie Dog: The 1st sentence should require 

species occupancy and distribution information that is complete, available, and current. This is how it is stated in Appendix M, but needs to be written correctly in the document as well. All of Appendix M measures needed to be completely integrated into the document. 

Tb

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-13, Section 2.2.1: A comprehensive and ongoing monitoring program is a critical element in determining the status and conservation needs for the Siler pincushion cactus. We recommend establishing monitoring plots to assist with successful species management. 

Io

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-13. Section 2.2.1: In an effort to conserve and recover Welsh's milkweed, we recommend establishment of a designated conservation area for Welsh's milkweed on BLM lands. Consideration should be given to managing portions of the Coral Pink Sand Dunes as a SRMA and other portions as an ACEC with applicable recreational use closures to protect the species habitat from motorized use. Management should consider the shifting nature of the sand dunes and ensure that the designation of a protected area is large enough or adaptive to changing habitat conditions. 

AOmuif

tw

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-13, Section 2.2.1: Monitoring for the past 10 years has shown that populations of the CPSD tiger beetle are in decline. Drought has probably been a primary factor in this decline. The RMP should clearly state that BLM will cooperate and facilitate recommendations from the CPSD tiger beetle 

Conservation Agreement technical team for ongoing monitoring, research, and conservation measures for this species. The 370 acre conservation area should continue to be monitored; adaptive management strategies may be appropriate given the shifting nature of the sand dunes. 

TR

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-15, Section 2.2.1, 1st paragraph: We recommend including the USFWS Raptor Guidelines as a Management Action in addition to the BLM BMPs. 

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s

McS

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-15, Section 2.2.1, Wildland Fire Ecology: There should be an objective that includes protection and enhancement of threatened and endangered species and their habitats. 

P

aFMrc2

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-17, Table 2-1: Sagebrush: Areas with more than 30% sagebrush cover are described as "dense sagebrush" and are to be treated with fire and/or mechanical or chemical methods to reduce the canopy cover. Consideration should be given to species that desire greater densities of sagebrush cover and to maintaining a diversity of habitats. As such, some areas should have more than 30% sagebrush cover. 

T2Mrsd

Special Status U.S. Fish and Wildlife Page 2-44, Section 2.4.1: The Sand Hills located North of Kanab and East of T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Species Service, Utah Field 

Office 

highway 89 is designated as critical habitat for Welsh's milkweed. Restrictive protections, including OHV management, should be considered for this area, in order to prevent adverse modification of the critical habitat. It is difficult to 

determine from the RMP if such protections are established in Alternative B. 

FWrAi

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-44, Section 2.4.1, Special Status Species (1st row): "...a case-by-case basis..." We recommend evaluating surface disturbing on a landscape level (not only case-by-case project activities) to ensure the development and implementation of successful, long-term conservation and recovery strategies for special status species. 

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-44, Section 2.4.1, Special Status Species Conservation and Habitat Enhancement (3rd row): For listed species, compensation of 1:1 for lost habitat is likely to be insufficient in most cases. Compensation would usually be greater than 1:1 due in part to the fact that the result would be a net habitat loss to the 

species even with mitigation. 

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-45, Section 2.4.1, Special Status Species Conservation and Habitat Enhancement (third row): For bald eagle nests, we recommend the seasonal 1.0 mile buffer be implemented in accordance with the U.S. Fish and Wildlife Service 

(Service) Raptor Guidelines and the June 2007 Biological Opinion for the Existing Utah BLM Resource Management Plans. The seasonal buffers for the other raptor species are appropriate for temporary surface disturbing activities. Permanent disturbances, particularly those that ensue human activities, should be precluded year-round within the spatial buffers. 

T2

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-47, Section 2.4.1, Last Row (Federally Listed and Candidate Plants): 

Please define the term "moderate constraints." BLM should recognize the 

potential that closed or NSO stipulations may be appropriate or necessary in special status plant species habitats. Alternative B should alow for major constraints (NSO) in special status plant habitat. 

Aes

H

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-49, Section 2.4.1, Special Status Species and Fish and Wildlife Management Action sections: See Attachment 1 to this spreadsheet (FWS Species-Specific Recommendations for Use in BLM RMP Plannin Efforts, May 2003). Although these were prepared for the Price, Richfield, and Vernal Field Office areas, many of the recommendations are applicable to the Kanab Field Office area. We recommend incorporating applicable guidelines (particularly those for "All Species" into Alternative B, as the Preferred Alternative. Incorporation of these measures will also help to strengthen the management 

direction for migratory birds. 

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-100, Section 2.4.1: Please check the acreage for Welsh's milkweed, 

Coral Pink Sand Dunes critical habitat throughout the document. Number stated on p. 2-13 is 790 acres. All of Coral Pink Sand Dunes is critical habitat for 

MCt

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Welsh's milkweed. OHV use in sand dunes open to cross country use is indicated as 1,100 acres on page 2-111. A rough, but not accurate, estimate of Coral Pink Sand Dunes acreage outside of the state park is 1,280 acres. In addition, critical 

habitat for Welsh's milkweed includes the acreage encompassing the Sand Hills areas. Jointly both areas are indicated to contain 4,000 acres on page 3-34. Also, please indicated critical habitat acreage involved in Moquith Mountain SRMA, in particular Dunes RMZ p. 2-71. 

Wc

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-32, Section 3.2.6: Translocation of Utah prairie dogs should be listed as a 

specific management activity. The translocation program is mentioned on p. 3-33, 

but it's authorization under the RMP is not clearly stated. Additionally, "control of plague vectors" needs to be included as an authorized UPD activity in this plan. These two management activities for UPDs (translocation and control of plague vectors) should be documented in all sections related to the species. 

Top

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-33, Section 3.2.6: The Coral Pink Sand Dunes tiger beetle (Cicindela albissima) has been determined to be a full species, not a subspecies of the tiger beetle Cicindela limbata (Morgan Knisley and Vogler 2000). 

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-34, Section 3.2.6: The RMP states that the 2000 Vermilion Management Framework Plan amendment addresses management and protection of the Welsh's milkweed. Pleae clarify what conservation measures are included in this current RMP revision, and retained in the preferred alternative. 

ARa

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-34, Section 3.2.6: Please update the document to include the most current available information. The area described in 2000 by Hreha and Meyer is no longer considered the most viable of all known populations. This population comprised less than 10 individuals in 2007, a loss of more than 90% of previously known population levels. A monitoring program should be renewed at this past thriving population to determine if seedling recruitment still occurs, and if measures should be implemented to recover the population. 

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-34, Section 3.2.6: Please update the document with the most recent best available information. Monitoring in 2003 is not the most recent monitoring, nor is a comparison of stems between 2002 and 2003 (i.e., 2 years), a good indication of trend. Data collected by BLM should also include statistical verification for long-term trends. 

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-34, Section 3.2.6: Please provide a brief summary regarding Welsh's milkweed populations in Arizona. 

Td

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-39, Section 3.2.6: Recent evidence indicates that the southern 

leatherside chub (Lepidomeda aliciae), the species in the Kanab FO area, is one of two taxa formerly known as leatherside chub (Snyderichthys copei) and qualifies as a unique species (Johnson and Jordan 2000, Dowling et al. 2002, Belk et al. 2005, Johnson et al. 2004). 

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Category Name Commentor Comment 

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-39, Section 3.2.6:Other populations of Bonneville cutthroat trout exist 

within the KFO area. Refer to the Conservation Agreement for additional populations of introduced, reintroduced and core populations in the Southern Bonneville GMU: Upper Sevier, East Fork Sevier, and Upper Virgin HUC. 

UC

Tn

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-84, Section 3.3.4: The document indicates that OHV use is resulting in impacts to resources at the Sand Hills and Coral Pink Sand Dunes areas. We therfore recommend that the RMP allow for the development and implementation of adaptive management strategies, including potential OHV use restrictions, in 

sensitive wildlife and plant habitats. Open use on all parts of these areas seems contra-indicated, as resources are already at risk. 

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-3, Table 4-2: The table does not include the Migratory Bird Treaty Act or EO 13186; these should be added to the table. 

M3

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-49 through 4-58, Section 4.2.5: Effects throughout the section are described generally, without relating to individual species. The exception appears to be the consistent reference and discussion for the Greater sage-grouse. It seems inconsistent that other special status species are not discussed more fully in the same manner that the Greater sage-grouse is discussed. Please provide 

full descriptions of effects to all special status species; use of species 

subheadings would assist readibility of the document. 

A 

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ctae1wsa

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-49, Section 4.2.5: This section should reference tables 3-12 (page 3-30), 3-13 (page 3-34, and 3-14 [migratory birds], which identify "species needing special conservation actions" (page 3-48)). Referencing these tables and the species within would provide readers with a consistent point of reference. 

TocsCdmT

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-50, Section 4.2.5, Impacts common to all Alternatives: The entire section is awkward -- it is difficult to discern if all activities/species have been evaluated for each alternative. Habitat alteration, fragmentation and/or loss is discussed 

relative to fire, ROW developments, and cultural resources, but fails to mention any other potential activity affecting habitat. For example, 48% of all acres would be open to oil and gas development under the preferred alternative, Therefore, it would be appropriate to list oil and gas development as an activity that would cause habitat loss, fragmentation and/or alteration. We recommend reorganizing by using subheadings for activities. 

Trrareipu

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Category Name Commentor Comment 

wridhro

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-51, Section 4.2.5: 2nd paragraph states, "...special status wildlife could seek alternative habitats." This section should also clarify that "alternative habitats" may be unsuitable or already occupied. 

T

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-56, Section 4.2.5, Alternative A: Only OHV use and Veg treatments are mentioned as activities that can cause displacement. There are other activities 

that should be included in this section -- e.g., grazing, recreation, oil and gas. 

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-57, Section 4.2.5, Alternative B, Habitat Alteration, Fragmentation, and/or Loss: This section appears to only evaluate impacts from OHV, oil & gas, forest/woodland products, and locatable minerals. Impacts to special status species and their habitats should be clearly described for all activities occurring on BLM lands. 

Tdi(d

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-57, Section 4.2.5, Alternative B, Habitat Alteration, Fragmentation, and/or Loss: The first paragraph states, "Managing OHV use...as limited to 1,387 miles...would minimize surface disturbances to special status species." We 

generally agree that less off-road use would reduce impacts to habitats. However, the document does not thoroughly evaluate 1) if/what special status species/habitats occur in the areas that will be open to OHV use, and 2) if/what effects will occur to those species/habitats. Please provide a thorough evaluation 

for each Alternative in Ch. 4. 

Aa

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-58, Section 4.2.5, Alternative B, Habitat Alteration, Fragmentation, and/or Loss: The 4th paragraph states, "...stipulations on disturbance in special status species habitats would decrease the potetnial for the impacts..." While this may 

be true, the section should also clearly describe the types of impacts that will still 

occur, e.g. habitat fragmentation. 

T55

it

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-59, Section 4.2.5, Alternative B, Displacement: "Impacts from dispersed recreation activitiy, mineral exploration and development, and ROW development would be the same as described in alternative A..." The Alternative A, Displacement, section does not include evaluations of these activities. See previous comment to 4.2.5 -- using activity subheadings would help clarify these sections. 

Tsas

Special Status U.S. Fish and Wildlife Page 4-70, Section 4.2.6: There is virtually no discussion on the impacts to T

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Category Name Commentor Comment 

Species Service, Utah Field 

Office 

migratory birds from management actions. Activities requiring vegetation removal in particular warrant some discussion. BMPs to reduce impacts to migratory birds, including seasonal buffers and habitat mitigation, should be developed and included in the RMP (see ATTACHMENT 1 recommendations). These may 

include commitments to develop and implement a standardized rigorous program to collect data on species identified in the BHCAs; and work with UDWR and others to develop a comprehensive monitoring program. Suveys should be completed one breeding season prior to land disturbing activities. Conservation measures should minimize habitat loss/fragmentation, prevent loss of eggs and 

nestlings, reduce indirect effects (e.g., introduction of noxious weeds), and avoid surface disturbing activities during the passerine breeding season (May 15 - July 15). 

F

t

rF

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-72, Section 4.2.6, Displacement (third paragraph): Oil on feathers of 

incubating birds will also kill developing embryos when adults are incubating eggs...it's not just ingestion; pits should be netted and propertly maintained to 

exclude migratory birds. 

T

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page AB-4, Appendix B, Unoccupied Nests (last paragraph): The document 

states that "empirical evidence would suggest that the 3-year non-use standard has been effective in conserving raptor species." We recommend the Kanab FO retain the seven-year non-use standard for nest protection as stated in the Raptor Guidelines. This seven year standard may be adjusted on a site-specific basis, depending on raptor species and other site-specific factors. The Utah Field Office has produced a white paper, “Elapsed Time between Raptor Nest Uses” (Megown and Romin, 2006) that reviews recent literature and expert knowledge to assess raptor nest reuse frequency. The paper finds that of the 19 raptor species examined regarding nest occupancy, half (10) of them have data that show the elapsed time between nest uses can be 7 or more years. Golden eagles, bald eagles, and peregrine falcons in particular can have especially long periods (i.e. 10-20 years) of nest non-use followed by successful nesting. 

Tusay

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Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page AB-8, Appendix B: The purpose of monitoring active raptor nests is more than simply documenting the impacts of an activity on the behavior and survival of raptors. The purpose of monitoring is to avoid impacts to raptors, particularly "take" of raptors (e.g., survival) which is an unlawful activity under the Migratory 

Bird Treaty Act. If monitoring detects an impact on bird behavior, especially one that might result in "take" the activity should be suspended or modified so that the 

impacts are removed. 

Tip

atbo

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page AL-4, Appendix L: "The U.S. Fish and Wildlife Service has completed a biological opinion on the Proposed Action..." This sentence is confusing because formal section 7 consultation has not been initiated for this RMP. In addtion, this 

entire section seems contradictory with Appendix M. Species-specific conservation measures were developed during section 7 consultation on the existing RMPs (not the RMP revisions). In an effort to streamline section 7 

A

tFFiw

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Category Name Commentor Comment 

consultation on the RMP revisions, we have recommended that BLM incorporate the same conservation measures into the RMP revisions. The Kanab RMP appears to include these conservation measures in Appendix M; therefore Appendix L should be deleted or updated to reflect the correct conservation measures. 

o7 mc

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page AM-1, Appendix M: Conservation measures should be developed and incorporated for federally listed plant species, including the Welsh's milkweed and Siler pincushion cactus. The Service is available to work with the BLM to develop these conservation measures. 

Ld

TR

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page AM-12, Appendix ML: Lease Notices should be developed and included for KFO Federally-listed plant species, such as Welsh's milkweed and Siler pincushion cactus. Stipulations for plants have been developed for plant species at the Vernal BLM Field Office (for example, a 100 foot buffer is now required 

between surface pipelines and plant locations, rather than 10 foot indicated in the 

past). Attached are the two updated plant lease notices now used by Vernal Field 

Office (Attachment 2 and 3). The Service is available to work with BLM to develop these lease notices. 

TtFl

Ai

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Page AM-13, Appendix M: Include the Range-Wide Conservation Agreement and Strategy for Bonneville Cutthroat Trout (Oncorhynchus clarki utah) (2004). 

TCi

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-6: Restrictions on visually obtrusive developments VRM Class I and II is defined as limiting development and protecting special status species (page 4-61). Critical habitat for Welsh's milk-weed at the Sand Hills in Alternative B is VRM Class III. In Alternative C, a VRM Class II is indicated. We recommend 

implementing a Class I or II designation for all alternatives at Sand Hills, to ensure long-term conservation and recovery of Welsh's milk-weed. 

AtTRma t

r

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-9: It is unclear if the Kanab Community, OHV RMZ encompasses Kanab Creek and, if so, what protections would be established for the stream and riparian area. Nearby upland landscape impacts also could affect these habitats. This reach of Kanab Creek is a historic site for the Kanab ambersnail and provides riparian habitat important for many species. We recommend appropriate buffers be established to protect the stream and riparian corridor from surfacedisturbing activities (including OHV use). 

TdKssd

w

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-13: The Kanab Community, OHV RMZ is located near Sand Hills, which provides habitat for the listed Welsh's milkweed. The document should evaluate the potential for the OHV RMZ open area to influence OHV use in the Sand Hills. We further recommend establishing OHV impact monitoring at Sand HIlls. 

A

2ctcl

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

p

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-13; page 4-57 thru 4-61: Alternative B includes open OHV use in Coral Pink Sand Dunes and limited trail use in the Sand Hills. We recommend BLM evaluate areas that support dense concentrations of Siler pincushion cactus and Welsh's milkweed for effects from OHV use, and consider OHV restrictions or removal in these areas if warranted. The RMP should specifically commit to 

ongoing monitoring and evaluation of OHV impacts to these species. We further recommend designating a conservation area at Coral Pink Sand Dunes that is closed to off-road vehicle use, in accordance with the Welsh's milweed Recovery Plan. 

Icpmmcca

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Maps 2-17, 2-20, 2-24, 2-30: We recommend that Welsh's milkweed critical habitat areas (the Coral Pink Sand Dunes and Sand Hill) and areas occupied by Siler pincushion cactus be designated as no surface occupancy. We recommend these areas be closed to mineral material disposals and have no new rights-ofway. 

W

iapA

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-34: The mineral leasing status is unclear for the areas that support Siler pincushion cactus and Welsh's milk-weed. We recommend that these areas be 

designated either closed or NSO to provide protection for these species. 

MF

m

Special Status Species 

U.S. Fish and Wildlife Service, Utah Field Office 

Map 3-4: The map showing "Areas with fragile soils or relict vegetation" should 

include Welsh's milkweed and Siler pincushion cactus habitats. Please revise accordingly. 

Ti

Special Status Species 

Walter Fertig Welsh's milkweed: Adoption of the Welsh's milkweed ACEC would help ensure 

that this Threatened species does not decline further. Unfortunately, its habitat at 

Coral Pink sand dunes overlaps with much of the area being proposed for crosscountry ATV recreation. The closure of 790 acres to ATV use at the extreme north end ofthe dunes is a good start (though this area doesn't cover the largest milkweed populations), but enforcement will remain a significant issue. 

TddTmct

Special Status Species 

Walter Fertig BLM monitoring data and independent research that I've been associated with 

indicate that the milkweed population is reasonably stable at Coral Pink (with weather-related fluctuations in numbers of stems). Data from the late Brent Palmer and my own team, however, show that flowering and fruit production are being depressed in areas where mature stems are run over. Vehicle damage tends to promote the production of new, vegetative stems (without flowers) through compensatory growth. Unfortunately, damage to flowering stems from vehicles results in the loss of fresh seeds to contribute to the seed bank and spread to new areas. We found flowering and seeding rates to be double inside the Coral Pink sand dunes tiger beetle exclosure compared to areas open to ATV travel in Coral Pink state park and BLM lands. This finding presents a management opportunity for the BLM - use ofa set of 5-10 short-term removable exclosures located over known patches of milkweed. These exclosures would 

Tacbo

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

remain in place for 2-5 years, giving the plants inside the opportunity to flower and set seed during that time (more than one year would be best to ensure that seed production isn't lost due to drought). After the allotted time, the exclosures would be removed and placed over different milkweed patches. At any given time the same amount of area would be in an exclosure (and the area outside open to recreation use), but the areas protected by exclosure would shift over time to increase the output of seed and allow new patches to develop. Exclosures could be as small as 20 x 20 feet and would need to be adequately marked to reduce impacts from collision. 

Transportation Barry Clarkson 

Clarkson Draper & Beckstrom, LLC 

The RMP, as drafted, does not address in any way the issue of access for private 

property owners across the public lands. In fact, Option C of the RMP leaves my client as well as others completely without access to their property. 

Fp

Transportation Betsy Shade ORVs are given far too much in BLM's Alternative B - 1,387 miles of routes 

(including 101 miles in proposed wilderness areas) and 1,100 acres of "free play" in the Coral Pink Sand Dunes, in Moquith Mountain Wilderness Study Area. There should be no "free play" area in a WSA, and all ORV routes in proposed wilderness areas should be closed and rehabilitated. Lands with wilderness character are too scarce to allow any more damage by ORVs. 

A

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OtCiRal

Transportation Bob Wallen During the comment period a Citizens Proposal to designate appropriate dry 

wash ways as Designated Off Highway Vehicle routes was presented to your 

planning team. Several conversations on this proposal between your office, Kane County officials as cooperative agency partners and myself indicated the BLM would consider this as a viable proposal for OHV management considerations. I could not find any reference that this Citizens Proposal was or would be considered in the recently released Draft RMP. This is cause for our concern that 

this request and information was omitted from your RMP planning considerations. Further concern is that by omitting consideration of this citizen proposal for dry wash routes OHV/ATV recreational opportunities have been substantially and 

negatively impacted. 

TR

Transportation Bob Wallen The requested trial(s) are located in an area currently designated as "open" and 

may have been "user created" within that designation. As a "user created route" this route was not considered in the draft planning. User created routes should 

still be considered if not created illegally or causing degradation or impairment. I believe these short trails should be considered. 

Ti

Transportation Debra Csenge Restricting the range of motorized vehicles ranks high in importance because of A

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the impact inherent in motorized traffic on the environment. It contributes noise, pollution, and physical damage to the eco-system which are considerably greater than that of non-motorized recreation. Secondly, enforcement of restrictions is a difficult enough issue out in these remote and vast lands, given the limited number of enforcers available. Certainly, some people justifiably turn to motorization, and they deserve some routes open to them. But if we create a spiderweb of designated motorized routes, resources will become impaired. The Draft Plan shows that a great deal of study has already been made, of biodiversity, arch sites, geology and habitat. These things deserve protection. Hikers and horseback riders are not the only ones disturbed by too much motorization. All the aforementioned resources are as well. 

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Transportation George and Frances 

Alderson 

Off-road Vehicles: The approval of 1,387 miles of ORV routes in Alternative B is excessive and would impose too many impacts on the wilderness, wildlife habitat, and public use values. Too many ORV routes are too close together, forming a 

dense network. We believe this network exceeds BLM's ability to enforce regulations keeping vehicles on the designated routes. We urge that ORVs be restricted to a smaller network of more widely spaced routes. In addition: • ORVs should be barred from all proposed wilderness areas, a total of 132,000 acres, including all the areas shown in Map 3-15 in either pink or green. • No ORV routes should be in riparian zones or dry washes, because these are essential 

wildlife habitat. 

Actdsp

Transportation Jack Johnston 

U4WDA 

I saw no provision for establishing new roads or trails. A

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Transportation Jim & Bonnie Vann It is my suggestion and proposal that the BLM place a sign at this location 

advising motorized users that the easement road continuing to the west is; 

"Closed - Private Utility Easement" as traveling further along it will only result in a dead end with no outlet without trespass across private property. Leaving this road open or unsigned will invite either trespass onto private property along the 

south side, or entrance into a road less closed BLM area on the north. 

S

Transportation Margaret Stone Moquith Sand Dunes The BLM is not only not proposing to protect one of these 

areas - Moquith San Dunes - but in their preferred plan is proposing to place it in grave peril. One of the motorized focus areas would extend northeast from Coral 

Pink Sand Dunes S.P. I have been in the park and the sand dune area NE of the S.P. both on my own and on a field trip with the Utah Native Plan Society. Signs that indicated the limit for motorized traffic were routinely ignored. In the Sand Springs area tracks were crossing areas of vegetation on the sand dunes and destroying the plants growing there. The Moquith Sand Dunes should be given ACEC status and they need to be given real physical protection since signs in sand dune areas are not successful. 

Triaadd1itc

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Transportation Mark Sterkel Often these ATV tracks result in torn up microbiotic soil, fragile plants crushed , 

streams churned & soiled, and emerging riparian flora squashed. Hikers have their impact, & inconsiderate bad apples, but boots leave seperate, noncontiguous impact prints, while ATV's leave a continuous track that can channel run off and lead to accelerated erosion much quicker. 

I

R

Transportation Mark Sterkel To protect the resource, the DRMP should include some provision to stop the 

lawless renegade riders who cause much of the impact. This group is confrontational, rude, threatening, inconsiderate, irresponsible, & dangerous. 

While on foot in the Canaan Mtn WSA, ATV's have sped by me, stopped & spun 'donughts' around me, increased the recklessness of their riding in my vicinity, and attempted to run me over. 

L

Transportation Mark Sterkel Shared use areas have been considered, but with hikers vs. OHV's, it is a futile 

concept. Quiet-sports people don't want to be near noisy lazy-sports riders because of the noise, fumes, damaged & torn-up terrain, & belligerent attitudes they create. Therefore, hikers won't use a 'shared' area, and it becomes a defacto OHN-only area. These machines simply need their own dedicated 

(preferably trash already by them) area in which to wreak havoc. 

Mprm

Transportation Mark Sterkel In the DRMP route designation maps, under all alternatives, there are shown rt's 

that are redundant, unnecessary, and parallel. BLM should consider only one route in each open to access area's, closing , obliterating, reclaiming & enforcing 

the unneeded routes, in order to "manage" the resource for continuity. 

A

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Transportation Norris Brown I, Norris Brown, own the Sheep Springs Grazing allotment at the head of Dairy 

Canyon out of Johnson Canyon. By limiting access you will severely impact the use and management of this allotment. 

T

Transportation Randy & Cynthia 

Norton 

The increasing demand for OHV recreation opportunities on public lands and National forests is extensively documented. Therefore, we believe it is incumbent upon the Kanab Field Office Draft Resource Management planning team to 

maximize recreation opportunities. It must be maintained that OHV use in roaded natural and semi-primitive motorized settings for recreation use, be acceptable and compatible with established resource management objectives. With the idea 

that OHV trails can be constructed and maintained with demand increases. 

TyilpbHaa

da 

Transportation Rebecca Mann Off-Highway Vehicle (OHV) use on BLM land. Areas with unrestricted overland 

travel by OHVs should be extremely limited or closed because OHV use destroys plants and biological soil crust, disturbs wildlife, threatens archeological and paleontological resources, and disturbs other visitors' experiences. In addition, 

existing roads and routes, which may be designated as established roads in the 

Actds

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Category Name Commentor Comment 

future, should be carefully assessed. Roads and routes should be closed if they a) cross through high value natural areas, such as riparian zones, wildlife breeding habitat, or rare plant territory b) are redundant - where one road could serve the same purpose as two, or c) have significantly low traffic and no particular value to travelers. The limitation of OHV roads will lessen environmental damage and make backcountry wilderness experiences much more pleasant for those wishing to escape the noise and pollution associated with motorized vehicles. 

p

Transportation Richard Csenge In the Kanab RMP Draft, Alternative B places greater restrictions than does 

current policy in key areas, however it does not go far enough. For example, the proposed number of miles of designated OHV routes are utterly unenforceable, 

given budget trends for hiring LE officers and Rangers within the BLM. Without constant enforcement and stiff penalties for infraction, OHV users will continue 

going "offtrail", spreading the kinds of damage already underway throughout the decision area. (see enclosure #2) 

BDrwu

Transportation Richard Csenge An intelligent policy would be to designate only the number of routes and mileage 

that can be reasonably expected to be patrolled. Later, ifbudgets increase, demand is present, and the policy of restriction to designated routes has been faithfully observed by the public, more could be added. Due to the inherent nature and impacts of motorized vehicle use both on or off highway, licensing, restrictions, and enforcement are essential tools to safeguard the public interest, in this case, shared ownership interests in public lands. (see enclosure #3) 

BDrwu

Transportation Richard Csenge Such values as visual, archaeological, vegetative, wildlife habitat, and water 

resources will all be adversely impacted if either alternative A, B, or D as proposed, is selected in the final decision for at least two reasons. One, all of 

these alternatives leave open too much of the decision area to damage by OHVs, through motorized recreation designations either as "open" or as "designated 

routes only" . Secondly, these alternatives also provide for mineral exploration and extraction of coal, oil and gas, for the most part at the least stringent standard throughout the southern region ofthe Kanab District, which virtually guarantees future damage to biological, archaeological, visual, water, and paleo resources that have been identified elsewhere within the Draft RMP, to be of high caliber. 

TyilpbHaada D

Transportation Ross Tocher BLM's preferred "Alternative B" looks backward to the era of ORVs, when BLM 

should be looking forward. It is ill-advised and damaging to the resource to suggest an ORV route network of 1,387 miles in Alternative B - many routes only a mile apart, many in areas of high value for wilderness and wildlife habitat. Alternative B would produce a route density of 1.6 miles of DRV routes for every square mile of public lands. That should be corrected in the final plan by severely reducing the ORV route network. 

Actdsp

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Category Name Commentor Comment 

Transportation Ross Tocher At the very least, BLM should exclude DRVs from wilderness study areas (WSA) 

and "wilderness characteristics" areas (WCA), because these represent a rare 

resource that is vital to southern Utah's tourist economy. I believe the following 

areas should have a high priority for closure to DRVs: • Parunuweap Canyon and its tributary canyons, a complex that connects with Zion National Park and attracts many visitors for its wild character. The areas shaded pink in Map 3-15 should receive the same protection, as these are among the most easily 

accessible parts of Parunuweap, bordering on main tourism routes US Highway 

89 and State Route 9. • Moquith Mountain WSA and WCA, a diverse area including pine forests and part ofthe Coral Pink Sand Dunes. An "open" area of 1,100 acres for ORV free play within the WSA (in Alternative B) would be inappropriate. The Moquith Mountain loop ORV route should be closed. • Areas close to Kanab city need more protection for their wild character, because these 

are the most accessible to visitors staying in Kanab, via US 89. Among them are Vermilion Cliffs, including Hog Canyon - an area BLM has unwisely excluded from the WCA; Upper Kanab Creek, including Elkheart Cliffs, with riparian habitat and perennial streams; and canyons in Moquith Mountain WCA on the west side ofUS 89. These areas are an asset to the tourist economy of Kanab, but ORV traffic could turm them into a liability. 

Tw

oOcmcR

Transportation Sedona Thomason I feel that the roads should not be closed because what about emergencies? I 

guess what I really mean is that if you have the roads closed are you going to let emergency vehicles through, example if there is a fire are you going to let fire trucks through or let the forest burn down? I feel very strongly on the subject of roads being closed down or even blocked, most people will break down gates if there is a serious emergency. So the Route Designations Map 2 - 19 Alternative D is the best choice where only a few roads down by Kanab Creek is closed. 

Ta

Transportation Thomas Forsythe The only actual road in this area comes off of Zion Rd and leads to a Kane 

County Water Conservancy water tank. None of the other trails are even claimed by Kane County. This even includes the former right of way for the highway - a road the county abandoned when Johnson Canyon was extended south to join Hwy 89. Notwithstanding that this former road now crosses private property, it remains on the BLM map as open to motorized use. The most egregious example of this affront to private property rights is the spur that leads across a pristine piece of high desert land near the water tower. This route crosses private property and dead ends at the boundary between the private land and public land. 

RiRP

Transportation Thomas Forsythe During this more careful review, it should also be considered that this area 

contains three spurs that lead to the base of Thompson point within 1/4 of a mile. 

These spurs lead to what is essentially the same viewpoint as the single Kane County road in the area. They provide no additional recreational opportunity than what is available through riding the well maintained county road. 

RiRP

Transportation Thomas Forsythe Furthermore, each of these spurs has become the launching pad for additional R

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

spurs, some of which I witnessed being created by rambunctious neighborhood teenagers who destroyed vegetation and destabilized sensitive hillsides in their efforts at 'finding their own way.' Once those trails were established, the children moved on to destabilize new areas, leaving behind dead foliage and new two tracks that the BLM now appears intent on legitimizing despite their lack of 

destination and their redundant nature. 

iRP

Transportation Tom Carter In general, I would like to point out that it is counter productive to designate OHV 

routes without adequate oversight and enforcement since otherwise there is no 

way to enforce these plans. Therefore, I propose that all OHV operators who wish to operate within the resource area be required to apply for an annual use permit and the revenues created be used to fund enforcement of use of designated routes. Otherwise, the proposed plan exists only on paper and there would be no way to know if the designated routes and closed areas are being observed by OHVers. This population has an history of not obeying regulations and is not accountable either as individuals or by organizational ties. 

T

Transportation Utah Archeological 

Research Institute 

We do not see a clear distinction between licensed passenger vehicles and OHVs on roads or an adequate and accurate discussion of these distinctions. Throughout nearly all of the DRMP/DEIS there is no discussion in each alternative distinguishing and separating OHV travel from that of licensed passenger vehicles. Whenever you discuss topics like Motorized Use of Routes, you need to differentiate OHV travel from that of licensed passenger vehicles. 

Furthermore, there is little discussion of existing roads verses designated roads. 

Tpn

v

Transportation Utah Archeological 

Research Institute 

Therefore, we ask that is distinction be made in the DRMP/DEIS and appropriate discussions and actions be added to all sections discussing OHV use. 

Tpnv

Transportation Utah Archeological 

Research Institute 

In addition, why can't you close an area to all OHVs and limit travel only to commercially manufactured licensed passenger vehicles? The absence of defining and separating motorized vehicles into at least two classes is the most frustrating and annoying feature ofthe DRMP/DEIS. 

Tpn

v

Transportation Vaughn Bussma The Plan does not solve the damage caused by hunters in their ATVs and trucks, 

a problem expressed by the BLM representatives at the meeting. More postings and restrictions will not change the way that they behave. More enforcement of 

existing rules during hunting will be necessary. 

L

Transportation Vaughn Bussma Much of the land designated as closed for ATV riders under Plan B will become 

inaccessible to the many Utahns in my elderly age group who can no longer hike the trails. 

FdHt

Transportation Walter Fertig Travel management: Again, I commend the BLM Kanab FO for eliminating crosscountry travel by vehicles (except for designated routes). This will be a big step 

towards reducing resource damage to soils and native vegetation, which in turn 

Act

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Category Name Commentor Comment 

negatively affects wildlife and livestock. Developing a system of designated routes for ATVs is a good step to ensuring that these recreationalists have a place to pursue their activities. I do think BLM could have done a better job in evaluating what roads and trails should be part ofthe designated route system. Essentially the BLM maps are an inventory ofroads and trails, not a plan for managing travel, as many of these roads were not established using any erosionreducing standards. The maps provided in the draft RMP depict a lot of redundant roads (roads that parallel each other and go to the same destination). BLM ought to develop a more public process to evaluate the necessity of some of these redundant roads - roads that reduce the visual appeal of our area, reduce cover for wildlife and livestock, and increase soil loss. Having roads and trails available for use is important, but I see little value in creating road densities that are so high that they impede other uses. 

d

s

Travel Management – OHV Area Categories 

Anne McKibbin I spend time each year in Utah's wild areas, particularly in the southern areas of 

the Grand Staircase-Escalante National Monument near the Cockscomb, the Paria River, and areas adjacent to (and including) the Paria Canyon wilderness. I am concerned that the BLM's Travel Plan for roads and recreational ORV use in the area would severely damage the beauty and quiet of these places. They are not appropriate places for a designated route, and I hope that you will reconsider your proposed Plan. Those of us who backpack, hike, camp, and ride horses in this area do so because of its unparalleled beauty and peacefulness. Please don't destroy that experience by allowing gasoline-driven vehicles. At the least, allow significant parcels of open space where a person can get two miles from a vehicle. Sound travels a long way in the open spaces of Utah and it would be a shame to never get out of earshot of an ORV. 

TmtbPO

Travel Management – OHV Area Categories 

Capital Trail Vehical Association 

Because ofthe significant cumulative effect of motorized closures at this point in time, we feel strongly that there can be "no net loss" of motorized recreational opportunities with the Kanab DRMP and DEIS project. We would ask that this project address the attached checklist of issues and address the goals and needs 

identified. 

AtFr

Travel Management – OHV Area Categories 

Lo I and Won Yin It would be a mistake to open 1,100 acres of Moquith Mountain wilderness study 

area to ORVs roving across the Coral Pink Sand Dunes. That area should be protected for its natural splendor. Also, the Moquith Mountain loop should be 

closed to vehicles, so this area can retain its wilderness character. 

Tdn

Travel Management – OHV Area Categories 

Lynn Hague In the Kanab plan it should be a high priority to stop abuse by off-road vehicles in 

the proposed wilderness areas, including Vermilion Cliffs, Upper Kanab Creek, Parunuweap Canyon, Moquith Mountain, Canaan Mountain, and Paria River. ORVs have damaged scarce riparian wildlife habitat, taking a toll on wildlife values. We urge BLM to close all proposed wilderness areas to ORVs, as in Alternative C. 

Twtdta

Travel Management – Marleen Bussma If new rules and boundaries are created to keep out offenders, what guarantee is B

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OHV Area Categories there that the offenders will now start to obey the restrictions? We were told that 

there are not enough BLM people to patrol the areas to ensure compliance with the rules. What will change after new rules go into effect? Those who go off the established trails will continue to do so, while I am not allowed anywhere near the area. The same goes for the littering problem. 

Drwu

Travel Management – OHV Area Categories 

Richard Csenge Lastly in the Vermillion Cliffs region, motorized recreation should be strictly 

limited to existing routes and trails in the Hog Canyon Trail System. Trails should not be extended into the North Fork ofHog Canyon, where incursions are already taking place. Nor should motorized use be allowed to impact hikers who have ascended the Squaw Trail from Kanab City. This trail, along with others, which cannot be negotiated by OHVs, provide those who favor quiet sports a place close to Kanab City, where they can recreate without being disturbed by dust and noise from ATVs. 

OdK mcmd

Travel Management – OHV Area Categories 

Utah Archeological Research Institute 

So, if an area is closed to OHVs, it is also closed to all motorized transportation on all roads? This is unreasonable. You need to clarify this in all areas of the 

DRMP/DEIS where OHVs are discussed. This is discussed in more detail below. 

Ta

Travel Management – OHV Area Categories 

Walter Fertig My main quibble with the proposal in Alternative B is that a larger area ofCoral 

Pink Sand Dunes should be off-limits to ATV travel to protect the federally Threatened Welsh's milkweed (Asclepias weishU) and other BLM Sensitive species. Coral Pink State Park already offers ATV recreation, and the area obligated to the rare species is unnecessarily small. The dune area needs to be shared among various interests more equitably. 

Tria

Travel Management – OHV Route Identification 

Amber Sharkey As a high school sophomore I am concerned with the closing of roads in Poverty 

and Steep Trail Areas surrounding my community. I believe that it is important to keep these roads open in case of emergencies and recreational activities. It is important to have extra roads in case if nature blocks roads then there will be outlet roads for emergencies. I also think it is good to have recreational areas for people can go and enjoy the out doors and the beautiful area that we have here. 

Ti

s

Travel Management – OHV Route Identification 

Anthony Frost After looking at the map Alternative B 2-17 I have noticed that the trail into 

poverty is on the list of being closed down to through traffic and becoming an area where only hiking will be permitted. One of the other reasons that we go 

there is to look at the scenery in our four wheel drive vehicles. There is a lot of 

country that is spectacular in this area. Many people from all around come here to look at what we have to show them. If these trails start closing then how are they going to be able to enjoy the things that they have always loved? 

Ti

Travel Management – OHV Route Identification 

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

Closure of roads and trails significantly affects the value of my client's property as 

well as his ability to use his property. Furthermore, his business, including trail rides and atv access to public lands will also be diminished. And yet, in spite of requirements to include matters of socio-economic data in any land use plan, the RMP did not include such data. 

Ci

Travel Management – Bill May ...these in my opinion should be added to Alternative B. Dry washes are an ideal F

139 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

OHV Route Identification 

route for OHV travel; rain erases any OHV tracts. c

A

Travel Management – OHV Route Identification 

BLM - Arizona Strip Field Office 

The route designations for Vermilion Cliffs National Monument will be completed with the Vermilion Cliffs National Monument Record of Decision/Approved Plan, however, the decisions on the routes in the Arizona Strip Field Office have not yet been made. These comments concern routes near or leading to routes in the Arizona Strip Field Office. We request that Kanab Field Office work with Arizona Strip Field Office to insure that routes crossing the Arizona/Utah state line are consistently designated. Most of these comments refer to possible inconsistencies across state lines (numbers refer to specific points on attached 

GIS map plots). 

TS

Travel Management – OHV Route Identification 

Bob Wallen Comment on road closure located at UTM 12 S 0341718, 4114570; See attached 

maps and photos. I would like to request that the Field Office reconsider the closing of this short 1 mile long road and instead utilize the way to establish a trail head at this site to allow easy and convenient non-motorized access from this point to the Parunuweap and Virgin river area as well as continue to provide long time established uses. Even when acknowledging this short way is within a WSA there appears to be significant evidence that the Field Office has acted without due consideration to all ofthe directives of managing a WSA. For example. I have 

traveled this road many times including 9 consecutive days this fall and while GPSing this route on Nov 4 and dispute any claims of OHV "intrusions" causing the "degradation and impairment" necessary to permit BLM to close this prior 

existing route.(see attached photos) It is also "unreasonable" for BLM to initiate closures on known Kane County RS 2477 assertions as they have in this case. 

A t

Ar

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Travel Management – OHV Route Identification 

Capital Trail Vehical Association 

Our comments document that the current management trend towards massive motorized closures (25 to 75% ofthe existing routes) is not responsible to the public's needs for motorized access and recreation and is contrary to the multiple-use management directives specified by congress. 

Tafa

Travel Management – OHV Route Identification 

Capital Trail Vehical Association 

The proposed action must meet the needs of motorized recreationists both today and tomorrow. We respectfully request that the evaluation and proposal be directed to adequately address these issues and goals. 

Tpm

Travel Management – OHV Route Identification 

Capital Trail Vehical Association 

The current approach for OHV management is inequitable because it takes the current motorized route inventory and tries to make it the route inventory for all 

users. It leaves out possibilities for constructing or otherwise developing nonmotorized trails and ignores existing non-motorized trails that exist in both the 

planning area and adjacent lands. 

TnDpmae

Travel Management – OHV Route Identification 

Capital Trail Vehical Association 

We request that the agency not use the existing motorized trail inventory for designating non-motorized trails. Instead, if there is a need for non- motorized trails, then the agency should consider options that do not reduce the existing 

TRd

140 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

opportunity for motorized users. m

t

Travel Management – OHV Route Identification 

Capital Trail Vehical Association 

The site specific analysis of each road or trail to be closed must address or identify where the public would go to replace the motorized resource proposed for closure. In other words, the analysis must adequately evaluate the site specific value of a road or trail proposed for closure to motorized recreationists. It must also quantify the significant negative cumulative impact experienced when motorized recreationists could not find a trail or road with a similar experience in the area. The quality of our experience has been significantly reduced. It must also quantify the significant cumulative impact that the closure of a system of 

road and trails would have collectively when enough routes are closed to eliminate a good motorized day outing. An incomplete analysis is not acceptable under NEPA requirements. 

TpKsic

d

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Travel Management – OHV Route Identification 

Capital Trail Vehical Association 

34. Note that some new construction may be required to accomplish a reasonable system of loops. Therefore, new construction must be included in the scope ofthe project. 

Tpm

Travel Management – OHV Route Identification 

Capital Trail Vehical Association 

We request that a system of dual-purpose roads, and OHV roads and trails that interconnect be one of the primary objectives of the travel management plan and 

that this objective be adequately addressed in the document and decision. 

Am

Travel Management – OHV Route Identification 

Capital Trail Vehical Association 

The Plan for this project area does not recognize and address this trend. The management plan for the Kanab project area must adequately recognize and address this trend. 

Tpm

Travel Management – OHV Route Identification 

Capital Trail Vehical Association 

A significant closing of roads and motorized trails in the project area is not consistent with meeting the needs ofthe public and the goals of Multiple-Use Management as directed under Federal Land Policy and Management Act of 1976 (FLPMA), Multiple Use Sustained Yield Act of 1960 and P.L. 88-657. 

Tafa

Travel Management – OHV Route Identification 

Charles Robinson The Proverty roads should not be closed in my opinion because we as older 

citizens need access into these very beautiful, interesting, and historical areas as 

the slot canyons, petroglyps, and Spanish sword engraving. I am all for all tracks 

to stay on existing roads. However, I and most of America, can't walk over a mile in deep sand, therefore I need a cherry stem road to these areas. These 

accesses to Prunaweep Canyon need to be left open for us to enter this most beautiful canyon. 

Ti

Travel Management – OHV Route Identification 

Charles Robinson The proposed road closure of Elephant Cove would be a sad day at our home. 

These roads have been open for many years. The Shuns berg Mail Drop is a very significant historical venue. The road needs to be left open to the areas as it is too far for anyone (except 20 year-olds) to walk. As I get older (60 year old) I need a cherry stem road to be able to visit the drop site. I work for the post office and this part ofhistory is not only interesting, but significant for Kane and Washington County history. 

TsA

141 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Travel Management – OHV Route Identification 

Charles Robinson The Broad Hollow Road should be left open for recreation and historical use. The 

loop is a great ride for the outdoor and historical enthusiast This could and should be a great ATV trail on BLM land. The old cabins, the beautiful scenery, the atmosphere are incredible and it would be a shame to shut us citizens out of such an area. 

Tt

Travel Management – OHV Route Identification 

Charles Robinson Access to Cannan Mountain from Broad Hollow should be left open for the 

scenery and historical reasons. The old sawmill, the shingle drop are really neat and we shouldn't be deprived of visiting this area. Only a very tiny percent (about 1/1000 of 1%) of American citizens or tourists will ever be able to visit, as it is way too far and difficult to walk to. A cherry stem road would at least get us into the vicinity of all this beauty. 

Tt

Travel Management – OHV Route Identification 

Charles Robinson Moquith Mountain (Lamb Point) closing the spurs off the loop road would be very 

detrimental to us older generations. The scenic pinnacles and pine trees are unmatched in beauty. The balanced rocks, windows and arches are incredible. Petroglyps and Indian caves are some ofthe best in the west. Each spur road goes to something incredible and is there for a reason. These should not be closed. 

TIR

Travel Management – OHV Route Identification 

Chris Bell U4WDA Not designating the following as wilderness since all these have existing machine 

made roads. A. Sheep Springs B. Four Mile Creek C. Kanab Creek 

Api

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Travel Management – OHV Route Identification 

Coalition to Preserve Rock Art 

As a result we believe that the proliferation of OHV routes in the area needs to be carefully considered. Those that provide direct access to important cultural 

resource sites should be closed at lease one quarter mile from sites eligible for NRHP status. 

Ataotppp

pprti

Travel Management – OHV Route Identification 

Colin Esplin The reason that I'm writing this letter is to express my concern on the issue of 

road closing, more specifically the Poverty road. Because I have used this road before and enjoyed the things that you can see from the use of this road I would like to see it remained open. The young men and young women in my ward went 

Tii

142 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

on a four wheeler ride on this road for an activity one night. I also went and had a great time. We rode down to the river to see the Indian art on the canyon walls. Being able to ride down there allows you to do it in one evening. The closing of this road would consequently not allow you to be able to do this. 

Travel Management – OHV Route Identification 

Colorado Plateau Archaeological Alliance 

Given the scope of the proposed Travel Plan as articulated in the Kanab Draft 

EIS, and the anticipated increase in OHV use over the next decade, a more careful consideration of cumulative impacts from future OHV use should be reflected in the planning and route designation document. 

IdnRKS

Travel Management – OHV Route Identification 

Dale Grange One of the routes that I feel should be included for continued use is the extension 

of the route on Moquith Mountain to the overlook at Hell’s Dive Canyon. This is a magnificent overlook and always brings me a sense of exhilaration. I always enjoy viewing the wildlife in the area. It is amazing to see how much less threatened they appear when I am on my ATV than when I am simply hiking. 

Ta

Travel Management – OHV Route Identification 

Dale Grange A second route I would object to being closed is the route to the overlook of the 

East Fork of the Virgin River at the Barracks in the Elephant Butte area. Several great hikes are available from the overlook at the termination of the existing route. This route existed prior to the WSA inventory and should have been “inventoried” prior to the creation of the WSA. I urge BLM to use their authority to leave it open in the WSA and ultimately let Congress determine whether it should be closed. At present it is not detrimental to the wilderness values in the WSA and would not prevent its ultimate designation. 

TRi

Travel Management – OHV Route Identification 

Dale Grange The third route that concerns me is the route from the Hog Canyon area to 

Thompson Point. Again the views are tremendous and I great a great sense of well-being when I travel in this area. Each of the proposed Jamboree routes loops will be negatively impacted if they were to be unavailable for travel. 

Ad

Travel Management – OHV Route Identification 

David Armbruster In general Special Recreation Management Areas (SRMA) designations need 

further clarification not to explicitly exclude any user group. Specifically the Kanab Community SRMA OHV Recreation Management Zone (RMZ) needs clarification for the process by which adding or expanding routes will be possible. 

Acf

Travel Management – OHV Route Identification 

David Armbruster In studying the maps and documents in the DRMP/DEIS for Alternative B, the 

U4WDA has found roads shown to be closed that should not be closed and has been informed by the local clubs that some existing roads are not shown on the maps. This seems to be a mistake and an attempt to close roads that are part of 

the Counties Transportation Plans or RS2477 roads that are being claimed by the Counties. It is imperative that the status of these routes be determined and a legal public review be done before any action is taken to close them. 

Tcea

Travel Management – OHV Route Identification 

Don Black U4WDA 

We support the RMZ, but the RMP should include more direction regarding when and how additional or expanded routes would be provided. We feel that an expanded and improved trail system in the area would give the public an 

A

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143 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

appropriate place for motorized tecreation and take pressure off of more sensitive areas. 

Travel Management – OHV Route Identification 

Donald Kramer Road closures that are shown in alternative B that concern me the most are the 

"lambs Point" at the southwest end of the Moquith Mountain road. This is a sandy area and keeping the road open does not appear to damage the environment while keeping the first 3/4 of the road open. In hot weather this lengthens the hike to the point with no available water to make it dangerous as hikers will not be able to carry enough water. This will also prevent a lot of people from being able to see this beautiful area as the hike will prevent the young, elderly and those not 

in "premium" physical condition from seeing it. Reasons to keep these motorized trails open- Benefits Personal- Bonding with family and friends, stress relief, enhanced awareness and appreciation of natural resources, greater self reliance and renewed human spirit, Improved physical fitness and health, closer relationship with nature. Community- Stronger sense of community dependancy 

on public lands, greater family/ group bonding. Economic- Enhanced local economy via purchases ( gas, groceries, lodging, outdoor equipment, etc) Environmental- Increased awareness and protection of natural landscapes for future generations. 

T

IR

Travel Management – OHV Route Identification 

Donald Kramer Two of the roads that lead to trail heads in the Parunuweap wilderness study 

area are shown for closure in alternatives "b and C" the one that is accessed from route 9 just west of the East Zion lodge and goes south into the wilderness study (73.11.910 by 112.47.715) area is listed for closure in these alternatives. I have hiked to mineral gulch from this road and its closure will make most of those areas unaccessible to me and my wife. Neither of us are handicapped but we are in average shape. Extending this hike would in effect make it inaccessible. Reasons to keep these motorized trails open- Benefits Personal- Bonding with family and friends, stress relief, enhanced awareness and appreciation of natural resources, greater self reliance and renewed human spirit. Improved physical fitness and health, closer relationship with nature. Community- Stronger sense of community dependancy on public lands, greater family/ group bonding. Economic- Enhanced local economy via purchases ( gas, groceries, lodging, 

outdoor equipment, etc) Environmental- Increased awareness and protection of natural landscapes for future generations. 

Ti

Travel Management – OHV Route Identification 

Donald Kramer Another motorized trail listed for closure is Lambs Point (36.59.952 byl12.41.418) 

the road most of the way down is shown open in option B but closed in option C. 

If there is not enough ecological impact to close the first 3/4 of the road how can the last couple miles make a difference. This is a beautiful area with views ofthe Arizona strip. Reasons to keep these motorized trails open- Benefits PersonalBonding with family and friends, stress relief, enhanced awareness and appreciation of natural resources, greater self reliance and renewed human spirit. Improved physical fitness and health, closer relationship with nature. CommunityStronger sense ofcommunity dependancy on public lands, greater family/ group 

TIR

144 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

bonding. Economic- Enhanced local economy via purchases ( gas, groceries, lodging, outdoor equipment, etc) Environmental- Increased awareness and protection ofnatural landscapes for future generations. 

Travel Management – OHV Route Identification 

Donald Kramer Rock Point approaching the Parunuweap Wilderness Study area from the south. 

(37.10.159 by 112.49.474) This closure will in effect close all access to the Virgin Canyon on that trail. It would be difficult to carry enough water to hike to the canyon then down in. It will also close access to all but the ultimately fit. This 

road is through thick sagebrush and I did not see any trails out off of the road. 

The road does not appear to create erosion problems and appears to be a wildlife trail. It does not appear to adversely effect wildlife. It is a popular hunting area and closures in this area will be hard to enforce with high numbers ofhunters 

used to access. Reasons to keep these motorized trails open- Benefits PersonalBonding with family and friends, stress relief, enhanced awareness and appreciation of natural resources, greater self reliance and renewed human spirit. Improved physical fitness and health, closer relationship with nature. CommunityStronger sense ofcommunity dependancy on public lands, greater family/ group 

bonding. Economic- Enhanced local economy via purchases ( gas, groceries, lodging, outdoor equipment, etc) Environmental- Increased awareness and protection ofnatural landscapes for future generations. 

TR

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Travel Management – OHV Route Identification 

Donald Sprecher I chose to address the road closures in the preferred Alternative "B". 

THOMPSON POINT T 0410 S ROAD CLOSURE IN SECTIONS: R 0090 W 20, 21,26,27, 28 This road has fantastic views to the south, from the top of Vermillion 

Cliffs, You can view the Kiabab Plateau, Kanab Creek, and Mt. Trumbull. If closed as marked it would require a hike for me of approximately 1-3/4 mile one 

way, over 3 miles round trip. I am physically unable to hike that distance. 

Ad

Travel Management – OHV Route Identification 

Donald Sprecher LAMBS POINT ROAD CLOSURE SECTIONS: T 0440 S 12 R0080W This road 

will deny access into Arizona and the Piute Indian Reservation. It has become 

obvious the BLM has had a request from the Piute Tribe to deny access, and the 

federal lands managed by the Arizona Strip Field Office has not taken Any consideration how that road continues and re-enters the State of Utah further west. The closure is denying access back into Utah. Lambs Point offers excellent 

views to the south of Kanab Canyon and west to Mt. Trumbull from the end of the road. That would require a hike of over 4 miles round trip without a place to replenish Water. 

TIR

Travel Management – OHV Route Identification 

Donald Sprecher MOQUITH MT. T 0430 S ROAD CLOSURE SECTIONS: R 0070 W 27, AND 28 

That road leads to a site of ancient historical resources. There are hieroglyphs 

and boulder-sized matates that are hard to find of that size. Plus there are pit houses that could be protected with a fence and an educational site and kiosk could be placed at the end of the road at that site. I can walk into that site. It 

would be impossible for me to hike the entire 2 1/2 mi round trip. And that would be a dry hike if no water in the canyon seep when you get there. I have worked with Doug McFadden (retired BLM archeologists) on privately owned property, 

Ta

145 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

and have experience with those type of sites. The BLM should use that site as an educational resource, rather than close the area. Use the area to educate. 

Travel Management – OHV Route Identification 

Donald Sprecher BARRACKS/ROCK CANYON T 0420 S ROAD CLOSURE SECTIONS: R 0090 

W 1, 11, 12, 14, 15,23 FANTASTIC VIEWS OF THE VIRGIN RIVER AND ZION NATIONAL PARK I HUNT THIS AREA FOR MULE DEER This road has been in use for many generations from the late 1800's according to my wife's grandfather (Merrill Robinson) who I questioned in 1987 his knowledge of this road. He told me that it was used as a cattle trail to cross the Virgin River and 4x4 vehicles had used the road after WW II when Jeeps and 4x4 became available to the civilians. I have a friend who was raised in Orderville Ut., and he told me when he was old 

enough at age 12, they would gather cattle on the Paria Plateau herd them across the Arizona Strip then to Moccasin Arizona, up thru Broad Hollow or over Canaan Mt. for water on top then back down into the Barracks or Rock Canyon. He told me they had many crossings down into the Virgin River and out to Mt Caramel or up Poverty and over to the Valley Junction up Long Valley to Alton or up to Glendale Bench to Alton. His name is Mac Sorenson. He hated the cattle drives. This closure would require a round trip of over 4 miles. 2 miles downhill, and 2 miles uphill with no place to refill water. I would have to carry over 2 gallons of water if I could make this hike. 

Tta

Travel Management – OHV Route Identification 

Donald Sprecher POVERTY ROAD CLOSURE SECTIONS T 0410 S R 0090 W SEE ABOVE 

COMMENT AS HISTORIC CATTLE TRAIL TURNED TO ROAD AS MODE OF TRANSPORTATION CHANGED THRU THE YEARS. I also hunt this area for mule deer. 

Ti

Travel Management – OHV Route Identification 

Donald Sprecher BLOCK MESA ROAD CLOSURE SECTIONS T 0420 S 1O, 11, 14, 18, 22, 27, 

R0090W Here we have roads on top of a relatively flat top mesa, with beautiful views, but the sand is very difficult for me to walk on. I use my ATV for access when I hunt mule deer in this area. Sections 10, 11, and 17 would require 4 miles 

round trip. Part of the loop thru section 22, and 27 from the main Jeep trail could be eliminated, but not the entire road in that section. 

TrS

PRs

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Travel Management – OHV Route Identification 

ECOS Consulting The BLM should state clearly that "limited" means that OHV use will be limited to 

designated routes within riparian areas, that OHV use will not be precluded from riparian areas, and that such OHV use will adversely affect the riparian areas. 

Ar

B

Travel Management – OHV Route Identification 

ECOS Consulting What are the purposes and reasons for each of the designated OHV routes? The 

DRMP/EIS fails to adequately address the purpose of these routes. 

TiraA

Travel Management – OHV Route 

ECOS Consulting Has the BLM documented the specific purpose of each OHV route it intends to 

designate? This must be done, and if a road is found to be redundant or if no 

Ti

146 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Identification specific and compelling purpose, it must be closed and rehabilitated. r

aA

Travel Management – OHV Route Identification 

Five County Association of Governments 

In many cases, such class D roads have been slated for closure. We ask that the final RMP remove submitted Class D roads from routes slated for closure. 

A naBta

Travel Management – OHV Route Identification 

Five County Association of Governments 

County officials submitted inventories of Class D county roads during the planning process, and requested that the RMP honor such designations. In many cases, such class D roads have been slated for closure. We ask that the final RMP remove submitted Class D roads from routes slated for closure. 

A naBta

Travel Management – OHV Route Identification 

Five County Association of Governments 

Many of the routes identified as open only for administrative use lead to important water sources. Most of these locations have been identified by the Utah State Engineer as the source of formally approved state water rights. These are valid 

existing rights held by private citizens or corporations. Access to these valid existing rights should not be constrained by administrative use designations that 

allow use only by federal employees. Holders of valid state water rights should be allowed access. 

Be

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fae

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Travel Management – OHV Route Identification 

Garrett Hill It has been brought to my attention that there is a plan to close the poverty and 

steep trail roads. I have a few questions and some concerns. First off I would like to know the reasons that you are closing these roads. I would like these roads to 

remain open. Me and my family enjoy recreation and travel down these roads. I don't see why these roads need to be closed. There is nothing there that is harmed by riding through these areas. Also I would like to inform you that I am a high school senior and a seasonal intern in the Range Department. If these roads are closed it would mean that to maintain the fences and the box canyon spring at steep trail we would have to hike 1 mile with all the supplies needed to maintain these fences and box canyon spring. That would take a full ten hour day. With the road open it only took us about four hours to ride out there pack the supplies down a little hill and build the fence and put the gate in. 

Ti

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Travel Management – OHV Route Identification 

Geno Ramsey Canyon Country 4x4 

The canan sawmill road is of major concern to me. The road has existed since the early 1900's and used for many things such as ranching, logging, and many recreational uses. Not to mention the unmatched beauty that the mountain has to offer and the local pioneer history. It is beyond be how such a road could closed. 

ToT

147 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Another is the "side roads" on the Moquith Loop road. These side roads lead to some ofthe most beautiful and unaccessible areas in our county. Rich in culture and history. 

i

Travel Management – OHV Route Identification 

Jacalyn & Charles Liebfried 

Roads to destinations such as, but not limited to, Lamb Point, Hell Dive and the Virgin River should remain open. These are beautiful spots and should not be limited to people in perfect physical condition. 

T

IRHs

Travel Management – OHV Route Identification 

Jack Christensen 3) Three areas having "Wilderness Characteristics" are in fact not. These areas 

are: Sheep Springs, Four Mile Creek and Kanab Creek. All three of these roads 

have been machine groomed and bladed by either the BLM or the County. 

Api

B

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Travel Management – OHV Route Identification 

James & Lorna Sills Kanab Community Special Recreation Management Area (SRMA) Off-Highway 

Vehicle (OVID Recreation Management Zone (RMZ) aka. Hog Canyon Trail System We support the RMZ, however the RMP lacks direction regarding when and how additional or expanded routes would be provided. An improved trail system would give the public an appropriate place for motorized recreation while reducing pressure on more sensitive areas. We support the proposal and map submitted by Canyon Country 4x4 for managing this RMZ. 

A

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Travel Management – OHV Route Identification 

James & Lorna Sills Transportation In perusing the maps in the DRMP/DEIS for Alternate B, we note 

roads closed that should not be closed. Why is an attempt being made to close roads that are part of the Counties Transportation plans? These roads along with the RS2477 roads that are being claimed by the counties should remain open and identified on subsequent maps and documents. Further there are existing 

roads not shown on the maps, thus making it difficult if not impossible to make meaningful comments regarding the RMP process as it pertains to Alternate B. Management Actions for the Transportation System Management 2-26 states; 

"Coordinate transportation planning with Kane and Garfield Counties". In view of the above stated omissions and errors we would like to know how this is to be accomplished. 

Tc

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Travel Management – OHV Route Identification 

Jeff, Kendalee, Mccrae, Buster and Maddie Cox C-4 Ranch 

Third question, if you just put a sign in the ground, would the road be opened for 

administrative purposes and permit holders? If so, that's not good either, because if you can use the roads but close then to the public, you will have a lawsuit on your hands. I'm sure you have logically thought through all the possible scenarios. Personnally as a permitee, I don't enjoy the noise, dust, the traffic and the risks involved with managing the range, however I wouldn't want to deny anyone the right to travel the roads and view the scenery that has been done so for so many years. There are plenty of other slot canyons and places that I go, 

Tdr

148 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

where travel is not permitted or accessible, to enjoy the serenity of the great outdoors. 

Travel Management – OHV Route Identification 

Jennifer Kaufman I ask that the BLM in the final plan of the RMP close to OHVs the trail that runs 

east from the television towers past the bench to a dead end. Squaw Trail is a very popular well developed non-motorized trail just north of Kanab City and offers a fantastic recreation opportunity for local citizens and visitors. When visitors ask me for a hike close to town, I send them to Squaw Trail. OHVs still 

would have a spectacular view of all vistas from vantage points on routes by the television towers and along the tops of the cliffs trails system so I feel that it is unnecessary to continue a route near the top destination of Squaw Trail. 

OdK s

Travel Management – OHV Route Identification 

Jennifer Kaufman I feel that all of the other proposed routes in this area duplicate each other as 

they appear to run parallel to each other and dead end into similar viewpoints. A few of the routes cross or deadend into private land. I have put a X on the routes that I feel are unnecessary as a motorized route for recreation. 

RiRP

Travel Management – OHV Route Identification 

Jerry & Cindy Foote 1. One of our favorite areas to ride is down Poverty Canyon to the Virgin River. 

Under Alternative B the access to the Virgin River is proposed to be closed. We are against this closure for several reasons. First, the Virgin River in this area is a very scenic area with a magnificent Indian rock art panel. Second, this access is part of the Kane County travel plan and should be under their control. Third, the excuse has been given that this road was not part of the 1976 road inventory and as such should be closed. We submit that the 1976 road inventory plan was 

hastily done without actually examining the roads on the ground and thus to close this road on that basis is without merit. 

TiiTc

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Travel Management – OHV Route Identification 

Jerry & Cindy Foote 2. Mirrored across the Virgin River is the Rock creek we are against the closure 

of the Rock creek access road. This road has been in existence for over 30 years and is considered an RS-2477 road by Kane County. 

TRiT

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Travel Management – OHV Route Identification 

Jerry & Cindy Foote We would like to comment on the closure of Moquith Mountian to Lambs Point 

road and the road to Hell Dive Canyon as proposed in Alternative B. Hell Dive Canyon has one of the premier Indian drawings and grinding stones in the area and to close them off to ATV access would deprive many from ever viewing their beauty. Making this an interpretive site by the BLM would allow people to enjoy 

and learn from these sites as well as offer any protection that is felt needed. This 

road is also considered an RS-2477 road by Kane County and is part of their transportation plan. 

TIRTaaBta

149 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Travel Management – OHV Route Identification 

Jerry & Cindy Foote The road out to the tip of Moquith Mountain, commonly called Lambs Point, 

presents the best panoramic views of the Arizona Strip and the Vermilion Cliffs. Alternative B proposes to close the road from where it leaves the Moquith Mountain road and enters Arizona. Further, according to the BLM Alternative B maps, this road does not exist where it returns back into Utah from Arizona. This indicates that the road inventory that the BLM has is wrong. This entire road from where it leaves the Moquith Mountian road out to Lambs Point was machine made and is clearly pre-1976. On this basis it is also an RS-2477 road and is rightfully claimed by Kane County as part of their transportation plan. 

TIRtt2d

Travel Management – OHV Route Identification 

Jim & Bonnie Vann 2.) The second road of concern is the one that crosses the state line into Arizona 

before returning to Utah and terminating at Ed Lamb Point. This road is of 

particular concern because it has been entirely omitted from the BLM maps 

under all four Proposed Alternatives as if it doesn't even exist. Interestingly, this road does appear on both the 2005 and 2006 BLM area maps however. What happened to it under this RMP? The Kanab Field Office staff have been verbally advised of this omission and oversight on several occasions, but have made no effort to correct this error. An error on the part of the BLM on a project of this size 

might be understandable were it not for a second road that has simply been eliminated from any maps associated with this RMP. That road leads to the north 

rim of the Virgin River and an incredible Indian petroglyph panel. Does the BLM think that they can simply take well known roads off a map and have them just disappear from comment? This shameful behavior by the BLM Field Office fuels the resentment, distrust, and animosity towards them by the local community. This road also qualifies as a Kane County road under RS-2477 rights. As stated earlier, I support those rights. Equally important however, is the fact that it allows access to Arizona and the upper reaches of the Kaibab Piute Indian Reservation, allows users to visit and enjoy a unique geologic area known locally as the "Beehives", and provides one of the few views off the Vermillion Cliffs across the Arizona Strip and down Kanab Creek to it's confluence with the Colorado River at 

the Grand Canyon. It is a truly spectacular "visual resource". 

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Travel Management – OHV Route Identification 

Jim & Bonnie Vann The area and roads of specific concern appear as part of "Alternative B and C" 

on the Mt. Carmel map in the Block Mesa portion of the WSA. The two roads 

proposed for closure are on the mesa top between Joseph Canyon and Merwin Canyon, and the second road is between Merwin Canyon and Baybill Canyon. Both of these roads were "mechanically built" sometime prior to 1976. The roads were put in to harvest juniper posts and for ranching purposes. These roads clearly appear on aerial photos prior to 1976 and are a part of the Kane County 

transportation plan by virtue of RS-2477 rights. I support the assertion of those 

county rights. The very nature of these roads should have eliminated any possibility of the surrounding lands being considered for Wilderness Study Areas after the completion of the previous WSA inventories. The fact that these roads were either accidentally or intentionally overlooked by the BLM in the prior 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

inventory calls into question the very validity of the WSA in this area now. More recently, these two roads have again been GPSed and photographed. The BLM Kanab Field Office staff have been specifically advised of the machine built nature of these roads. Yet, the roads remain on the map as a proposed closure. It would appear that the BLM is intentionally overlooking facts that are evident on the ground in an effort to support an inappropriate de facto WSA and using those distorted facts to drive road closures in the area. This deliberate error on the part of the BLM, and the fact that they continue to ignore new information that would not support a WSA, would call into question the completeness and integrity of the entire prior inventory, possibly affecting the existence of other Wilderness Study Areas within the Kanab Field office operating area. I do not believe that the BLM has the authority to designate this area as a WSA, and to propose the closure of these roads. 

Travel Management – OHV Route Identification 

Jim & Bonnie Vann The area and road of specific concern appears as part of "Alternative B and C" 

on the Thompson Point map. The road that is proposed to close is at the very south end of a section line fence road that terminates near a point on the topographical map called the "Mansard". This road, for all purposes turns into an ATV track where it comes off the ledges and descends to a spectacular Indian site under a large overhang. The site has numerous art drawings pecked into the stone and unusual slide marks that have been worn into the rock after years of use by native peoples. This area has been frequented for years by local residents and is well known to all. There is no impairment or degradation at this site even 

after years of visits. The only other way to reach this site is by an arduous climb up the face of the Vermillion Cliffs that takes about 1-1/2 hours and is not possible in the summer due the cliffs being south facing. 

Ad

Travel Management – OHV Route Identification 

Jim & Liz Robinson It would be a mistake to establish an "open" zone for ORVs in the Coral Pink 

Sand Dunes in Moquith Mountain WSA. The adjacent state park caters to ORVs, allowing them on a "play area" of 1,000 acres. The wilderness character of the WSA would be degraded by allowing ORVs driving cross-country. 

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Travel Management – OHV Route Identification 

Jim and Bonnie Vann 1.) The first road of concern is the furthest east of the three roads with proposed 

closures under Alternatives B and C. It is a very short (but very significant) road 

that runs east & west off the main road from Elephant Cove and terminates at a place referred to as "Steep Trail" This area is well know to the BLM. This road was originally put in as a river crossing for sheep wagons and is a "cultural resource", although its descent down to the river gorge is no longer used, or passable. Grazing permitees are currently using this area, and cattle frequent it in their trips down to the river to drink. This road provides a spectacular view into 

the Virgin River Gorge and is claimed by Kane County as a RS2477 road. Since there is no possibility of travel beyond the current termination. I suggest that this road remain open for its "visual resource" view into the river gorge. 

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Travel Management – OHV Route 

Jim and Bonnie Vann 3.) The third road on the south side of the river that is listed as a closure under 

Alternatives B and C is on the west side of Rock Creek. This road is proposed to 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Identification close under alternative B where it exits a State School Section and enters the 

WSA. If this happens, it will require users to walk approximately 2.5 miles in very 

soft sand to reach the end. This road essentially ends at a big outcropping of rock 

and again provides a spectacular view into the Virgin River gorge (probably the best of the three roads on the south rim). The BLM has recently put posts in the ground to discourage OHV users from continuing down to the river. This area would make an excellent interpretive site for the BLM while still allowing the public to visit and enjoy it. This area would lend itself to a cooperative effort between the OHV communities and the BLM as a project to fence the end of the road at its current location with a kiosk containing interpretive information for visitors as both a "cultural and visual resource" area. 

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Travel Management – OHV Route Identification 

Jim and Bonnie Vann 1.) The first road proposed for closure under both Alternative B and C is the one 

farthest to the east and terminates across from the road described above as 

"Steep Trail" on the south rim. This is the north side of the old wagon road that 

crossed the Virgin River and is of both historical and cultural significance. At its motorized end on the ledges above the river, it provides one of the easier access 

points by foot trail down to the river. This road is also a Kane County RS-2477 road and should remain open to its current point. 

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Travel Management – OHV Route Identification 

Jim and Bonnie Vann 2.) Moving to the west, the second road proposed for closure has again been 

simply eliminated from any maps associated with the RMP where it exits a State School Section and heads south above the Virgin River. This road exists both on the ground and on previous BLM maps. The road is listed as a Kane County RS2477 road and is used frequently for its access to one of the best Indian art panels in the entire area. This area would make an excellent interpretive site for 

the BLM while still allowing the public to visit and enjoy it, and there has been no impairment or degradation to this site. This area would lend itself to a cooperative 

effort between the OHV communities and the BLM as a project to fence the end of the road at its current location with a kiosk containing interpretive information for visitors as a "cultural resource" area. The real question is, what happened to this road under this RMP? The Kanab Field Office staff has been verbally 

advised of this omission and oversight on several occasions, but have made no effort to correct this error. An error on the part of the BLM on a project of this size might be understandable were it not for a second road that has simply been eliminated from any maps associated with this RMP. That road leads to Lamb's Point and has been noted previously. Does the BLM think that they can simply take well known roads off a map and have them just disappear from comment? 

This is shameful behavior by the BLM Field Office and fuels the resentment, distrust, and animosity towards them by the local community. 

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Travel Management – OHV Route Identification 

Jim and Bonnie Vann 3.) The third and last road in this area is the one farthest to the west and currently 

terminates above the Virgin River at Poverty Flat after crossing Poverty Wash.. 

This road was also machine built as a bulldozed stock tank exists at its end. It is 

a claimed RS-2477 road by Kane County and I do not believe the BLM has the 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

authority to close it to travel. 

Travel Management – OHV Route Identification 

Joan Thacher I request that each separate route be evaluated to show it's necessity and 

"contribution to protection of sensitive resources". I do not believe that Alternative B should simply open 92% ofthe routes because they are already there. 

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Travel Management – OHV Route Identification 

Joan Thacher I request that the routes in these areas be re-evaluated and closed where erosion 

and scaring is a problem. 

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Travel Management – OHV Route Identification 

Joan Thacher OHV routes have no business in these areas. ATV's often use these areas as 

playgrounds. I request that you protect these areas and restrict travel there. 

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Travel Management – OHV Route Identification 

John Veranth However, I will comment that in general, the proliferation of ORV routes shown in 

BLM Alt B is far in excess of any reasonable accomodation of recreational vehicle use and will lead to future resource management problems. A well defined network of main routes, scenic loops, and spurs to overlooks is managable and enforceable. The haphazard jumble of proposed routes not. 

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Travel Management – OHV Route Identification 

Josh Heaton Because I really like to go hunting and four wheeling down on the poverty. And if 

those roads are closed that will stop me and many other people from enjoying a favorite past time. 

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Travel Management – OHV Route Identification 

Karen Kramer In the Kanab RMP/EIS area, I have hiked to Mineral Gulch, what a great slot 

canyon!!! However if I had to hike from the proposed closure site in plan "B" and "C" into Poverty Flat, which is part ofthe Parunuweap Wilderness study area, the hike down and then on the return hiking UP would stop me from even trying to hike into this slot The access to this slot canyon is by way of State Route 9 west ofthe Zion Lodge and goes south into the wilderness study area. 

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Travel Management – OHV Route Identification 

Karen Kramer Lamb's Point gives a wonderful view ofthe Arizona Strip. This vista is on the 

southwest end of the Moquith Mountain road. This is one ofthose deep sandy 

roads that are very tiring to hike, with no water source. 

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Travel Management – OHV Route Identification 

Karen Kramer In plan "B" the Moquith Mountain road would be open except for the last several 

miles, essentially closing it to all except for the very fit hiker. In plan "C" the entire 

road would be closed, essentially closing it to everyone. 

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Travel Management – OHV Route Identification 

Karen Kramer I have yet to get to Rock Point on the south end of the Parunuweap Wilderness 

study area. My understanding is that by closing this road it will close the access 

to the Virgin Canyon on the south end, to all except for the extreme hiker. It will make this area an additional 5+ mile hike just to the edge ofthe Virgin Canyon, with a 5+ mile return, this does not even include hiking into the Virgin Canyon itself. Effectively closing Virgin Canyon to almost everyone. 

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Travel Management – Lance Jackson The closures that I am referring to are the following: The last mile of the Moquith T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

OHV Route Identification 

mountain road, the roads that go down into the Parunaweap canyon from the south side of the river, and the roads going down to the parunaweap canyon 

froom the north side of the river known as the poverty area. 

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Travel Management – OHV Route Identification 

Land Use Volunteers of Kane County 

There are significant problems with a number of the route segments contained in the Alternative B Travel Management Plan. The following tracks should be removed from the plan because they are already creating excessive resource damage, or they will encourage significant resource damage as more and more ORV's enter the area. 

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Travel Management – OHV Route Identification 

Land Use Volunteers of Kane County 

Because this geographic area is of wilderness quality and has fulfilled the requirements for ACEC status, a more extensive inventory of resources should 

be completed before approval of an RMP Travel Plan. The current BLM inventory is inadequate and does not include or accurately map the distribution of many of 

the archeological, botanical, wildlife , cultural , and ecological resources present 

in the area that may be impacted by ORV's. This inventory needs to be completed before the final version of an DRMP is approved. 

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Travel Management – OHV Route Identification 

Land Use Volunteers of Kane County 

We recommend that designated routes be placed in dry washes only when the 

route is an established road that is necessary to travel to a major destination. The rest of the dry wash routes should be deleted from the Travel Plan. 

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Travel Management – OHV Route Identification 

Land Use Volunteers of Kane County 

We recommend that the Travel Management Plan avoid designating any routes 

that parallel streams or riparian zones. Alternative designated routes should be sought out and used. 

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Travel Management – Land Use Volunteers We recommend that the BLM complete the necessary field work and analysis to A

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

OHV Route Identification 

of Kane County rid the Travel Plan of redundant, parallel, and unnecessary routes before 

completing the final version of the RMP. 

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Travel Management – OHV Route Identification 

Land Use Volunteers of Kane County 

We also think that routes that dead end at the boundaries of Wilderness Study Areas and School Trust Lands be deleted from inclusion in the Travel Plan for the same reason mentioned above. 

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Travel Management – OHV Route Identification 

Land Use Volunteers of Kane County 

We recommend that no designated transportation routes should cross private land. Additionally, no designated routes should dead end at the border of private 

land, because this will lead to uninvited incursions onto private land by ORV's. We have seen this happen in the field. Sometimes the riders break down gates and cut fences to gain entry. 

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Travel Management – OHV Route Identification 

Laura Welp Does this re-opening of roads imply that the problems for which the designated 

trail system was put in place, i.e. "to protect soil, vegetation, wildlife, cultural and riparian area resources that have been adversely impacted or are at risk of being adversely impacted by OHV use", resolved? The level of non-compliance with the Hog Canyon OHV trail system is such that reopening roads will only lead to more damage (photos available upon request). 

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Travel Management – OHV Route Identification 

Laura Welp The plan also shows new roads that were not in the original Hog Canyon 

transportation plan (for example, see photos on page 9 of attachment). Those roads were not planned under the appropriate NEPA process and should not be legitimized in the RMP. 

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Travel Management – OHV Route Identification 

Laura Welp In doing so, the BLM failed to conduct any analysis concerning whether these 

roads were necessary, had defined destinations, went through sensitive areas, were duplicative, etc. The plan lacks the rigorous analysis that would have 

supported the BLM's decision. 

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Travel Management – OHV Route Identification 

Laura Welp The BLM can not please everyone with their transportation plan, but it would go 

down easier with all segments of the public if the method by which the BLM decided which roads to close and which to leave open was transparent and understandable. To provide the best transportation plan for the public, the BLM 

should analyze all roads before designating them as open or closed. Analysis should include impacts to wildlife, soil erosion, hydrological function, loss of AUMs, vegetation, and archaeological resources. As it stands, the BLM's proposed transportation plan is not a fair balance between open and closed areas. 

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Travel Management – OHV Route Identification 

Laura Welp These OHV trails are often just tracks that were driven on once, but they are 

being enshrined in the RMP. Many of the homeowners adjacent to this informal 

network of trails will be subjected to noise, dust, declining property values, and annoyance of OHV use directly adjacent to their homes. The concentration of roads within this two-section block is excessive and unnecessary; in fact, the 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

BLM is creating a de-facto, back-door play area here. Every ridgeline does not have to have a trail on it. 

Travel Management – OHV Route Identification 

Laura Welp Trails should not be designated open in riparian zones. A

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Travel Management – OHV Route Identification 

Margaret Stone Routes that end up causing damage to the resources and beauty of an area 

either because of their location or because riders refuse to stay on them should be eliminated. 

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Travel Management – OHV Route Identification 

Marlin Sharp Lone Peak 4 Wheelers 

I believe the BLM needs to allow for additional trails to be added to the area in the future. This area economy of recreation could benefit by added trails and an expanded trail system. 

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Travel Management – OHV Route Identification 

McClain Cox I looked at the information that was given and I am still at a loss as too why 

exactly the roads are being closed down. If you could tell me why the poverty road on map M-217 is possibly being closed I would be most appreciative. I know there is reasons for this and I know that there is a compromise available. If the BLM could let us locals know exactly what we are doing wrong that is hurting the landscape let us know instead of cutting it off from us. 

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Travel Management – OHV Route Identification 

Mitch Thompson Specifically the Mail Drop. Please consider leaving access to these areas open in 

your plans. 

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Travel Management – OHV Route Identification 

Richard Csenge To manage OHV use properly, there must be a transportation system that 

identifies designated routes and trails . No lands should be simply left open for 

cross country travel. The number ofmiles of routes should be small; three to five hundred miles at most. 

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Travel Management – OHV Route Identification 

Robert Aiken The road to Thompson Point, in "Alternative B" is proposed to be closed. This will 

eliminate all the accesses for individuals to see the beautiful views along the rim to the point. We have made several visits to area and enjoy the views and the wildlife in the area. In our visits we have not seen any other ATV operators. People with handicaps and limited mobility will not be able to enjoy the area. 

Ad

Travel Management – OHV Route Identification 

Russell Howe I believe that the BMP User Stats are not correct, and that Table 3.26 should be 

eliminated. I believe many of the proposed closing of roads should be kept open to large groups of familys, friends, and friendly organizations. These roads include Rock Canyon, Spur, The Poverty, Flat Road, Virgin River Access Road (The Barracks). Also the Hell Drive, Ed Lamb Point Road (Moquith Mountain), Vermillion Route, Willis Canyon (Thompson Point) and Black Mesa Route (Black Mesa). Also the Sheep Springs, Four Mile Creek, and Kanab Creek have existing machine made roads which have been in service for many years. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Travel Management – OHV Route Identification 

Samuel & Janet Smith We have noticed that the road to Thompson Point, in "Alternative B", is proposed 

to be closed. This will eliminate all the accesses for individuals to see the beautiful views and vistas offered as the road winds its way out to Thompson 

Point. For the past 8 years our family and visitors have traveled to the point to enjoy the vista overlooking the Shinarump Cliffs, the White Sage Flats and beyond; the Kaibab Plateau. We have taken numerous photos ofour family from this location. We have enjoyed this area very much. From there we are able to hike to the white rock outcroppings and enjoy other explorations as we hike along the Vermillion Cliffs which overlooks our home below. In our many visits we have only seen other OHV operators, all of which have been locals from this area. 

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Travel Management – OHV Route Identification 

Samuel & Janet Smith We are equally distressed at the proposed closing of access into Willis Canyon. 

That is where we take our Grandchildren, visiting from the City, and teach them of the importance of conservation, respecting the land as an obligation for them to remember. We have visited and picnicked along Willis Creek on many occasions. Here we have rarely seen others, and have not disturbed the land other than passing over the deep sand to reach our favorite locations. 

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Travel Management – OHV Route Identification 

Samuel & Janet Smith I would also like to make a comment on the proposed closure ofthe Moquith 

Mountain and the road to Hells Dive Canyon. Hells Dive Canyon has some ofthe premier Indian Pictographs and Grinding Stones in this area, to close access off from the general public would be very disappointing. We would suggest that the B.L.M. use this area as an interpretive site, somewhat like the one in Indian Canyon where people could go and enjoy these great sites without damaging them. This should be a relatively easy project with help coming from both the Hiking and O.H.V. community. This would also keep another Kane Co. RS 2477 road open for public use. 

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Travel Management – OHV Route Identification 

Samuel & Janet Smith The view off the end of Moquith Mountain is one of the most spectacular views 

that are available of the Arizona Strip. It is the only place that a person can look 

off the Vermillion Cliffs to see this magnificent view that reaches to the confluence of the Kanab Creek and the Grand Canyon to the south. This is also a very long hike, 10 to 15 miles, through the deep sand; that I'm sure is not for the general public or senior citizens. Without the use of an OHV many of us senior citizens will be denied the opportunity to enjoy many areas of public lands. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Travel Management – OHV Route Identification 

Shane Baird The first comment is that I believe Alternative D is the best choice except for the 

roads to Poverty I think they should stay open, because the community and I plan to hunt there. 

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Travel Management – OHV Route Identification 

Steven Edmunds Sheep Springs Road, Four Mile Creek and Kanab Creek are man made roads 

with many man made fixtures, such as corrals, tanks, spurs. 

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Travel Management – OHV Route Identification 

Susan Hand Parunaweap, Motorized Canyon RMZ. I strongly disagree with the placement of 

an OHV touring route in a WSA! There are many opportunities available elsewhere, and motors are simply not compatible with management guidelines established for WSA's. On the other hand, I applaud the closure of the Barracks and Poverty Flat routes. 

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Travel Management – OHV Route Identification 

Susan Hand Upper Squaw Trail. This is the most popular hiking trail in our community, and the 

one that most visitors are directed to. The ridge which is the primary destination 

of this trail should not be open to OHV use. The KFO provides few developed hiking trails, and it seems a shame to sacrifice any of them. Please protect this important resource from unnecessary user conflicts. 

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Travel Management – OHV Route Identification 

SUWA Th BLM preferred alternative travel plan includes high route density across the 

planning, and wanton designation of redundant routes devoid of clear purpose 

and need to the very real detriment of non-motorized recreation and resource preservation. 

AcUvoanm

Travel Management – OHV Route Identification 

SUWA The DRMP/EIS does not present this information with respect to the differing 

travel networks under consideration in the DRMP/EIS. There is no way for a reviewer to identify the basis for the specific route designations proposed or confirm that the BLM has ensure that these designations comply with the legal and policy obligations set out above. 

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Travel Management – OHV Route Identification 

SUWA In order to justify the suitability of the proposed route network, the BLM must 

provide information on the reasons for designating the routes (i.e., destination, use), impacts of the routes on other resources, how those impacts can otherwise 

be mitigated or avoided, and the manner in which designation of the route for the proposed use is consistent with the agency's obligations under its regulations and 

policy. 

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Travel Management – Tobin Gardner The roads I pray will remain open include: Rock Canyon Spur, (The Barracks) the T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

OHV Route Identification 

Poverty Flat Road, (The Barracks) Virgin River Access Rd, (The Barracks) Hell Dive, (Moquith Mountain) Ed Lamb Point Road, (Moquite Mountain) Vermillion Route, (Thompson Point) Willis Canyon (Thompson Point) Block Mesa Route (Block Mesa). Sheep Springs, Four Mile Creek, and Kanab Creek all have existing machine made roads that have been around for many many years. It would be a shame to see this beautiful land closed. 

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Travel Management – OHV Route Identification 

Tom Carter I live below the Thompson Point Archeological site located above my residence 

where I have hiked to observe the unique and irreplaceable Petroqlyphs over the past 10 years. And I have witnessed the steady illegal intrusion by OHVs into this area, creating a worn entry road that has at this time been developed to a point 

just below the arc site and has continued below as well making a illegal loop around the mesa that shelters the site. I suggest that barriers be constructed to block entry and that the two track illegal road be re- vegetated. 

Ad

Travel Management – OHV Route Identification 

Tom Grant The Squaw Trail. Under the proposed plan "B" the top of this trail would be 

opened to ATV traffic. Although it is currently closed, I see regular evidence of ATV use. This includes tracks not limited to an old road heading out to the "bench" and the Kanab Overlook, but tracks all over the top of the plateau, without regard to any trails. 

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Travel Management – OHV Route Identification 

Tony Wright All of the roads that lead down to the Virgin River, below the Barracks, in 

"Alternative B", are proposed to be closed. This will eliminate all the accesses for anyone to see the beautiful Virgin River as it winds its way down the canyon through the White Cliffs. 

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Travel Management – OHV Route Identification 

Tony Wright You may say that hikers will visit this area. But they will have to travel about 15 to 

20 miles in an O.H.V. before being able hike to the river on the Poverty side of the Virgin River. It would eliminate the general public from seeing one of the best 

Indian Pictographs in our area, because of the hike into them, about 3 miles one 

way. 

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Travel Management – OHV Route Identification 

Tony Wright On the south side of the Virgin River, you are proposing to close the Rock Creek 

accesses road. This road has been in existence for over 30 years, and I personally traveled down this road in 1972 with a group of 10 people who were camping and sightseeing in the area in our O.H.V.'s. This is also, considered a RS2477 road claimed by Kane County. It is my understanding that a RS2477 road cannot be closed except by court order and there have been no cases in the 

court, to date, that have changed this ruling. 

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Travel Management – OHV Route Identification 

Tony Wright This is the access that hikers use when they travel down Fatmans Misery 

Canyon to the Virgin River, they then travel up stream and come out at their 

O.H.V.'s at Rock Creek for the trip home. This closure would make them hike another 4 to 5 miles in the deep sand. It would also keep any handicaped people from seeing the great site off of the end of this road down to the Virgin. 

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Travel Management – Tony Wright I have heard from an employee of the B.L.M. that the Rock Creek road is being T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

OHV Route Identification 

closed because there has been some damage to the area out on the end. Wouldn't it be better to put up a fence around the end of the road, so that people 

can not go any further than where the road ends? This seems like a better 

alternative than to close the road to everyone, who would like to enjoy it. 

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Travel Management – OHV Route Identification 

Tony Wright Hells Dive Canyon has some of the premier Indian drawings and Grinding Stones 

in this area, and to close them off from the public would be a crime. I would 

suggest that the B.L.M. use this area as an interpretive site, somewhat like the 

one in Indian Canyon where people could go and enjoy these great sites without damaging them. This should be a relatively easy project with help coming from both the Hiking and O.H.V. community. This would also keep another Kane Co. RS 2477 road open for public use. 

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Travel Management – OHV Route Identification 

Tony Wright All of the roads that lead down to the Virgin River, below the Barracks, in 

“Alternative B”, are proposed to be closed. This will eliminate all the accesses for any one to see the beautiful Virgin Riveras it winds its way down the canyon 

through the White Cliffs. You may say that hikers will visit this area. But they will have to travel about 15 to 20 miles in an O.H.V. before being able hike to the river on the Poverty side of the Virgin River. It would eliminate the general public from seeing one of the best Indian Pictographs in our area, because of the hike into them, about 3 miles one way. 

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Travel Management – OHV Route Identification 

Tony Wright On the south side of the Virgin River, you are proposing to close the Rock Creek 

accesses road. This road has been in existence for over 30 years. This is the access that hikers use when they travel down Fatmans Misery Canyon to the Virgin River, they then travel up stream and come out at their O.H.V.’s at Rock Creek for the trip home. This closure would make them hike another 4 to 5 miles 

in the deep sand. 

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Travel Management – OHV Route Identification 

Tony Wright Hells Dive Canyon has some of the premier Indian drawings and Grinding Stones 

in this area, and to close them off from the public would be a crime. I would 

suggest that the B.L.M. use this area as an interpretive site, somewhat like the 

one in IndianCanyonwhere people could go and enjoy these great sites without damaging them. 

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Travel Management – OHV Route Identification 

Tracy Hiscock The BLM RMP recognizes and allows use of numerous short, spur routes which 

lead to the boundaries of legislatively protected areas such as Wilderness Study 

Areas, Zion National Park, Bryce Canyon National Park, and Grand Staircase/Escalante National Monument, where continued motorized travel onto 

such adjacent lands is prohibited. All such spurs should be closed under the RMP because they only create opportunities for illegal behavior resulting in resource damage. 

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Travel Management – OHV Route Identification 

Utah Rock Art Research Association 

We believe the only OHV road that should provide access to this area is the current trail that starts from Highway 237 and proceeds through Elephant Gap to the rim of the East Fork of the Virgin River and then proceeds east along the river 

to Mount Carmel. The many other trails in this area, both east and west and on 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

the north side of the river, should be closed. This will provide the most appropriate level of protection for the area rich in archeology and wilderness resources. 

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Travel Management – OHV Route Identification 

Utah Rock Art Research Association 

As a result we believe that the proliferation of OHV routes in the area needs to be carefully considered. Those that provide direct access to important cultural 

resource sites should be closed at least one quarter mile from sites eligible for NRHP status. 

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Travel Management – OHV Route Identification 

Wayne Cox I strongly disagree with the proposed road closures in the Barracks and Poverty 

BLM areas. These roads have existed for decades and should remain open to the public. I have traveled these roads my whole life, with my father and siblings, 

and now with my own family. For many people, these roads are the only access to certain areas along the Virgin River. I feel there are many benefits to leaving these roads open. 

TicR

Travel Management – OHV Route Identification 

Western Watersheds Project, Inc. 

The DEIS/RMP should provide or reference more specific details concerning motorized and non- motorized designations and designated travel routes 

including the total and percentage of acres and their condition within: .each stream drainage or subbasin; aoverlapplnq livestock grazing allotments, 

aoverlapplnq special designation area (ACECs, WSAs etc) asensitive areas such as fragile soils, sensitive wildlife habitats .and those acres of sensitive values affected by motorized and non-motorized and travel route proposals. 

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Travel Management – OHV Route Identification 

Western Watersheds Project, Inc. 

BLM has not adequately analyzed the direct, indirect and cumulative effects of the RA's road and trail network, the huge number of closed roads and trails that continue to be used illegally by ATVs and dirt bikes, and the incidence of newly created, illegal routes. There has been no analysis of road density effects. 

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Travel Management – OHV Route Identification 

Zion National Park As part of the Preferred Alternative for the FRMP, we ask that the KFO designate 

specific roads and/or trails for mountain bike use. 

TnD

161 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Vegetation ECOS Consulting What are these treatments? The BLM must provide a list of proposed treatments, 

a detailed description of them, and the direct , indirect, and cumulative impacts that they entail. 

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Vegetation ECOS Consulting The BLM must show an analysis of why particular habitats have become 

degraded, and provide maps of the locations of degraded areas and proposed "vegetation treatments". 

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Vegetation ECOS Consulting Casting the vague term "vegetation treatments" as the remedy to most of the 

impacts of proposed management actions is arbitrary, and in direct violation ofNEPA, and must not be used in this Kanab DRMP/DEIS. 

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Vegetation ECOS Consulting The BLM is proposing to manage the resources by “vegetation treatment” of an 

average of 22,300 acres a year, or over 88% of the total area of the decision area in the next 20 years. This appears to be an arbitrary and excessive figure for which no basis is provided in the Draft RMP/EIS. 

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Vegetation ECOS Consulting Vegetation treatments over 22,300 acres a year is excessive and over the life of 

this management plan would cover the whole Decision Area. This is intensive management at its worst because of the long-term negative impacts to soils 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

(destruction of BSC's and compaction) and potential natural vegetation communities. 

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Vegetation John Veranth Section 3.2.5 Regarding Non-native and Invasive Plants, there is inadequate 

attention paid to this issue throughout the RMP specifically in regard to effects of 

motorized recreation surface disturbance and grazing. Eradication efforts are the 

only way to deal with invasive plants. An aggressive program to control Russian olive, tamarisk, and other non-native invasive plants needs to be part of all alternatives. Active invasive plant control programs in Glen Canyon NRA and in 

GSENM will benefit from upwind / upstream control on Kanab RMP mananaged lands. This is only indirectly addressed in the listed alternatives as part of the vegetative treatments. 

Tniar

Vegetation Laura Welp With this in mind, I recommend that the plan not put minimum acreages for 

restoration in the plan alternatives. As recent history has shown on the Grand 

Staircase Escalante National Monument, putting minimal acreages in the plan and projecting that you'll get X number of acres done in your annual objectives 

puts pressure on the BLM to implement projects when it might be better to wait, or re-design a project to do fewer acres. 

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Vegetation Merlin Esplin Page 2-9 discloses that" ... preventing net loss of properly functioning sagebrush 

steppe habitat" is one of the objectives listed under vegetation. What is meant by this statement? Do you intend to try to have more sagebrush? Do you want pure stands of sagebrush, or un-evenaged stands, etc.? Perhaps the answer to my question is on page 217? 

Tda

Vegetation U.S. Fish and Wildlife 

Service, Utah Field Office 

Page 2-42, Section 2.4.1, Vegetation Restoration Treatments (first row): Under the preferred alternative, up to 80% of the total acres would be treated over the 

life of the plan (4% x 20 years). This time frame (20 years) may not allow 

sufficient time for vegetative communities to develop a full range of age classes and diversity, depending in part on the habitat type. This is especially true for 

long-lived species and for maintaining old growth. Consider removing the minimum requirement for vegetation treatments and allowing managers to implement appropriate acreages given habitat and climatic circumstances. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Vegetation U.S. Fish and Wildlife 

Service, Utah Field Office 

Page 2-43, Section 2.4.1: Alternative B, consider adding the following factor: "Restore special status species habitats to achieve long-term conservation and 

recovery objectives." 

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Vegetation Walter Fertig Vegetation treatments: I think setting numeric goals of 51% or 76% or more of 

lands at a state of "potential natural community" is an unrealistic management expectation. Potential natural community is essentially the "climax" state for a specific vegetation type and is more of an abstraction than a biological/ecological reality. A better (and more realistic) goal would be to manage BLM lands to have a mix of seral states - including early, mid, and late successional and PNC conditions. This would allow for the maximum diversity of wildlife and plants, provide a mixture of habitats for forage and cover, and improve fire/fuel management. The BLM should develop vegetation management plans to ensure this range of natural variability using existing grazing allotment boundaries, or develop vegetation management zones analogous to those proposed for recreation management. 

Tooo

Visual Resources Brent Gardner In Kanab Creek Canyon, approximately 2 to 3 miles North of Kanab on the East 

and West sides of Highway 89, water is derived from the Navajo Sandstone formation. These areas, where underground water resources are being developed, are classified as a Class III visual resource in Alternative B and Class I, II, and III in Alternatives C & D. This would be too restrictive for water development with its associated wells, access roads, and power lines. Alternative A, with its class IV designation, is preferred in this area. 

TpIfs

Visual Resources Bryce Canyon 

National Park 

The scenic values in and around Bryce Canyon National Parks is well known and is a primary park purpose. We believe that the appropriate Visual Resource Management objective in the Resource Management Plan in the vicinity of Bryce Canyon National Park should be VRM Class I, or "To preserve the existing character of the landscape. The level of change to the characteristic landscape should be very low and must not attract attention." The VRM objective should be no less than similar BLM-managed National Monument lands near Bryce Canyon with a VRM Class II, where the objective is "...to retain the existing character of the landscape. The level of change to the characteristic landscape should be low. 

Management activities may be seen, but should not attract the attention of the 

casual observer. And changes must repeat the basic elements of form, line, color, and texture found in the predominant natural features of the characteristic 

landscape." 

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Visual Resources David Armbruster There is no clear definition of the Visual Resources Management (VRM) in the 

DEIS. The DEIS states that "To the extent practicable, bring existing visual contrasts into VRM Class conformance as the opportunity arises." This statement is far too vague and subjective to be useful. I believe this language should be eliminated unless the specific Management Action to be done is defined. 

TR

Visual Resources James & Lorna Sills Visual Resources Management Classes (VRM) The DEIS page 2-58 states" To T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

the extent practicable, bring existing visual contrasts into VRM Class conformance as the opportunity arises. What is meant by "To the extent practicable"? This is too vague and subjective regarding what the Management Action is. Unless the Management Actions are properly defined, we are opposed to the designation of VRM Classes as shown in Alternate B. 

R

Visual Resources PacifiCorp The foIlowing statement is included in Appendix A, Page, 5 Reducing Impacts to 

Visual Resource Management Class II and III Areas BuIlet 4: "paint all above ground structures". This statement contradicts the statement in Chapter 2, 

Section 2.4.1, Lands and Reality Table where it states "Construct power lines using non-reflective conductor. Towers would be constructed using non-reflective material". 

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Visual Resources SUWA The Kanab Field Office should ensure that scenic value is a resource that will be 

conserved and must establish clear management direction describing areas 

inventoried and possessing high scenic importance with clearly defined objectives that limit surface disturbance within important viewsheds. 

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Water Resources Barry Clarkson 

Clarkson Draper & Beckstrom, LLC 

A third issue which was not addressed in any way in the RMP is that of water rights and access to points of diversion. The fact is that there are many water 

rights which exist on the public lands in question. The point of diversion of several water rights also lie within the affected parcels of public land. Yet, the RMP makes no mention whatsoever of access points and use by those who hold said water rights and/or points of diversion. In order for a full and accurate assessment of the true impacts of the RMP the issue of water rights must be addressed. A map needs to be included which shows the existence of any and all water rights and/or points of diversion located upon the public lands. Said map should also include authorized routes to access and to use the water rights identified. 

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Water Resources ECOS Consulting The results of past monitoring, showing trends, must be presented in order for 

the public to determine if these areas are being properly managed, and if not, 

what mitigation needs to be done to improve conditions. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

D

Water Resources ECOS Consulting It is highly recommended that the BLM take the time to complete WPM's for at 

least the major watersheds within the Kanab Decision Area before this Kanab DRMP is finalized. 

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Water Resources ECOS Consulting Have there been any peer-reviewed reports? If so, this data should be 

summarized in this DRMP/EIS, so that the public can assess trends and whether or not the BLM is effectively managing this resource. 

TGp

Water Resources ECOS Consulting In this DRMP/EIS, the BLM must show plans to be proactive in assessing water 

quality trends and identifying sources of water quality deterioration. Waiting for 

water bodies to be included on the 303(d) list is ineffective management and may be too late for many systems. 

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Water Resources ECOS Consulting This includes Cottonwood Canyon for the Fredonia water supply, and the 

watersheds serving Kanab, Panguitch, Hatch, Orderville, Escalante, Glendale, Tropic, Big Water, and Boulder. Are there any additional safeguards for these watersheds? If so, what are they, and they should be listed in this DRMP/EIS. 

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Water Resources Five County 

Association of Governments 

These are valid existing rights held by private citizens or corporations. Access to these valid existing rights should not be constrained by administrative use designations that allow use only by federal employees. Holders of valid state water rights should be allowed access. 

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Water Resources L. Edward Robbins 

Kane County Water Conservancy District 

While a good number of these are accessed by roads which would not be affected by any alternative under the RMP, there are certainly many whose primary access is by way of roads which are addressed by one or more of the 

alternatives considered under the RMP, and again, we are unable to determine from the RMP the extent to which water-related access was considered, if at all, in evaluating the alternatives under the RMP. 

Tda

Water Resources Laura Welp However, I'm confused that the area around Zion National Park has no such 

restrictions, although that area is within the watershed for the park and for the town of Springdale. This seems inconsistent. Watersheds providing water for all 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

towns in the management area should have the same restrictions. d

Water Resources Mark Sterkel A concievable end result of escalating OHV abuse in the Lake Powell watershed, 

not addressed in DRMP, is the increase in siltation that results from all the erosion from all those machines churning in & out of formerly unimpacted & remote canyons and drainages. Lake Powell will fill up with sediment faster, if the BLM doesn't get control of and manage OHV use shouldn't burec be concerned? 

BDrwu

Water Resources Merlin Esplin Another objective under the same heading is to "Ensure water availability for 

multiple-use management and functioning, healthy riparian and upland systems." What do you mean by this and where will you get the water rights, considering BLM has no way to put the water to "beneficial use" as required by state law to hold water rights? 

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Water Resources Merlin Esplin Under Water Resources on page 2-37, I believe some statement about working 

with the State of Utah on these issues would be appropriate since the state has the principle responsibility to protect water quality, etc. as it relates to the division 

of Oil, Gas, and Mining. 

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Water Resources Norris Brown 

Kanab Irrigation Company 

The areas north of Kanab City, involving all of the Kanab Creek drainage has had 

a serious erosion problem that impacts the Kanab City. The Kanab Irrigation Company is the major stock holder in the Kanab Creek drainage and we need access to maintain our water right of ways. It will also effect UDOT road highway 89, sportsman and livestock permits. The NRCS (soil conservation) have been cooperative with the Kanab Irrigation company and KCWCD to establish a reeseding project to reduce the erosion and silt in the Kanab Creek and stabilize the water supply. We feel that now is not the time to close down the access to these areas of Kane County, but to join and cooperate with local and national agencies to improve and restore these vital resources of water and range management. Limiting access will severely hurt managing our water right of ways. 

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Water Resources Susan Hand Oil and Gas Leasing I appreciate the more restrictive guidelines for oil and gas 

leasing in the vicinity of Kanab as imposed by Alternative B. This is especially important to protect our community watershed. It would seem that the watershed for Zion National Park and the town of Springdale--indeed any community watershed--are equally deserving of protection. 

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Water Resources Western Watersheds 

Project, Inc. 

BLM in relying on the State of Utah to list streams in its TMDL process, is 

abrogating its responsibility to manage so that water quality standards are met. A copy of thatJ vJfirT review is included as Appendix 3. 

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Wild and Scenic Rivers 

BLM - Arizona Strip Field Office 

Appendix G, Wild and Scenic Rivers, Pages AG-36 and 37 This section on the Paria River Wild and Scenic River status fails to mention the recommended Wild and Scenic River status for this river in either Grand Staircase-Escalante National Monument or in Vermilion Cliffs National Monument. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Wild and Scenic Rivers 

John Veranth Regarding Wild and Scenic river segments the segments listed in Alternative C 

all are appropriate. Appendix G, I disagree with the statement that the geologic formations in the North Fork of the Virgin River, East Fork of Virgin River, 

Orderville Canyon etc are not rare or unique. The fact that the same geologic formation occurs elsewere in the area does not address the specifics of a canyon with Class A scenery. 

AS

Wild and Scenic Rivers 

L. Edward Robbins Kane County Water Conservancy District 

However, the District would add that there is no adequate factual basis on which long-term or permanent management of any of the proposed river segments could give rise to a federal reserved water right, and no legal basis on which any river segment upgradient from Zion National Park could be found to carry any federal reserved water. The District is a signer of the 1996 Zion National Park Water Rights Settlement Agreement. This Agreement entirely settles the issue of federal reserved water rights with respect to all waters which are upgradient from Zion National Park. The District reiterates its earlier position that at least with 

respect to those waters which are upgradient from Zion National Park, the entire wild and scenic rivers process is flawed since the issues inherent in that process have already been settled contractually by the United States, the State of Utah, and other entities including the Kane County Water Conservancy District. 

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Wild and Scenic Rivers 

Mark Sterkel Page AG-8 shows Birch Creek, 5 miles west of Escalante, as not having potential 

(let alone existing) outstanding remarkable value. A quick field visit will indicate that Birch Creek is a recovering riparian area, functioning under risk. It is a stunning, stark, beautiful canyon & stream corridor, wth high brownish-yellow scuplpted & block cliffs, archaeo & paleo resources, year round stream flow & associated flora/fauna. Views of the Escalante Monocline and distant Henry Mtns. can be seen from the old-growth pinyon-juniper benches. Birch Creek is recovering from 150 yrs. of grazing abuse. The DRMP should protect it as WSR, 

or at least an ACEC. 

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Wild and Scenic Rivers 

Merlin Esplin Page 2-3, 2-28, and elsewhere discuss the desire or apply "protective 

management" to seven river segments by recommending them to be included in the national Wild and Scenic Rivers system. Once again, I question why this is 

even needed or desired. Current policies and laws give ample authority to the protection of all resources along or near streams or anywhere on public lands. 

SmpirPpWR

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Wild and Scenic Rivers 

Merlin Esplin In particular I question the Meadow Creek/Mineral Gulch segment. Man's 

influence certainly is limited, practically non-existent, except for a couple of short fence segments, however, I doubt these canyons meet the real intent of the 

congressional directive. I realize there are no diversions within the segment listed, however water is damned and diverted above the segment and water rarely flows through the segment. 

AS

Wild and Scenic Rivers 

Merlin Esplin Some of the river segments listed for inclusion in the National Wild and Scenic 

Rivers system flow through Zion National Park, which is very scenic. However, if one wishes to see a flagrant misinterpretation of the Wild and Scenic Rivers Act 

(WSR), look at the number of segments in Zion where "man's influence" is 

certainly more than "temporary". Numerous rock walls, trails, rip-rap of various sorts, and roads are the rule along the Virgin River - not the exception. Please follow the intent of the law when considering river segments to recommend for inclusion in the Wild and Scenic Rivers system. 

SmpirPpWRtmf

Wild and Scenic Rivers 

SUWA The East Fork of the Virgin River, through Parunuweap Canyon, has been found 

eligible with the classification of "wild" (Segment 37-40a). DRMP/EIS 2-104. The preferred alternative would downgrade this classification to "scenic," perhaps to allow the BLM to add some facilities along the primitive way through this section. However, this section is already within a WSA, and as such, should be managed to the IMP standard. SUWA urges the BLM to classify this section as ''wild,'' which is appropriate within a WSA. 

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Wild and Scenic Rivers 

Utah Rivers Council However, the Council respectfully disagrees with failing to include several rivers 

in that recommendation and with the classification of two segments in the 

preferred alternative. The Council supports all of the following rivers as suitable to become Wild and Scenic Rivers with the classifications listed: *North Fork Virgin River segment 48-49: Wild *North Fork Virgin River segment 46-47: Recreational *Orderville Gulch and Esplin Gulch: Wild *Meadow Creek and Mineral Gulch: Wild *East Fork Virgin River segment 36-37a: Scenic *East Fork Virgin River segment 371-41: Wild *Paria River: Wild *Kanab Creek segment 7-8: Wild *Kanab Creek segment 8-9: Wild *Kanab Creek segment 9-10: Scenic *Bob Creek: to be determined *Tiny Creek: to be determined 

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Wild and Scenic Rivers 

Utah Rivers Council The Council urges the Kanab Field Office to give these segments the 

classification that they were given in the Draft Evaluation Report, which is the same as that given in Alternative C on page 2-104 for segment 37-40a. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Wild and Scenic Rivers 

Utah Rivers Council But then the Draft goes on to muddle the clear language of the Wild and Scenic 

Rivers Act by finding segment 37-40a of the East Fork Virgin River "wild" in alternative C and "scenic" in alternative B. Similarly, segment 36-37 of the East Fork Virgin River was found to be "scenic" in the Draft Evaluation Report and "recreational" respectively in Alternative B of the Draft RMP. All of these segments are downgraded in the preferred Alternative, Alternative C of the Draft RMP. 

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Wild and Scenic Rivers 

Utah Rivers Council The tentative classification given to East Fork Virgin River segments 36 through 

41 in the 2005 Draft Evaluation Report is based on the actual development and accessibility to the river at the time of the study. Thus, this is the classification that these segments should be given in the suitability determination. Downgrading the classification of these segments is not consistent with current 

development and simply opens them up to future threats that may negatively harm the outstanding values of these rivers. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Wild and Scenic Rivers 

Utah Rivers Council The Council requests that the Kanab Field Office respond to and incorporate all 

of the comments on the Draft Evaluation Report, and make those publicly available. 

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Wild and Scenic Rivers 

Utah Rivers Council Regardless of the Kanab Field Office's eventual or potential designations of river 

segments, the identification of all qualifying sections is required and should be 

completed objectively without predecisional influences. We kindly request that the Kanab Field Office properly revaluate the eligibility of those streams found 

ineligible in the 2005 Draft Evaluation Report, including but not limited to: North Fork Virgin River segment 46-47, Bob Creek, Tiny Creek, and all segments of Kanab Creek. Additionally, we request that the Kanab Field Office fully disclose the results of the revaluation to the public. 

TPoSrcta Aded

Wild and Scenic Rivers 

Utah Rivers Council The Council requests that those streams dismissed from being evaluated for 

eligibility due to their being ephemeral be reconsidered in the evaluation based on this and a more appropriate evaluation of ORVs. These rivers are not limited to the following: *Fisher Canyon *Robinson Creek *Sink Valley Wash *Trail Canyon *Pugh Canyon *Maranger Canyon *Oak Canyon *Dairy Canyon *Dry Wash *Peterson Wash *Butler Wash *Bunting Canyon 

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Wild and Scenic Rivers 

Utah Rivers Council However, the Kanab Field Office did not follow this regarding the eligibility of 

segment 46-47 of the North Fork Virgin River. For example, in their evaluation of the North Fork Virgin River, when looking at ORVs, "Wildlife -Spotted Owl designated critical habitat is present; however, checkerboard ownership makes management difficult." Checkerboard ownership is not something that should be considered in the eligibility phase. Furthermore, this segment possesses spotted owl habitat, which means that this segment has a wildlife value. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Wild and Scenic Rivers 

Utah Rivers Council The Council concurs with the Kanab Field Office that all segments of the East 

Fork of the Virgin River are suitable to become a Wild and Scenic River. However, the Council respectfully disagrees with the Kanab Field Office regarding classification of the segments. The Council recommends the East Fork Virgin River be found suitable with the following classifications: *East Fork Virgin River segment 36-37a: Scenic *East Fork Virgin River segment 371-41: Wild 

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Wild and Scenic Rivers 

Utah Rivers Council This change in classification of segment 37-40a makes no sense based on the 

development and accessibility to the river. As stated in the Draft RMP, classification of a river segment is based on the type and degree of human development associated with the river and adjacent lands at the time of inventory.12 

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Wild and Scenic Rivers 

Utah Rivers Council Therefore, instead of downgrading the classification of the entire segment from 

Wild to Scenic it could be resegmented in order to better reflect the reality on the ground. The Council requests the E Fork Virgin River be resegmented from point 

38 upstream to where the road leaves the corridor, point 37a, as Wild, then have 

the next part of the segment upstream to 37 as Scenic. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

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Wild and Scenic Rivers 

Utah Rivers Council The preferred alternative proposes to designate a road along the East Fork of the 

Virgin River, specifically along segment 36-37a. This proposed road crosses the river numerous times during its course along the East Fork Virgin River.13 We request that this entire proposed road along the river corridor be closed in order to protect the outstanding values of the East Fork of the Virgin River. 

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Wild and Scenic Rivers 

Utah Rivers Council Therefore, the Council requests that the Kanab Field Office close the proposed 

road that follows the East Fork of the Virgin River in order to be consistent with the intention of the Wild and Scenic Rivers Act and protect the values for which the East Fork Virgin River is being recommended as suitable to become a Wild and Scenic River. With the closure of the proposed road we request that the East 

Fork Virgin River be found suitable and classified as follows: *East Fork Virgin River segment 36-37a: Scenic *East Fork Virgin River segment 37a-41: Wild 

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Wild and Scenic Rivers 

Utah Rivers Council The Council reiterates the same concerns that we expressed in comments 

submitted to the Kanab Field Office on the Draft Evaluation Report in a letter dated January 27, 2006. The Council respectfully disagrees with the Kanab Field Office's determination that Kanab Creek is not eligible. The Council strongly recommends that the entire length of Kanab Creek be found eligible for wild and scenic status as classified below: *Segment 7-8 from the falls to the BLM boundary in the northeast corner in section 32- Wild *Segment 8-9 from the falls at T.40S., R.6W., Sec.35 to T.41S., R.6W., Sec.33 - Wild *Segment 9-10 - from point 9 to the Highway 89 crossing - Scenic 

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Wilderness Study Allen Gilberg The proposed play area in the Moquith Mountain WSA would become a sacrifice T

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Areas area – and would damage that area irreparably. Non-motorized visitor use on 

BLM lands is larger – in visitor days – than are visitor days by ATVs and ORVs. But the damage created by motorized visitation is much, much greater. 

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Wilderness Study Areas 

Charles and Nancy Bagley 

The chart of WSA Management options, page 2-110, shows for your preferred Alternative B that 1100 acres of Moquith Mt WSA will be open to cross-country 

OHV use. This is an increase from current management (No Action) that allows 730 acres of such OHV use. Yet your Objectives for WSA management (2-30) are stated in the first sentence: "Manage WSA's in a manner that does not impair their suitability for designation as wilderness." Obviously, allowing 1100 acres of cross-country OHV use in a WSA will impair its suitability for wilderness designation!! Your plan fails to meet your stated objectives. 

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Wilderness Study Areas 

Christopher Lish I am extremely upset that the BLM's plan will allow 1,100 acres of the Moquith 

Mountain WSA to be used as an ORV recreation area, where vehicles would be allowed to travel anywhere on these lands which have otherwise been found suitable for wilderness designation - unnecessarily putting at risk the sensitive plant and invertebrate species that have been found in this area, as well as the 

wilderness values that the agency is charged to protect. 

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Wilderness Study Areas 

Connie Ball It is noted in the RMP that there are incursions into Wilderness Study-Areas 

which the BLM is required under the law to protect as wilderness until Congress acts on those areas. Most notably there-are- proposed Of existing ATV trails into areas such as Moquith Mountain and Coral Pink Sand Dunes. Any ATV trails in these areas as well as areas of critical environmental concern must be protected to the fullest extent possible, and as required by law, and to a degree greater 

than your RMP calls for in any of the Alternates. It should also be noted that the 

BLM should have assessed the impact of ATV's on global warming and their impact on regional air quality. Certainly the Wilderness Study Areas are adversely affected by ATV emissions, plant destruction and erosion from soft tires cutting deeply into soil, and wildlife disturbance from the high decibel level of the engines. Again, these vehicles should not be allowed at all in all such areas. 

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Wilderness Study Areas 

Connie Ball As a citizen of the area concerned about the welfare of the wildlife, including the 

protection of the Coral Pink Sand Dunes tiger beetle which is a candidate for Federal protection under the Endangered Species Act, which is threatened by ATV's, according to the State of Utah's Division of Wildlife Resources, I request that the BLM go beyond Alternative C in restricting ATV's t-o very small and already destroyed areas and to strictly enforce the candidate areas for Wilderness Study Areas as well as the existing Wilderness Study Areas, by disallowing all ATV traffic. 

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Wilderness Study Areas 

Jim & Bonnie Vann It is my belief that there are several current areas with inappropriate Wilderness 

Study Area designations. I believe that these are either the result of previously flawed inventories, or an intentional act by the BLM to create de-facto wilderness in areas that clearly do not qualify. This thought would hold true as well for lands 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

with Wilderness Characteristic designations. I do not believe it is appropriate for the BLM to attempt to manage these lands as if they have already been approved by Congress as Wilderness Areas. Some of these areas would include Kanab Creek, Four Mile Creek, and Sheep Springs. There are numerous areas of both WSA and lands with Wilderness Characteristic that clearly have machine built roads on them prior to 1976 that a simple review of Kane County aerial maps will confirm. 

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Wilderness Study Areas 

Land Use Volunteers of Kane County 

The Kanab BLM has been unable to curb illegal ORV activity and resulting damage to wilderness quality lands within its jurisdiction; therefore, no 

designated routes should be placed within areas identified to be of wilderness quality by the 1999 BLM Wilderness Inventory or in existing Wilderness Study Areas. 

Tpa

Wilderness Study Areas 

Land Use Volunteers of Kane County 

The current BLM inventory is inadequate and does not include or accurately map 

the distribution of many of the archeological, botanical, wildlife, cultural, and ecological resources present in WSA's or wilderness characteristic areas. Designating hundreds of miles of travel routes will impact these resources over time. Even if there are not designated routes in the WSA's and other wilderness characteristic areas, there will probably be extensive illegal travel by ORV's. This inventory needs to be completed before the final version of the RMP is approved , so that the BLM can monitor the impact of ORV's over time in these sensitive areas. 

Tpa

Wilderness Study Areas 

Land Use Volunteers of Kane County 

Both the Kanab BLM and the Land Use Volunteers of Kane County have documented evidence of persistent and increasing damage being done to this WSA by OHVs. No designated motorized routes should be placed within the Moquith Mountain WSA. 

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Wilderness Study Areas 

Land Use Volunteers of Kane County 

Given the wilderness quality of this land, and the laws governing the preservation 

of resources within a WSA, it is inappropriate to place designated transportation 

routes in the area. Both the Kanab BLM and the Land Use Volunteers of Kane County have documented evidence of persistent and increasing damage being done to WSA's by OHV's. No designated motorized routes should be placed within the Parunuweap WSA. 

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Wilderness Study Areas 

Laura Welp I commend you for making the difficult decision to close some roads in the 

WSAs. However, there should be no designated routes in wilderness quality 

lands because they degrade the wilderness quality of those areas, which is contrary to the BLM's charge to maintain wilderness characteristics. 

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Wilderness Study Areas 

Laura Welp However, as with other WSAs in the project area, there are roads open to OHV 

use throughout, which is incompatible with wilderness designation that Congress might make in the future. Activities in WSAs must create no new surface disturbance, but as the attached photos show, Sand Springs, Coral Pink Sand Dunes, and the Moquith Mountain Loop all show OHV damage that has not been 

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175 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

confined to designated areas. 

Wilderness Study Areas 

Laura Welp I understand that this is a popular campground and provides convenient OHV 

access to the dunes, but its proximity to the wilderness study area is problematic. 

These photos show OHV use within the WSA closed area, well within sight of signs indicating that the area is closed. I suggest moving the campground to a 

location with less impact to the WSA. 

Mw

Wilderness Study Areas 

Lynn Hague Alternative B is off-base in proposing an "open" area for ORVs on 1,100 acres 

within Moquith Mountain Wilderness Study Area in the Coral Pink Sand Dunes. Wilderness values should come first in the WSA. ORVs can romp in the Coral Pink Sand Dunes State Park, where 1,000 acres are already open to them. 

A C

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Wilderness Study Areas 

Lynn Hague We also urge BLM to close ORV routes that are degrading wilderness values 

within WSAs on the Moquith Mountain loop and on Canaan Mountain. 

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Wilderness Study Areas 

Ray and Sharon Wells Paruunuweap WSA road closures: 1. West end of the main road leaving the state 

section to be closed was in fact a machine built road that had to have been built 

prior to the 1976 WSA proposal T0410S - R0090W Sec. 33,34,35 2. The southwest road, which doesn’t even show on the work maps, to be closed south of the state section goes over slick rock down to an area suitable for parking then walking down towards the river to a unique petroglph panel T0420S - R0090W Sec. 11 3. The southeast road to be closed used to be a part of a connecting road that crosses the Virgin River and goes up the south side to what is called 

steep trail. T0420S - R0090W Sec. 12. All of the above roads were inventoried pre- 1976 by Kane County road department. Which leads me to believe that the WSA really should not qualify to even be a WSA. If I’m not mistaken WSA’s were supposed to have wilderness characteristics before becoming a WSA, not developed into WSA’s by closing existing roads after the fact. I also believe it states in managing WSA’s, existing roads in a WSA are not to be closed just because they are in a WSA. 

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Wilderness Study Areas 

Ray and Sharon Wells South of Virgin River - Parunuweap WSA 1. Rock Canyon road. The most 

western road on south side of the Virgin, to be closed from state section to the view point above the river and the Barracks. This is another Kane County pre 1976 inventoried road. It is approximately two miles from the proposed closure to the view point above the river. This is a view point that is frequently visited and 

closing the road two miles up from the view point would eliminate the use of this area from all but the few people willing and able to hike the distance. This would be managing the area for a select group of people, not the majority. T0420S - R0090W Sec. 11,14, 15 2. Steep trail, the short road on the south side of the river which is the south half of the road coming out of Poverty across to the sands. A short road offering a good view of the river, Barracks and Poverty. T0420S - R0080W Sec. 18 

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Wilderness Study Ray and Sharon Wells Moquith WSA 1. Southeastern road leading to Lamb’s point view area goes to T

176 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Areas and through Arizona boarder, to two beautiful view points, one being the Bee 

Hives, and overlook, from atop the Vermilion Cliffs into the Arizona Strip. The 

Bee Hives area is very interesting and the view fabulous. The road continues back into Utah, to Lambs Point. Another beautiful view toward Fredonia from above the Vermilion cliffs. Note, this road also does not appear on the BLM work maps! Few people drive there almost no one will ever walk there. What a loss, let 

alone, I was told that the BLM has evidence that this road was built in the 1950’s by a Kanab resident, probably to access the area for a cattle operation. T0440S - R0080W Sec. 12 2. Hell Dive road closure east of the state section fairly steep and sandy leads to a turn around area,where a short steep walk takes you to a beautiful pictograph panel, along with a big row of rocks, that are filled with 

matatees. A very special place I would suggest leaving the road open to the turn around area then possibly an informative sign explaining the significance of the 

area. T 0430S - R0070W Sec. 28, 29 

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Wilderness Study Areas 

Ray and Sharon Wells After inventorying and photographing, I question how the Moquith and 

Parunuweap WSA’s every managed to qualify as WSA’s in the first place. There were too many roads and other improvements that must have been overlooked at the time by the BLM to have been able to set the areas aside as WSA’s and trying to do it now in retrospect, to make these areas more suitable as WSA’s is just wrong. 

TdTso

Wilderness Study Areas 

SUWA We emphasize that continued motorized use in WSAs (i.e. "open" areas and on 

"ways" BLM proposes to designate as official ORV routes) can damage wilderness suitability and therefore should be prohibited in this DRMP under both the interim management policy and the ORV regulations. 

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Wilderness Study Areas 

SUWA The proposed "open" ORV designation within the sand dunes portion of the 

Moquith Mountain WSA is inimical to IMP management. BLM must account for soil, riparian, wildlife, vegetative, and T&E species impacts at the dunes which according to the IMP should cause the BLM to stop this use - not propose to legitimize it in the RMP. BLM must also take into account its own surveillance 

reports and other documentation regarding impacts to wilderness values in the WSA, and ensure that concerns which flow from those documents are 

addressed. 

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Wilderness Study Areas 

SUWA The DRMP/EIS provides for designation of "routes" in the WSAs. DRMP/EIS, 

p.2-43. In order to comply with the IMP, any designations should refer only to ''ways,'' rather than routes. 

Ti

Wilderness Study Areas 

SUWA These portions of the RMP set out an appropriate summary of the standards for 

managing WSAs and how those standards should apply to permitting continued use of ways in WSAs. However, the analysis and management approach set out 

in the RMP do not comply with these standards. 

Twiwat

177 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

d

Wilderness Study Areas 

SUWA This conclusion is not supported and is contradicted by the analysis of impacts in 

the DRMP/EIS and accepted science. Further, there is no acknowledgment of the important benefits to biological or environmental characteristics from closing WSAs to ORV use in the RMP's description of management of WSAs. 

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Wilderness Study Areas 

SUWA Recommendations: Leaving any portion of WSAs open to cross-county ORV use 

violates the BLM's obligations under both the IMP and the ORV regulations to protect wilderness suitability. There should be no open areas in the WSAs. 

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Wilderness Study Areas 

SUWA In order to ensure ongoing protection of the wilderness characteristics in the 

WSAs, the Preferred Alternative should provide for the WSAs to be managed to protect wilderness characteristics in the event that all or part of any WSA is released by Congress. 

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Wilderness Study Areas 

Walter Fertig Wilderness Study Areas: WSA management remains driven by needs to maintain 

wilderness characteristics until such time that Congress designates these areas as official Wilderness Areas, or releases them. These were areas BLM itself identified as having wilderness potential and qualified for Wilderness designation when they were selected. Developing travel corridors through these areas goes against the spirit of WSA management and would seem to put the BLM in violation of its own WSA policy. This needs to be reassessed before the final decision is made on the RMP. 

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Wildlife and Fish Bryant Shakespear 

Garkane Energy 

Alternative B, C, D require the use of non-reflective wore (non-specular 

conductor). Projects using non-specular conductor have had a marked increase of avian collision with the conductor and its use may be counterproductive to the avian protection measures included as part of the draft RMP. 

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Wildlife and Fish Carl Albrecht 

Garkane Energy 

Alternative B, C, and D require the use of non-specular conductor). Projects 

using non-specular conductor have had a marked increase of avian collision with the conductor and its use may be couterproductive to the avian protection measures included as part of the Draft RMP. 

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Wildlife and Fish ECOS Consulting All of these activities will adversely affect migratory birds, yet there is no mention 

of the impacts of these activities on migratory birds. The BLM must fully analyze 

the impact of these activities on migratory bird habitat. 

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baistt

178 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

Wildlife and Fish ECOS Consulting The BLM must plan for the protection of migratory birds by listing and mapping 

important habitat types, and keeping designated OHV routes and other management activities to a minimum in these areas. Natural processes must be 

allowed in certain areas, unencumbered by management activities or treatments. None of this type of planning is evident in this document. 

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Wildlife and Fish ECOS Consulting Page 4-75, 8th paragraph: Forest and woodland product harvest, cross-country 

and on-route OHV use, road construction, facility construction, mineral development and the construction of related facilities, and ROW construction all can individually have serious adverse impacts. The activities are of such intensity and seriousness that they should not be lumped together, but considered separately. Their impacts should be treated separately and then an analysis of 

cumulative impacts should follow. This is important because habitat loss, alteration, and fragmentation are the primary causes of fish and wildlife population loss throughout the country. 

BRa

Wildlife and Fish Merlin Esplin On page 2-47 under Utah Prairie Dog, the Draft RMP uses the wording, "Allow 

introduction, ...." Please ensure that any and all introductions of any species are reviewed through the public process, and that permittees are notified directly. 

Ta

Wildlife and Fish Norman McKee 2 – 12: Fish & wildlife management actions should include a beaver habitat 

inventory, along with a recommendation to re-introduce beaver in appropriate areas. 

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Wildlife and Fish Norman McKee 2 – 15: The majority of bighorn sheep lambing occurs prior to April 15 to June 15, 

usually a month earlier. 

HZtsbA

Wildlife and Fish Norman McKee 3 – 46: Does the Panguitch Valley pronghorn population also include the Sage 

Hen Hollow population? Maybe, should be clarified. The two populations are 

physically separated from each other. 

Tt

Wildlife and Fish SUWA Despite the accepted and readily available scientific study and methods, the 

Kanab DRMP/EIS fails to conduct a sufficiently detailed analysis of fragmentation, which impairs the consideration of impacts of the various 

alternatives and prevents an informed comparison. 

B

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Wildlife and Fish SUWA As in the discussion special status species, there is no analysis of the actual B

179 
Public Comments and Responses - Kanab Draft RMP/EIS 

Category Name Commentor Comment 

fragmentation of habitat that is likely to occur using standard metrics or a thorough discussion of individual species. While the data provided is relevant, it is not sufficient. Without this information, the BLM cannot fully assess the direct, indirect and cumulative impacts of the management alternatives, as required by NEPA. 

ffs

Wildlife and Fish SUWA In order to comply with the requirements of NEPA to conduct a thorough analysis 

of impacts of the management alternatives and to facilitate meaningful public 

participation and review of the DRMP/EIS, the BLM must thoroughly analyze the specific impacts of habitat fragmentation on affected species and provide a comparison of the management alternatives, as described in detail above. This analysis should include the impacts of ORVs and motorized routes, as well as roads. 

B

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Wildlife and Fish SUWA The DRMP/EIS should be revised to give sufficient weight to the benefits to 

wildlife, including special status species, from managing areas to maintain wilderness characteristics, including by reducing fragmentation. The management alternatives, including the Preferred Alternative, should include managing more lands outside WSAs to maintain wilderness characteristics. 

Tn

Wildlife and Fish Theodore Roosevelt 

Conservation Partnership 

The Kanab DEIS fails to adequately address oil and gas development and how it can be conducted in a way that does not unnecessarily impact fish and wildlife and their habitats. 

PoSw

Wildlife and Fish Theodore Roosevelt 

Conservation Partnership 

We recommend that all areas of crucial fish and wildlife habitats available for oil 

and gas leasing and without NSO stipulations should have upfront planning prior to leasing to ensure that subsequent developments will be conducted responsibly. 

T

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Wildlife and Fish Theodore Roosevelt 

Conservation Partnership 

The DEIS fails to provide a commitment to adequate fund wildlife management, monitoring, and restoration for oil and gas development projects. In times of increasing pressure from energy development on our federal public lands, fish and wildlife management needs more funding, not less. 

Tlo

Wildlife and Fish Theodore Roosevelt 

Conservation Partnership 

The BLM fails to show how it will work to maintain wildlife objectives set by the 

UT Division of Wildlife Resources (UT DWR). Any determination of areas available for leasing and the appropriate development of those leases should be done with careful consideration of wildlife management objectives set by the UT DWR. 

TcCami

Wildlife and Fish Western Watersheds 

Project, Inc. 

Pronghorn protection stipulations within Chapter 2 page 2-50 identify May 15 to June 15 as protection periods during fawning. However, based on local phenology, protective periods are too late to protect spring forbs necessary for successful fawning and lactation. Authorization should require rest from livestock 

grazing which extend from March 15 to June 15 for adequate protection of forage 

Bp

180 
Public Comments and Responses - Kanab Draft RMP/EIS 

181 

Category Name Commentor Comment 

cover and other habitat requirements. 

Wildlife and Fish Western Watersheds 

Project, Inc. 

There was no meaningful analysis of the benefits of roadless areas (WSA, Wilderness, potential, conservation/refugia, research natural areas) to wildlife, 

and how those benefits to wildlife will be diminished by the visual and sound presence of these machines across the landscape. 

Sa

Wildlife and Fish Western Watersheds 

Project, Inc. 

The same goes for protection of sage grouse nesting and brood rearing areas. Where are the criteria for sage grouse habitats as regards maintaining forb, grass and shrub canopy cover and height that are ecologically necessary? Where are important wildlife areas that support sensitive species or those listed or proposed 

for listing under the ESA. 

ADNlsf
Public Comments and Responses - Kanab Draft RMP/EIS 

Public Comments and Respons

Kanab Draft RMP/EIS 

July 2008 

Sorted by Commentor Name

Commentor Comment C

Alexander Kowalski Please include in your final RMP access possibilities for personal, noncommercial rock and fossil collecting. Restrictions on mining for commercially 

valuable minerals, and restrictions on off highway travel directly affects our ability to access remote areas and enjoy our hobby. 

All of the alternatives allo

provide the protection of categories would apply t

Allen Gilberg The proposed play area in the Moquith Mountain WSA would become a sacrifice 

area – and would damage that area irreparably. Non-motorized visitor use on BLM lands is larger – in visitor days – than are visitor days by ATVs and ORVs. But the damage created by motorized visitation is much, much greater. 

The OHV open area in thuse since during the initibeen in use without impainventoried. 

Amber Sharkey As a high school sophomore I am concerned with the closing of roads in Poverty 

and Steep Trail Areas surrounding my community. I believe that it is important to 

keep these roads open in case of emergencies and recreational activities. It is important to have extra roads in case if nature blocks roads then there will be outlet roads for emergencies. I also think it is good to have recreational areas for people can go and enjoy the out doors and the beautiful area that we have here. 

The Proposed RMP/EIS identified way open to Osegment that parallels th

Anne McKibbin I spend time each year in Utah's wild areas, particularly in the southern areas of 

the Grand Staircase-Escalante National Monument near the Cockscomb, the Paria River, and areas adjacent to (and including) the Paria Canyon wilderness. I am concerned that the BLM's Travel Plan for roads and recreational ORV use in the area would severely damage the beauty and quiet of these places. They are not appropriate places for a designated route, and I hope that you will reconsider your proposed Plan. Those of us who backpack, hike, camp, and ride horses in this area do so because of its unparalleled beauty and peacefulness. Please don't destroy that experience by allowing gasoline-driven vehicles. At the least, allow significant parcels of open space where a person can get two miles from a vehicle. Sound travels a long way in the open spaces of Utah and it would be a shame to never get out of earshot of an ORV. 

The final designated roumix of motorized use alothose designated routesblocks of non-motorized Proposed RMP does recOHV use. 

Anthony Frost After looking at the map Alternative B 2-17 I have noticed that the trail into 

poverty is on the list of being closed down to through traffic and becoming an area where only hiking will be permitted. One of the other reasons that we go 

there is to look at the scenery in our four wheel drive vehicles. There is a lot of 

country that is spectacular in this area. Many people from all around come here to look at what we have to show them. If these trails start closing then how are 

The Proposed RMP/EIS identified way open to O

1 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

they going to be able to enjoy the things that they have always loved? 

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

Finally upon my review of the maps included it has become apparent that there 

are errors in the maps as to which land falls under the RMP and in fact which 

land is public. For example, Map 2-16 shows that the BLM Property extends to the Arizona border between the Kanab City area and property owned by my client. This is incorrect. There is a strip of land along the Arizona border which is private and belongs to my client and his successors in interest. I have attached a set of maps which clearly show this to be true. 

The BLM acknowledges Arizona border is private RMP/EIS is 1:100,000 a

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

My client has access to his property ONLY through the affected lands subject to the RMP. The applicable statute requires, "A list of individuals and groups known to be interested in or affected by a resource management plan shall be maintained by the District Manager and those on the list shall be notified of public participation activities" 43 CFR 1610.2(d). It is clear that my client has a direct interest in, and is affected by the proposed RMP and yet he has not been notified of any change. 

The RMP process was in

Intent in the Federal Regradio advertisements, anKanab RMP process. In 

participation were held thand after releasing the Dthroughout the RMP probeen posted on the BLM participation was detaileRMP/Final EIS. 

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

Issue No.1; Failure to Cooperate with Local Government Agencies. As you know the RMP was prepared as a requirement of NEPA as well as FLPMA. NEPA requires that local and state governments be consulted prior to taking action. In 

the present case no report or input was included or considered from either the 

involved counties or affected cities. Failure to include a report from a local government seems to violate NEPA and the cooperative principals upon which it is based. In the event there has been some report or suggestions from local governments or officials, said information should be included in the report and identified as such. 

Both Kane and Garfield involved as cooperating Draft RMP/EIS details th

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

In the present case no individual from the community has been included in any advisory committee thus depriving the decision making process of any local flavor or information which related to historical or socio-economic impacts to the proposed changes. 

Both Kane and Garfield involved as cooperating 

Draft RMP/EIS details thregulation to include an a

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

It is impossible to respond in sufficient detail on the proposed RMP given the time before public comment is closed. 

The BLM provided the pRMP/EIS, as required by 

1610.2(E)). The standard accordance with CEQ rethe BLM planning and N

provides a 90-day comm

review and comment on available, free of charge CD, and online. In additigroups or individuals to e

2 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

comment efforts. Finally, facilitate review of the Ka

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

The RMP, as drafted, does not address in any way the issue of access for private property owners across the public lands. In fact, Option C of the RMP leaves my client as well as others completely without access to their property. 

FLPMA and 43 CFR 280property owners through 

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

Closure of roads and trails significantly affects the value of my client's property as well as his ability to use his property. Furthermore, his business, including trail rides and atv access to public lands will also be diminished. And yet, in spite of requirements to include matters of socio-economic data in any land use plan, the RMP did not include such data. 

Chapter 3 and 4 of the D

impacts of the proposed 

Barry Clarkson Clarkson Draper & Beckstrom, LLC 

A third issue which was not addressed in any way in the RMP is that of water rights and access to points of diversion. The fact is that there are many water rights which exist on the public lands in question. The point of diversion of several water rights also lie within the affected parcels of public land. Yet, the RMP makes no mention whatsoever of access points and use by those who hold said water rights and/or points of diversion. In order for a full and accurate assessment of the true impacts of the RMP the issue of water rights must be addressed. A map needs to be included which shows the existence of any and all water rights and/or points of diversion located upon the public lands. Said map should also include authorized routes to access and to use the water rights identified. 

BLM is obligated by law existing rights are obliga

lands for the exercise of which BLM's obligations that would prevent the hworks diligently with the from occurring. If the holan action that prevents tequitable compensation the context of a land use 

Betsy Shade ORVs are given far too much in BLM's Alternative B - 1,387 miles of routes 

(including 101 miles in proposed wilderness areas) and 1,100 acres of "free play" in the Coral Pink Sand Dunes, in Moquith Mountain Wilderness Study Area. There should be no "free play" area in a WSA, and all ORV routes in proposed wilderness areas should be closed and rehabilitated. Lands with wilderness character are too scarce to allow any more damage by ORVs. 

Appendix K of the Draft 

criteria used to identify athe commentor raises weduplicative routes, envirosensitivity, and current a

OHV use in sand dunes 

the WSA phase. The IMChapter 4 describes impin WSAs and non-WSA lRMP/Final EIS has been areas with wilderness chlimited to designated rou

Bill May I do not believe that the BLM should create artificial wilderness by designating it 

As an area with Wilderness Characteristic areas ... I believe the BLM should seek Out alternate methods to manage and protect the land, without giving it a WC Designation... I believe that some WC areas such as Sheep Springs, Four Mile Creek and Kanab Creek have been improperly inventoried and should not receive Such recognition. These areas have historically used machine built roads. 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

Bill May Calling a new WSA by a different name does not make it legal. 2) Please The Proposed RMP/Fina

3 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

disclose the difference in management prescriptions between "non-WSA lands with wilderness characteristics" and WSAs in the Final Environmental Impact Statement (FEIS). 3) The 1999 inventory found lands that contain extensive OHV trails to have "wilderness characteristics." If the presence ofOHV use did not impact the presence or absence of "wilderness characteristics," then by what rationale is the BLM proposing to significantly reduce OHV trails in these areas? 4) The Supplemental Environmental Impact Statement (SEIS) is utilizing the Utah 

BLM 1999 statewide wilderness re-inventory. This inventory was based on criteria that were not available for public comment and review. 

areas of non-WSA areas Proposed RMP/Final EISroutes. 

Bill May I believe that some WC areas such as Sheep Springs, Four Mile Creek and 

Kanab Creek have been improperly inventoried and should not receive Such recognition. These areas have historically used machine built roads. 

As part of BLM’s wildernperformed a combination inspections, Interdisciplin

BLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

Bill May I do not believe that group sizes should be limited to 25 people under the Special 

Recreation Permit... This number in my opinion is unrealistic and makes group events such as family picnics or scouting events impossible... I believe the rules and authorized exceptions for these SRP's should be clarified and added to Alternative B. 

The special recreation pdetermining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Bill May "I believe the information and data collected by the BLM in Table 3-26 is faulty. 

The BLM's own report indicates that critical information was not available for this Table ... In my personal experiences I don't believe the numbers to be accurate... 

Table 3-26 in the Draft Rinformation system (RMIpage 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

Bill May Special Recreation Permits: I do not believe that group sizes should be limited to 

25 people under the Proposed Special Recreation Permit... This number in my opinion is unrealistic and Makes group events such as family picnics or scouting events impossible... I Believe the rules and authorized exceptions for theses SRP's should be clarified And added to Alternative B. 

The special recreation pdetermining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

4 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Bill May I believe the information and data collected by the BLM in Table 3-26 is faulty. 

The BLM’s own report indicates that critical information was not available for this Table... In my personal experiences I don’t believe the numbers to be accurate... I Do not believe that any decisions should be made based upon this faulty table 

Table 3-26 in the Draft R

information system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition 

used among federal age

Bill May Special Recreation Permits: I do not believe that group sizes should be limited to 

25 people under the Proposed Special Recreation Permit... This number in my opinion is unrealistic and Makes group events such as family picnics or scouting events impossible... I Believe the rules and authorized exceptions for theses SRP’s should be clarified And added to Alternative B 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Bill May In addition, I believe That the BLM should recognize the RS2477 road claims that 

are part of Kane and Garfield Counties Transportation Plans ... 

The RMP does not adjudclaimed ROWs. The BLM 

elements of this RMP thracknowledged administr

Bill May ...these in my opinion should be added to Alternative B. Dry washes are an ideal 

route for OHV travel; rain erases any OHV tracts. 

Future route designationconsidered in implementAppendix K of the Draft 

BLM - Arizona Strip Field Office 

Map 2-44, General Surface Disturbance Restrictions, Alternative B Why is the Paria Canyon-Vermilion Cliffs Wilderness indicated on this map with "seasonal restrictions" for surface disturbance restrictions? Is this to accommodate fire use? Why would the wilderness not be classified as "no surface disturbing actions?" 

The Draft RMP/EIS Map 

or no surface disturbancRMP/EIS Glossary. Desnot contain a specific resdesignated wilderness mtool analysis before implthe non-impairment stanlands under Wilderness being permitted under thsurface disturbing action

BLM - Arizona Strip Field Office 

Page 2-4, under Alternative B, the Preferred Alternative, states "Require no prescriptions specifically to maintain WC areas." Why are there no prescriptions 

The Proposed RMP/Finaareas of non-WSA areas 

5 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

to maintain wilderness characteristics areas in the preferred alternative? Page 2-23 lists the objective for management of non-WSA lands with wilderness characteristics as "Maintain wilderness characteristics (appearance of naturalness, outstanding opportunities for solitude, or primitive and unconfined recreation) of WC areas, as appropriate. Manage these primitive and backcountry landscapes for their undeveloped character and to provide opportunities for primitive recreational activities and experiences of solitude, as appropriate." How can this objective be obtained when there are no management actions in the Preferred Alternative to do this? 

BLM - Arizona Strip Field Office 

The discussion on pages 2-59 and 2-60 addresses management of non-WSA lands with wilderness characteristics. Several of the areas included for management to maintain wilderness characteristics under Alternative C are areas that were determined to not have these characteristics, such as Black Hills and Heaps Canyon. Why would these areas be managed for characteristics they do not possess? In addition, the Alternative C text should make it clear that only portions of other wilderness characteristics areas (those parts determined to have wilderness characteristics) would be managed to maintain those characteristics. 

The Black Hills, Heaps Cand Paria/Hackberry areRMP/EIS. As described not found to have wildernChapter 2. The Propose

BLM - Arizona Strip Field Office 

There is a contradiction in decisions in Chapter 2. Page 2-91 states that Alternatives B, C, and D would "Retain non-WSA lands with wilderness characteristics in federal ownership." However, pages 2-59 and 2-60 indicate this is only true for Alternative C since alternatives B and D would "Require no prescriptions specifically to maintain wilderness characteristics areas." 

While there are no speci

protect wilderness characharacteristics (Alternativlands with wilderness chRMP/Final EIS there are lands with wilderness ch

BLM - Arizona Strip Field Office 

The route designations for Vermilion Cliffs National Monument will be completed with the Vermilion Cliffs National Monument Record of Decision/Approved Plan, however, the decisions on the routes in the Arizona Strip Field Office have not yet been made. These comments concern routes near or leading to routes in the Arizona Strip Field Office. We request that Kanab Field Office work with Arizona Strip Field Office to insure that routes crossing the Arizona/Utah state line are consistently designated. Most of these comments refer to possible 

inconsistencies across state lines (numbers refer to specific points on attached 

GIS map plots). 

The Kanab Field Office iStrip Field Office on trav

BLM - Arizona Strip Field Office 

Appendix G, Wild and Scenic Rivers, Pages AG-36 and 37 This section on the Paria River Wild and Scenic River status fails to mention the recommended Wild and Scenic River status for this river in either Grand Staircase-Escalante National Monument or in Vermilion Cliffs National Monument. 

This is addressed on pag

Bob Wallen During the comment period a Citizens Proposal to designate appropriate dry 

wash ways as Designated Off Highway Vehicle routes was presented to your planning team. Several conversations on this proposal between your office, Kane County officials as cooperative agency partners and myself indicated the BLM 

The proposal the commeRMP/EIS (see page 2-82

6 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

would consider this as a viable proposal for OHV management considerations. I could not find any reference that this Citizens Proposal was or would be considered in the recently released Draft RMP. This is cause for our concern that this request and information was omitted from your RMP planning considerations. Further concern is that by omitting consideration of this citizen proposal for dry wash routes OHV/ATV recreational opportunities have been substantially and negatively impacted. 

Bob Wallen The requested trial(s) are located in an area currently designated as "open" and 

may have been "user created" within that designation. As a "user created route" this route was not considered in the draft planning. User created routes should 

still be considered if not created illegally or causing degradation or impairment. I believe these short trails should be considered. 

The route the commentois open in the Proposed 

Bob Wallen Comment on road closure located at UTM 12 S 0341718, 4114570; See attached 

maps and photos. I would like to request that the Field Office reconsider the closing of this short 1 mile long road and instead utilize the way to establish a trail head at this site to allow easy and convenient non-motorized access from this point to the Parunuweap and Virgin river area as well as continue to provide long time established uses. Even when acknowledging this short way is within a WSA there appears to be significant evidence that the Field Office has acted without due consideration to all ofthe directives of managing a WSA. For example. I have traveled this road many times including 9 consecutive days this fall and while GPSing this route on Nov 4 and dispute any claims of OHV "intrusions" causing the "degradation and impairment" necessary to permit BLM to close this prior existing route.(see attached photos) It is also "unreasonable" for BLM to initiate closures on known Kane County RS 2477 assertions as they have in this case. 

A portion of the one-mile the initial wilderness inveAlternative B of the Draft remaining portion of the 

inventory and is not reco

Brent Gardner In Kanab Creek Canyon, approximately 2 to 3 miles North of Kanab on the East 

and West sides of Highway 89, water is derived from the Navajo Sandstone formation. These areas, where underground water resources are being developed, are classified as a Class III visual resource in Alternative B and Class I, II, and III in Alternatives C & D. This would be too restrictive for water development with its associated wells, access roads, and power lines. Alternative A, with its class IV designation, is preferred in this area. 

This area would be VRM preclude underground wIII would have certain stifacilities, coloration, shapspecific and case-by-cas

Bruce Bunting Kane County Conservation District UACD 

Do not attempt to close roads that are part of the counties transportion plans or RS-2477 roads that are being claimed by the counties. There would be less conflict with these road areas if these routes were determined before attempts made later to close these important rights of way. The district does not believe the BLM has this kind of authority to over ride RS-2477 roads to begin with. 

The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Bryant Shakespear Garkane Energy 

While recognizing existing "major" energy corridors the draft RMP fails to meet the planning objective of providing new utility corridors that could be utilized for needed electrical transmission projects. See pages 1-10, 2-26, 3-87, 3-88. To the extent possible the RMP should identify corridors connecting the communities 

The objectives on page 2utility corridors to focus ptransportation systems." state "Preference would 

7 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

within the planning area. Creating such corridors would promote joint use, limit more applications and facilities to previously disturbed areas and allow utility companies to better plan upgrades and new facilities for placement in identified corridors. 

existing ROWs/disturban

Bryant Shakespear Garkane Energy 

The plan fails to coordinate the placement of utility corridors with existing corridors identified by the current Dixie National Forest Management Plan. Specifically the existing corridor south of Wilson Peak, Township 36 S Range 4.5 W. See pages 1-10, 1-15, 1-18, 2-26. 

The objectives on page 2utility corridors to focus ptransportation systems." 

state "Preference would existing ROWs/disturban

Bryant Shakespear Garkane Energy 

Alternatives B, C, D identify avoidance and exclusion areas. Most of these parallel US Highway-89, the Sevier River, or SR-9. As indicted on page 1-10 these areas are identified "for the goals and objectives of other resources" which certainly is important. However, the proposed avoidance and/or exclusion areas around the communities of Hatch, and Panguitch/Spry effectively cut these and other down line communities off from the existing electrical transmission backbone. Without an access route/corridor to these existing electrical transmission facilities Garkane will be unable to serve the current and future power needs of Hatch, Spry, Long Valley, Cedar Mountain, and Alton. See pages 4-193 to 4-197 and maps 2-20 to 2-22. 

Avoidance areas are intenecessarily exclude a ne

location that is feasible. accordance with the IMPthat satisfy the nonimpaitemporary or permanent under any of the conditio

Bryant Shakespear Garkane Energy 

Specifically Garkane has applied to construct a 138 kV transmission line from Tropic to Hatch, and a 69 kV upgradeable to 138 kV transmission line from Hatch to Long Valley Junction. Our porposed routes and several possible alternatives will cross the lands identified for avoidance or exclusion. If Garkane is unable to obtain ROW for these and future projects local citizens will likely experience more outages and will be become increasingly dependant on mobile diesel generation to meet peak power demands. Garkane would also be forced to take measures to reduce peak and base loads in these areas be establishing new service hookup moratoriums, load shedding (rolling black outs), and increased electrical rates. The lack of sufficient power would substantially constrain local economic development contrary to the statement on page 4-260 of the draft RMP. 

Avoidance areas are intenecessarily exclude a nelocation that is feasible. accordance with the IMPthat satisfy the nonimpaitemporary or permanent under any of the conditio

Bryant Shakespear Garkane Energy 

Alternative B requires that consideration be given to burying new and reconstructed utility lines up to 34.5 kV. Alternative C requires burying new and reconstructed utility lines up to 34.5 kV. These requirements create unsafe working conditions and the potential for electrical flash over. See page 2-89. 

The Final RMP/EIS will b

Bryant Shakespear Garkane Energy 

It is our opinion that these requirements should be modified to include voltages up to 24 kV for burial rather than the proposed 34.5 kV in order to provide safe working conditions. Please review the enclosed article. 

The Final RMP/EIS will b

Bryant Shakespear Garkane Energy 

The cost increase of burying lines is significant. Based on current material prices and trenching rates Garkane estimates it will costs a project proponent 300 percent more to construct an underground distribution line opposed to an overhead line. The maintenance costs are also increased and reliability of lines 

A range of alternatives mwill be considered in det

8 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

decreased with underground distribution line construction. The burial requirement of Alternative C is arbitrary and does not consider the effected resources, location, and environment of a proposed line. Underground distribution linjes should only be considered when overhead lines cannot meet other resource objects. See pages 2-89. 

Bryant Shakespear Garkane Energy 

Cummulative Impact Analysis fails to include Garkane Energy proposed Tropic to Hatch 138 kV Transmission Line, application submitted to Kanab Field Office 

April of 2007. See pages 4-276, 4-285, 4-286. 

Chapter 4 of the Proposeto Hatch transmission lin

Bryant Shakespear Garkane Energy 

Alternative B, C, D require the use of non-reflective wore (non-specular conductor). Projects using non-specular conductor have had a marked increase of avian collision with the conductor and its use may be counterproductive to the avian protection measures included as part of the draft RMP. 

The Proposed RMP/Finalines greater than 230 KV

Bryce Canyon National Park 

Stipulations for Mineral Leasing: As the resources management planning process moves forward, we would like to work with you to develop appropriate stipulations for mineral extraction activities near the park. The fundamental purpose of such stipulations will be to protect those values that we have identified in this letter. 

The BLM has coordinateproviding opportunities foprocess. These coordinapage 5-5. 

Bryce Canyon National Park 

"Under no circumstances should this decision become the only basis for protection of the values for which Bryce Canyon National Park was established and I direct that these park values be taken into account in future decisions by the bureaus of this Department on mining plans, permit applications for other activities on undesignated Federal lands near the park." (Emphasis added). We believe that the intent and specifics of the Secretarial Order should be noted in the Resources Management Plan. 

The document has been 

Bryce Canyon National Park 

The scenic values in and around Bryce Canyon National Parks is well known and is a primary park purpose. We believe that the appropriate Visual Resource Management objective in the Resource Management Plan in the vicinity of Bryce Canyon National Park should be VRM Class I, or "To preserve the existing character of the landscape. The level of change to the characteristic landscape should be very low and must not attract attention." The VRM objective should be no less than similar BLM-managed National Monument lands near Bryce Canyon with a VRM Class II, where the objective is "...to retain the existing character of the landscape. The level of change to the characteristic landscape should be low. Management activities may be seen, but should not attract the attention of the casual observer. And changes must repeat the basic elements of form, line, color, and texture found in the predominant natural features of the characteristic landscape." 

The Draft RMP/EIS provclassifications in the parcEach alternative of the Dthe identified purpose anscoping period. The rangprocess starting with the throughout the planning and during the public comalternatives in the vicinity resources and uses, inclresource uses to addres

Capital Trail Vehical Association 

The maps and figures are not easily understood. There are no identifiable or named features and no road and trail numbers on the maps. It is very difficult for the public to orient themselves and to interpret the proposed action for each specific road and trail. Therefore, the public cannot adequately evaluate the proposal and cannot develop comments with reference to specific roads and 

The maps in the Draft Rconvey the decisions bescale maps at a 1:24,000 five public meetings for twere also provided on co

9 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

trails. Office, at request. Comm

identification exercised tvery detailed comments 

Capital Trail Vehical Association 

The project has a critical flaw which is the lack of a true "pro-recreation alternative that adequately addresses motorized recreation. All of the alternatives developed for consideration represent a significant reduction in routes available for motorized use. Not one Alternative even sustains the current opportunity. 

BLM has provided a reasDraft RMP/EIS analyzes alternative, except for Althe identified purpose anbegan early in the RMP through February 2005) coordination with our coo

Capital Trail Vehical Association 

Therefore, it is incumbent upon the project team to formulate at least one alternative that maximizes motorized recreation, or at least does not reduce motorized recreational opportunities in the planning area. Therefore, we request that the project team formulate a wide range of alternatives including at least one Alternative that maximizes motorized recreational . opportunities in the project area and addresses the following: 

Alternative A addresses throughout the decision 

84% of the decision area miles of inventoried route

Capital Trail Vehical Association 

The cumulative effect of all motorized closures has been significant and is growing greater every day yet they have not been adequately addressed. Ignoring cumulative effects allows the agency to continue to close motorized routes unchecked because the facts are not on the table. CEQ guidance on cumulative effects was developed to prevent just this sort of blatant misuse of NEPA. 

Cumulative impacts to mRMP/EIS Section 4.6.3, boundary for transportatadjacent land managemPark, Glen Canyon NatioRichfield FO, St. George 

Trust Lands). In additionreflect the change in the 

Capital Trail Vehical Association 

The existing level of motorized access and recreation must not be dismissed without adequate consideration because it is only associated with the No Action Alternative. The existing level of motorized access and recreation is reasonable alternative and an alternative other than No Action must be built around it. 

Alternative A addresses throughout the decision 84% of the decision area miles of inventoried route

Capital Trail Vehical Association 

The difference between an RMP (general guidance) and the Travel Plan (implementation decision) is not clearly described in the DEIS. The FEIS should clearly articulate the difference. 

The Proposed RMP/Finaimplementation and land 

Capital Trail Vehical Association 

We are concerned that many of the restrictions in all ofthe Action Alternatives are simply not justified. The FEIS should clearly draw a connection between the facts on the ground and the decision made. 

CEQ regulations implemrequire agencies evaluatenvironmental impact stainformation, if that informalternatives (43 CFR 150specific data is used to tAdditional information on section 4.1.6 of the Draft 

Capital Trail Vehical Association 

The different management plans being developed by the BLM and Forest Service are using generated, estimated and inadequate data to forward an agenda 

CEQ regulations implemrequire agencies evaluat

10 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

ofeliminating access and motorized recreation from public lands. The economic impact ofthese closures will be devastating to small communities throughout the West. Models can be manipulated to predict any result Economic models such as IMPLAN should not be used when the input data is estimated and not factual or actual. Adequate effort must be exercised by the agencies to gather true on the ground data from businesses and individuals that use our public lands. We request that the economic analysis use actual local data to determine the true economic and social impact ofproposed motorized access and closures on the public. 

environmental impact stainformation, if that informalternatives (43 CFR 150specific data is used to tAdditional information on section 4.1.6 of the Draft 

Capital Trail Vehical Association 

We request that these deficiencies be addressed by developing a starting benchmark alternative that identifies all of the existing roads and trails available to motorized recreationists including non-system routes and those falling under some undefined definition of "unusable" and those additional routes required to meet the needs of the public. 

The best available route 

routes/trails. The route inIn addition, to the route ipublic comment period wbe considered in prepari

Capital Trail Vehical Association 

We request that the environmental document adequately addresses the social economic, and environmental justice issues associated with multiple-use access and motorized recreation. We request that the environmental document include a travel management alternative for the project area that adequately responds to these issues and the needs for multiple-use access and recreation. 

The social, economic, an

4.5.1 of the Draft RMP/E

Capital Trail Vehical Association 

Please explain why the needs of non-motorized recreationists are provided for at a much higher level (quality and quantity) than motorized recreationists? 

Motorized and non-motoplanning process. The D

resource values are protmotorized access and re

Capital Trail Vehical Association 

Most of the non-motorized focus areas have designated routes open to motorized vehicles] within them. If implemented as written in Alternatives B, C and D, many visitors will perceive these focus areas as establishing blanket restrictions on motorized use. The unintended consequences will likely result in increasing, not reducing actual or perceived "user conflict." 

Identifying an RMZ as mmanagement emphasis f

identified motorized routare used for accessing nbetween motorized and chapter 4. 

Capital Trail Vehical Association 

Because vehicles are not permitted to travel off designated routes - for any reason - the Kanab BLM is proposing a "vehicle camping only in designated campsites" in the entire Field Office. Such a restrictive policy would be appropriate for National Parks or National Monuments, but for Public Lands this is truly unheard of. 

Chapter 2 of the Draft RMdispersed camping withiThere is no restriction to 

Capital Trail Vehical Association 

All planning projects should disclose the added benefit to non-motorized recreational resources resulting from the closure of roads by adding the miles of closed roads to the miles of existing non-motorized trails. We request that this procedure be used by this project and all future agency projects. Additionally, we request that the cumulative negative impact on motorized recreationists resulting from this lack of adequate accounting be evaluated and adequately mitigated. 

The impacts requested bRMP/EIS chapter 4 (star

Capital Trail Vehical We request that this planning project include adequate research ofthe county The Proposed RMP/Fina

11 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Association records and adequate formal consultation and coordination with the county to get 

their input on RS 2477 routes. 

assertions will be settled through other legal mean3 page 3-83. 

Capital Trail Vehical Association 

Additionally, we request that the cumulative negative impact resulting from inadequate evaluation of economic and social impacts in past actions are considered in the analysis and decision-making and that an adequate mitigation plan be included as part of this action to compensate for past cumulative 

negative impacts. 

The impact analysis usedetermine the economic The Draft RMP/EIS chapeconomic and social imp

analysis. Performing an forgone opportunities is for past cumulative nega

Capital Trail Vehical Association 

Because ofthe significant cumulative effect of motorized closures at this point in time, we feel strongly that there can be "no net loss" of motorized recreational opportunities with the Kanab DRMP and DEIS project. We would ask that this project address the attached checklist of issues and address the goals and needs identified. 

Alternative A of the Draft 

throughout the decision FLPMA does not require recreational opportunitie

Capital Trail Vehical Association 

Our comments document that the current management trend towards massive motorized closures (25 to 75% ofthe existing routes) is not responsible to the public's needs for motorized access and recreation and is contrary to the multiple-use management directives specified by congress. 

The BLM considered a ralmost 21% of miles of m

flexibility to ensure the reacceptable levels of mot

Capital Trail Vehical Association 

The proposed action must meet the needs of motorized recreationists both today and tomorrow. We respectfully request that the evaluation and proposal be directed to adequately address these issues and goals. 

The current use and proj

planning process. The ramotorized recreation. 

Capital Trail Vehical Association 

The current approach for OHV management is inequitable because it takes the current motorized route inventory and tries to make it the route inventory for all users. It leaves out possibilities for constructing or otherwise developing nonmotorized trails and ignores existing non-motorized trails that exist in both the planning area and adjacent lands. 

The route identification pnew routes. Appendix K, 

Draft RMP/EIS outlines tprocess is an implementmotorized route identificaaddress route/trail identifexplained in Appendix K

Capital Trail Vehical Association 

We request that the agency not use the existing motorized trail inventory for designating non-motorized trails. Instead, if there is a need for non- motorized trails, then the agency should consider options that do not reduce the existing opportunity for motorized users. 

The route/trail identificat

RMP/EIS addresses motdecisions could address motorized uses as explatype, route/trail alignmen

Capital Trail Vehical Association 

The site specific analysis of each road or trail to be closed must address or identify where the public would go to replace the motorized resource proposed for closure. In other words, the analysis must adequately evaluate the site specific value of a road or trail proposed for closure to motorized recreationists. It must also quantify the significant negative cumulative impact experienced when motorized recreationists could not find a trail or road with a similar experience in 

The BLM analyzed each 

potential uses of each roK, to determine route idesetting, recreation activitinformation was used in chapter 4 addressed the 

12 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

the area. The quality of our experience has been significantly reduced. It must also quantify the significant cumulative impact that the closure of a system of 

road and trails would have collectively when enough routes are closed to eliminate a good motorized day outing. An incomplete analysis is not acceptable under NEPA requirements. 

does not require analysis 

impacts of the identified RMP/EIS on pages 4-18

Capital Trail Vehical Association 

34. Note that some new construction may be required to accomplish a reasonable system of loops. Therefore, new construction must be included in the scope ofthe project. 

The current use and proj

planning process. The ramotorized recreation. 

Capital Trail Vehical Association 

We request that a system of dual-purpose roads, and OHV roads and trails that interconnect be one of the primary objectives of the travel management plan and that this objective be adequately addressed in the document and decision. 

All routes identified in the mode of travel. 

Capital Trail Vehical Association 

The Plan for this project area does not recognize and address this trend. The management plan for the Kanab project area must adequately recognize and address this trend. 

The current use and proj

planning process. The ramotorized recreation. 

Capital Trail Vehical Association 

A significant closing of roads and motorized trails in the project area is not consistent with meeting the needs ofthe public and the goals of Multiple-Use Management as directed under Federal Land Policy and Management Act of 1976 (FLPMA), Multiple Use Sustained Yield Act of 1960 and P.L. 88-657. 

The BLM considered a ralmost 21% of miles of mflexibility to ensure the reacceptable levels of mot

Capital Trail Vehicle Association 

There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Once the "603 Process" was completed, the agency was done with its Wilderness review. The question of which lands should be included in the National Wilderness Preservation System is now between Congress and the American people. Other than the management of existing WSA's, the BLM should have no part in this issue. To do so is a tragic loss of management resources. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to hasimilar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character ma

13 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

provides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and objectnecessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Carl Albrecht Garkane Energy 

1. While recognizing existing "major" energy corridors, the Draft RMP fails to meet the planning objective of providing new utility corridors that could be utilized for needed electrical transmission projects. See Pages 1-10, 2-26, 3-87, 3-88. To the extent possible, the RMP should identify corridors connecting the 

communities within the planning area. Creating such corridors would promote joint use, limit more applications and facilities to previously disturbed areas, and 

allow utility companies to better plan upgrades and new facilities for placement in identified corridors. 

The objectives on page 2utility corridors to focus ptransportation systems." state "Preference would existing ROWs/disturban

Carl Albrecht Garkane Energy 

2. The plan fails to coordinate the placement of utility corridors with existing corridors identified by the current Dixie National Forest Management Plan. Specifically the existing corridor south of Wilson Peak, Township 36 S Range, 4.5 W. See Pages 1-10, 1-15, 1-18, 2-26. 

The objectives on page 2utility corridors to focus ptransportation systems." 

state "Preference would existing ROWs/disturban

Carl Albrecht Garkane Energy 

4. Alternatives B, C, and D identify avoidance and exclusion areas. Most of these parallel Highway 89, the Sevier River; or SR-9. As indicated on Page 1-10, these areas are identified "for the goals and objectives of other resources" which certainly is important, However, the proposed avoidance and/or exclusion areas around the communities of Hatch, and the Panguitch/Spry Area effectively cut these and other down line communities off from the existing electrical transmission backbone. Without an access route/corridor to these exisiting electrical transmission facilities, Garkane will be unable to serve the current and future power needs of Hatch, Spry, Long Valley, Cedar Mountain, and Alton. See Page 4-193 to 4-197 and Maps 2-20 to 2-22. 

Avoidance areas are intenecessarily exclude a ne

location that is feasible. accordance with the IMPthat satisfy the nonimpaitemporary or permanent under any of the conditio

Carl Albrecht Garkane Energy 

Garkane has two pending applications for new transmission lines that will cross these areas. Addditional distribution lines will be needed in the Hatch and Panguitch areas as these locations continue to develop and grow. The Avoidance and/or Exclusion Zone boundaries need to be moved so that the east boundaries are west of the existing power lines. 

Avoidance areas are inte

necessarily exclude a nelocation that is feasible. accordance with the IMPthat satisfy the nonimpaitemporary or permanent 

14 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

under any of the conditio

Carl Albrecht Garkane Energy 

Our proposed routes and several possible alternatives will cross the lands idenified for avoidance or exclusion. If Gakane is unable to obtain a ROW for these and future projects, local citizens will likely experience unacceptable power service and will become increasingly dependent on diesel generation to meet peak power demdns. Garkane would also be forced to take measures to reduce peak and base loads in these areas by establishing new service hoop-up moratoriums, load shedding (rolling black outs), and increased electrical rates. The lack of sufficient power would substantially constrain local economic development, contrary to the statement on Page 4-260 of the Draft RMP. 

Avoidance areas are intenecessarily exclude a ne

location that is feasible. accordance with the IMPthat satisfy the nonimpaitemporary or permanent under any of the conditio

Carl Albrecht Garkane Energy 

Alternative C requires burying new and reconstructed utilities lines up to 34.5 kV. These requirements create unsafe working conditions and the potential for electrical flash over. See Page 2-89. 

The Final RMP/EIS will b

Carl Albrecht Garkane Energy 

Alternative B, C, and D require the use of non-reflective wire (non-specular conductor). Projects using non-specular conductor have had a marked increase of avian collision with the conductor and its use may be counterproductive to the avian protection lmeasures inxluded as part of the Draft RMP. 

The Proposed RMP/Finalines greater than 230 KV

Carl Albrecht Garkane Energy 

It is our opinion that these requirements should be modified to include voltages up to 25 kV for burial, rather than the proposed 34.5 kV in order to provide safe working conditions. Please review the ennclosed articles and information (Enclosure). 

The Final RMP/EIS will b

Carl Albrecht Garkane Energy 

The cost increase of burying lines is significant. Based on current material prices and trenching rates, Garkane estimates it will cost a project proponent 300 perecent more to construct an underground distribution line opposed to an overhead line. The maintenance costs are also increased and reliability of lines decreased with underground distribution line construction. The burial requirement of Alternative C is arbitrary and does not consider the effected resources, location, and environment of a proposed line. Underground distribution lines should only be considered when overhead lines cannot meet other resources objects. See Pages 2-89. 

A range of alternatives mwill be considered in det

Carl Albrecht Garkane Energy 

3. Cumulative Impact Analysis fails to include Garkane Energy's proposed Tropic to Hatch 138 kV Transmission Line Application submitted to Kanab Field Office in April of 2007. See Pages 4-276,4-285, 4-286. 

Chapter 4 of the Proposeto Hatch transmission lin

Carl Albrecht Garkane Energy 

Alternative B, C, and D require the use of non-specular conductor). Projects using non-specular conductor have had a marked increase of avian collision with the conductor and its use may be couterproductive to the avian protection measures included as part of the Draft RMP. 

The Proposed RMP/Fina

lines greater than 230 KV

Charles and Nancy Bagley 

The chart of WSA Management options, page 2-110, shows for your preferred Alternative B that 1100 acres of Moquith Mt WSA will be open to cross-country OHV use. This is an increase from current management (No Action) that allows 

There is no intended chaMoquith Mountain WSA. has been corrected in th

15 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

730 acres of such OHV use. Yet your Objectives for WSA management (2-30) are stated in the first sentence: "Manage WSA's in a manner that does not impair their suitability for designation as wilderness." Obviously, allowing 1100 acres of cross-country OHV use in a WSA will impair its suitability for wilderness designation!! Your plan fails to meet your stated objectives. 

acres. 

Charles Robinson The Proverty roads should not be closed in my opinion because we as older 

citizens need access into these very beautiful, interesting, and historical areas as the slot canyons, petroglyps, and Spanish sword engraving. I am all for all tracks to stay on existing roads. However, I and most of America, can't walk over a mile in deep sand, therefore I need a cherry stem road to these areas. These accesses to Prunaweep Canyon need to be left open for us to enter this most beautiful canyon. 

The Proposed RMP/EIS 

identified way open to O

Charles Robinson The proposed road closure of Elephant Cove would be a sad day at our home. 

These roads have been open for many years. The Shuns berg Mail Drop is a very significant historical venue. The road needs to be left open to the areas as it is too far for anyone (except 20 year-olds) to walk. As I get older (60 year old) I need a cherry stem road to be able to visit the drop site. I work for the post office and this part ofhistory is not only interesting, but significant for Kane and 

Washington County history. 

The Shunsberg Mail Droscope of the Kanab RMPAlternative and remains 

Charles Robinson The Broad Hollow Road should be left open for recreation and historical use. The 

loop is a great ride for the outdoor and historical enthusiast This could and should be a great ATV trail on BLM land. The old cabins, the beautiful scenery, the atmosphere are incredible and it would be a shame to shut us citizens out of such an area. 

The Broad Hollow Road the Kanab RMP. 

Charles Robinson Access to Cannan Mountain from Broad Hollow should be left open for the 

scenery and historical reasons. The old sawmill, the shingle drop are really neat and we shouldn't be deprived of visiting this area. Only a very tiny percent (about 1/1000 of 1%) of American citizens or tourists will ever be able to visit, as it is way too far and difficult to walk to. A cherry stem road would at least get us into the vicinity of all this beauty. 

The Broad Hollow Road the Kanab RMP. 

Charles Robinson Moquith Mountain (Lamb Point) closing the spurs off the loop road would be very 

detrimental to us older generations. The scenic pinnacles and pine trees are unmatched in beauty. The balanced rocks, windows and arches are incredible. Petroglyps and Indian caves are some ofthe best in the west. Each spur road goes to something incredible and is there for a reason. These should not be closed. 

The Lamb’s Point route cIn consultation with the TRMP/Final EIS. 

Chris Bell U4WDA 

Not limiting group sizes under special recreation permit rules. The special recreation p

determining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

16 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Chris Bell U4WDA 

Elimination of the user statistics (table 3-26) since they are clearly flawed. Table 3-26 in the Draft R

information system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

Chris Bell U4WDA Not designating the following as wilderness since all these have existing machine 

made roads. A. Sheep Springs B. Four Mile Creek C. Kanab Creek 

As part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

Christopher Lish Unlimited damage would also occur to the historical record of native cultures, 

because the BLM has not conducted any surveys to determine the location and extent of archaeological artifacts or culturally important sites, or the impact of ORVs on these irreplaceable resources, despite authorizing ongoing ORV use that could destroy them forever. 

The BLM will comply witregulations and BLM IM-Considerations for Off-Hdescribed in BLM IM-200and strategies will vary d

activity and the expected existing inventory informA. Class III inventory is nuse of an existing route; an open area or travel roarea open. B. Where there is a reas

concentrate or expand tradversely affected, Clason areas where adverse C. Proposed designation

require Class III inventor

Section 106 prior to desi

17 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

with Section 106 will also as staging areas or similD. Class II inventory, or probability model, followspecific projects, may be information is currently aThe SHPO concurrence Proposed RMP/Final EIS 

Christopher Lish I am extremely upset that the BLM's plan will allow 1,100 acres of the Moquith 

Mountain WSA to be used as an ORV recreation area, where vehicles would be allowed to travel anywhere on these lands which have otherwise been found suitable for wilderness designation - unnecessarily putting at risk the sensitive plant and invertebrate species that have been found in this area, as well as the wilderness values that the agency is charged to protect. 

The OHV open area in thuse since during the initibeen in use without impainventoried. 

Coalition to Preserve Rock Art 

As a result we believe that the proliferation of OHV routes in the area needs to be carefully considered. Those that provide direct access to important cultural resource sites should be closed at lease one quarter mile from sites eligible for NRHP status. 

As noted in the Draft RMthe impact analysis is tha

allocations contained in tof actions and analyses that individuals can inadvprescriptions, none of wh

prescriptions. Impacts fro

prescriptions contained ipresence is an Administrplanning decision to impraises were considered ito develop the alternativeimpacts associated with 

Colin Esplin The reason that I'm writing this letter is to express my concern on the issue of 

road closing, more specifically the Poverty road. Because I have used this road before and enjoyed the things that you can see from the use of this road I would like to see it remained open. The young men and young women in my ward went on a four wheeler ride on this road for an activity one night. I also went and had a great time. We rode down to the river to see the Indian art on the canyon walls. Being able to ride down there allows you to do it in one evening. The closing of this road would consequently not allow you to be able to do this. 

The Proposed RMP/EIS 

identified way open to Oin the Proposed Plan du

Colorado Plateau Archaeological Alliance 

CPAA recognizes that cultural resources can be adversely impacted through the course of non-regulated surface-disturbing activities such as cross-country OHV travel, wildfires, collection of artifacts, vandalism and pedestrian impacts that are not typically considered through Section 106 reviews. However, such adverse impacts to cultural resources are, in many instances, the indirect consequence of regulated surface-disturbing activities that are considered during the Section 106 

As noted in the Draft RMthe impact analysis is tha

allocations contained in tof actions and analyzes that individuals can inadvprescriptions, none of wh

18 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

review process (e.g., road access to accommodate development that subsequently provides access to looters and vandals). Consequently, the Draft EIS must adequately consider all impacts of undertaking on National Registereligible properties that may be a consequence of the undertaking but not directly related to it. The document currently does not address this issue. 

prescriptions. Impacts froprescriptions contained i

presence is an Administrplanning decision to imp

Colorado Plateau Archaeological Alliance 

The Draft EIS also fails to properly consider cumulative impacts (DEIS 4-280 to 4-281). A mere acknowledgement that resource decisions resulting from the RMP "could produce cumulative impacts on cultural resources and resources of religious or traditional importance to Native American tribes" does not constitute a careful consideration of what those cumulative impacts would be under each of the alternatives. In fact, there is no acknowledgement that components of all alternatives increase the risk to cultural resources from looting, vandalism and other inadvertent impacts. Other Draft EISs prepared for Moab and Monticello at least recognize "the potential impacts from the continually increasing recreational visitation" and that "the substantial increase in OHV ownership and recreational use will continue to subject cultural resources in the region to heightened risk of damage, vandalism and/or looting" (see Moab DEIS 4-502). CPAA concurs with the assessment in the Moab DEIS, and recommends that the Kanab Draft EIS be modified to acknowledge and fully analyze the potential impacts of OHV use on such a massive scale that could result in cumulative effects to site setting and integrity, even if the historic properties themselves are not directly impacted (see 36 CFR 800.5(a)(2)(v)). 

As noted in the Draft RMthe impact analysis is tha

allocations contained in tof actions and analyzes that individuals can inadvprescriptions, none of wh

prescriptions. Impacts fro

prescriptions contained ipresence is an Administrplanning decision to imp

Colorado Plateau Archaeological Alliance 

As such, the Travel Plan is fundamentally flawed on two important points: (1) The failure of the BLM to conduct adequate analysis in the past related to OHV impacts along routes currently being used by motorized vehicles was and still remains an abrogation of agency's Section 106 responsibilities, and the failure of the agency to recognize or correct this deficiency in the new Travel Plan appears to validate and perpetuate the agency's failure to comply with Section 106 requirements in the past; and (2) the failure to require Class III inventories along routes prior to designation suggests the agency official has already made a determination, as per 36 CFR 800.3(a), that travel route designations in such 

instances are not an undertaking as defined in 36 CFR 800.16(y). 

The BLM will adhere to iregulations and BLM IM-Considerations for Off-Hdescribed in BLM IM-200and strategies will vary d

activity and the expected existing inventory informA. Class III inventory is nuse of an existing route; an open area or travel roarea open. B. Where there is a reas

concentrate or expand tradversely affected, Clason areas where adverse C. Proposed designation

require Class III inventor

designation. Class III invalso be required prior to 

19 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

similar areas of concentrD. Class II inventory, or probability model, followspecific projects, may be information is currently a

Colorado Plateau Archaeological Alliance 

A factual inaccuracy needs to be corrected in Section 3.2.9 Current Conditions (DEIS 3-58) that states Noel Morss led the pioneering archaeological investigations of the Claflin Emerson Expedition. Morss, a major figure in Utah archaeology, was actually a minor figure on the Claflin Emerson Expedition, which was led in 1929 and 1930 by Henry B. Roberts, and in 1931 by Donald Scott. Morss was a member of the expedition but only peripherally, conducting his own investigations in Wayne County in 1928 and 1929 (mostly in areas managed by the Richfield Field Office, Price Field Office and Capitol Reef National Park that are irrelevant to this Draft EIS). 

The Proposed RMP/Finatextual recommendations 

Colorado Plateau Archaeological Alliance 

As described in Areas of Importance to Native American Tribes (DEIS2-56), the BLM would "allow Native American non-commercial traditional use of vegetation and forest and woodland products for the collection of herbs, medicines, traditional use items, or items necessary for traditional, religious or ceremonial purposes, through permits" (emphasis added). The establishment of a permitting process to allow Native American use of items necessary for traditional, religious or ceremonial purposes would appear to contradict the spirit of the American 

Indian Religious Freedom Act (42 U.S.C. 1996) guaranteeing the freedom of Native Americans to worship through ceremonials and traditional rites. 

The BLM has a very gooresources. However, to euses the permitting procto what extent resource charge to Native AmericThese are not intended t

Colorado Plateau Archaeological Alliance 

We emphasize that the BLM cannot properly manage cultural resources it does not know exist, and hence the absence of a statistically valid sample militates against adequate consideration of potential impacts to unknown cultural 

resources. 

In preparing the PRMP/Dthe basis for the cultural Section 106 and 110 inv

information available. Aproposals will require codocumentation. 

Colorado Plateau Archaeological Alliance 

The primary consideration in this discussion is that OHVs allow greater public access to archaeological sites, and that this access facilitates adverse effects. This is casually acknowledged in the Draft EIS with the statement that "As access to an area increases, incidental damage of cultural resources adjacent to the access routes would increase. Impacts from incidental damage would be reduced as distance from the access route increases" (DEIS 4-96). As discussed above, damage to or destruction of archaeological sites is most prevalent along existing routes, usually within 200 meters of an existing route (cf. Spangler, Arnold and Boomgarden 2006). Hence, the limitation of OHV travel to existing or designated routes may not significantly reduce impacts to cultural resources along those routes. These data stand in decided contrast to statements in the Draft EIS, Alternatives B and D, that the designation of routes "would result in minimal additional impacts on cultural resources due to existing use on these routes. 

As noted in the Draft RMthe impact analysis is thaallocations contained in tof actions and analyses that individuals can inadvprescriptions, none of whprescriptions. Impacts froprescriptions contained i

presence is an Administrplanning decision to imp

20 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Because the designated routes currently exist, the damage to them would also be minimal" (DEIS 2-119). 

Colorado Plateau Archaeological Alliance 

Given the scope of the proposed Travel Plan as articulated in the Kanab Draft EIS, and the anticipated increase in OHV use over the next decade, a more careful consideration of cumulative impacts from future OHV use should be reflected in the planning and route designation document. 

Impacts from continued decision area are addres

noted in this section are RMP/EIS. The commentKanab Field Office of imSection 4.6. 

Connie Ball It is noted in the RMP that there are incursions into Wilderness Study-Areas 

which the BLM is required under the law to protect as wilderness until Congress acts on those areas. Most notably there-are- proposed Of existing ATV trails into areas such as Moquith Mountain and Coral Pink Sand Dunes. Any ATV trails in these areas as well as areas of critical environmental concern must be protected to the fullest extent possible, and as required by law, and to a degree greater than your RMP calls for in any of the Alternates. It should also be noted that the BLM should have assessed the impact of ATV's on global warming and their impact on regional air quality. Certainly the Wilderness Study Areas are adversely affected by ATV emissions, plant destruction and erosion from soft tires cutting deeply into soil, and wildlife disturbance from the high decibel level of the engines. Again, these vehicles should not be allowed at all in all such areas. 

The IMP allows for contiphase. The IMP does no

and law enforcement are 4 describes impacts from WSAs. 

Connie Ball As a citizen of the area concerned about the welfare of the wildlife, including the 

protection of the Coral Pink Sand Dunes tiger beetle which is a candidate for Federal protection under the Endangered Species Act, which is threatened by ATV's, according to the State of Utah's Division of Wildlife Resources, I request that the BLM go beyond Alternative C in restricting ATV's t-o very small and already destroyed areas and to strictly enforce the candidate areas for Wilderness Study Areas as well as the existing Wilderness Study Areas, by disallowing all ATV traffic. 

A range of alternatives wCoral Pink Sand Dunes country OHV use in AlteDunes tiger beetle are n

Dale Grange I strongly object to the creation of areas with wilderness characteristics (WCs). 

This is simply a hollow way of creating new WSAs where that authority expired in 1991! The BLM should not be creating areas that will be managed in the same ways as existing WSAs. Before BLM creates such areas, it should be necessary to explain in detail how the management of these two types of lands will differ and have public comment before the fact, not after. It is always disappointing to see how closely BLM areas for WC follow the boundaries that the more extreme environmental groups (SUWA) are proposing for wilderness. Creating these 

areas is really only one more step toward making them permanent wilderness. One big problem with this is that most areas being considered as having WC already have motorized travel occurring. If this type of use does not disqualify these areas from having WC, then these kinds of uses must not be so bad! 

The Black Hills, Heaps Cand Paria/Hackberry areRMP/EIS. As described not found to have wildernChapter 2. The Propose

Dale Grange One of the routes that I feel should be included for continued use is the extension The Proposed RMP/EIS 

21 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

of the route on Moquith Mountain to the overlook at Hell’s Dive Canyon. This is a magnificent overlook and always brings me a sense of exhilaration. I always enjoy viewing the wildlife in the area. It is amazing to see how much less threatened they appear when I am on my ATV than when I am simply hiking. 

access for development 

Dale Grange A second route I would object to being closed is the route to the overlook of the 

East Fork of the Virgin River at the Barracks in the Elephant Butte area. Several great hikes are available from the overlook at the termination of the existing route. This route existed prior to the WSA inventory and should have been “inventoried” prior to the creation of the WSA. I urge BLM to use their authority to leave it open in the WSA and ultimately let Congress determine whether it should be closed. At present it is not detrimental to the wilderness values in the WSA and would not prevent its ultimate designation. 

The Rock Canyon route RMP/EIS. The Proposed identified way open to O

Dale Grange The third route that concerns me is the route from the Hog Canyon area to 

Thompson Point. Again the views are tremendous and I great a great sense of well-being when I travel in this area. Each of the proposed Jamboree routes loops will be negatively impacted if they were to be unavailable for travel. 

An adjustment was maddevelopment of a public-

Darren Brinkerhoff I have listed several reasons below why the BLMshould open up the land instead 

of close it down: 1) The Americans with disabilities Act (ADA) prohibits discrimination on the basis of disability by public entities. Subtitle A protects 

qualified individuals with disabilities from discrimination on the basis of disability in the services, programs, or activities of all State and local governments. It extends the prohibition of discrimination in federally assisted programs. 

The ADA accessibility guaccess that must be allopublic lands be vehicle aroutes are an administraaccessibility guidelines wpublic lands. 

David Armbruster Regarding definition of Non-Wilderness Areas with Wilderness Characteristics, 

the U.S. District Court decided that Congress requires the U.S. Forest Service by law to maintain a balance between wilderness protection and motorized use in authorized Wilderness Study Areas. On BLM managed lands, given that Congress rightly expected continued motorized use in WSAs, there is no legal basis by which the BLM is attempting to exclude motorized use by including a new category for Non-Wilderness Areas with Wilderness Characteristics. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to hasimilar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character ma

22 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

provides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and objectnecessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

David Armbruster Table 3-16, Recreation Visitation, is based on unreliable information and should 

not be used as planning criteria in the RMP process. Specifically this Table 

appears to be very biased towards a specific user group and seems to utilize badly flawed data. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

David Armbruster In general Special Recreation Management Areas (SRMA) designations need 

further clarification not to explicitly exclude any user group. Specifically the Kanab Community SRMA OHV Recreation Management Zone (RMZ) needs clarification for the process by which adding or expanding routes will be possible. 

Appendix K of the Draft criteria used to identify afuture. 

David Armbruster In studying the maps and documents in the DRMP/DEIS for Alternative B, the 

U4WDA has found roads shown to be closed that should not be closed and has been informed by the local clubs that some existing roads are not shown on the maps. This seems to be a mistake and an attempt to close roads that are part of the Counties Transportation Plans or RS2477 roads that are being claimed by the Counties. It is imperative that the status of these routes be determined and a legal public review be done before any action is taken to close them. 

The RMP does not adjudclaimed ROWs. The BLM elements of this RMP thracknowledged administr

David Armbruster There is no clear definition of the Visual Resources Management (VRM) in the 

DEIS. The DEIS states that "To the extent practicable, bring existing visual 

The definition of visual reRMP/EIS. 

23 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

contrasts into VRM Class conformance as the opportunity arises." This statement is far too vague and subjective to be useful. I believe this language should be eliminated unless the specific Management Action to be done is defined. 

David Fackrell I never remember seeing a hiker or back packer, which leads me to believe that 

your data shown in Table 3-26 is incorrect. I ran into an occasional hunter on foot, but never a hiker or back packer. It is inconceivable to me that so much of the public lands should be closed to use of so many. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition 

used among federal age

David Fackrell I never remember seeing a hiker or back packer, which leads me to believe that 

your data shown in Table 3-26 is incorrect. I ran into an occasional hunter on foot, but never a hiker or back packer. It is inconceivable to me that so much of the public lands should be closed to use of so many. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition 

used among federal age

David Fackrell Special Recreation Permits: should not be required of groups of 25. Such a low 

number would eliminate Family Reunions, Church Groups and ORV Clubs using our public lands. Numbers over 100 is more feasible. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Debra Csenge Restricting the range of motorized vehicles ranks high in importance because of 

the impact inherent in motorized traffic on the environment. It contributes noise, 

Appendix K of the Draft criteria used to identify a

24 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

pollution, and physical damage to the eco-system which are considerably greater than that of non-motorized recreation. Secondly, enforcement of restrictions is a difficult enough issue out in these remote and vast lands, given the limited number of enforcers available. Certainly, some people justifiably turn to motorization, and they deserve some routes open to them. But if we create a spiderweb of designated motorized routes, resources will become impaired. The Draft Plan shows that a great deal of study has already been made, of biodiversity, arch sites, geology and habitat. These things deserve protection. Hikers and horseback riders are not the only ones disturbed by too much motorization. All the aforementioned resources are as well. 

the commentor raises weduplicative routes, enviro

sensitivity, and current aproposed routes is discu

Desiree Smith I do not believe that Far Mile Creek, Kanab Creek, and Sheep Springs Road 

should not considered wilderness places because they all have roads that run through them that lead to trails. 

As part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

Desiree Smith I feel that the special use permits should not be reduced to 25 per group. The special recreation p

determining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Diane Orr BeecherFilms 

The BLM has overall failed to provide an alternative which fulfills the BLM’s duty to protect cultural resources in the Kanab Management Area as outlined by the National Historic Preservation Act.. I am profoundly concerned that cultural resources, particularly rock art, will be damaged or completely destroyed if the BLM proceeds to allow the extensive energy development suggested in all alternatives. I have consulted with J. Claire Dean of Dean and Associates Conservation Services. Ms. Dean has over 27 years of experience in rock art and archeological conservation. Ms. Dean states that industrial traffic can damage rock art in several ways. Dust accumulates on the rock surface. The natural hydrology of the rock lays down a mineral layer on the rock surface which may mix with the dust and essentially coat the rock art, reducing the visibility of the petroglyphs. The extent and amount of damage depends on the geologic and hydrologic characteristics of the rock surface. Without studying these characteristics, the BLM can not know whether or not energy development will damage or destroy world class cultural resources. Your plans do not discuss or even mention these important factors in your energy development plans. Further, without such research, no development should occur where rock art would be exposed to industrial dust. Another consideration, entirely neglected by the BLM draft management plan, is the impact of wind-blown dust on the surface of rock art. In NineMileCanyon, industrial traffic has caused 30 foot plumes of dust which 

It appears the commentoKanab planning area is c

foreseeable oil and gas d90 wells over the next 20 and therefore the impact

development could occurock art sites. The impacidentified as an issue in tregards to development note these potential impaprojects are covered throand sites identified throuneeded during project imwhat impacts a site may the side of caution. All rprotective and mitigative 

25 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

have covered panels on high cliff surfaces. Ms. Dean states that wind-blown dust and sand act like an abrasive on rock surfaces. The rock art literally can be sanded off the surface with cumulative and continual sand blasting. I saw no mention of this danger in you consideration of energy development in cultural resource areas. I have discussed dust resulting from industrial traffic, but ORVs and ATVs may also cause sufficient dust to do damage to rock art. URARA recommends that no roads or trails be further designated within one quarter mile of rock art. We feel this is a conservative request without the benefit of necessary research. Without further research, BLM is putting rock art at risk in all of the alternatives provided for public comment. 

Dirk Clayson Future right of ways and easements should not be restricted in the plan in large 

geographical areas. All easements for access, water right, fence maintenance, etc should be evaluated on their own merits and not restricted without evaluation. 

Right-of-way restiction a2. FLPMA: Systematic inconsideration of physica

Dirk Clayson Cross county motorized travel should not be eliminated for cattle maintenance 

and fence repairs. There may be a number of other items as well that require this access such as cedar post, mining, engineering, survey work, re-seeding, etc. 

Administrative use for crimprovement maintenanmining, engineering, survNEPA. 

Don Black Canyon Country 4x4 Club 

Although Alternate B "Requires no prescriptions specifically to maintain WC areas." We oppose having the designation of Non WSA Lands with Wilderness Characteristics. The Map 3-15 and table 3-22 should not be included as part of this process. Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Managing WC areas as shown in Alternate C to specifically maintain wilderness characteristics, does not meet the multiple use and sustain yield mandate. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to hasimilar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and object

26 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

necessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Don Black U4WDA 

Although Alternative B “Requires no prescriptions specifically to maintain WC areas.” U4WDA opposes having the designation of Non WSA Lands with Wilderness Characteristics. The Map 3-15 and table 3-22 should not be included as part of this process. Congress gave very specific instructions to the BLM regarding Wilderness. Those instructions are contained in Section 603 of FLPMA. There is no justification, no mandate in FLPMA and no process 

requirement for engaging in an ongoing Wilderness inventory and review. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to hasimilar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and objectnecessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Don Black Making it impossible to hold these organized events by prohibitive SRP The special recreation p

27 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

requirements is a step in the wrong direction. It does nothing to stop the individuals who are uninformed or disrespectful and cause damage to resources, but does restrict those that would be trying to educate against abuse of public lands. The SRP requirements as shown in Alternate B are unworkable as written. 

determining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Don Black Canyon Country 4x4 Club 

The Special Recreation Permit requirements as written in Alternate B are totally unworkable. As written, not only would organized 4x4 and ATV events be unlikely, but probably any organized events like family reunions, scout camps or even a large barbeque. Clear cut guidelines are needed for when a SRP is required. The Group size limit of 25 people is totally unrealistic. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Don Black Canyon Country 4x4 Club 

We believe that none of the Alternates have adequately addressed the issue of Heritage Tourism. Many of the routes listed in Alternate B to be closed, go to areas that include historic, cultural and natural resources that have been visited by people for many years for thise purpose of experiencing settings that represent the past. 

Heritage tourism is addreRMP/Final EIS modified cultural, and natural reso

Don Black Canyon Country 4x4 Club 

Table 3-26 appears to be very unreliable and slanted towards a specific user group. Anyone who has spent any time in any of the areas managed by the KFO can see how greatly flawed this table is. Some special interest groups are making grossly inaccurate statements using this table as evidence. Unless there is some data that could give some credence to the highly unbelieveable numbers on the table, we ask that this table be removed in it's entirety from the RMP documents as it is being misused to distort issues rather than determine how areas should be managed. Also, this table is contradicted in 4.1.6; Incomplete or Unavailable Information, which states; "Direct recreation visitation based on actual use and economic expenditure data associated with such use" 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition 

used among federal age

Don Black Canyon Country 4x4 Club 

We believe that the management action for Special Recreation Permits as shown in Alternate B is totally unreasonable. It would seem to be an arbitrary attempt to eliminate any organized group events. There have been SRP's issued to local clubs for events and I am not aware of any problems arising from these permitted events. There is no justification for these excessive restrictions. 

The special recreation pdetermining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Don Black Canyon Country 4x4 Club 

Just with the points I brought up here indicates the fact that the tables 3-26 Recreation Visitation were poorly done and should NOT be used to justify any decision on land use overall. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring faci

28 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

monitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition used among federal age

Don Black U4WDA 

The Special Recreation Permit requirements as written Alternative B are totally unworkable. As written, not only would organized 4x4 and ATV events be unlikely, but probably any organized events like family reunions, scout camps or even a large barbeque. Clear cut guidelines are needed for when a SRP is required. The Group size limit of 25 people is totally unrealistic. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Don Black U4WDA 

Table 3-26 appears to be very unreliable and slanted towards a specific user group. Anyone who has spent any time in any of the areas managed by the KFO can see how greatly flawed this table is. Some special interest groups are making grossly inaccurate statements using this table as evidence. Unless there is some data that could give some credence to the highly unbelievable numbers on the table, we ask that this table be removed in it’s entirety from the RMP documents as it is being misused to distort issues rather than determine how areas should be managed. Also, this table is contradicted in 4.1.6; Incomplete or Unavailable Information, which states; “Direct recreation visitation based on actual use and economic expenditure data associated with such use.” 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition 

used among federal age

Don Black U4WDA 

We support the RMZ, but the RMP should include more direction regarding when and how additional or expanded routes would be provided. We feel that an expanded and improved trail system in the area would give the public an appropriate place for motorized tecreation and take pressure off of more sensitive areas. 

Appendix K of the Draft 

criteria used to identify afuture. 

Don Black Canyon Country 4x4 Club 

We also consider it a mistake to attempt to close roads that are part of the Counties Transportation Plans or RS2477 roads that are being claimed by the Counties. Less conflict would arise by having the validity of these route determined before any attempt was made to close any of these roads. 

The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Don Black Canyon Due to popularity, improved equipment and technological advancements, we The recommendations th

29 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Country 4x4 Club need to update and get prepared for future use. Attached is a list of people who 

have also acknowledged the need for these improvements. We ask that you consider this proposal and retain it in your records. We look forward to working with you regarding the following: 1) The Hog Canyon OHV area should be treated as a separate entity from the RMP due to its complexity and previous determination. 2) The Trail Patrol functions and activities should be better coordinated with land managers. 3) Have an unbiased member of land management to work with the motorized community on day to day issues. 4) All actions taken for the betterment of the system be a mutual effort between land managers and users. 5) A trail be developed to the North to better access the states existing trail systems. 6) Trails on attached map be considered to make this a more adequate and complete trail system. 

RMP. The recommendatimplementation-level pla

Don Black U4WDA We also consider it a mistake to attempt to close roads that are part of the 

Counties Transportation Plans or RS2477 roads that are being claimed by the Counties. Less conflict would arise by having the validity of these route 

determined before any attempt was made to close any of these roads. We also feel that not having existing roads on the maps as part of the RMP process does not give us the opportunity to make meaningful comments on the roads shown on the maps as part of Alternate B. 

The RMP does not adjudclaimed ROWs. The BLM 

elements of this RMP thracknowledged administr

Donald Kramer SUBJECT STATISTICS CHARTED IN TABLE 3-26 RECREATION VISITATION. 

I believe the estimates in this table are extremely misleading at best and extremely slanted to support the point ofview that wants OHV use stopped or curtailed. First the idea of limiting a user day to twelve hours at the resource is ludicrous. This slants the use ofthe resource to those disciplines that require more time in the field. In order for 20.000 backpackers to get five user days they would spend 2.5 , 24 hour days at the resource. The estimate of 20,000 backpackers in the Kanab Field Office area looks awfully high especially if you take away those backpackers in the Wire Pass Coyote Butte area, an area where accurate statistics are available. The OHV use block appears low in the overall numbers and since the inaccurate way of calculating "user days needs 12 hours, it may take OHV users two or three trips to total a user day. A user day should be calculated as any day or part of a day the user visits the resource, even if it is only a short while. This would give a more accurate picture of land use by recreationists. Big game hunting is the worst example ofstatistics I have seen. On 11-06-2007 I attended a Utah Dept of Wildlife Regional Advisory Committee meeting in Hurricane. At that meeting the biologist reported that Big Game 

Hunters spent an average of 4 days in the field during the " Any Weapon season". According to your "estimates" the hunters spend less than a day and a half in the field. The biologists were going to ask the Wildlife Board to extend the deer season in the Southern Region to nine days. This however was rejected by the board. Your "estimates" of32,463 Big game hunters is way off. There were 16,200 any weapon deer permits during the 2007 season and this encompasses 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

30 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

the entire southern region. An area that encompasses 1/4 ofthe state. And 14,000 archery permits statewide. Elk permits in the subject area were 7, the antelope permits limited to 5 and the general elk hunting (no permit required) limited to the Zion unit that is mostly private land.(These numbers are from the 

2007 Utah Big Game publication). All other hunts in the region were mostly on Forest service land. Along with the fact that very few archery hunters hunt the lower sage-juniper land that makes up the lower halfofthe Kanab field office area would reduce those numbers drastically. ( during the archery season the migratory mule deer herds are up higher in the pine-aspen forest). As you can see these numbers are way off from the "estimates" in table 3-26. If accurate hunter numbers were multiplied by the documented 4 user days the hunter numbers would be lower but the user days would be higher. In addition almost all hunters use OHV access to get into the more remote hunting areas. Just with the points I brought up here indicates the fact that the tables 3-26 Recreation 

Visitation were poorly done and should NOT be used to justify any decision on land use overall. 

Donald Kramer Road closures that are shown in alternative B that concern me the most are the 

"lambs Point" at the southwest end of the Moquith Mountain road. This is a sandy area and keeping the road open does not appear to damage the environment while keeping the first 3/4 of the road open. In hot weather this lengthens the hike to the point with no available water to make it dangerous as hikers will not be able to carry enough water. This will also prevent a lot of people from being able to see this beautiful area as the hike will prevent the young, elderly and those not in "premium" physical condition from seeing it. Reasons to keep these motorized trails open- Benefits Personal- Bonding with family and friends, stress relief, enhanced awareness and appreciation of natural resources, greater self reliance and renewed human spirit, Improved physical fitness and health, closer relationship with nature. Community- Stronger sense of community dependancy on public lands, greater family/ group bonding. Economic- Enhanced local economy via purchases ( gas, groceries, lodging, outdoor equipment, etc) Environmental- Increased awareness and protection of natural landscapes for future generations. 

The Lamb’s Point route cIn consultation with the TRMP/Final EIS. 

Donald Kramer Two of the roads that lead to trail heads in the Parunuweap wilderness study 

area are shown for closure in alternatives "b and C" the one that is accessed from route 9 just west of the East Zion lodge and goes south into the wilderness study (73.11.910 by 112.47.715) area is listed for closure in these alternatives. I 

have hiked to mineral gulch from this road and its closure will make most of those areas unaccessible to me and my wife. Neither of us are handicapped but we are in average shape. Extending this hike would in effect make it inaccessible. Reasons to keep these motorized trails open- Benefits Personal- Bonding with family and friends, stress relief, enhanced awareness and appreciation of natural resources, greater self reliance and renewed human spirit. Improved physical 

The Proposed RMP/EIS identified way open to O

31 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

fitness and health, closer relationship with nature. Community- Stronger sense of community dependancy on public lands, greater family/ group bonding. Economic- Enhanced local economy via purchases ( gas, groceries, lodging, outdoor equipment, etc) Environmental- Increased awareness and protection of natural landscapes for future generations. 

Donald Kramer Another motorized trail listed for closure is Lambs Point (36.59.952 byl12.41.418) 

the road most of the way down is shown open in option B but closed in option C. If there is not enough ecological impact to close the first 3/4 of the road how can the last couple miles make a difference. This is a beautiful area with views ofthe Arizona strip. Reasons to keep these motorized trails open- Benefits PersonalBonding with family and friends, stress relief, enhanced awareness and appreciation of natural resources, greater self reliance and renewed human spirit. Improved physical fitness and health, closer relationship with nature. CommunityStronger sense ofcommunity dependancy on public lands, greater family/ group bonding. Economic- Enhanced local economy via purchases ( gas, groceries, lodging, outdoor equipment, etc) Environmental- Increased awareness and protection ofnatural landscapes for future generations. 

The Lamb’s Point route cIn consultation with the TRMP/Final EIS. 

Donald Kramer Rock Point approaching the Parunuweap Wilderness Study area from the south. 

(37.10.159 by 112.49.474) This closure will in effect close all access to the Virgin Canyon on that trail. It would be difficult to carry enough water to hike to the canyon then down in. It will also close access to all but the ultimately fit. This road is through thick sagebrush and I did not see any trails out off of the road. The road does not appear to create erosion problems and appears to be a wildlife trail. It does not appear to adversely effect wildlife. It is a popular hunting area and closures in this area will be hard to enforce with high numbers ofhunters used to access. Reasons to keep these motorized trails open- Benefits PersonalBonding with family and friends, stress relief, enhanced awareness and appreciation of natural resources, greater self reliance and renewed human spirit. Improved physical fitness and health, closer relationship with nature. CommunityStronger sense ofcommunity dependancy on public lands, greater family/ group bonding. Economic- Enhanced local economy via purchases ( gas, groceries, lodging, outdoor equipment, etc) Environmental- Increased awareness and protection ofnatural landscapes for future generations. 

The Rock Canyon route RMP/EIS. The Proposed identified way open to O

Donald Sprecher 5: An explanation why the BLM used in the resource plan the chart that showed 

usage by the various recreation groups based on estimates and not real numbers. I strongly protest using that chart as a basis of information in decisionmaking, because it is flawed. There is nothing in place for OHV users to log into 

any kiosk, or station, so the BLM can obtain an accurate number of users and 

user hours. I feel the BLM is making decisions based on unknown real numbers. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does n

32 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

popular use areas/trails accurately determine the As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition used among federal age

Donald Sprecher I chose to address the road closures in the preferred Alternative "B". 

THOMPSON POINT T 0410 S ROAD CLOSURE IN SECTIONS: R 0090 W 20, 

21,26,27, 28 This road has fantastic views to the south, from the top of Vermillion 

Cliffs, You can view the Kiabab Plateau, Kanab Creek, and Mt. Trumbull. If closed as marked it would require a hike for me of approximately 1-3/4 mile one way, over 3 miles round trip. I am physically unable to hike that distance. 

An adjustment was maddevelopment of a public-

Donald Sprecher LAMBS POINT ROAD CLOSURE SECTIONS: T 0440 S 12 R0080W This road 

will deny access into Arizona and the Piute Indian Reservation. It has become obvious the BLM has had a request from the Piute Tribe to deny access, and the federal lands managed by the Arizona Strip Field Office has not taken Any consideration how that road continues and re-enters the State of Utah further west. The closure is denying access back into Utah. Lambs Point offers excellent views to the south of Kanab Canyon and west to Mt. Trumbull from the end of the road. That would require a hike of over 4 miles round trip without a place to replenish Water. 

The Lamb’s Point route cIn consultation with the TRMP/Final EIS. 

Donald Sprecher MOQUITH MT. T 0430 S ROAD CLOSURE SECTIONS: R 0070 W 27, AND 28 

That road leads to a site of ancient historical resources. There are hieroglyphs and boulder-sized matates that are hard to find of that size. Plus there are pit houses that could be protected with a fence and an educational site and kiosk could be placed at the end of the road at that site. I can walk into that site. It would be impossible for me to hike the entire 2 1/2 mi round trip. And that would be a dry hike if no water in the canyon seep when you get there. I have worked with Doug McFadden (retired BLM archeologists) on privately owned property, and have experience with those type of sites. The BLM should use that site as an educational resource, rather than close the area. Use the area to educate. 

The Proposed RMP/EIS access for development 

Donald Sprecher BARRACKS/ROCK CANYON T 0420 S ROAD CLOSURE SECTIONS: R 0090 

W 1, 11, 12, 14, 15,23 FANTASTIC VIEWS OF THE VIRGIN RIVER AND ZION NATIONAL PARK I HUNT THIS AREA FOR MULE DEER This road has been in use for many generations from the late 1800's according to my wife's grandfather (Merrill Robinson) who I questioned in 1987 his knowledge of this road. He told me that it was used as a cattle trail to cross the Virgin River and 4x4 vehicles had used the road after WW II when Jeeps and 4x4 became available to the civilians. I have a friend who was raised in Orderville Ut., and he told me when he was old enough at age 12, they would gather cattle on the Paria Plateau herd them across the Arizona Strip then to Moccasin Arizona, up thru Broad Hollow or over 

The Barracks/Rock Cany

the Draft RMP/EIS. The an identified way open to 

33 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Canaan Mt. for water on top then back down into the Barracks or Rock Canyon. He told me they had many crossings down into the Virgin River and out to Mt Caramel or up Poverty and over to the Valley Junction up Long Valley to Alton or up to Glendale Bench to Alton. His name is Mac Sorenson. He hated the cattle drives. This closure would require a round trip of over 4 miles. 2 miles downhill, and 2 miles uphill with no place to refill water. I would have to carry over 2 gallons of water if I could make this hike. 

Donald Sprecher POVERTY ROAD CLOSURE SECTIONS T 0410 S R 0090 W SEE ABOVE 

COMMENT AS HISTORIC CATTLE TRAIL TURNED TO ROAD AS MODE OF TRANSPORTATION CHANGED THRU THE YEARS. I also hunt this area for mule deer. 

The Proposed RMP/EIS identified way open to O

Donald Sprecher BLOCK MESA ROAD CLOSURE SECTIONS T 0420 S 1O, 11, 14, 18, 22, 27, 

R0090W Here we have roads on top of a relatively flat top mesa, with beautiful views, but the sand is very difficult for me to walk on. I use my ATV for access when I hunt mule deer in this area. Sections 10, 11, and 17 would require 4 miles round trip. Part of the loop thru section 22, and 27 from the main Jeep trail could be eliminated, but not the entire road in that section. 

The sections cited by the 

routes were included in tSome routes identified in 

Proposed RMP due to reRoutes not identified in tsystem. Identifying and i

of this plan. The route ininventory (1979-1990). 

Duane Smith I feel that the special use permits should not be reduced to 25 veh. per group The special recreation p

determining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Duane Smith I feel that Table 3.26 should be eliminated-that data is flawed and inaccurate Table 3-26 in the Draft R

information system (RMIpage 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

Duane Smith The roads that run to, through and around Rock Canyon Spur, Poverty Flat The RMP does not adjud

34 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Road, Virgin River Access, Hell Dive, Ed Lamb Point Rd. Verillion Routt, Willis Canyon, Black Mesa quilify under RS2477 as road that should remain open to public acess of all types. 

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Earl Stuker Alternative B (Preferred) has some excellent points. Some modifications I would 

like to see are the following: A. Manage three RMZs specifically for motorized 

uses (21, 800 acres) I think this should read 42,000 acres. B. Manage six RMZs specifically for non-motorized uses (44,900 acres) I think this should read 21000 acres. C. You do not have to close a land to study it for a prospective wilderness area. 

Motorized and non-motoplanning process. The D

resource values are protmotorized access and reany lands for wilderness Congress. 

ECOS Consulting This section is not an analysis of impacts, as it is supposed to be, it is just a 

series of statements stating the obvious. What is the extent of the direct, indirect, and cumulative impacts on these species if fire suppression and management plans are enacted? 

Wildland fire resource pr

would be applied based Stabilization and Rehabispecific conditions includPage 2-20 of the Draft Rmeasures. 

ECOS Consulting The width and extent of "Right-of Ways" and "Easements" proposed in the 

alternatives are too large and expansive to maintain functional ecosystems, viable unfragmented wildlife populations, natural vegetation communities, intact soil structure, and prevent widespread wind (dust) and soil erosion. 

The Draft RMP/EIS idenon resource and resourc

implementation level decusing site-specific NEPA 

ECOS Consulting In order to protect the ecological integrity of the Kanab Decision Area, it is 

recommended that all "rights-of-ways" and "easements" are limited to a maximum width of 100 meters or less, and that the total number be minimized. 

The Draft RMP/EIS idenon resource and resourcimplementation level dec

using site-specific NEPA 

ECOS Consulting The BLM is being irresponsible in the future planning of ROW's when it 

recommends that 72% of the Decision Area be open to the cumulative potential of all these adverse impacts, that's almost 400,000 acres out of a total of 520,000 acres. This is not reasonable, and is another example of mismanagement by not dealing directly with the issues. 

While 399,400 acres are 

necessarily mean that rigareas. Prior to applicatiocompleted. The rights-ofon resource concerns. In are listed on page 2-88. 

ECOS Consulting The BLM must limit all "right-of-ways" and "easements" to no more than 100 

meters in width. The unlimited extent of "Right-ofWays" and "Easements" planned over 72% of the Decision Area in the preferred alternative is too large to maintain functional ecosystems, viable unfragmented wildlife populations, natural vegetation communities, intact soil structure, and prevent widespread wind (dust) and soil erosion. 

The Draft RMP/EIS idenon resource and resourc

implementation level decusing site-specific NEPA 

ECOS Consulting If the authorization of ROW's would have potential direct, indirect, and cumulative 

short- and long-term adverse impacts on wildlife, then there should be an indepth analysis of these impacts on wildlife and an estimate of locations and extent of these impacts and what wildlife would be most impacted and how these impacts affect BLM species population goals. 

Page 4-71 is the impact impacts to fish and wildliare discussed under eac

35 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

ECOS Consulting The DRMP does not analyze the serious short- and long-term adverse impacts 

from livestock grazing in desert environments. 

Nearly all of the Kanab F

and is not a true desert e(http://pubs.usgs.gov/gipand long-term impacts fr

ECOS Consulting Page 4-17, 3r d Paragraph: Actions that allow livestock trampling ofbiological soil 

crusts are not short-term and localized, as stated in this paragraph. It is well documented in the scientific literature that BSC's are easily destroyed by livestock trampling and that recovery time for BSC's can take from up to 300 years, depending on micro-site characteristics. With the loss ofBSC's from the trampling of livestock grazing the ecosystem would suffer the loss of many positive ecological functions. Thus the impacts are severe and long-term. 

The analysis the commethe impacts to all soil typ

analysis of impacts to so

ECOS Consulting Page 4-25, 5th Paragraph: The BLM must show how livestock grazing according 

to BLM Standards and Guidelines would eliminate long-term impacts. What specifically will the Standards and Guidelines direct the BLM to do in order to 

mitigate the effects of erosion from compacted soil, from the destruction of biological soil crusts, from vegetation loss, from the invasion of exotic species, from stream bank failure due to vegetation loss and erosion, and from direct fecal matter input into surface water? 

The BLM Standards and The Standards and Guidlivestock grazing managtowards attaining rangela

ECOS Consulting If the BLM can, it must show the documentation that these conditions are indeed 

improving, and why they are improving. Or at least, the BLM must summarize this information in this DRMP/EIS, or provide a list of allotments or areas and their conditions and trends. There is a total lack of any of this kind of information in this DRMP/EIS. How is the public able to determine if the BLM is managing the range properly if there are no results, analyses, recommendations, or feedback from over 12 years of commitment to the Standards and Guidelines? There are a number of areas in the Decision Area that clearly do not meet the current BLM standards. What are the plans for those areas? 

The Rangeland Health Acomparison to the four fuassessments were summchapter 3 (see section 3the current assessment functioning at risk. The oare located in the Kanab describes the regulatory 

attain to one of the standgrazing. 

ECOS Consulting The Kanab DRMP/DEIS fails to adequately address the negative direct, indirect, 

and cumulative effects of livestock grazing on the soils, vegetation, water quality, and stream functions within riparian areas. 

Nearly all of the Kanab F

and is not a true desert e(http://pubs.usgs.gov/gipand long-term impacts fr

ECOS Consulting The DRMP should state what actions will be taken based on various drought 

conditions. 

Chapter 2 of the Proposedrought, and natural disa

ECOS Consulting This Kanab DRMP/DEIS does not adequately address direct, indirect, and 

cumulative impacts. The purpose of the National Environmental Policy Act (NEPA) is to provide line officers and the public with full disclosure of the environmental consequences of taking action so they can make "informed" decisions. The Council on Environmental Quality regulations require that impact analyses include discussions of adverse and beneficial effects, short- and longterm effects, direct and indirect effects, and cumulative effects. The 

A systematic interdiscipland scientifically sound econsequences associateeach alternative. The anon the public lands resoureasoned choice among explains: "Council on En

36 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

characterization of impacts must not only be simply an accounting of acres affected, as is the case throughout this Kanab DRMP/DEIS, but it must include descriptions of potential beneficial and adverse impacts, of impact duration, intensity or magnitude, and context (site specific, local, regional, and national effects, etc.), and there must be an analysis of direct, indirect, and cumulative impacts. In this Kanab DRMP/DEIS, many of the conclusions regarding potential impacts were presented without supporting scientific analysis, agency monitoring data or rationale, and, as such, appear arbitrary and unfounded. 

National Environmental reasonably foreseeable an EIS identify incompleessential to a reasoned cRegulations [CFR] 1502specific data are used to best available informatiodeveloping this Draft ReStatement (DRMP/DEIS

ECOS Consulting Many areas within the Kanab Decision Areas are adversely impacted, and have 

been for many years by activities allowed by the BLM. These impacts must be analyzed in greater detail, and BLM must provide supporting analysis and the rationale for the agency's subsequent conclusions. This is particularly evident in the sections on livestock grazing, mineral resources, and recreational and travel decisions. BLM fails to provide quantitative and/or qualitative analyses, and it fails to adequately consider the direct, indirect, and cumulative effects of the proposed alternatives. 

The current condition of 

Environment. This descrnon-BLM actions on the includes the impact analSome impacts cannot be Where this gap occurs, isituations, subsequent pand examine site-specifiapplication of RMP-level and other agencies withiinformation that will be u

ECOS Consulting BLM's Kanab DRMP/DEIS fails to include a reasonable range of Alternatives. 

Specifically, it contains no alternative that would adequately protect the scarce riparian resources of the Kanab BLM Decision Area from OHV use, livestock grazing, mineral development and associated damages from these activities. 

BLM has provided a reasDraft RMP/EIS represenand need and of resolvinrange of alternatives beg

public scoping period anin coordination with our cperiod on the RMP DEIS

ECOS Consulting Reasonable alternatives that limit the number and extent of OHV routes must be 

presented. 

BLM has provided a reasDraft RMP/EIS represenand need and of resolvinrange of alternatives beg

public scoping period anin coordination with our cperiod on the RMP DEIS

ECOS Consulting What are the direct, indirect, and cumulative impacts of these OHV routes within 

specific riparian areas? The Kanab DRMP/EIS mentions some direct impacts but 

fails to disclose the long-term indirect and cumulative impacts. 

The impact analysis usedetermine the impacts to stated in Appendix K, imroutes and will continue riparian conditions, as nehealth and functionality wprotect these areas befo

37 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

ECOS Consulting It is highly recommended that the BLM perform these types of analyses before 

committing to 10-20 more years of management without adequate background baseline, trend, and potential habitat extent information. 

CEQ regulations implemrequire agencies evaluatenvironmental impact stainformation, if that informalternatives (43 CFR 150specific data is used to tAdditional information on section 4.1.6 of the Draft 

ECOS Consulting This Kanab DRMP does not present an adequate range of Alternatives for the 

proposed number and extent of open OHV routes in the Travel Plan. 

BLM has provided a reasDraft RMP/EIS analyzes alternative, except for Althe identified purpose anbegan early in the RMP through February 2005) coordination with our coo

ECOS Consulting BLM does not provide an adequate range of alternatives for the number and 

extent of OHV routes allowed. BLM ignores the seriousness of the impacts. 

BLM has provided a reasan alternative means of resolving issues raised dbegan early in the RMP and was further developour cooperating agencieDEIS. Chapter 4 discloseand route identification. 

ECOS Consulting It is recommended that the BLM analyze the direct, indirect, and cumulative 

effects of roads, throughout the 524,000 acres of the Kanab Decision Area that will contribute to the fragmentation of wildlife habitat. 

Impacts to wildlife habita

Impacts to Fish and Wildsections of Chapter 4 of 

ECOS Consulting It is recommended that the BLM act wisely and in the spirit of its mandates and 

commitments to maintain healthy and sustainable ecosystems, by eliminating and restoring many of these OHV routes. If many of these roads remain open for the next 10-20 years, the future of much wildlife habitat will continue to be at risk due to many of the adverse impacts listed above. 

The resources and uses 

routes. The process use

ECOS Consulting The DRMP's range of alternatives for livestock grazing is not adequate and must 

be expanded to include alternatives that allow little (15-25%) or no grazing (0%) or some grazing(50%), or a lot of grazing (>90%). 

The BLM did consider an 

grazing, but did not analy2.3.2). NEPA does not resimply for the sake of anthe BLM to develop a reaalternative, the preferred the issues raised during alternatives to address thby NEPA, the Draft RMPEach alternative, except 

38 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

satisfying the identified palternatives began early period (April 2004 througthe process in coordinaticomment period. 

ECOS Consulting Many of the impacts described in this Kanab DRMP/DEIS have been monitored 

by the BLM, but the BLM has failed to provide analyses, trends, and summary data for the information collected in the field. 

Chapter 3 of the Draft RMdecision area. This chapBLM. Additional informatthe Management Situatioregulatory requirement to Draft RMP/EIS. 

ECOS Consulting Page 4-24, 3r d Paragraph: Mitigation is mentioned here but details are not 

forthcoming. According to NEPA, planned mitigation must be described in detail. What mitigation protocols will be used to restore biological soil crusts? How long will it take for the biological soil crusts to become ecologically effectual? The mitigation described briefly in this DRMP/EIS cannot restore biological soil crusts within 5 years, thus the direct impacts are long-term. The direct loss of biological soil crusts on 8,426 acres is unacceptable when considering the indirect and cumulative effects, which can spread to a much larger adjacent area. What are the projected indirect and cumulative effects? The BLM makes no effort to analyze these. 

Individual mitigation meaincluding, soil types, and Additionally, mitigation m

implementation action. Tactions after NEPA analy

ECOS Consulting In this Draft RMP/EIS, where is the analysis of cumulative effects regarding the 

past, present, and reasonably foreseeable future actions of the impacts discussed? There is no mention of the past impacts of livestock grazing, mineral development, and OHV use, and how these have adversely affected the biological soil crusts and vegetation today, and in the future. 

The Draft RMP/EIS addrfuture actions. The existiin the Draft RMP/EIS cha

grazing, transportation, mactions. Therefore, impabaseline condition of resAnticipated impacts from reflected in Chapter 4 of associated with the alter

through 4-5. Anticipated 

contained in Draft RMP/

ECOS Consulting There is also no mention of the context, intensity, and duration of an impact. The impact analysis in C

intensity, and duration of 

ECOS Consulting In relation to Appendix A on page AA-1 – Although BMP's have been in place for 

many years, the BLM doesn't ever mention a monitoring program, or an evaluation of the success of one BMP application, nor any feedback. Are there any monitoring/ evaluation/ feedback reports on any of the projects where BMP's were used? If there are, these must be summarized in this document so that these BMP's can be judged effective or not, so that future management planning can be successful. 

There is no legal or regufeedback reports in the D

site-specific conditions, sindustry experience and adjusted would be applie

39 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

ECOS Consulting National Environmental Policy Act (NEPA) court precedence states that rather 

than just listing mitigation, the Environmental Impact Statement (EIS) must analyze mitigation in detail and explain the effectiveness of the measures in terms of the resulting impacts (Northwest Indian Cemetery Protective Association v. Peterson, 795 F. 2d 288 (9th Cir. 1986)). The BLM has not done this in this DRMP/EIS for many of the issues for which it recommends mitigation. 

Individual mitigation meaincluding, soil types, and Additionally, mitigation mimplementation action. Tactions after NEPA analy

ECOS Consulting National Environmental Policy Act (NEPA) court precedence states that rather 

than just listing mitigation, the Environmental Impact Statement (EIS) must analyze mitigation in detail and explain the effectiveness of the measures in terms of the resulting impacts (Northwest Indian Cemetery Protective Association v. Peterson, 795 F. 2d 288 (9th Cir. 1986)). This discussion of acres impacted must be more thorough and not only analyze the direct impacts, but also the indirect and cumulative impacts. 

Individual mitigation meaincluding, soil types, and Additionally, mitigation m

implementation action. Tactions after NEPA analy

ECOS Consulting In this DRMP/EIS, where is the analysis of cumulative effects regarding the past, 

present, and reasonably foreseeable future actions of the impacts discussed? There is no mention of the past impacts of livestock grazing, mineral development, and OHV routes and use, and how these have adversely affected the biological soil crusts, vegetation, and water quality and quantity today, and in the future. 

The Draft RMP/EIS addrfuture actions. The existiin the Draft RMP/EIS cha

grazing, transportation, mactions. Therefore, impabaseline condition of resAnticipated impacts from reflected in Chapter 4 of associated with the alter

through 4-5. Anticipated 

contained in Draft RMP/

ECOS Consulting These indirect and cumulative effects must be analyzed or estimated by the BLM 

in this document. Simply stating, as the BLM does numerous times in this DRMP/DEIS, that all actual and potential problems will be mitigated is not enough in a NEPA-based EIS. 

Individual mitigation meaincluding, soil types, and Additionally, mitigation mimplementation action. Tactions after NEPA analy

ECOS Consulting Page 4-41, 5th Paragraph: The magnitude of impacts would indeed decrease 

when compared to alternative A, but is that the standard that all impact analysis 

should be compared to? I don't think that is the intention of NEPA. Instead of comparing alternative B impacts to the worst case management scenario (alternative A), the BLM must concentrate on and describe the actual intensity and duration of direct, indirect, and cumulative impacts. 

In the document prepare(accessed on June 5, 20

CEQ clarified the definiti“...projected impacts of athe EIS to those impacts RMP/EIS chapter 4 com

described in Alternative A

ECOS Consulting The BLM's conclusions of cumulative effects in this document were presented 

without supporting scientific analysis or rationale, and, as such, appear arbitrary and unfounded. 

A systematic interdiscipland scientifically sound econsequences associateeach alternative. The anon the public lands resou

40 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

reasoned choice among 

ECOS Consulting In planning these activities the BLM must show that it is taking every precaution 

to protect biological soil crusts and minimize surface disturbance. Has the BLM done this? If so, where is the documentation and what are the measures? 

Individual mitigation meaincluding, soil types, and Additionally, mitigation mimplementation action. Tactions after NEPA analy

ECOS Consulting The BLM lists many direct and indirect impacts but fails to adequately discuss 

intensity and duration. The biggest short-coming of this analysis is to call all of these impacts "short-term" when in fact they are long-term (last more than 5 years). 

The impact analysis in Cintensity, and duration of 

ECOS Consulting In this Kanab DRMP/DEIS, by not including a reasonable range of alternatives, 

and not dealing directly with the impacts of livestock grazing, OHV routes, and mineral development, the BLM is skirting the NEPA requirements that compel the 

agencies to concentrate on the significant issues that will seriously effect the protection, restoration, and enhancement of the human environment. Only by considering a full range of alternatives and the full direct, indirect, and cumulative impacts of these activities can the BLM make sound management decisions. 

BLM has provided a reasDraft RMP/EIS analyzes alternative, except for Althe identified purpose anbegan early in the RMP through February 2005) coordination with our coo

ECOS Consulting For cumulative impacts the following questions must be answered according to 

the Judicial Review Standard: The "Fritiofson v. Alexander" Test ( Fritiofson v. Alexander, 772 F.2d 1225 (5th Cir. 1985). 

The case cited is not autauthority for the principle as part of its cumulative 

be included. BLM defineImpact Analysis section foreseeable actions are in Chapter 4. 

ECOS Consulting The riparian "330 foot" buffer proposed within this Kanab DRMP/DEIS is woefully 

inadequate to prevent widespread riparian long-term, direct, indirect and cumulative impacts. 

Not allowing surface distis the Utah BLM policy oevaluated not allowing sriparian/wetland areas a

ECOS Consulting For these reasons, and many more, the BLM must establish an effective buffer 

zone that protects the less than 1% of the Kanab Decision Area that riparian habitat encompasses. When there is nearby surface disturbance, the proposed BLM buffer of "100 meters" is inadequate in this dry desert environment, because ofthe ease of the spread of soil disturbance and erosion, vegetation loss, and soil and water contamination that can spread into the floodplain and riparian habitat. 

Not allowing surface distis the Utah BLM policy oevaluated not allowing sriparian/wetland areas a

ECOS Consulting The DRMP/EIS fails to provide enough information to adequately assess the 

direct, indirect, and cumulative impacts of OHV use in the riparian areas within the Kanab Decision Area. In particular, the DRMP/EIS fails to identify what specific riparian areas will be affected, how much of the total percentage of riparian areas and floodplains will contain OHV routes in the different alternatives, or what specific riparian areas will be "Closed." 

The impact analysis usedetermine the impacts to stated in Appendix K, imroutes and will continue riparian conditions, as nehealth and functionality wprotect these areas befo

41 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

ECOS Consulting It is recommended that the DRMP fully disclose what riparian areas will have 

OHV routes in/near them. Specifically, each riparian area should be listed as either open or closed to OHV use, with "open" being those riparian areas that have an OHV route within the riparian area and/or floodplain. The DRMP/EIS should also disclose each of the routes clearly, and address how they will be maintained. The DRMP/EIS should also address future relocation and closure due to deteriorating riparian conditions and deteriorating route conditions due to continuous wear and tear and storm events. 

The impact analysis usedetermine the impacts to stated in Appendix K, imroutes and will continue riparian conditions, as nehealth and functionality wprotect these areas befo

ECOS Consulting Thus, the BLM must manage the small percentage ofriparian habitat that is in the 

Kanab DRMP project area, less than 1% of the total area, for the maximum benefit of renewable resources, and for the ecological benefit of surrounding areas. 

Page 2-38 of the Draft Rareas. 

ECOS Consulting These potential impacts are not addressed adequately in this Kanab 

DRMP/DEIS; this is especially relevant considering the increase in mining and oil 

and gas exploration applications and future plans of the industry. 

Riparian management anot allowing surface distdevelopments, within 33best management practidisturbances near riparia

ECOS Consulting Where monitoring programs have been developed and used, the BLM must write 

summary and trend reports so that management and the public can make determinations on the effectiveness of the management of allowed activities. 

There is no legal or regurequest is outside the sc

ECOS Consulting In particular, we would like to see Wildlife Management Plans for mountain lions, 

bobcats, bears, foxes, and coyotes that include habitat improvements and the protection of areas large enough to support viable populations of these predators. 

Wildlife management is tResources. As described is responsible for managstate wildlife agencies w

ECOS Consulting Besides population numbers, this DRMP lacks overall goals and objectives for 

the management of fish and wildlife for the next 10-20 years. It also lacks what the basic wildlife needs are and how the BLM plans to meet any objectives. 

Wildlife management is tResources. As described is responsible for managstate wildlife agencies w

ECOS Consulting By all measures, the loss of wildlife habitat in this area would be devastating, 

immediate, and very long-term. What wildlife use this habitat? Are there any populations that would be significantly impacted by these activities? This must be thoroughly discussed in this section. 

The document currently 

question notes that “wildacres.” It also notes that disturbance, “sagebrush years to reestablish.” Thwildlife would be lost to sfor coal does not identify located, it is not possible mine. The site-specific Nimpacts of this nature. 

ECOS Consulting The destruction of biological soil crusts is a "long-term" impact. The loss of 

biological soil crusts has long-term indirect and cumulative effects on soil stability and moisture, on the amount of vegetation, vegetation type, vegetation health 

Chapter 3, section 3.2.3

soil crusts and their impothe Draft RMP/EIS: “Tota

42 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

and vigor, and is directly responsible for the loss of many important ecological functions within the ecosystem. 

cover, as less plant covegrowth of crustal organisOffice have generally shassumption that 90 perccovered by biological soRMP/EIS: “The BLM’s st

involves the use of ecolodeveloped for specific soand developed by the NaDepartment of Agriculturnot contain specific inforexpected to be on the sitsoil crusts within the decespecially in areas with ltheir professional judgmepresent in functional and ecological processes in cRMP/EIS management acondition of a site rather designed to maintain or healthy condition tend to distribution. The impacts addressed in Chapter 4 

decision making in the Dcrusts would be covered 

renewals, special recrea

ECOS Consulting The BLM Kanab Field Office must classify biological soil crusts as a "sensitive 

and fragile soil." BSCs are classified as such in the Moab Field Office. 

Fragile soils were definesoils that are most fragile even with management aflora cover type in their oRemoval of any vegetatiDraft RMP/EIS chapter 4definition of fragile soils. crusts in the Kanab Field Therefore, biological soil Draft RMP/EIS as in the 

ECOS Consulting Given the scientific literature on the ecological importance of BSC's, how can this 

component not be part of the evaluation? Without this component included, the results of these evaluations cannot be seriously considered as an effective indication of the health of the land. 

Chapter 3, section 3.2.3soil crusts and their impothe Draft RMP/EIS: “Tota

cover, as less plant covegrowth of crustal organisOffice have generally sh

43 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

assumption that 90 perccovered by biological soRMP/EIS: “The BLM’s stinvolves the use of ecolodeveloped for specific soand developed by the NaDepartment of Agriculturnot contain specific infor

expected to be on the sitsoil crusts within the decespecially in areas with ltheir professional judgmepresent in functional and ecological processes in cRMP/EIS management acondition of a site rather designed to maintain or healthy condition tend to distribution. The impacts addressed in Chapter 4 decision making in the Dcrusts would be covered renewals, special recrea

ECOS Consulting It is recommended that the Kanab Field Office classify BSC's as sensitive soils 

and limit surface disturbance wherever they are present, and wherever they have historically occurred. 

Fragile soils were define

soils that are most fragile even with management aflora cover type in their oRemoval of any vegetatiDraft RMP/EIS chapter 4definition of fragile soils. crusts in the Kanab Field Therefore, biological soil Draft RMP/EIS as in the 

ECOS Consulting Because of the widespread occurrence of biological soil crusts in the Decision 

Area, it is essential that the BLM include the protection of these fragile and sensitive biological soil crusts as a fundamental part oftheir land management, and as a top priority in their best management practices (BMP's). 

Chapter 3, section 3.2.3soil crusts and their impothe Draft RMP/EIS: “Tota

cover, as less plant covegrowth of crustal organisOffice have generally shassumption that 90 perccovered by biological soRMP/EIS: “The BLM’s st

44 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

involves the use of ecolodeveloped for specific soand developed by the NaDepartment of Agriculturnot contain specific inforexpected to be on the sitsoil crusts within the decespecially in areas with ltheir professional judgmepresent in functional and ecological processes in cRMP/EIS management acondition of a site rather designed to maintain or healthy condition tend to distribution. The impacts addressed in Chapter 4 decision making in the Dcrusts would be covered renewals, special recrea

ECOS Consulting Page 4-24, 2nd Paragraph: This statement is wrong. The short-term use of soil 

resources will definitely affect long-term productivity of the biological soil crusts and the vegetation that depends on it for water retention and vital minerals. Reclaiming disturbed areas, as outlined in the BMP's in Appendix A, will not be nearly as effective in this dry desert environment. Especially on soils that contain biological soil crusts, which is about 89% of the Decision Area. 

Application of BMPs will 

and montane climates pr

ECOS Consulting In particular, the BLM must update, develop, and maintain strict protocols or Best 

Management Practices (BMP's) that are designed to minimize damage to biological soil crusts, vegetation, water, and riparian resources during extractive industry activities. 

Appendix A of the Draft 

(BMPs) designed to maxnegative environmental i

ECOS Consulting Boilogical soil crusts are a significant part of a majority of vegetation types in the 

Kanab Decision Area. Desert Scrub, Sagebrush Steppe, and Pinyon-Juniper 

Woodland encompass approximately 90% of the Kanab Decision Area. This is why the protection, restoration, and, enhancement of the biological soil crust is so important. 

Chapter 3, section 3.2.3soil crusts and their impothe Draft RMP/EIS: “Tota

cover, as less plant covegrowth of crustal organisOffice have generally shassumption that 90 perccovered by biological soRMP/EIS: “The BLM’s stinvolves the use of ecolodeveloped for specific soand developed by the Na

45 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Department of Agriculturnot contain specific inforexpected to be on the sitsoil crusts within the decespecially in areas with ltheir professional judgmepresent in functional and ecological processes in cRMP/EIS management acondition of a site rather designed to maintain or healthy condition tend to distribution. The impacts addressed in Chapter 4 decision making in the Dcrusts would be covered renewals, special recrea

ECOS Consulting The BLM should state clearly that "limited" means that OHV use will be limited to 

designated routes within riparian areas, that OHV use will not be precluded from riparian areas, and that such OHV use will adversely affect the riparian areas. 

As defined in the Draft Rroutes means that OHV 

BLM regardless of resou

ECOS Consulting What are the purposes and reasons for each of the designated OHV routes? The 

DRMP/EIS fails to adequately address the purpose of these routes. 

The BLM is not required identified route. Resourcroutes in each alternativeas specified in the BLM’s Appendix K. 

ECOS Consulting Has the BLM documented the specific purpose of each OHV route it intends to 

designate? This must be done, and if a road is found to be redundant or if no specific and compelling purpose, it must be closed and rehabilitated. 

The BLM is not required identified route. Resourcroutes in each alternativeas specified in the BLM’s Appendix K. 

ECOS Consulting What are these treatments? The BLM must provide a list of proposed treatments, 

a detailed description of them, and the direct , indirect, and cumulative impacts that they entail. 

The RMP sets the goals planning handbook (BLMvegetative resources, incstages, and landscape avegetation treatments inmanagement practices s

(including fuels treatmenNEPA analysis would ocgive the public a chance proposed. 

46 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

ECOS Consulting The BLM must show an analysis of why particular habitats have become 

degraded, and provide maps of the locations of degraded areas and proposed "vegetation treatments". 

Ecological sites (habitatsjuniper encroachment, c

complex, multifaceted, aanalyzed with site-specif

3 of the Draft RMP/EIS iecological sites and a vedisturbance regimes. 

ECOS Consulting Casting the vague term "vegetation treatments" as the remedy to most of the 

impacts of proposed management actions is arbitrary, and in direct violation ofNEPA, and must not be used in this Kanab DRMP/DEIS. 

Ecological sites (habitatsjuniper encroachment, c

complex, multifaceted, aanalyzed with site-specif

3 of the Draft RMP/EIS iecological sites and a vedisturbance regimes. 

ECOS Consulting The BLM is proposing to manage the resources by “vegetation treatment” of an 

average of 22,300 acres a year, or over 88% of the total area of the decision area in the next 20 years. This appears to be an arbitrary and excessive figure for which no basis is provided in the Draft RMP/EIS. 

The management action 

22,300 acres a year is dvegetation treatments. A

Draft RMP/EIS, the treatamount of acres that wo

on the ecological threshoon the research describesummarized in Table 3-8 year planning window fodisturbance regimes. 

ECOS Consulting Vegetation treatments over 22,300 acres a year is excessive and over the life of 

this management plan would cover the whole Decision Area. This is intensive management at its worst because of the long-term negative impacts to soils (destruction of BSC's and compaction) and potential natural vegetation communities. 

The management action 

22,300 acres a year is dvegetation treatments. ADraft RMP/EIS, the treatamount of acres that wo

on the ecological threshoon the research describesummarized in Table 3-8 year planning window fodisturbance regimes. 

ECOS Consulting The results of past monitoring, showing trends, must be presented in order for 

the public to determine if these areas are being properly managed, and if not, what mitigation needs to be done to improve conditions. 

The water quality monitoused in the Draft RMP/Epage at http://ww.epa.goChapter 3 of the Draft RMdecision area. This chapBLM. Additional informatthe Management Situatio

47 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

regulatory requirement to Draft RMP/EIS. 

ECOS Consulting It is highly recommended that the BLM take the time to complete WPM's for at 

least the major watersheds within the Kanab Decision Area before this Kanab DRMP is finalized. 

The Draft RMP/EIS chapWMP (Upper Sevier WatVirgin River Watershed. Watershed Management RMP/EIS was modified tManagement Plans are irequired for the BLM to cscope of this NEPA docu

ECOS Consulting Have there been any peer-reviewed reports? If so, this data should be 

summarized in this DRMP/EIS, so that the public can assess trends and whether or not the BLM is effectively managing this resource. 

The Utah Division of Wa

Groundwater quality monproject-level program. 

ECOS Consulting In this DRMP/EIS, the BLM must show plans to be proactive in assessing water 

quality trends and identifying sources of water quality deterioration. Waiting for 

water bodies to be included on the 303(d) list is ineffective management and may be too late for many systems. 

Chapter 2 of the Draft RMwater quality. Additionallcontinue to actively partiadministered by the Utah 

ECOS Consulting This includes Cottonwood Canyon for the Fredonia water supply, and the 

watersheds serving Kanab, Panguitch, Hatch, Orderville, Escalante, Glendale, Tropic, Big Water, and Boulder. Are there any additional safeguards for these watersheds? If so, what are they, and they should be listed in this DRMP/EIS. 

The Cottonwood Canyon RMP/EIS provides proteculinary water system. T

Kanab culinary water suactions to continue to wowater sources. 

ECOS Consulting All of these activities will adversely affect migratory birds, yet there is no mention 

of the impacts of these activities on migratory birds. The BLM must fully analyze 

the impact of these activities on migratory bird habitat. 

The Draft RMP/EIS consnoted as a planning issu3.2.7, including Table 3-

bird species and their haand management actionidentifies impacts to thesstatus species sections. 

that was considered throthe identification of route

ECOS Consulting The BLM must plan for the protection of migratory birds by listing and mapping 

important habitat types, and keeping designated OHV routes and other management activities to a minimum in these areas. Natural processes must be allowed in certain areas, unencumbered by management activities or treatments. None of this type of planning is evident in this document. 

The Draft RMP/EIS cons

noted as a planning issu3.2.7, including Table 3-

bird species and their haand management actionidentifies impacts to thesstatus species sections. that was considered throthe identification of route

48 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

ECOS Consulting Page 4-75, 8th paragraph: Forest and woodland product harvest, cross-country 

and on-route OHV use, road construction, facility construction, mineral development and the construction of related facilities, and ROW construction all can individually have serious adverse impacts. The activities are of such intensity and seriousness that they should not be lumped together, but considered separately. Their impacts should be treated separately and then an analysis of cumulative impacts should follow. This is important because habitat loss, alteration, and fragmentation are the primary causes of fish and wildlife population loss throughout the country. 

Based on the condition aRMP/EIS chapter 3, the alteration, fragmentation

Evan Day Please include in your final RMP access possibilities for personal, noncommercial rock and fossil collecting. Restrictions on mining for commercially 

valuable minerals, and restrictions on off highway travel directly affects our ability to access remote areas and enjoy our hobby. 

All of the alternatives allo

provide the protection of categories would apply t

Five County Association of Governments 

The Draft RMP goes on to simply state that the preferred alternative is consistent 

with local plans to the extent possible. No analysis of how this conclusion was reached is made. This is a serious omission. The consistency section should be expanded to include such an analysis. 

A consistency review of Plans is included in Cha

Five County Association of Governments 

Wilderness inventories ended pursuant to the provisions of FLPMA. BLM identified lands with wilderness qualities, and has forwarded these recommendations to Congress. The final RMP should limit wilderness management to formally designated wilderness areas and wilderness study areas. Subsequent inventories, especially those conducted by non-professional special interest groups should not hold any credence in management actions laid out in the final RMP. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to hasimilar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and object

49 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

necessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Five County Association of Governments 

The final RMP must include a description of the process employed to recognize RS2477 assertions that have gained judicial authorization, and provide county governments with a procedure to submit such assertions. 

The adjudication or non-outside the scope of the 

recognized by non-bindinwould be revised accordRMP/EIS. 

Five County Association of Governments 

In many cases, such class D roads have been slated for closure. We ask that the final RMP remove submitted Class D roads from routes slated for closure. 

A “D” route does not equ

not distinguish between adjudicate, analyze, or oBLM will update and adjuthrough plan maintenancadministratively or adjud

Five County Association of Governments 

County officials submitted inventories of Class D county roads during the planning process, and requested that the RMP honor such designations. In many cases, such class D roads have been slated for closure. We ask that the final RMP remove submitted Class D roads from routes slated for closure. 

A “D” route does not equ

not distinguish between adjudicate, analyze, or oBLM will update and adjuthrough plan maintenancadministratively or adjud

Five County Association of Governments 

Many of the routes identified as open only for administrative use lead to important water sources. Most of these locations have been identified by the Utah State Engineer as the source of formally approved state water rights. These are valid existing rights held by private citizens or corporations. Access to these valid existing rights should not be constrained by administrative use designations that 

allow use only by federal employees. Holders of valid state water rights should be allowed access. 

BLM is obligated by law existing rights are obligalands for the exercise of which BLM's obligations that would prevent the hworks diligently with the from occurring. If the holan action that prevents tequitable compensation 

the context of a land use 

Five County Association of Governments 

These are valid existing rights held by private citizens or corporations. Access to these valid existing rights should not be constrained by administrative use designations that allow use only by federal employees. Holders of valid state water rights should be allowed access. 

BLM is obligated by law existing rights are obliga

lands for the exercise of which BLM's obligations that would prevent the hworks diligently with the 

50 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

from occurring. If the holan action that prevents tequitable compensation the context of a land use 

Frank and Kaye Alleman 

We also don't think you have the authority to create areas of Wilderness Characteristics in non WSA lands. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to hasimilar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and objectnecessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Frank and Kaye Alleman 

Closing of roads that have RS2477 rights. We don't think you have the authority to do this. 

The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Garrett Hill It has been brought to my attention that there is a plan to close the poverty and The Proposed RMP/EIS 

51 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

steep trail roads. I have a few questions and some concerns. First off I would like to know the reasons that you are closing these roads. I would like these roads to remain open. Me and my family enjoy recreation and travel down these roads. I don't see why these roads need to be closed. There is nothing there that is harmed by riding through these areas. Also I would like to inform you that I am a high school senior and a seasonal intern in the Range Department. If these roads are closed it would mean that to maintain the fences and the box canyon spring at steep trail we would have to hike 1 mile with all the supplies needed to maintain these fences and box canyon spring. That would take a full ten hour day. With the road open it only took us about four hours to ride out there pack the supplies down a little hill and build the fence and put the gate in. 

identified way open to Osegment that parallels th

Gary Tsujimoto I think that some of the data in 3.26 is flawed and should NOT be considered. Table 3-26 in the Draft R

information system (RMIpage 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition 

used among federal age

Geno Ramsey Canyon Country 4x4 

I do not believe that the BLM should create artificial wilderness by designation it as an area with Wilderness Characteristic areas. I believe the BLM should seek out alternate methods to manage and protect the land, without giving it a WC designation. I believe that some WC areas such as Sheep Springs, Four Mile Creek and Kanab Creek have been improperly inventoried and should not receive such recognition. These areas have historically used machine built roads. (NOTE: If approved as WC areas, this land would basically be locked up just like a Wilderness Study Area, without the act of Congress needed to legally make Wilderness. Naming these lands as such is one step closer to them becoming full-blown Wilderness, not necessarily a bad thing in every case, but a step that shouldn't be included in this RMP nor be performed by the BLM. 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

Geno Ramsey Canyon Country 4x4 

I do not believe that group sizes should be limited to 25 people under the proposed Special Recreation Permit. This number in my opinion, is unrealistic and makes group events such as family outings or scouting events impossible. I believe the rules and authorized exceptions for these SRP'S should be clarified 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-by

52 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

and added to Alternative B. after evaluation of possib

Geno Ramsey Canyon Country 4x4 

I believe the information and data collected by the BLM in Table 3-26 is faulty. The BLM's own report indicates that critical information was not available for this table. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition 

used among federal age

Geno Ramsey Canyon Country 4x4 

I believe that the BLM should recognize the RS2477 road claims that are part of Kane and Garfield Counties Transportation Plans. The validity ofthese claims should be determined before a final decision is made in the RMP. 

The RMP does not adjudclaimed ROWs. The BLM 

elements of this RMP thracknowledged administr

Geno Ramsey Canyon Country 4x4 

The canan sawmill road is of major concern to me. The road has existed since the early 1900's and used for many things such as ranching, logging, and many recreational uses. Not to mention the unmatched beauty that the mountain has to offer and the local pioneer history. It is beyond be how such a road could closed. Another is the "side roads" on the Moquith Loop road. These side roads lead to some ofthe most beautiful and unaccessible areas in our county. Rich in culture and history. 

The Canaan Sawmill rouof the Kanab RMP. The Hell Dive route is onin the Proposed Plan. 

George and Frances Alderson 

Off-road Vehicles: The approval of 1,387 miles of ORV routes in Alternative B is excessive and would impose too many impacts on the wilderness, wildlife habitat, and public use values. Too many ORV routes are too close together, forming a dense network. We believe this network exceeds BLM's ability to enforce regulations keeping vehicles on the designated routes. We urge that ORVs be restricted to a smaller network of more widely spaced routes. In addition: • ORVs should be barred from all proposed wilderness areas, a total of 132,000 acres, including all the areas shown in Map 3-15 in either pink or green. • No ORV routes should be in riparian zones or dry washes, because these are essential wildlife habitat. 

Appendix K of the Draft 

criteria used to identify athe commentor raises weduplicative routes, envirosensitivity, and current aproposed routes is discu

Glenn Wimpee Please include in your final RMP access possibilities for personal, noncommercial rock and fossil collecting. All of the alternatives allo

provide the protection of categories would apply t

53 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Hal Hamblin As the lessee for the Kinne Kernie (?) Springs alotment, I would to have the 

active AUM's available for use be looked into & possibly re-evaluated. 

Moving AUMs from suspdecision and is therefore 

Illegible Illegible Alternative B is preferred with reservations. I do not feel the BLM has the 

authority to implement changes to RS 2477 roads let alone any public roads and needs good reasons to close any roads whether established or not. 

The RMP does not adjud

claimed ROWs. The BLM 

elements of this RMP thracknowledged administr

J. Capozzelli There needs to be adequate opportunities to get out of earshot of motorized 

trails. Currently the large majority of the lands BLM manages are within 1 mile of a motorized road or trail. This is not acceptable in Southern Utah, one of the most remote and unspoiled parts of the lower 48. Therefore many routes which penetrate deeply into otherwise roadless areas should be closed, in order to have a more balanced spectrum of near-road and far-from-a-road recreational 

opportunities. 

Motorized and non-motoplanning process. The Dresource values are protmotorized access and re

Jacalyn & Charles Liebfried 

Table 3-26 is almost a complete fabrication. In logging over 6,000 off highway miles in Kane county we have encountered few vehicles and NO backpackers. Unless these hikers are raking out their tracks as they go, they simply do not exist. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition 

used among federal age

Jacalyn & Charles Liebfried 

Any and all RS 2477 roads must remain open. Litigation over these roads is paid for by the taxpayers for both sides of the issue. Avail yourselves to Kane County's pre 1976 aerial maps. 

The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Jacalyn & Charles Liebfried 

Roads to destinations such as, but not limited to, Lamb Point, Hell Dive and the Virgin River should remain open. These are beautiful spots and should not be limited to people in perfect physical condition. 

The Lamb’s Point route cIn consultation with the TRMP/Final EIS. The ProHell Dive. The commentspecific route is being re

Jack Christensen 1) Special Recreation Permits should be left as is not limit group size to 25. The special recreation p

determining if the permitlisted on page 2-80. If a 

54 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

25 people. On a case-byafter evaluation of possib

Jack Christensen User statistics in Table 3.26 seem to be flawed and should not be considered 

because it shows analysis and decision towards hiking at the expense of motorized use. There are far mor 4x4's and ATVs than hikers in the Kanab area. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

Jack Christensen 3) Three areas having "Wilderness Characteristics" are in fact not. These areas 

are: Sheep Springs, Four Mile Creek and Kanab Creek. All three of these roads 

have been machine groomed and bladed by either the BLM or the County. 

As part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

Jack Johnston U4WDA 

Special permit for groups over 25 means my family reunion, 32, would require a permit. Make it at least 40-50. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Jack Johnston U4WDA 

Was RS2477 considered when closing Sheep Springs Road and Kanab Creek Road as I know these roads are man made & maintained. 

The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Jack Johnston U4WDA 

I saw no provision for establishing new roads or trails. Appendix K of the Draft 

criteria used to identify afuture. 

James & Lorna Sills Areas of Critical Environmental Concern (ACEC) Cottonwood Canyon ACEC is 

proposed in Alternate B. We can understand and accept this ACEC to protect the watershed, but 3800 acres seems extreme and we question whether this much acreage is needed. In addition, we strongly oppose the designation of any 

Appendix H of the Draft evaluate proposed ACECCFR 1610.7-2, and BLM ACEC was expanded to 

55 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

additional ACECs existing ACEC that exten

James & Lorna Sills Non WSA Lands With Wilderness Characteristics (WC) Congress gave very 

specific instructions to the BLM regarding Wilderness. Those instructions are contained in section 603 ofFLPMA. There is no justification, no mandate in FLPMA and no process requirement for engaging in an ongoing Wilderness inventory and review. Therefore the Map 3-15 and table 3-22 should not be included as part of this process. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District Clands it determined to hasimilar to the manner in authority for managing laderived directly from FLPBLM’s organic statute givpublic lands for multiple 

the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for curren

Planning Handbook (H-1preserve wilderness chasolitude, and outstanding 

Include goals and object

necessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishi

FLPMA §603 and those impairment standard, an§202 land management 

James & Lorna Sills Special Recreation Management Areas (SRMA) The DRMP needs to provide 

more direction on how these areas are to be managed. The "focus areas" need to be inclusive and avoid excluding other uses categorically. 

Appendix D of the Draft managed. An activity levof decision is signed. 

James & Lorna Sills Special Recreation Permits We do not support the Special Recreation Permit 

requirements as currently proposed in Alternate B. The group size limit of 25 people is unacceptable. We frequently have 4 people in our vehicle alone and like to travel in groups or travel with a club. Clear-cut guidelines need to be established for when a SRP is required. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

56 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

James & Lorna Sills Recreation Visitation We take exception to Table 3-26. Having visited areas 

managed by the KFO it is plain to see that this table is greatly flawed. Further, certain special interest groups are making grossly inaccurate statements based on this. We would like to see Table 3-26 removed completely from the RMP. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

James & Lorna Sills Kanab Community Special Recreation Management Area (SRMA) Off-Highway 

Vehicle (OVID Recreation Management Zone (RMZ) aka. Hog Canyon Trail System We support the RMZ, however the RMP lacks direction regarding when and how additional or expanded routes would be provided. An improved trail system would give the public an appropriate place for motorized recreation while reducing pressure on more sensitive areas. We support the proposal and map submitted by Canyon Country 4x4 for managing this RMZ. 

Appendix K of the Draft 

criteria used to identify afuture. 

James & Lorna Sills Transportation In perusing the maps in the DRMP/DEIS for Alternate B, we note 

roads closed that should not be closed. Why is an attempt being made to close roads that are part of the Counties Transportation plans? These roads along with the RS2477 roads that are being claimed by the counties should remain open and identified on subsequent maps and documents. Further there are existing roads not shown on the maps, thus making it difficult if not impossible to make meaningful comments regarding the RMP process as it pertains to Alternate B. Management Actions for the Transportation System Management 2-26 states; "Coordinate transportation planning with Kane and Garfield Counties". In view of the above stated omissions and errors we would like to know how this is to be accomplished. 

The RMP does not adjud

claimed ROWs. The BLM 

elements of this RMP thracknowledged administr

James & Lorna Sills Visual Resources Management Classes (VRM) The DEIS page 2-58 states" To 

the extent practicable, bring existing visual contrasts into VRM Class conformance as the opportunity arises. What is meant by "To the extent practicable"? This is too vague and subjective regarding what the Management Action is. Unless the Management Actions are properly defined, we are opposed to the designation of VRM Classes as shown in Alternate B. 

The definition of visual reRMP/EIS. 

James Bulkeley The alternatives are also flawed in that they do not address any mitigation 

measures for loss of motorized recreational opportunities. 

BLM is not required to m

Under FLPMA’s multiple

57 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

values and uses on publobjectives for each of thoaccomplish those objectnecessarily manage evemany different values anthe Draft RMP/EIS descrresources and resource 

James Bulkeley I have reviewed the plans and noticed the following major flaw. The plan is flaw 

because it does not include the Grand Staircase-Escalante National Monument (GSENM) (1,900,000-acre). An adjacent land mass the size of the GSENM should be included in any regional plan. All of the proposed alternative failed to address a balance of recreational values and opportunities. 

The decision area does Monument (see page 1-3 

Staircase-Escalante Nat

The cumulative impacts cumulative impacts of th

decisions in the Kanab R

James McEwen Please include in your final RMP access possibilities for personal, noncommercial rock and fossil collecting. Restrictions on mining for commercially 

valuable minerals, and restrictions on off highway travel directly affects our ability to access remote areas and enjoy our hobby. 

All of the alternatives alloprovide the protection of categories would apply t

Jan Kobialka Areas of wilderness character contiguous to Zion National Park should be closed 

to ORVs, because Zion visitors often hike in these areas, as our friends did on their last trip. These include Parunuweap Canyon, Canaan Mountain and Moquith Mountain. Please close the Moquith Mountain ORV loop and keep ORVs out of the Coral Pink Sand Dunes, a beautiful area that should be managed for unspoiled character. Areas near the town of Kanab also need to be closed against the growing impacts of ORVs - Vermilion Cliffs, Upper Kanab Creek, and Moquith Mountain. 

The Proposed RMP/Finaareas of non-WSA areas 

Jana Hassett The plan proposed alternative does not recognize the City of Escalante Water 

System and existing ROW's for the water mains currently crossing BLM lands within the management area. solution - These ROW's need to be added and acknowledged within the plan and recognize the need for vehicle access to all segments of the ROW for maintenance. 

This is a site-specific ROexisting federal regulatio

Jay McIlwaine Coral Pink Sand Dunes etc.. Our noninvasive hiking trips are becoming harder to 

enjoy and sadly more infrequent. Off road vehicles are quickly and effectively 

destroying our ability to be "untrammeled". 

Motorized and non-motoplanning process. The D

resource values are protmotorized access and re

Jeff, Kendalee, Mccrae, Buster and Maddie Cox C-4 Ranch 

We have recently signed a long term lease agreement with the Barracks Ranch 

and are in the middle of leasing the poverty allotment, which places us smack dab in the middle of two proposed road closurs. The Poeverty and Steep Train 

roads are the only way to access water on these permits. As you well know, the watering hole is the focal point of cattle permits. We need the access to make frequent visits to make sure the cows are watering, and to monitor and maintain riparian areas. 

There are exclusions badefined in 43 CFR 8340.range improvements and 

58 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Jeff, Kendalee, Mccrae, Buster and Maddie Cox C-4 Ranch 

Third question, if you just put a sign in the ground, would the road be opened for administrative purposes and permit holders? If so, that's not good either, because if you can use the roads but close then to the public, you will have a lawsuit on your hands. I'm sure you have logically thought through all the possible scenarios. Personnally as a permitee, I don't enjoy the noise, dust, the traffic and the risks involved with managing the range, however I wouldn't want to deny 

anyone the right to travel the roads and view the scenery that has been done so for so many years. There are plenty of other slot canyons and places that I go, where travel is not permitted or accessible, to enjoy the serenity of the great outdoors. 

There are exclusions badefined in 43 CFR 8340.range improvements and 

Jennifer Kaufman I ask that the BLM in the final plan of the RMP close to OHVs the trail that runs 

east from the television towers past the bench to a dead end. Squaw Trail is a very popular well developed non-motorized trail just north of Kanab City and offers a fantastic recreation opportunity for local citizens and visitors. When visitors ask me for a hike close to town, I send them to Squaw Trail. OHVs still would have a spectacular view of all vistas from vantage points on routes by the television towers and along the tops of the cliffs trails system so I feel that it is unnecessary to continue a route near the top destination of Squaw Trail. 

OHV use in Hog Canyon designated by an interdisK of the Draft RMP/EIS. system due to resource 

Jennifer Kaufman I feel that all of the other proposed routes in this area duplicate each other as 

they appear to run parallel to each other and dead end into similar viewpoints. A few of the routes cross or deadend into private land. I have put a X on the routes that I feel are unnecessary as a motorized route for recreation. 

Routes in the area below interdisciplinary team acRMP/EIS. Changes were Proposed RMP/Final EIS

Jerry & Cindy Foote I believe that the BLM is establishing new wilderness areas without the authority 

to do so. To manage areas that have "wilderness characteristics" as WSAs is illegal. If these "wilderness characteristic" areas are based on the Utah BLM 1999 statewide wilderness re-inventory then these areas have no standing as this re-inventory was performed without public oversight, comment or review. Further, those areas claimed to have "wilderness characteristics" may not be managed as WSAs and OHV travel in these areas may not be restricted. Further still, these non-WSA "wilderness characteristic" areas are being managed and considered part of the Kane County General Plan for the citizens of Kane County. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to hasimilar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character ma

59 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

provides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and objectnecessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Jerry & Cindy Foote Table 3-26 in Chapter 3 of the Draft has obvious errors in it. Specifically: 1. The 

number of backpackers during the 05-06 year is listed as 20,000. This number is 3 times the entire population of Kane and Garfield counties. If that number was correct the influx of that many people would be highly noticeable in both parking areas of trail heads and at the grocery stores in the counties. The claim that these "20,000" backpackers spent on average 5 nights in the field clearly indicates that the BLM staff has not been in the field or they would have noticed that these people are not there. As one that has been in the field both hiking and ATVing it is clear that these numbers are highly inflated. 2. To indicate that the number of big game hunters in the Kane and Garfield counties during the 05-06 year is 36,726 implies that there have been hunting permits for 36,726 hunters. A quick look at the Utah Division on Wildlife Resources information shows that the permits issued during these years is only about 30% of that number. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

Jerry & Cindy Foote We would like to comment on the Special Recreation Permit group size limitation. 

Limiting groups to less than 25 individuals is unrealistic and abridges the people's rights to access to public lands. Many times family picnics, scouting events, club outings would normally exceed this limit. As the present permitting process is 

very involved, lengthy and requires months of pre-planning it would not be possible to hold an event based on weather or other circumstances. With the current work load of the Field Office permits would not be available in a timely manor. 

The special recreation pdetermining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Jerry & Cindy Foote 1. One of our favorite areas to ride is down Poverty Canyon to the Virgin River. 

Under Alternative B the access to the Virgin River is proposed to be closed. We are against this closure for several reasons. First, the Virgin River in this area is a very scenic area with a magnificent Indian rock art panel. Second, this access is part of the Kane County travel plan and should be under their control. Third, the 

The Proposed RMP/EIS identified way open to Oin the Proposed Plan duThe RMP does not adjudclaimed ROWs. The BLM 

60 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

excuse has been given that this road was not part of the 1976 road inventory and as such should be closed. We submit that the 1976 road inventory plan was hastily done without actually examining the roads on the ground and thus to close this road on that basis is without merit. 

elements of this RMP thracknowledged administr

Jerry & Cindy Foote 2. Mirrored across the Virgin River is the Rock creek we are against the closure 

of the Rock creek access road. This road has been in existence for over 30 years and is considered an RS-2477 road by Kane County. 

The Rock Canyon route RMP/EIS. The Proposed identified way open to OThe RMP does not adjud

claimed ROWs. The BLM 

elements of this RMP thracknowledged administr

Jerry & Cindy Foote We would like to comment on the closure of Moquith Mountian to Lambs Point 

road and the road to Hell Dive Canyon as proposed in Alternative B. Hell Dive Canyon has one of the premier Indian drawings and grinding stones in the area and to close them off to ATV access would deprive many from ever viewing their beauty. Making this an interpretive site by the BLM would allow people to enjoy 

and learn from these sites as well as offer any protection that is felt needed. This road is also considered an RS-2477 road by Kane County and is part of their transportation plan. 

The Lamb’s Point route cIn consultation with the TRMP/Final EIS. The Proposed RMP/EIS access for development adjudicate, analyze, or oBLM will update and adjuthrough plan maintenancadministratively or adjud

Jerry & Cindy Foote The road out to the tip of Moquith Mountain, commonly called Lambs Point, 

presents the best panoramic views of the Arizona Strip and the Vermilion Cliffs. 

Alternative B proposes to close the road from where it leaves the Moquith Mountain road and enters Arizona. Further, according to the BLM Alternative B maps, this road does not exist where it returns back into Utah from Arizona. This indicates that the road inventory that the BLM has is wrong. This entire road from where it leaves the Moquith Mountian road out to Lambs Point was machine made and is clearly pre-1976. On this basis it is also an RS-2477 road and is rightfully claimed by Kane County as part of their transportation plan. 

The Lamb’s Point route c

In consultation with the TRMP/Final EIS. The RMthe validity of the claimetransportation plan and e2477 ROW assertions ardecision. 

Jim & Bonnie Vann Another area is the proposed Cottonwood Canyon ACEC. Although this canyon 

deserves protection primarily as a water source for the town of Fredonia, I believe its current scope is too broad and that there is no need for any additional ACEC's. 

The boundary of the Cotrelevant and important vbeyond the current boun

process and criteria used are based on FLPMA, 43 

Jim & Bonnie Vann The Recreation Management Zone in Hog Canyon is a good example of 

intelligent management as it is close to town for visiting tourists, already provides ample roads to travel, and is a cooperative effort with the BLM and the Canyon Country 4x4 Club. I support this RMZ and suggest that future expansion of it be considered, or at least not excluded. I am aware that Kane County is proposing a 

The RMP does not adjudclaimed ROWs. The BLM 

elements of this RMP thracknowledged administr

61 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

similar SRMA for the John R. Flat area, and I support the County's efforts to that end. I also support Kane County's legal right to protect both their road rights, and our access rights to areas provided under RS-2477 Statutes. I believe that the BLM should recognize those rights for all Utah counties and should not consider any final road closure decisions until the validity of those claims are resolved. I fully intend to support any litigation that the County finds necessary with both my tax dollars and individual contribution if necessary. 

Jim & Bonnie Vann 1.) The road out to Hell Dive is an old established road that was originally put in 

for ranching purposes and qualifies as part of Kane Counties RS-2477 road rights, and I support those rights . It currently traverses a State School Section and terminates just a short distance further at a spectacular Indian site hidden under the rock rims with beautiful Indian drawings on the walls, and grinding stones still in place. This area has been visited by local residents for well over 100 years and shows virtually no signs of impairment or degradation. This is a beautiful destination site to take people to who are unfamiliar with the Indian cultures. A short time spent in silence here conjures images of ancient native peoples working, cooking, and playing under the overhanging cliffs. This area would make an excellent interpretive site for the BLM while still allowing the public to visit and enjoy it. This area would lend itself to a cooperative effort between the OHV communities and the BLM as a project to fence the end of the 

road at its current location with a kiosk containing interpretive information for visitors as a "cultural resource" area. 

The Proposed RMP/EIS RMP does not adjudicateclaimed ROWs. The BLM elements of this RMP thracknowledged administr

Jim & Bonnie Vann It is my suggestion and proposal that the BLM place a sign at this location 

advising motorized users that the easement road continuing to the west is; 

"Closed - Private Utility Easement" as traveling further along it will only result in a dead end with no outlet without trespass across private property. Leaving this road open or unsigned will invite either trespass onto private property along the south side, or entrance into a road less closed BLM area on the north. 

Signing is an implementa

Jim & Bonnie Vann 2.) The second road of concern is the one that crosses the state line into Arizona 

before returning to Utah and terminating at Ed Lamb Point. This road is of particular concern because it has been entirely omitted from the BLM maps under all four Proposed Alternatives as if it doesn't even exist. Interestingly, this road does appear on both the 2005 and 2006 BLM area maps however. What happened to it under this RMP? The Kanab Field Office staff have been verbally advised of this omission and oversight on several occasions, but have made no effort to correct this error. An error on the part of the BLM on a project of this size 

might be understandable were it not for a second road that has simply been 

eliminated from any maps associated with this RMP. That road leads to the north rim of the Virgin River and an incredible Indian petroglyph panel. Does the BLM think that they can simply take well known roads off a map and have them just disappear from comment? This shameful behavior by the BLM Field Office fuels the resentment, distrust, and animosity towards them by the local community. 

The first route the comm

wilderness inventory. Ide

beyond the scope of this initial wilderness inventoThe second route that leCanyon route. The Rock alternatives in the Draft Rinclude this as an identifThe third route is the Lamline into the Kaibab-PaiuPoint route is closed in th

62 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

This road also qualifies as a Kane County road under RS-2477 rights. As stated earlier, I support those rights. Equally important however, is the fact that it allows access to Arizona and the upper reaches of the Kaibab Piute Indian Reservation, allows users to visit and enjoy a unique geologic area known locally as the "Beehives", and provides one of the few views off the Vermillion Cliffs across the Arizona Strip and down Kanab Creek to it's confluence with the Colorado River at the Grand Canyon. It is a truly spectacular "visual resource". 

The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Jim & Bonnie Vann The area and roads of specific concern appear as part of "Alternative B and C" 

on the Mt. Carmel map in the Block Mesa portion of the WSA. The two roads proposed for closure are on the mesa top between Joseph Canyon and Merwin Canyon, and the second road is between Merwin Canyon and Baybill Canyon. Both of these roads were "mechanically built" sometime prior to 1976. The roads were put in to harvest juniper posts and for ranching purposes. These roads clearly appear on aerial photos prior to 1976 and are a part of the Kane County transportation plan by virtue of RS-2477 rights. I support the assertion of those county rights. The very nature of these roads should have eliminated any possibility of the surrounding lands being considered for Wilderness Study Areas after the completion of the previous WSA inventories. The fact that these roads were either accidentally or intentionally overlooked by the BLM in the prior inventory calls into question the very validity of the WSA in this area now. More recently, these two roads have again been GPSed and photographed. The BLM Kanab Field Office staff have been specifically advised of the machine built nature of these roads. Yet, the roads remain on the map as a proposed closure. 

It would appear that the BLM is intentionally overlooking facts that are evident on the ground in an effort to support an inappropriate de facto WSA and using those distorted facts to drive road closures in the area. This deliberate error on the part of the BLM, and the fact that they continue to ignore new information that would not support a WSA, would call into question the completeness and integrity of the entire prior inventory, possibly affecting the existence of other Wilderness Study Areas within the Kanab Field office operating area. I do not believe that the BLM has the authority to designate this area as a WSA, and to propose the closure of these roads. 

The first route was identin the Proposed RMP duThe second route was nand inventorying new waroute inventory within W1990). The RMP does not adjudclaimed ROWs. The BLM elements of this RMP thracknowledged administr

Jim & Bonnie Vann The area and road of specific concern appears as part of "Alternative B and C" 

on the Thompson Point map. The road that is proposed to close is at the very south end of a section line fence road that terminates near a point on the topographical map called the "Mansard". This road, for all purposes turns into an ATV track where it comes off the ledges and descends to a spectacular Indian site under a large overhang. The site has numerous art drawings pecked into the stone and unusual slide marks that have been worn into the rock after years of use by native peoples. This area has been frequented for years by local residents and is well known to all. There is no impairment or degradation at this site even after years of visits. The only other way to reach this site is by an arduous climb 

An adjustment was maddevelopment of a public-

63 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

up the face of the Vermillion Cliffs that takes about 1-1/2 hours and is not possible in the summer due the cliffs being south facing. 

Jim & Bonnie Vann It is my belief that there are several current areas with inappropriate Wilderness 

Study Area designations. I believe that these are either the result of previously flawed inventories, or an intentional act by the BLM to create de-facto wilderness in areas that clearly do not qualify. This thought would hold true as well for lands with Wilderness Characteristic designations. I do not believe it is appropriate for the BLM to attempt to manage these lands as if they have already been approved by Congress as Wilderness Areas. Some of these areas would include Kanab Creek, Four Mile Creek, and Sheep Springs. There are numerous areas of both WSA and lands with Wilderness Characteristic that clearly have machine built roads on them prior to 1976 that a simple review of Kane County aerial maps will confirm. 

The WSAs are managed 

designate these areas aAs part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and high

of high-standard approacfindings, particularly the inventory maintenance. 

Jim & Liz Robinson It would be a mistake to establish an "open" zone for ORVs in the Coral Pink 

Sand Dunes in Moquith Mountain WSA. The adjacent state park caters to ORVs, allowing them on a "play area" of 1,000 acres. The wilderness character of the 

WSA would be degraded by allowing ORVs driving cross-country. 

The OHV open area in thuse since during the initibeen in use without impa

inventoried. 

Jim and Bonnie Vann 2.) The second road is to the west of the one just described and terminates at a 

viewpoint on the south rim of the Virgin River Gorge just east of Rock Canyon.. This is also a Kane County RS-2477 road and should remain open. Like the above described road, it is a significant "visual resource" for its view into the Virgin River Gorge and travel is not possible beyond its current end. To reach this spot, you would have to travel over 15 miles by OHV to the edge ofthe WSA, and then walk approximately 2 miles in soft sand to the viewpoint end. No one would do this, and you would be denying the general public the ability of enjoying this spectacular view. 

The Proposed RMP/EIS The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Jim and Bonnie Vann 1.) The first road of concern is the furthest east of the three roads with proposed 

closures under Alternatives B and C. It is a very short (but very significant) road that runs east & west off the main road from Elephant Cove and terminates at a place referred to as "Steep Trail" This area is well know to the BLM. This road was originally put in as a river crossing for sheep wagons and is a "cultural resource", although its descent down to the river gorge is no longer used, or passable. Grazing permitees are currently using this area, and cattle frequent it in their trips down to the river to drink. This road provides a spectacular view into the Virgin River Gorge and is claimed by Kane County as a RS2477 road. Since there is no possibility of travel beyond the current termination. I suggest that this road remain open for its "visual resource" view into the river gorge. 

Most of the Steep Trail r

closed in the Proposed Ridentified in the initial wilwithin WSAs is beyond tbased on the initial wildeThe RMP does not adjudclaimed ROWs. The BLM 

elements of this RMP thracknowledged administr

Jim and Bonnie Vann 3.) The third road on the south side of the river that is listed as a closure under 

Alternatives B and C is on the west side of Rock Creek. This road is proposed to close under alternative B where it exits a State School Section and enters the WSA. If this happens, it will require users to walk approximately 2.5 miles in very 

The Rock Canyon route RMP/EIS. The Proposed 

identified way open to O

64 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

soft sand to reach the end. This road essentially ends at a big outcropping of rock and again provides a spectacular view into the Virgin River gorge (probably the best of the three roads on the south rim). The BLM has recently put posts in the ground to discourage OHV users from continuing down to the river. This area would make an excellent interpretive site for the BLM while still allowing the public to visit and enjoy it. This area would lend itself to a cooperative effort between the OHV communities and the BLM as a project to fence the end of the road at its current location with a kiosk containing interpretive information for visitors as both a "cultural and visual resource" area. 

Jim and Bonnie Vann 1.) The first road proposed for closure under both Alternative B and C is the one 

farthest to the east and terminates across from the road described above as 

"Steep Trail" on the south rim. This is the north side of the old wagon road that crossed the Virgin River and is of both historical and cultural significance. At its motorized end on the ledges above the river, it provides one of the easier access points by foot trail down to the river. This road is also a Kane County RS-2477 road and should remain open to its current point. 

The route that leads to threcurring impacts to the The RMP does not adjudclaimed ROWs. The BLM elements of this RMP thracknowledged administr

Jim and Bonnie Vann 2.) Moving to the west, the second road proposed for closure has again been 

simply eliminated from any maps associated with the RMP where it exits a State School Section and heads south above the Virgin River. This road exists both on 

the ground and on previous BLM maps. The road is listed as a Kane County RS2477 road and is used frequently for its access to one of the best Indian art panels in the entire area. This area would make an excellent interpretive site for 

the BLM while still allowing the public to visit and enjoy it, and there has been no impairment or degradation to this site. This area would lend itself to a cooperative effort between the OHV communities and the BLM as a project to fence the end of the road at its current location with a kiosk containing interpretive information for visitors as a "cultural resource" area. The real question is, what happened to this road under this RMP? The Kanab Field Office staff has been verbally advised of this omission and oversight on several occasions, but have made no effort to correct this error. An error on the part of the BLM on a project of this size might be understandable were it not for a second road that has simply been 

eliminated from any maps associated with this RMP. That road leads to Lamb's Point and has been noted previously. Does the BLM think that they can simply take well known roads off a map and have them just disappear from comment? This is shameful behavior by the BLM Field Office and fuels the resentment, distrust, and animosity towards them by the local community. 

The route was not identifinventorying new ways winventory within WSAs is 

Jim and Bonnie Vann 3.) The third and last road in this area is the one farthest to the west and currently 

terminates above the Virgin River at Poverty Flat after crossing Poverty Wash.. This road was also machine built as a bulldozed stock tank exists at its end. It is a claimed RS-2477 road by Kane County and I do not believe the BLM has the authority to close it to travel. 

The Proposed RMP/EIS identified way open to O

Jimmy Page *3 areas that are classified w/ wilderness characters" (Sheep Springs, four mile As part of BLM’s wildern

65 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

U4WDA & Wasatch Cruisers 

creek, Kanabe creek) have machine created Roads! These areas are in use right now. 

performed a combination inspections, InterdisciplinBLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

Jimmy Page U4WDA & Wasatch Cruisers 

*Special Recreation permits should not be limited to 25 or less. (Many clubs are >25. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Jimmy Page U4WDA & Wasatch Cruisers 

*Table 3.26 in the RMP is flawed and eliminated due to should be eliminated due to incomplete data (as stated in the RMP). 

Table 3-26 in the Draft R

information system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition 

used among federal age

Joan Thacher The DRMP has designated this area as having Wilderness Characteristics but 

again you are giving it no special protection. Where are hikers such as myself to go close to Kanab where we can still enjoy some solitude? I used to hike in Hog Canyon, but not anymore. 

The Proposed RMP/Finaseveral non-WSA areas Additionally, there are serecreation experiences. 

Joan Thacher I request that any transportation plan have a sufficient strategy for enforcement. Law enforcement is outs

enforcement presence is require a specific plannin

Joan Thacher I request that each separate route be evaluated to show it's necessity and 

"contribution to protection of sensitive resources". I do not believe that Alternative B should simply open 92% ofthe routes because they are already there. 

The process used to des

Appendix K was used to chapter 4 addressed the 

does not require analysis 

impacts of the identified RMP/EIS on pages 4-18

Joan Thacher I request that the routes in these areas be re-evaluated and closed where erosion In the Proposed RMP, c

66 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

and scaring is a problem. areas. 

Joan Thacher OHV routes have no business in these areas. ATV's often use these areas as 

playgrounds. I request that you protect these areas and restrict travel there. 

As noted in Appendix K areas were considered in 

John Keeler Utah Farm Bureau Federation 

Yet in Section 2-55 (Fish and Wildlife Management Actions) and 2-64 (Livestock Grazing Management Actions) you plan to reallocate AUMs from livestock to wildlife which is not consistent with the Taylor Grazing Act either. In fact, you mention that you are going to suspend 88 livestock AUMs and reallocate them to wildlife into the Water Canyon, Sawmill and Lower Northfork allotments under the various alternatives. Not only do we feel this action would be inconsistent but it may very well be a violation of the Act. We realize these are a very few number of AUMs but we feel it unwise for you to pursue the course of reallocating livestock AUMs to wildlife. These reallocations are also mentioned in Sections 4-113, 4-169 and 4-171 under "Cultural Impacts" and other places in the document. 

The Draft RMP/EIS does grazing” as addressed in allow the BLM to adjust puse shall be based upon established in the land uhandbook (BLM-H-1601

available for livestock grplan and are reversible thandbook also directs thlivestock (expressed in aof alternatives of lands athe allocation of the foraover the life of the plan uwildlife. 

John Veranth Both alternative B and C are major improvements over the current situation, 

Alternative A. As a general comment, I consider Alternative C to be the most appropriate of the listed alteratives and am disappointed that the BLM did not consider a true "maximum resource protection" alternative that would have been more restrictive than even alternative C. NEPA requires consideration of a full spectrum of alternatives. 

The CEQ regulations (40 alternatives, which would 

quality of the human envin the case (CEQ 40 Momanagement prescriptiodetermine a reasonable concerns, and alternativeessential in this process alternatives identified incdetailed analysis. 

John Veranth For the record, I will state that the RMP maps available online were inadequate to 

allow proper public comment. The scale of the map, the lack of background transportation and culture information, and the resolution of the file preclude figuring out where the proposed designated route is in many cases even when viewed at 800%. For Example In Alt B, the OHV route on private land east of Escalante appears to be the start of the Boulder Mail Trail, but could also be another route farther west or could be one of the vehicle tracks heading from Hwy 12 to the monument boundary. Likewise, to the west of Escalante it appears that one route is the Middle Canyon Road, but it could be something else. Since one cannot tell the exact route alignment, it is impossible to comment on the impact this route would have on the adjacent Federal land. The combination of 

The maps in the Draft Rconvey the decisions bescale maps at a 1:24,000 five public meetings for twere also provided on coOffice, at request. Comm

identification exercised tvery detailed comments 

67 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

low and high resolution maps as was used in the Moab RMP was a much better approach. 

John Veranth Regarding parking pullouts for hiking, picnics, and car camping along open 

vehicle routes, this seem to be an issue that always gets lost between the OHV and Wilderness advocacy groups. The RMP should explicitly address this issue. In general, vehicle travel immediately adjacent to the designated route (for example 25-33 ft) for the purpose of parking should be allowed. In more sensitive areas an adequate number of informal parking areas or spur should be designated to concentrate this type of use adjacent to open routes. 

Page 2-78 of the Draft R

John Veranth Perhaps I did not read carefully enough, but mountain bikes also seem to have 

gotten lost between the OHV and Wilderness advocacy groups There seems to be no consideration of non-motorized single-track routes, but I presume some mountain bike groups will comment. Mountain bikes are mentioned as nonmotorized in 3.5.1 and the use statistics in Table 3-26 seem totally inconsistant with my "eyeball" observations of bike groups along Hwy 12 alone. 

Although the RMP does mountain bikes are allowbe added during the impactivity plans. 

John Veranth In fact, it appears that all of Table 3-26 is badly skewed by the fact that many 

activities are hard to count and use surveys are incomplete. Counting trailers at an ORV trailhead is an easy way to estimate use. Picnicking and day hiking on BLM land are very dispersed and since on registration is required there is no efficient way to get a count beyond a sampling and extrapolation study. As a 

specific example, I frequently hike onto nearby BLM land starting either directly from my private property or after walking a only short way on the public road. There is no way such use will be included in the visitor statistics, but it represents 

real user days, and there are many, many others who do similar informal hikes. If I drive my stock SUV to a trailhead on a county road and then start walking is this counted as "OHVs (Cars/Trucks/ Sport Utility Vehicles) and All- Terrain Vehicles" or as "Hiking/Walking/Running" or both? Further, I question whether environmental and nature study really jumped from 0 in 2004 to 3352 in 2005 - rather I suspect the prior years were really (N/M = not measured). Although the DEIS acknowledges the limitations of the data in 3-26 on page 3-77, I want to remark that management decisions based on these statistics are flawed since "direct monitoring by BLM staff ... focused on areas of greater use and conflict" is likely to overstate use at motorized play areas and motorized trail heads. Thus the BLM statement p3-80 that "More recreationists participate in OHV riding than in any other form of recreation use," is likely to be inaccurate due to systematic undercounting of hiking, wildlife watching, sightseeing, photograpy, and picnicking. 

Table 3-26 in the Draft R

information system (RMIpage 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

John Veranth Regarding the "quantitiative objectives" for the recreation management zones. I 

am not sure what "75% of responding visitors" means if you ask hikers about benefits of OHV play areas (or conversly ask OHV riders about benefits of nonmotorized areas). This whole criteria discussion seems artificial and contrived. 

The BLM recreation guidplans to develop recreatoriented, measurable, an

68 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

John Veranth However, I will comment that in general, the proliferation of ORV routes shown in 

BLM Alt B is far in excess of any reasonable accomodation of recreational vehicle use and will lead to future resource management problems. A well defined network of main routes, scenic loops, and spurs to overlooks is managable and enforceable. The haphazard jumble of proposed routes not. 

A range of alternatives wThe process used to ideAppendix K. 

John Veranth Section 3.2.5 Regarding Non-native and Invasive Plants, there is inadequate 

attention paid to this issue throughout the RMP specifically in regard to effects of motorized recreation surface disturbance and grazing. Eradication efforts are the only way to deal with invasive plants. An aggressive program to control Russian olive, tamarisk, and other non-native invasive plants needs to be part of all alternatives. Active invasive plant control programs in Glen Canyon NRA and in GSENM will benefit from upwind / upstream control on Kanab RMP mananaged lands. This is only indirectly addressed in the listed alternatives as part of the vegetative treatments. 

The Draft RMP/EIS Chanoxious weeds and invaimplementation-level decalternatives will have on recreation) is addressed 

John Veranth Regarding Wild and Scenic river segments the segments listed in Alternative C 

all are appropriate. Appendix G, I disagree with the statement that the geologic formations in the North Fork of the Virgin River, East Fork of Virgin River, 

Orderville Canyon etc are not rare or unique. The fact that the same geologic formation occurs elsewere in the area does not address the specifics of a canyon with Class A scenery. 

Appendix G describes thStudy. 

Josh Heaton Also I would like to voice a concern about the coal mine going in up in Alton. And 

since I live up there I really don't want it to go in. Because the trucks that will be hauling it out, will constantly be driving threw the town. 

The approval of a lease the Kanab RMP. This co

Josh Heaton Because I really like to go hunting and four wheeling down on the poverty. And if 

those roads are closed that will stop me and many other people from enjoying a favorite past time. 

The Proposed RMP/EIS identified way open to O

Karen Kramer In the Kanab RMP/EIS area, I have hiked to Mineral Gulch, what a great slot 

canyon!!! However if I had to hike from the proposed closure site in plan "B" and "C" into Poverty Flat, which is part ofthe Parunuweap Wilderness study area, the 

hike down and then on the return hiking UP would stop me from even trying to hike into this slot The access to this slot canyon is by way of State Route 9 west ofthe Zion Lodge and goes south into the wilderness study area. 

The Proposed RMP/EIS identified way open to O

Karen Kramer Lamb's Point gives a wonderful view ofthe Arizona Strip. This vista is on the 

southwest end of the Moquith Mountain road. This is one ofthose deep sandy roads that are very tiring to hike, with no water source. 

The Lamb’s Point route cIn consultation with the TRMP/Final EIS. 

Karen Kramer In plan "B" the Moquith Mountain road would be open except for the last several 

miles, essentially closing it to all except for the very fit hiker. In plan "C" the entire road would be closed, essentially closing it to everyone. 

The Proposed RMP/EIS access for development 

69 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Karen Kramer I have yet to get to Rock Point on the south end of the Parunuweap Wilderness 

study area. My understanding is that by closing this road it will close the access 

to the Virgin Canyon on the south end, to all except for the extreme hiker. It will make this area an additional 5+ mile hike just to the edge ofthe Virgin Canyon, with a 5+ mile return, this does not even include hiking into the Virgin Canyon itself. Effectively closing Virgin Canyon to almost everyone. 

The Rock Canyon route RMP/EIS. The Proposed identified way open to O

Keith Robinson Kanab City Public Works 

After looking over the Kanab Field Office Draft Resource Management Plan and Draft Environmental Impact Statement I would like to see the shaded area of the attached map designated as open for water development by Kanab City. Roads to the wells, water lines and power lines should also be allowed in this area. The BLM has worked with Kanab City over the years in helping developing our culinary water sources. Some of the above area is already within a Land Use Agreement to protect the Kanab City watershed. 

In the RMP/EIS the areaallowed unless site-specthe land use agreement 

L. Edward Robbins Kane County Water Conservancy District 

While a good number of these are accessed by roads which would not be affected by any alternative under the RMP, there are certainly many whose primary access is by way of roads which are addressed by one or more of the alternatives considered under the RMP, and again, we are unable to determine from the RMP the extent to which water-related access was considered, if at all, in evaluating the alternatives under the RMP. 

There are exclusions badefined in 43 CFR 8340.as diversion structures a

L. Edward Robbins Kane County Water Conservancy District 

However, the District would add that there is no adequate factual basis on which long-term or permanent management of any of the proposed river segments could give rise to a federal reserved water right, and no legal basis on which any river segment upgradient from Zion National Park could be found to carry any federal reserved water. The District is a signer of the 1996 Zion National Park Water Rights Settlement Agreement. This Agreement entirely settles the issue of federal reserved water rights with respect to all waters which are upgradient from Zion National Park. The District reiterates its earlier position that at least with respect to those waters which are upgradient from Zion National Park, the entire wild and scenic rivers process is flawed since the issues inherent in that process have already been settled contractually by the United States, the State of Utah, and other entities including the Kane County Water Conservancy District. 

There is no effect on watmade in a land use plan 

were to designate rivers such designation would (b) of the Wild and Scendetermined by establishe

over water. Although the water right for designateinstead establishes that acquired. Because the Srequired to adjudicate thState processes. Thus, f

Federal reserved water rpriority date as of the da

the minimum amount nepractice, however, Fede

alternative means of ensoutstandingly remarkable 

Lance Jackson The closures that I am referring to are the following: The last mile of the Moquith 

mountain road, the roads that go down into the Parunaweap canyon from the 

south side of the river, and the roads going down to the parunaweap canyon froom the north side of the river known as the poverty area. 

The last mile of the Moq

crosses the state line intTribe, the Lamb’s Point rThe road down to the Pa

70 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

route. The Rock Canyon Draft RMP/EIS. The Proidentified way open to OOne route down to the PProposed Plan due to resecond route down to thidentified in the initial wilwithin WSAs is beyond tbased on the initial wilde

Land Use Volunteers of Kane County 

We ask that the BLM implement all 5 of these ACEC areas in the final RMP. We also ask that the BLM reconsider the original nomination of the White Cliffs ACEC and reinstate the land that was originally specified for that ACEC. For some reason, the BLM had removed the upper Kanab Creek riparian corridor from the proposed ACEC area. This stream and riparian corridor needs to remain in the White Cliffs ACEC. There is no reason not to include it. Streams like Kanab Creek are very rare in our area and need protection. 

Appendix H of the Draft evaluate proposed ACECCFR 1610.7-2, and BLM the commentor raises weand therefore the ACEC 

Land Use Volunteers of Kane County 

Given the wilderness quality of most of this land, it is inappropriate to place designated transportation routes in the area. No designated routes should be placed within the areas identified to be of wilderness quality by the 1999 BLM Wilderness Inventory. 

Motorized routes in non-necessarily contrary to thChapter 4 of the Draft RMwilderness characteristic

Land Use Volunteers of Kane County 

This projection of future OHV travel and impacts on our public land needs to be completed and included in the planning process before approving a Travel Plan for the Hog Canyon and JR Flat areas. 

The current use and proj

planning process. The ramotorized recreation. Adimplementation level (se

Land Use Volunteers of Kane County 

The Kanab BLM needs to complete projections of future OHV use in our area for the next 20 years, then include these projections in their land use planning . What 

resources will be impacted by greatly increasing numbers of OHVers over time, and which of these resources need to be protected by prudent transportation 

route planning? 

The current use and projplanning process. The ramotorized recreation. 

Land Use Volunteers of Kane County 

This projection of future OHV travel and impacts on our public land needs to be completed and included in the planning process before approving a Resource Management Plan that will last for 20 years. 

The current use and proj

planning process. The ramotorized recreation. 

Land Use Volunteers of Kane County 

Because this geographic area has been inventoried by the BLM to contain wilderness characteristics, a more extensive inventory of resources should be completed before approval of an RMP Travel Plan. The current BLM inventory is inadequate and does not include or accurately map the distribution of many of the archeological, botanical, wildlife, cultural, and ecological resources present in the area that may be impacted by ORV's. This extensive inventory needs to be completed before the final version of an RMP is approved. 

While the entire Kanab Fetc. the best available da

efforts, site-specific data available. The route identification proutes from the transportthe criteria and process. 

71 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

route/trail identification foAppendix K. 

Land Use Volunteers of Kane County 

The current BLM inventory of Moquith Mountain WSA is inadequate and does not include or accurately map the distribution of many of the archeological, botanical, wildlife, cultural, and ecological resources present in the area that have already been impacted by ORV's. This extensive inventory needs to be completed before the final version of an RMP is approved. 

While the entire Kanab Fetc. the best available da

efforts, site-specific data available. The route identification proutes from the transportthe criteria and process. route/trail identification foAppendix K. 

Land Use Volunteers of Kane County 

The current BLM inventory of Parunuweap WSA is inadequate and does not include or accurately map the distribution of many of the archeological, botanical , wildlife, cultural, and ecological resources present in the area that have already been impacted by ORV's. This extensive inventory needs to be completed before the final version of an RMP is approved. 

While the entire Kanab Fetc. the best available da

efforts, site-specific data available. The route identification proutes from the transportthe criteria and process. route/trail identification foAppendix K. 

Land Use Volunteers of Kane County 

There are significant problems with a number of the route segments contained in the Alternative B Travel Management Plan. The following tracks should be removed from the plan because they are already creating excessive resource damage, or they will encourage significant resource damage as more and more ORV's enter the area. 

The routes described by 

described in Appendix K Proposed Plan. 

Land Use Volunteers of Kane County 

Because this geographic area is of wilderness quality and has fulfilled the requirements for ACEC status, a more extensive inventory of resources should be completed before approval of an RMP Travel Plan. The current BLM inventory is inadequate and does not include or accurately map the distribution of many of the archeological, botanical, wildlife , cultural , and ecological resources present in the area that may be impacted by ORV's. This inventory needs to be completed before the final version of an DRMP is approved. 

While the entire Kanab Fetc. the best available da

efforts, site-specific data available. The route identification proutes from the transportthe criteria and process. route/trail identification foAppendix K. 

Land Use Volunteers of Kane County 

We recommend that designated routes be placed in dry washes only when the route is an established road that is necessary to travel to a major destination. The rest of the dry wash routes should be deleted from the Travel Plan. 

Future route designationconsidered in implementAppendix K of the Draft 

72 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Land Use Volunteers of Kane County 

We recommend that the Travel Management Plan avoid designating any routes that parallel streams or riparian zones. Alternative designated routes should be sought out and used. 

As noted in Appendix K 

areas were considered in The route identification proutes from the transport

the criteria and process. 

route/trail identification foAppendix K. 

Land Use Volunteers of Kane County 

We recommend that the BLM complete the necessary field work and analysis to rid the Travel Plan of redundant, parallel, and unnecessary routes before completing the final version of the RMP. 

Appendix K of the Draft criteria used to identify afuture. The criteria in Apunnecessary routes. 

Land Use Volunteers of Kane County 

We also think that routes that dead end at the boundaries of Wilderness Study Areas and School Trust Lands be deleted from inclusion in the Travel Plan for the same reason mentioned above. 

Appendix K of the Draft 

criteria used to identify afuture. Dead end routes and access needs. 

Land Use Volunteers of Kane County 

We recommend that no designated transportation routes should cross private land. Additionally, no designated routes should dead end at the border of private land, because this will lead to uninvited incursions onto private land by ORV's. We have seen this happen in the field. Sometimes the riders break down gates and cut fences to gain entry. 

BLM does not designate plan is limited to routes oRMP/EIS includes a desin the route system. Whi

designation process, the was used as a sole dete

Land Use Volunteers of Kane County 

The Kanab BLM has been unable to curb illegal ORV activity and resulting damage to wilderness quality lands within its jurisdiction; therefore, no designated routes should be placed within areas identified to be of wilderness quality by the 1999 BLM Wilderness Inventory or in existing Wilderness Study Areas. 

The IMP allows for contiphase. The IMP does no

and enforcement are iss

Land Use Volunteers of Kane County 

The current BLM inventory is inadequate and does not include or accurately map the distribution of many of the archeological, botanical, wildlife, cultural, and ecological resources present in WSA's or wilderness characteristic areas. Designating hundreds of miles of travel routes will impact these resources over time. Even if there are not designated routes in the WSA's and other wilderness characteristic areas, there will probably be extensive illegal travel by ORV's. This inventory needs to be completed before the final version of the RMP is approved , so that the BLM can monitor the impact of ORV's over time in these sensitive areas. 

The IMP allows for contiphase. The IMP does no

and enforcement are iss

Land Use Volunteers of Kane County 

Both the Kanab BLM and the Land Use Volunteers of Kane County have documented evidence of persistent and increasing damage being done to this WSA by OHVs. No designated motorized routes should be placed within the Moquith Mountain WSA. 

The IMP allows for contiphase. The IMP does no

and law enforcement are 4 describes impacts from WSAs. 

73 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Land Use Volunteers of Kane County 

Given the wilderness quality of this land, and the laws governing the preservation of resources within a WSA, it is inappropriate to place designated transportation routes in the area. Both the Kanab BLM and the Land Use Volunteers of Kane County have documented evidence of persistent and increasing damage being done to WSA's by OHV's. No designated motorized routes should be placed within the Parunuweap WSA. 

The IMP allows for contiphase. The IMP does no

and law enforcement are 4 describes impacts from WSAs. 

Laura Kamala Grand Canyon Trust 

There is an omission of relevant information from the planning document in the absence of any reference to global climate destabilization. Climate models predict that current trends of higher temperatures and reduced precipitation will continue in the Upper Colorado River Basin leading to a decrease in quantity and quality of river water and severe consequences for humans, agricultural uses, wildlife and ecosystems. The KFO planning area has already been affected by the prolonged drought. Soil disturbing activities such as cattle grazing, energy exploration and development and recreation have increased dramatically and these uses destabilize soils. Massive dust storms from soil loss deposit darkcolored dust on mountain snowpacks which absorb heat and melt too soon. Snowmelt storage in watersheds is reduced. The implications of these and other 

climate effects on management decisions on the public lands are not adequately addressed in the RMP. 

A growing body of scientchange will result from thatmosphere. While uncemagnitude and regional evidence supports the viemissions will lead to climthe Proposed RMP/FinaChapter 4. 

Laura Kamala Grand Canyon Trust 

We strongly urge BLM to keep livestock out of riparian areas to assure properly functioning conditions of these areas and especially during times when an already arid environment is stressed by drought. 

It is BLM policy to monitoresource condition and mwatershed basis. These 

implementation of an RMas well the other objectivthat the terms and condiconformance with the prHealth and further 43 CFexceed the livestock car

Laura Welp In addition, all the motorized SRMPs contradict the ACECs that were proposed in 

these areas. 

The CEQ regulations (40 alternatives, which would 

quality of the human envin the case (CEQ 40 Momanagement prescriptiodetermine a reasonable concerns, and alternativeessential in this process alternatives identified. Thmanagement actions froDRMP/DEIS and create current conditions in the 

Laura Welp This is inconsistent with the preferred alternative's proposal for a motorized RMZ 

in the middle of Welsh's milkweed designated critical habitat. The Special 

The Welsh's milkweed cremains closed to OHV i

74 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Management Area Moquith Mountain Dunes RMZ could be disastrous for this plant. In ACEC analysis, recommendation to maintain existing management is not being followed if you put a motorized RMZ on top of the main portion ofthe population (see map on page 12 of attachment). The OHV's already have the Coral Pink Sand Dunes State Park for cross-country motorized recreation, and don't need a special management area on the BLM portion ofthe dunes, especially when it might impact a listed Threatened species. 

in consultation with the Uadequate protection of th

Laura Welp I suggest that you include a plan for dealing with drought in the RMP. Drought is 

such a constant in this area that grazing management must have a plan to prepare for it, yet many field offices don't have a formal method in place. 

Chapter 2 of the Proposedrought, and natural disa

Laura Welp The boundary in the nominated map is not the same as the map I submitted (see 

map on page 11 of attachment). My original boundary is much closer to the boundary you determined was eligible for ACEC designation. 

The ACEC proposal provincluded a legal land desa map (see Draft RMP/Ethat the nominated relev(see Draft RMP/EIS Appthe commentor’s commedocument that was cons

Alternative C that include

Laura Welp Allowing motorized use in these areas is contrary to these objectives, so the 

alternatives A, B, and D are in conflict with these objectives. 

Motorized routes in non-necessarily contrary to thChapter 4 of the Draft RMwilderness characteristic

Laura Welp I think it would be judicious ofyou to increase the time available for public 

comment. 

The BLM provided the pRMP/EIS, as required by 

1610.2(E)). The standard accordance with CEQ rethe BLM planning and N

provides a 90-day comm

review and comment on available, free of charge CD, and online. In additigroups or individuals to ecomment efforts. Finally, facilitate review of the Ka

Laura Welp This SRMA should not be implemented until further studies show that the OHV 

impact to this plant would not affect its reproduction. 

The impact analysis of O

4.2.5 of the Draft RMP/E

Laura Welp Although this part of the trail is not on BLM land, the BLM is obviously part of the 

larger road system that is required to take OHVs from Kanab to the Hog Canyon Trailhead. 

This route is open to OH

Laura Welp A monitoring plan should be described in detail in the RMP. If impacts are 

identified, how will they be mitigated? 

Appendix K describes hotime based on changing 

75 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Laura Welp Welsh's milkweed The RMP does not address the best available data showing a 

potential conflict between motorized damage to plants and reduction in reproductive output. 

The BLM has utilized the milkweed from OHV use

BLM could consider in th

Laura Welp To sum up, this policy would have a negative effect on rare plant surveys and 

appears to be politically motivated. It should be removed from the draft. 

BLM included the langua

botanist with understandsurveys. 

Laura Welp Does this re-opening of roads imply that the problems for which the designated 

trail system was put in place, i.e. "to protect soil, vegetation, wildlife, cultural and riparian area resources that have been adversely impacted or are at risk of being adversely impacted by OHV use", resolved? The level of non-compliance with the Hog Canyon OHV trail system is such that reopening roads will only lead to more damage (photos available upon request). 

OHV use in Hog Canyon designated by an interdisK of the Draft RMP/EIS. system due to resource 

Laura Welp The plan also shows new roads that were not in the original Hog Canyon 

transportation plan (for example, see photos on page 9 of attachment). Those 

roads were not planned under the appropriate NEPA process and should not be legitimized in the RMP. 

OHV use in Hog Canyon designated by an interdisK of the Draft RMP/EIS. system due to resource 

Laura Welp In doing so, the BLM failed to conduct any analysis concerning whether these 

roads were necessary, had defined destinations, went through sensitive areas, were duplicative, etc. The plan lacks the rigorous analysis that would have 

supported the BLM's decision. 

OHV use in Hog Canyon 

designated by an interdisK of the Draft RMP/EIS. system due to resource 

Laura Welp The BLM can not please everyone with their transportation plan, but it would go 

down easier with all segments of the public if the method by which the BLM decided which roads to close and which to leave open was transparent and understandable. To provide the best transportation plan for the public, the BLM should analyze all roads before designating them as open or closed. Analysis should include impacts to wildlife, soil erosion, hydrological function, loss of AUMs, vegetation, and archaeological resources. As it stands, the BLM's proposed transportation plan is not a fair balance between open and closed areas. 

The process used to desand uses that the comm

criteria in Appendix K waanalysis in chapter 4 addidentification. NEPA doe

identified route. The imp

chapter 4 of the Draft RM

Laura Welp These OHV trails are often just tracks that were driven on once, but they are 

being enshrined in the RMP. Many of the homeowners adjacent to this informal 

network of trails will be subjected to noise, dust, declining property values, and annoyance of OHV use directly adjacent to their homes. The concentration of roads within this two-section block is excessive and unnecessary; in fact, the BLM is creating a de-facto, back-door play area here. Every ridgeline does not have to have a trail on it. 

The identified routes in tsubdivision have been mKanab Field Office. 

Laura Welp Trails should not be designated open in riparian zones. As noted in Appendix K 

areas were considered in 

76 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Laura Welp With this in mind, I recommend that the plan not put minimum acreages for 

restoration in the plan alternatives. As recent history has shown on the Grand Staircase Escalante National Monument, putting minimal acreages in the plan and projecting that you'll get X number of acres done in your annual objectives puts pressure on the BLM to implement projects when it might be better to wait, or re-design a project to do fewer acres. 

The management action 

22,300 acres a year is dvegetation treatments. A

Draft RMP/EIS, the treatamount of acres that wo

on the ecological threshoon the research describesummarized in Table 3-8 year planning window fodisturbance regimes. 

Laura Welp However, I'm confused that the area around Zion National Park has no such 

restrictions, although that area is within the watershed for the park and for the 

town of Springdale. This seems inconsistent. Watersheds providing water for all towns in the management area should have the same restrictions. 

Kanab and Fredonia spearound their water systeField Office lands to prot

during the public scoping 

Laura Welp I commend you for making the difficult decision to close some roads in the 

WSAs. However, there should be no designated routes in wilderness quality lands because they degrade the wilderness quality of those areas, which is contrary to the BLM's charge to maintain wilderness characteristics. 

The IMP allows for contiphase. The IMP does nodescribes impacts from t

and non-WSA lands with 

Laura Welp However, as with other WSAs in the project area, there are roads open to OHV 

use throughout, which is incompatible with wilderness designation that Congress might make in the future. Activities in WSAs must create no new surface disturbance, but as the attached photos show, Sand Springs, Coral Pink Sand Dunes, and the Moquith Mountain Loop all show OHV damage that has not been confined to designated areas. 

The IMP allows for contiphase. The IMP does no

and enforcement are iss

Laura Welp I understand that this is a popular campground and provides convenient OHV 

access to the dunes, but its proximity to the wilderness study area is problematic. 

These photos show OHV use within the WSA closed area, well within sight of signs indicating that the area is closed. I suggest moving the campground to a 

location with less impact to the WSA. 

Moving the campground with development of a re

Lisa Rasmussen I go 4-wheeling with my rig with various clubs and often times it is with more than 

25 rigs. To break up a party for arbitrary reasons is ludicrous. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Lisa Rasmussen The RMP statistics are flawed. Please take out Table 8-26. Table 3-26 in the Draft R

information system (RMIpage 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff 

77 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition used among federal age

Liz Kolle I'd like to see KFO develop a campground for RVS, to replace the Dry Lake Bed 

as a camping area. I'd prefer the WSA there to be closed to overnight camping. 

The development and lo

decisions that will be con

Lo I and Won Yin It would be a mistake to open 1,100 acres of Moquith Mountain wilderness study 

area to ORVs roving across the Coral Pink Sand Dunes. That area should be protected for its natural splendor. Also, the Moquith Mountain loop should be closed to vehicles, so this area can retain its wilderness character. 

The 1,100 acres within thdunes. BLM continues IMnecessary to protect the 

Lynn Hague In the Kanab plan it should be a high priority to stop abuse by off-road vehicles in 

the proposed wilderness areas, including Vermilion Cliffs, Upper Kanab Creek, Parunuweap Canyon, Moquith Mountain, Canaan Mountain, and Paria River. ORVs have damaged scarce riparian wildlife habitat, taking a toll on wildlife values. We urge BLM to close all proposed wilderness areas to ORVs, as in Alternative C. 

The range of alternatives wilderness characteristicto designated routes in ndesignated ways in WSAthe potential impacts to rassumption that users w

Lynn Hague Alternative B is off-base in proposing an "open" area for ORVs on 1,100 acres 

within Moquith Mountain Wilderness Study Area in the Coral Pink Sand Dunes. Wilderness values should come first in the WSA. ORVs can romp in the Coral Pink Sand Dunes State Park, where 1,000 acres are already open to them. 

A range of alternatives wCoral Pink Sand Dunes country OHV use in Alte

analyzed in Chapter 4 of 

Lynn Hague We also urge BLM to close ORV routes that are degrading wilderness values 

within WSAs on the Moquith Mountain loop and on Canaan Mountain. 

The IMP allows for contiphase. The IMP does noand enforcement are iss

Margaret Stone ACEC's Five areas were nominated and found eligible to be Areas of Critical 

Environment Concern. These areas contain an approved total of 60600 ac. Since 60600 ac were found to be eligible why is the BLM recommending only 3800 ac in its preferred plan? These areas should by given priority and all should be implemented. 

There is no requirement preferred alternative. Thpotential ACECs be carrone alternative in the DRpotential ACECs. The raforward into the PRMP/F

The BLM Manual 1613.2of each alternative, the m

meets the planning criterpreferred alternative reflemanagement of ACECs.for the various alternativ

78 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

comparison of estimated leads to development anShould BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being propsuch as wilderness and w3. The manager has coneither because of exposuarea is designated or thecan be taken to protect tviable condition. BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources wanother use which would authorized officer must fother use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

Margaret Stone Moquith Sand Dunes The BLM is not only not proposing to protect one of these 

areas - Moquith San Dunes - but in their preferred plan is proposing to place it in grave peril. One of the motorized focus areas would extend northeast from Coral 

The Welsh's milkweed cremains closed to OHV iin consultation with the U

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Pink Sand Dunes S.P. I have been in the park and the sand dune area NE of the S.P. both on my own and on a field trip with the Utah Native Plan Society. Signs that indicated the limit for motorized traffic were routinely ignored. In the Sand Springs area tracks were crossing areas of vegetation on the sand dunes and destroying the plants growing there. The Moquith Sand Dunes should be given ACEC status and they need to be given real physical protection since signs in sand dune areas are not successful. 

adequate protection of thallows for vehicle use on dune... areas" if they medoes not identify addition1979-80 inventory. The iidentifies short-term locathese ways, but this use consideration by Congre

Margaret Stone Routes that end up causing damage to the resources and beauty of an area 

either because of their location or because riders refuse to stay on them should be eliminated. 

Appendix K of the Draft 

criteria used to identify afuture. Resource impacts transportation system. 

Mark Sterkel BLM should provide in the RMP for a buffer zone around Zion, Bryce, and Grand 

Staircase Natl Parks. I mile should be considered a minimum, where no locatable or leasable energy or mineral drilling or mining should be allowed. The DRMP affords the Springdale/Virgin watershead far less protection than it does for it's own Kanab watershed. 

An arbitrary buffer arounGSENM would be contra

The Draft RMP/EIS provof the Draft RMP/EIS reppurpose and need and oThe range of alternatives the public scoping period process in coordination wcomment period. The Drclassifications, right-of-widentified OHV routes, Wwilderness characteristicdisturbing activities and Springdale/Virgin waterswithin WSAs, WC areasclosed to oil and gas leaand Fredonia specifically their water collection sys

requested BLM to manacollection systems. This period. 

Mark Sterkel As for unique, rare, threatened riparian areas, the DRMP does not provide for 

management to protect them. Utah is the 2nd dryest state, so should not our 

vulnerable streams, wetlands, and riparian areas be treasured & protected? Why continue to ignore proper management and let them be overgrazed, and trashed by OHV's? 

Not allowing surface distis the Utah BLM policy oevaluated not allowing sriparian/wetland areas a

Mark Sterkel 40 million tons of coal from a mine near Alton, over the next 20 years, raises 

serious questions that may be within the scope of the RMP. For the I, 430 acres 

of public land (nearly 2 1/2 sq. miles) that would be strip mined, a seperate E.I.S. 

seems in order how many haul trucks per day through Kanab, Panguitch, or 

The approval of a lease 

the Kanab RMP. This co

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Cedar City? Every 5 minutes, 24 hrs/day, for the next 20 years? Will the drivers slow down for, or even see our children? Will the drivers be on meth or crack? How many highway wrecks will be caused by the frantic rush hours to and from Alton, from Kanab, Cedar, Escalante, Kingston, or Burrville? Will the housing & services for all those workers change our quality of life? What about crime, air pollution, crowded govt offices & jails, our teenage daughters? BLM should study a slower approach, before we end up with traffic lights in Hatch & Orderville. 

Mark Sterkel Often these ATV tracks result in torn up microbiotic soil, fragile plants crushed , 

streams churned & soiled, and emerging riparian flora squashed. Hikers have 

their impact, & inconsiderate bad apples, but boots leave seperate, noncontiguous impact prints, while ATV's leave a continuous track that can channel run off and lead to accelerated erosion much quicker. 

Impacts from OHV use a

RMP/EIS. 

Mark Sterkel To protect the resource, the DRMP should include some provision to stop the 

lawless renegade riders who cause much of the impact. This group is confrontational, rude, threatening, inconsiderate, irresponsible, & dangerous. 

While on foot in the Canaan Mtn WSA, ATV's have sped by me, stopped & spun 'donughts' around me, increased the recklessness of their riding in my vicinity, and attempted to run me over. 

Law enforcement is beyo

Mark Sterkel Shared use areas have been considered, but with hikers vs. OHV's, it is a futile 

concept. Quiet-sports people don't want to be near noisy lazy-sports riders because of the noise, fumes, damaged & torn-up terrain, & belligerent attitudes they create. Therefore, hikers won't use a 'shared' area, and it becomes a defacto OHN-only area. These machines simply need their own dedicated (preferably trash already by them) area in which to wreak havoc. 

Motorized and non-motoplanning process. The Dresource values are protmotorized access and re

Mark Sterkel In the DRMP route designation maps, under all alternatives, there are shown rt's 

that are redundant, unnecessary, and parallel. BLM should consider only one route in each open to access area's, closing , obliterating, reclaiming & enforcing the unneeded routes, in order to "manage" the resource for continuity. 

Appendix K of the Draft 

criteria used to identify athe commentor raises weduplicative routes, envirosensitivity, and current a

Mark Sterkel A concievable end result of escalating OHV abuse in the Lake Powell watershed, 

not addressed in DRMP, is the increase in siltation that results from all the erosion from all those machines churning in & out of formerly unimpacted & remote canyons and drainages. Lake Powell will fill up with sediment faster, if the BLM doesn't get control of and manage OHV use shouldn't burec be concerned? 

BLM has developed manDuring the process, BLM rules in affect. In addition

with organizations and uuse areas and these effo

Mark Sterkel Page AG-8 shows Birch Creek, 5 miles west of Escalante, as not having potential 

(let alone existing) outstanding remarkable value. A quick field visit will indicate that Birch Creek is a recovering riparian area, functioning under risk. It is a stunning, stark, beautiful canyon & stream corridor, wth high brownish-yellow scuplpted & block cliffs, archaeo & paleo resources, year round stream flow & 

associated flora/fauna. Views of the Escalante Monocline and distant Henry Mtns. can be seen from the old-growth pinyon-juniper benches. Birch Creek is 

Appendix G of the DRMPreview process including 

well as the Suitability Cocomplied with all applicaScenic Rivers Study Proapproach used to evaluasuitability findings. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

recovering from 150 yrs. of grazing abuse. The DRMP should protect it as WSR, or at least an ACEC. 

Marleen Bussma If new rules and boundaries are created to keep out offenders, what guarantee is 

there that the offenders will now start to obey the restrictions? We were told that 

there are not enough BLM people to patrol the areas to ensure compliance with the rules. What will change after new rules go into effect? Those who go off the established trails will continue to do so, while I am not allowed anywhere near the area. The same goes for the littering problem. 

BLM has developed manDuring the process, BLM rules in affect. In addition

with organizations and uuse areas and these effo

Marlin Sharp Lone Peak 4 Wheelers 

I believe that some WC areas such as Sheep Springs, Four Mile Creek and Kanab Creek have been improperly inventoried and should not receive such recognition ... These areas have historically used machine built roads. 

As part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

Marlin Sharp Lone Peak 4 Wheelers 

Concerning Special Recreation Permits. I do not believe that group sizes should be limited to 25 people under the proposed Special Recreation Permit. .. This number in my opinion is unrealistic and makes group events such as family picnics or scouting events impossible I believe the rules and authorized exceptions for theses SRP's should be clarified and added to Alternative B. If the BLM were to require permits for all "groups", and only allow each group to consist of 25 people, even a weekend club 4x4 run or family reunion would have to apply for a permit, a lengthy, expensive and troublesome process in most cases. For groups of over 25 people, that permit would have to be evaluated and authorized on a "case by case" situation, meaning the BLM has no set guidelines for authorizing larger groups. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Marlin Sharp Lone Peak 4 Wheelers 

In addition, I believe that the BLM should recognize the RS2477 road claims that are part of Kane and Garfield Counties Transportation Plans. The validity of these claims should be determined before a final decision is made in this RMP. I believe Kane and Garfield counties should be consulted regarding all road decisions prior to decision. 

The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Marlin Sharp Lone Peak 4 Wheelers 

I believe the BLM needs to allow for additional trails to be added to the area in the future. This area economy of recreation could benefit by added trails and an expanded trail system. 

Appendix K of the Draft 

criteria used to identify afuture. 

McClain Cox I looked at the information that was given and I am still at a loss as too why 

exactly the roads are being closed down. If you could tell me why the poverty road on map M-217 is possibly being closed I would be most appreciative. I know there is reasons for this and I know that there is a compromise available. If the BLM could let us locals know exactly what we are doing wrong that is hurting the landscape let us know instead of cutting it off from us. 

The Proposed RMP/EIS identified way open to O

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Melanie BooneReznick In reviewing the Kanab Resource Management Plan, there is a lack of recognition of the intrinsic values that the resources of the area provide to the 

local social and economic welfare of the surrounding communities. 

The commentor is referrnot available to the BLMdesignated wilderness, t

other “wild lands”. Even Areas (WSAs), the impascope of the current plan

such studies are generaFLPMA Section 202, (c) “In the development and the extent it is available 

their resources, and otheThe BLM does recognize managing for wilderness 

Melissa Gardner Please do not limit the group size to 25. The special recreation p

determining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Merlin Esplin Page ES-7, and other places discuss the idea of reallocating 48 animal unit 

months (AUM's) from livestock to wildlife. I am strongly opposed to this move and believe it is in direct conflict with the earlier agreements between resource managers, ranchers, and wildlife managers. Wildlife AUM's were allocated early on. There is no need for reallocations of this sort now or ever. Are the AUM's for wildlife on table 3-24, new allocations or existing? Wording in the text below table 3-24 indicates AUM's are over allocated - if this is the case they should not be transferred to wildlife. Once the range recovers from drought AUM's could be reallocated to livestock as per the intent of the Taylor Grazing Act. 

The BLM does not propothereof. However, certain of the plan. The allotmen

Subsequent revisions of livestock grazing. 

Merlin Esplin Secondly, there is a statement about combining allotments. I believe this 

statement is out of place in the RMP, at least until affected permittees have had 

the opportunity to respond (which they have not in this case). If the allotments are held by the same permittee this may not be much of an issue, however if the allotments are held by different people it may be a very serious issue . Does this action even need to be included in the RMP? 

The BLM concurrs that cplan decision. However, administrative convenienquestion have been cont

Merlin Esplin On page 2-67 I have great concerns about the language consistent with all action 

alternatives under Grazing Management Practices. Under "Allocation of Relinquished Preference for Livestock Forage" the language is confusing and appears to favor a permittee desiring to sell to a non-bonified livestock operator, because he may choose to relinquish all or part for no reason at all. It looks like a loop hole to get around the intent of the Taylor Grazing Act, and could possible be used as another tool to remove livestock from the public lands. Please review 

The relinquishment langis consistent to law, regu

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

the wording very carefully and ensure BLM's meaning is clearly stated and consistent with law and policy. 

Merlin Esplin Is BLM required by law to discuss "Non-WSA Lands with Wilderness 

Characteristics"? It looks like another defacto wilderness attempt which does not need space on paper. BLM, again, has authority to administer the kinds of uses and activities permitted on public lands. It is enough. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to hasimilar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and objectnecessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Merlin Esplin All action alternatives propose to "prohibit OHV or mountain bike tours in... " as 

listed on page 2-81. BLM cannot enforce the restrictions currently in place. Please be wise and careful when considering additional restrictions. 

BLM has developed manDuring the process, BLM rules in affect. In additionwith organizations and uuse areas and these effo

Merlin Esplin Page 2-13 Welsh's Milkweed: BLM desires to close motorized use in and through 

islands of vegetation in designated critical habitat for Welsh's milkweed. The 

The 790 acre figure is idCommon to All Alternativ

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Coral Pink Sand Dunes State Park already provides education and administration in this regard, and a sizable portion of the dunes is already off limits to motorized activity. Is the 790 acres proposed for closure in addition to the area already closed? If so, current data and ongoing research does not support this action. Reports clearly show that Welsh's milkweed needs disturbance for survival. Closing the dunes creates two concerns; first, the dunes become vegetated more quickly - thus crowding out the milkweed faster, and second, it displaces OHV's to other areas where greater damage may occur to vegetation, soil, water, wildlife, livestock, and recreation. Any decision to alter the current management of the dunes may be met by unintended consequences. 

Vermilion MFP amendmalternatives. As stated aalternatives that would carea. 

Merlin Esplin Page 2-9 discloses that" ... preventing net loss of properly functioning sagebrush 

steppe habitat" is one of the objectives listed under vegetation. What is meant by this statement? Do you intend to try to have more sagebrush? Do you want pure stands of sagebrush, or un-evenaged stands, etc.? Perhaps the answer to my question is on page 217? 

The objective is addressdesired wildland fire conaddresses how future im

Merlin Esplin Another objective under the same heading is to "Ensure water availability for 

multiple-use management and functioning, healthy riparian and upland systems." 

What do you mean by this and where will you get the water rights, considering BLM has no way to put the water to "beneficial use" as required by state law to hold water rights? 

The federal government boundaries to state goveagency, it must seek watwater for BLM uses (e.g

Merlin Esplin Under Water Resources on page 2-37, I believe some statement about working 

with the State of Utah on these issues would be appropriate since the state has the principle responsibility to protect water quality, etc. as it relates to the division of Oil, Gas, and Mining. 

As stated on page 3-15 o

Utah administers the waOffice has been and woumonitoring program admoversight from the EPA. 

Merlin Esplin Page 2-3, 2-28, and elsewhere discuss the desire or apply "protective 

management" to seven river segments by recommending them to be included in the national Wild and Scenic Rivers system. Once again, I question why this is even needed or desired. Current policies and laws give ample authority to the protection of all resources along or near streams or anywhere on public lands. 

Section 5(d) of the Wild management agencies mplanning. Two stages of involving river values. Suresource conflicts. As peProgram, Section .32C, planning effort as to theiWild and Scenic Rivers SROD for the PRMP/FEIStentative classification of 

makes a decision on desfor the Wild and Scenic R

Merlin Esplin In particular I question the Meadow Creek/Mineral Gulch segment. Man's 

influence certainly is limited, practically non-existent, except for a couple of short fence segments, however, I doubt these canyons meet the real intent of the congressional directive. I realize there are no diversions within the segment 

Appendix G describes thStudy. 

85 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

listed, however water is damned and diverted above the segment and water rarely flows through the segment. 

Merlin Esplin Some of the river segments listed for inclusion in the National Wild and Scenic 

Rivers system flow through Zion National Park, which is very scenic. However, if one wishes to see a flagrant misinterpretation of the Wild and Scenic Rivers Act (WSR), look at the number of segments in Zion where "man's influence" is certainly more than "temporary". Numerous rock walls, trails, rip-rap of various sorts, and roads are the rule along the Virgin River - not the exception. Please follow the intent of the law when considering river segments to recommend for inclusion in the Wild and Scenic Rivers system. 

Section 5(d) of the Wild management agencies mplanning. Two stages of involving river values. Suresource conflicts. As peProgram, Section .32C, planning effort as to theiWild and Scenic Rivers SROD for the PRMP/FEIStentative classification of 

makes a decision on desfor the Wild and Scenic R

Merlin Esplin On page 2-47 under Utah Prairie Dog, the Draft RMP uses the wording, "Allow 

introduction, ...." Please ensure that any and all introductions of any species are reviewed through the public process, and that permittees are notified directly. 

The BLM is required to cactions. 

Michelle Young I do not feel the BLM has the Authority to create Wilderness Characteristic Areas. The BLM has long ackno

requiring a one-time wildlands is authorized by FL

2006, the Utah District C

lands it determined to ha

similar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and object

86 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

necessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Michelle Young Alternative B is preferred with reservations. I do not feel the BLM has the 

authority to implement closures to RS 2477 roads. And needs good reasons to close any roads whether established or not. 

The RMP does not adjud

claimed ROWs. The BLM 

elements of this RMP thracknowledged administr

Mitch Thompson Specifically the Mail Drop. Please consider leaving access to these areas open in 

your plans. 

The Shunsberg Mail Droscope of the Kanab RMP

Monte Chamberlin Proposed RMP plans are not in accordance with the Kane County General Plan 

or state law and federal law. The elected officials of the County were "bypassed" and/or given misinformation during the planning stage ofthe process. BLM does not have the authority to override or "bully" county officials or usurp the authority of duly elected individuals to govern. 

The BLM is aware that thto aspects of public land Federal law. However, tthat the development of consistent with County pinconsistencies between the extent practical (FLPState and local plans concannot be resolved or reThus, while County and to be as integrated and cprocess is not bound by planning stipulations. Ththat the State and local gimpacts of the PRMP on review of the PRMP with Chapter 5. 

Monte Chamberlin Canyon Country Rural Alliance 

Under the proposal water rights are being threatened-rights which are already threatened under wild and scenic designation, wilderness characteristics management, watershed protection provisions, etc. 

There is no effect on watmade in a land use plan 

were to designate rivers such designation would 

Name not legible I do not feel the BLM has the authority to create wilderness Characteristic Areas. The BLM has long ackno

requiring a one-time wildlands is authorized by FL

87 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

2006, the Utah District Clands it determined to hasimilar to the manner in authority for managing laderived directly from FLPBLM’s organic statute givpublic lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and objectnecessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Nate Delaney Please disclose the difference in management prescriptions between "non-WSA 

lands with wilderness characteristics" and WSAs in the Final Environmental Impact Statement (FEIS). 

The difference between 60) and WSAs is discussRMP/Final EIS includes wilderness characteristicto the IMP. 

Nate Delaney The 1999 inventory found lands that contain extensive OHV trails to have the 

"wilderness characteristics." If the presence of OHV use did not impact the presence or absence of "wilderness characteristics," then by what rationale is the BLM proposing to significantly reduce OHV trails in these areas? 

The Proposed RMP/Finaareas of non-WSA areas Proposed RMP/Final EISroutes. 

National Parks Conservation Association 

BLM mentions the National Park Service data show an improving visibility trend for the clearlest days; it fails to mention that the visibility trend for the haziest days is worsening (2005 Annual Performance & Progress Report: Air Quality in 

Based on public commeGrand Canyon National National Park has been 

88 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

National Parks). There is also no mention of ammonium; a component of acid precipitation which is also worsening. Additionally, no data from other national parks including Zion and Capitol Reef bordering the planning area are mentioned. There is also no mention of ozone trends showing a decline in all area parks where trend data has been collected. 

issues raised by the com

National Parks Conservation Association 

The BLM erroneously states that "A direct relationship between emissions and visibility impairment does not exist, and so the qualitative emissions analysis cannot be used to assess potential visibility impacts on nearby Class I areas from activities within the decision area." According to the National Park Service" Visibility monitoring and research by NPS and others have found fine particles less than 2.5 millionths of a meter in diameter (PM2.5) in the form of sulfates, nitrates, organics, elemental carbon, and soil particles are primarily responsible for visibility impairment." According to EPA visibility impairment or haze is caused by particulate matter emitted from sources including power plants, automobiles and other industries. 

A meaningful quantificat

information associated wsource location. At the ladue to the unknown sousite-specific air quality ima case-by-case basis. 

National Parks Conservation Association 

BLM errs in using a "qualitative analysis" instead of using available air quality data. They have ignored their obligation to analyze the direct and indirect impacts of their management actions. BLM states "Because a quantitative relationship between the expected air emissions calculated above and the subsequent potential impacts on the air quality values of visibility, atmospheric depositon, or ozone are not known, it is not possible to draw any conclusions about the potential impacts expected to these air quality values." However, there is an ample air data including trend data available through a variety of sources including the National Park Service, IMPROVE, WRAP and EPA. The BLM needs to re-evaluate its finding of "no significant" impacts since it failed to utilize existing air quality data and make a meaningful analysis of current and future conditions. 

The quantification of potemission sources require

application of dispersion about those sources, suc

large uncertainty. This ucompromise the reliabilitanalysis will be conducte

National Parks Conservation Association 

The cumulative air analysis fails to adequately address the threats from increased energy development in the area. The Four Corners region is seeing an explosion in oil and gas development along with proposed coal fired power plant. There are also four new proposed coal fired power plants across the border in Nevada. Additionally, the surrounding BLM regions of Richfield and Monticellow are releasing resource management plans that were not considered but have potential impacts on the Kanab planning area. BLM needs to adquately address these impacts. 

BLM continues to have c

air resources analysis, inpotential impacts of the pto existing sources and wair quality standards. 

National Parks Conservation Association 

With the exception of Map 1-01 Landownership, the maps do not show the national park boundaries for parks within or adjacent to the planning area. Without this information it is impossible to evaluate the impacts on the affected national parks and their resources. BLM must provide adequate mapping so that the impacts of their alternatives may be analyzed by the public. 

The maps associated wiowernship map. The bouon the land ownership m

National Parks BLM has erred in excluding the National Park Service as cooperating agency. While the National Park 

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Public Comments and Responses - Kanab Draft RMP/EIS 

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Conservation Association 

The have ignored the directive outline in January 30, 2002 Memorandum from James Connaughton, Council on Environmental Quality (CEQ) Chair. The exclusion of the NPS from cooperating agency status has limited the input from this most qualified agency on the import of effects on Bryce Canyon, Zion and Capitol Reef National Parks and on the preferred approach to managing these effects. BLM must invite the National Park Service to act as a cooperating 

agency for the remainder of the RMP revision, including assessment of comments and recommendations for revising the Preferred Alternative. In addition, the NPS should be given the opportunity to review the information 

previously provided to the other cooperating agencies, and then provide input on the analysis of effects and management recommendations pertaining to Bryce Canyon, Zion and Capitol Reef National Parks. 

agency, none of the threNational Park, and Glen the planning area expresscoping period or in their 

cooperating agency statuidentifying their concerns key points of the planninDraft RMP/EIS chapter 5

National Parks Conservation Association 

The BLM has completely failed to address the impact that the proposed Alton Coal Mine or increased oil and gas development would have upon the pristine night skies within the parks. 

Night skies were addresAlternatives. A specific im

development on night skwould be addressed in s

Norman McKee 2 – 26: The BLM should take a very pro-active approach to make land trades with 

SITLA. Without trades, WSA’s are in jeopardy, crucial wildlife habitat is compromised, and new roads and utility corridors are required as trust lands are privatized and developed within BLM lands. 

The Final RMP/EIS has Chapter 2, page 2-26 "G

consideration, particularl

Norman McKee 2 – 8: In management actions, is there consideration to include the use of beaver 

for riparian management? 

Beaver are not specificaDraft RMP/EIS Chapter 2 "introduction, translocatioestablishment of native aand collaboration with U

Norman McKee 2 – 9: To remove all exotic plants would also include Russian Olive trees. This is 

a tree that is an important winter food source for several wildlife species, notably wild turkeys. Please reconsider the proposal to removal all Russian Olive trees in occupied or potential turkey habitat. 

The Draft RMP/EIS on dtrees, but the BLM is req

noxious weeds, and Chaand invasive species conmanagement plans in cocounties..." 

Norman McKee 2 – 12: Fish & wildlife management actions should include a beaver habitat 

inventory, along with a recommendation to re-introduce beaver in appropriate areas. 

The Draft RMP/EIS Cha

"introduction, translocatioestablishment of native aand collaboration with Uthe proposed alternativeRMP. 

Norman McKee 2 – 15: The majority of bighorn sheep lambing occurs prior to April 15 to June 15, 

usually a month earlier. 

Habitat for desert bighorZion National Park in the than most of the Desert sheep lambing season c

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Public Comments and Responses - Kanab Draft RMP/EIS 

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bighorn sheep in colder April-June” (Bighorn Inst

Norman McKee 3 – 46: Does the Panguitch Valley pronghorn population also include the Sage 

Hen Hollow population? Maybe, should be clarified. The two populations are 

physically separated from each other. 

The Proposed RMP/Finatwo pronghon population

Norris Brown I, Norris Brown, own the Sheep Springs Grazing allotment at the head of Dairy 

Canyon out of Johnson Canyon. By limiting access you will severely impact the use and management of this allotment. 

There are exclusions ba

Norris Brown Kanab Irrigation Company 

The areas north of Kanab City, involving all of the Kanab Creek drainage has had a serious erosion problem that impacts the Kanab City. The Kanab Irrigation Company is the major stock holder in the Kanab Creek drainage and we need access to maintain our water right of ways. It will also effect UDOT road highway 89, sportsman and livestock permits. The NRCS (soil conservation) have been cooperative with the Kanab Irrigation company and KCWCD to establish a reeseding project to reduce the erosion and silt in the Kanab Creek and stabilize the water supply. We feel that now is not the time to close down the access to these areas of Kane County, but to join and cooperate with local and national agencies to improve and restore these vital resources of water and range management. Limiting access will severely hurt managing our water right of ways. 

There are exclusions badefined in 43 CFR 8340.as diversion structures a

PacifiCorp Such activities (pole replacement, conductor and/or insulator replacement, etc.) 

would presumably occur within the company's existing transmission right-of way. However, the company must retain the right to service our existing power line(s) if maintenance is required within the restricted area(s) represented on the map. 

Maintenance and emergnot be affected by the RM

PacifiCorp The Executive Summary (Pg. ES-I0) recommends limiting OHV use to 

"designated routes". Rocky Mountain Power generally concurs with this policy insofar as protecting natural and cultural resources. However, we also maintain an interest in reserving access to electrical facilities where needed to accommodate ongoing repair/maintenance and inspection needs. 

Maintenance and emergnot be affected by the RM

PacifiCorp PacifiCorp recommends that BLM designate energy corridors in areas where 

PacifiCorp has submitted proposed corridors as part of the West-Wide Energy 

Corridor PElS . We have attached a map that shows the locations of the proposed utility corridors contained in the draft EIS as compared to the locations of the proposed energy corridors that were submitted by PacifiCorp to the Department of Energy for consideration as part of the PElS. It should be noted that PacifiCorp's proposed energy corridors depicted on the map simply connect two end points of energy resource areas and areas of energy demand. We did not apply engineering design or environmental analysis when developing these options. An electronic version of this map is contained on the enclosed CD. PacifiCorp supports the establishment of energy corridors throughout the Kanab BLM Resource Area. 

The West-Wide Energy Cfinalized. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

PacifiCorp Communication facilities may be adversely affected by siting additional 

communication facilities in close proximity. Recommended Revision!Action PacifiCorp recommends that the following statement be added to all of the alternatives, "The addition of new communications devices on existing towers will be considered where it is practical and does not present a safety or operational risk." 

The Lands and Realty maddition of new communconsidered where it is pr

PacifiCorp There are two places in the report that state to bury distribution power lines 

including Appendix A, Page 3, Mineral Exploration and Development, Bbullet 10 and Page 4 Reducing Impacts to Visual Resource Management Class II and III Areas, Bullet 1. PacifiCorp believes that these statements are overly restrictive and need to be qualified. 

The Best Management Pdetermined to be the moresults and minimizing c

management actions. Thallow for flexibility in app

PacifiCorp Timing Limitations are detailed for a variety of Resources of Concern in Table 

AC-l. PacifiCorp requires access to existing electric lines without restriction to perform emergency maintenance and repairs that may include rebuilding of structures within the line. 

Maintenance and emergnot be affected by the RM

PacifiCorp Solar and wind powered renewal resources are becoming an increasingly 

important source of electric generation. No discussion of the potential for this development is included in this section. 

The reasonable foreseeaaddressed in Chapter 3 

PacifiCorp PacifiCorp recommends that the EIS and final RMP include a specific provision 

within the EIS and RMP stating that ROW facilities will not be placed adjacent to each other if issues with safety or incompatibility or resource conflicts are identified. The Western Electric Coordinating Council (WECC), a regional coordinating council for western utility groups, also supports this approach. 

The Lands and Realty maddition of new communconsidered where it is pr

PacifiCorp PacifiCorp recommends that the EIS and final RMP include a specific provision 

within the EIS and RMP stating that ROW facilities will not be placed adjacent to each other if issues with safety or incompatibility or resource conflicts are identified. The Western Electric Coordinating Council (WECC), a regional coordinating council for western utility groups, also supports this approach. 

The Lands and Realty maddition of new communconsidered where it is pr

PacifiCorp PacifiCorp is concerned that the EIS does not address electrical emergency 

situations. In an electrical emergency situation, PacifiCorp must be able to enter onto and conduct repairs or adjustments within a rights-of-way area governed by a ROW grant at any time. 

Maintenance and emergnot be affected by the RM

PacifiCorp Section 4.2.11 discusses the allowed development of Oil and Gas and mineral 

exploration and production but does not discuss the connected action of electric 

transmission right-of-way (ROW) to serve these developments. 

The reasonable foreseeadisturb approximately 4 a

electric transmission righ

PacifiCorp The foIlowing statement is included in Appendix A, Page, 5 Reducing Impacts to 

Visual Resource Management Class II and III Areas BuIlet 4: "paint all above ground structures". This statement contradicts the statement in Chapter 2, Section 2.4.1, Lands and Reality Table where it states "Construct power lines using non-reflective conductor. Towers would be constructed using non-reflective 

Best management practi

techniques determined tbeneficial results and mifrom management actioncontrols, specific operati

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Public Comments and Responses - Kanab Draft RMP/EIS 

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material". before, during, and after 

impacts. BMPs are not oadapted through interdispractices are necessary Management Plan (RMPparticular site are evaluaPolicy Act process and vlocal resource conditions

Randy & Cynthia Norton 

The increasing demand for OHV recreation opportunities on public lands and National forests is extensively documented. Therefore, we believe it is incumbent upon the Kanab Field Office Draft Resource Management planning team to 

maximize recreation opportunities. It must be maintained that OHV use in roaded natural and semi-primitive motorized settings for recreation use, be acceptable and compatible with established resource management objectives. With the idea that OHV trails can be constructed and maintained with demand increases. 

The FLPMA directs BLM yield (Section 102(a)(7))implement laws, regulatiland uses and to resolve 

plans. The BLM’s Land Ube made for each resourHandbook “H-1601-1”). Salternatives analyzed dualternative is formulateddecisions and inconsistea compatible mix of uses 

Randy Parker Utah Farm Bureau Federation 

Allocation of resources for wildlife was previously addressed. Farm Bureau opposes reallocation of livestock AUM's to wildlife. 

The Draft RMP/EIS does grazing” as addressed in allow the BLM to adjust puse shall be based upon established in the land uhandbook (BLM-H-1601

available for livestock grplan and are reversible thandbook also directs thlivestock (expressed in aof alternatives of lands athe allocation of the foraover the life of the plan uwildlife. 

Randy Parker Utah Farm Bureau Federation 

Suggestions within the RMP that reduced grazing decreases erosion is contrary to science. Most of the soils are heavy clay, resisting water infiltration. Grazing disturbs the surface crust, allowing moisture into the soil and fertilizer perpetuating plant germination. 

Proper grazing managem

Draft RMP/EIS acknowleconditions of upland comerosion, and reducing opinvasive species.” The Dlivestock grazing could h

Randy Parker Utah Farm Bureau Federation 

Farm Bureau is opposed to the BLM's use of the RMP process to retain federal ownership of the federal lands in violation of the equal footing doctrine of the U.S. 

Constitution and other pertinent federal law, including FLPMA. 

Section 102(a)(1) of FLPUnited States that the pu

result of the land use pla

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Public Comments and Responses - Kanab Draft RMP/EIS 

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that disposal of a particuThe land tenure adjustmRMP/EIS. Public lands many form of land tenure alaw, specifically FLPMA. list of lands designation f

Ray and Sharon Wells Area with wilderness characteristics - White Cliffs area up to Glendale bench and 

down Four mile and Kanab Creek. 1. Sheep Springs road and spring area are machine built on top of the Whites T0410S -R0060W Sec. 25 2. Four mile Creek and Kanab Creek area were machine built which BLM has pictures of showing this and this was a main corridor from Glendale bench down to Kanab since the late 1800’s, there are at least three signature rocks along the way with a couple of mileage markers still visible on rocks down Kanab Creek. also there are at least two lime kiln sites where lime was produced along Kanab Creek This was a main road and industrial area. How does it now qualify as a wilderness or even an area with wilderness qualities. Our ancestors would laugh at us! This area is riddled with roads and improvements (fences, springs, kilns, water tanks, etc. this area is ridden from top to bottom by trucks, jeeps, and OHV’s and has been for decades. How can it qualify for wilderness characteristics? 

As part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

Ray and Sharon Wells Paruunuweap WSA road closures: 1. West end of the main road leaving the state 

section to be closed was in fact a machine built road that had to have been built prior to the 1976 WSA proposal T0410S - R0090W Sec. 33,34,35 2. The southwest road, which doesn’t even show on the work maps, to be closed south of the state section goes over slick rock down to an area suitable for parking then walking down towards the river to a unique petroglph panel T0420S - R0090W Sec. 11 3. The southeast road to be closed used to be a part of a connecting road that crosses the Virgin River and goes up the south side to what is called steep trail. T0420S - R0090W Sec. 12. All of the above roads were inventoried pre- 1976 by Kane County road department. Which leads me to believe that the WSA really should not qualify to even be a WSA. If I’m not mistaken WSA’s were supposed to have wilderness characteristics before becoming a WSA, not developed into WSA’s by closing existing roads after the fact. I also believe it states in managing WSA’s, existing roads in a WSA are not to be closed just because they are in a WSA. 

Inventoried ways within W603 wilderness review. Mrecommendation numbeRecommendations 1 and the range of alternatives modified to include recomuse. 

Ray and Sharon Wells South of Virgin River - Parunuweap WSA 1. Rock Canyon road. The most 

western road on south side of the Virgin, to be closed from state section to the view point above the river and the Barracks. This is another Kane County pre 1976 inventoried road. It is approximately two miles from the proposed closure to the view point above the river. This is a view point that is frequently visited and closing the road two miles up from the view point would eliminate the use of this area from all but the few people willing and able to hike the distance. This would 

Inventoried ways within W603 wilderness review. Mrecommendation numbeRecommendation 1 addrrange of alternatives in t

modified to include recom

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Public Comments and Responses - Kanab Draft RMP/EIS 

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be managing the area for a select group of people, not the majority. T0420S - R0090W Sec. 11,14, 15 2. Steep trail, the short road on the south side of the river which is the south half of the road coming out of Poverty across to the sands. A short road offering a good view of the river, Barracks and Poverty. T0420S - R0080W Sec. 18 

Ray and Sharon Wells Moquith WSA 1. Southeastern road leading to Lamb’s point view area goes to 

and through Arizona boarder, to two beautiful view points, one being the Bee Hives, and overlook, from atop the Vermilion Cliffs into the Arizona Strip. The 

Bee Hives area is very interesting and the view fabulous. The road continues back into Utah, to Lambs Point. Another beautiful view toward Fredonia from above the Vermilion cliffs. Note, this road also does not appear on the BLM work maps! Few people drive there almost no one will ever walk there. What a loss, let alone, I was told that the BLM has evidence that this road was built in the 1950’s by a Kanab resident, probably to access the area for a cattle operation. T0440S - R0080W Sec. 12 2. Hell Dive road closure east of the state section fairly steep and sandy leads to a turn around area,where a short steep walk takes you to a beautiful pictograph panel, along with a big row of rocks, that are filled with matatees. A very special place I would suggest leaving the road open to the turn around area then possibly an informative sign explaining the significance of the area. T 0430S - R0070W Sec. 28, 29 

The commentor’s first rethe Kaibab-Paiute reservhas requested that BLM Recommendation 2 addrrange of alternatives in t

modified to include recom

Ray and Sharon Wells After inventorying and photographing, I question how the Moquith and 

Parunuweap WSA’s every managed to qualify as WSA’s in the first place. There were too many roads and other improvements that must have been overlooked at the time by the BLM to have been able to set the areas aside as WSA’s and trying to do it now in retrospect, to make these areas more suitable as WSA’s is just wrong. 

The WSAs are managed 

designate these areas aThe Moquith and Parunusection 603 wilderness rof this land use plan. 

Rebecca Mann Regarding the preferred designation of Areas of Critical Environmental Concern 

(ACECs). Designating protective boundaries around currently undisturbed and high-quality wilderness areas ensures the persistence of unique, high-quality natural resources and ecological processes. All areas proposed as potential ACEC units should be designated as such. Many of these areas contain irreplaceable habitat, such as the sand dunes in which the federally threatened Welsh's Milkweed (Asclepias welshii) thrive. For this particular case, if the Coral Pink Sand Dunes area is opened for ORV use, the individuals of Welsh's Milkweed in the affected area will not have adequate reproductive opportunities, damaging the genetic diversity and overall health of this critical population. Other potential Areas of Critical Concern, including Cottonwood Canyon, Parunuweap Canyon, Moquith Mountain WSA, and the Vermillion and White Cliffs, share similar unique and special resources, and only a strict designation to protect these areas will ensure their natural values. 

There is no requirement preferred alternative. Thpotential ACECs be carrone alternative in the DR

potential ACECs. The raforward into the PRMP/F

Rebecca Mann Rangeland assessment. Science-based ecological assessments, using 

standardized data collection methods such the Rangeland Health Indicator 

It is BLM policy to monitotrend of resource conditi

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

system, should be regularly conducted to determine if allotments are being properly managed and not overgrazed. Unfortunately, I haven't looked into current methods being used, but wish to express my concern that the assessments be standardized, regularly conducted, and that the data collected is 

regularly analyzed with results utilized in an adaptive management program. Rangeland that is not properly maintained and is over-exposed to grazing, risks undergoing an irreversible transition to a degraded state, creating ecological problems such as erosion and top soil loss, loss of plant, animal, and microbial biodiversity, exotic weed invasion, and altered fire regimes. To best ensure the long-term viability of rangelands, regular ecological assessments should be a part of an adaptive management program. 

watershed basis. These implementation of an RMas well the other objectivthat the terms and condiconformance with the prHealth and further 43 CFexceed the livestock car

Rebecca Mann Off-Highway Vehicle (OHV) use on BLM land. Areas with unrestricted overland 

travel by OHVs should be extremely limited or closed because OHV use destroys plants and biological soil crust, disturbs wildlife, threatens archeological and paleontological resources, and disturbs other visitors' experiences. In addition, existing roads and routes, which may be designated as established roads in the future, should be carefully assessed. Roads and routes should be closed if they a) cross through high value natural areas, such as riparian zones, wildlife breeding habitat, or rare plant territory b) are redundant - where one road could serve the same purpose as two, or c) have significantly low traffic and no particular value to travelers. The limitation of OHV roads will lessen environmental damage and make backcountry wilderness experiences much more pleasant for those wishing to escape the noise and pollution associated with motorized vehicles. 

Appendix K of the Draft 

criteria used to identify athe commentor raises weduplicative routes, envirosensitivity, and current aproposed routes is discu

Richard Csenge Identified ACECs including the Vermillion Cliffs, Parunuweap, White Cliffs, 

Cottonwood Canyon and Welsh's Milkweed, and eligible Wild and Scenic River segments are not being given the protection they deserve in Alternatives A, B or D. If ACECs and WSRs in the Kanab District have been found to be suitable for designation, they should be included in the preferred alternative. 

The FLPMA states that ithe designation and protdesignation and preservNominations for ACECs scoping period. Five of thcriteria of relevance and management as propose

Draft RMP/EIS describes 

Richard Csenge Designating 1385 miles of totally unplanned routes, as does Alternative B is 

unnecessary, absurdly redundant, and is neither manageable nor enforceable. Even Alternative C, with 884 miles of designated routes is far too many. Such designations do not constitute a well-designed transportation plan. No proper study or inventory process could yield such proposals. BLM KFO has not completed current assessments of existing OHV damage, nor impact studies projecting future damage. NEPA rules have not been followed in the creation of the Hog Canyon Trail System. 

BLM used the process d

routes to be included in tBLM has provided a reasEach alternative represepurpose and need and oThe range of alternatives 

the public scoping period process in coordination wcomment period on the R

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

resource uses from OHV 

Richard Csenge In addition, by their very nature, motorized uses of public lands impact very large 

areas due to the speed and power, and noise ofthe machines, disturbing wildlife, and creating conflicts with other uses, such as non-motorized recreation. It is therefore necessary that separate recreational management zones be established and enforced for motorized and non-motorized use. Until such time as Congress decides , establishment of such zones must not violate existing wilderness, WSAs, or non-wilderness lands with wilderness characteristics, which are specifically contained in the America's Red Rock Wilderness Act, pending in U. S. Congress. 

Motorized and non-motoplanning process. The Dresource values are protmotorized access and re

Richard Csenge In Alternative B and D, Maps 2-17 and 2-19, BLM appears to be designating 

open routes for motorized travel within the Parunuweap, and Moquith WSAs. Maps 2-9, and 2-11 seem to introduce motorized RMZs into WSAs. Is this not against federal law, and will not such mismanagement inevitably lead to resource impairment? Vegetation damage from OHVs is prevalent in each of these areas, which are already being impacted by a multitude of meandering routes created by motorized vehicle travel. In addition, maps 3-10 and 3-11 list these areas as crucial, high, or substantial habitat for mule deer. Frequent and increasing intrusions by OHVs over the term of the RMP may significantly reduce, if not eventually banish herds from these areas. One prime public interest, that of hunting, would surely be adversely impacted.(see enclosures #4 & #5) Such management would be contradictory to the preservation of resource values as required by law. In this regard, only alternative C, indicated by Map 2-18, provides the bare minimum of protection that wildlife deserves. 

The IMP allows for contiphase. The IMP does nodescribes impacts from t

Richard Csenge In the Kanab RMP Draft, Alternative B places greater restrictions than does 

current policy in key areas, however it does not go far enough. For example, the proposed number of miles of designated OHV routes are utterly unenforceable, given budget trends for hiring LE officers and Rangers within the BLM. Without constant enforcement and stiff penalties for infraction, OHV users will continue going "offtrail", spreading the kinds of damage already underway throughout the 

decision area. (see enclosure #2) 

BLM has developed manDuring the process, BLM rules in affect. In addition

with organizations and uuse areas and these effo

Richard Csenge An intelligent policy would be to designate only the number of routes and mileage 

that can be reasonably expected to be patrolled. Later, ifbudgets increase, demand is present, and the policy of restriction to designated routes has been faithfully observed by the public, more could be added. Due to the inherent nature and impacts of motorized vehicle use both on or off highway, licensing, restrictions, and enforcement are essential tools to safeguard the public interest, in this case, shared ownership interests in public lands. (see enclosure #3) 

BLM has developed manDuring the process, BLM rules in affect. In addition

with organizations and uuse areas and these effo

Richard Csenge Such values as visual, archaeological, vegetative, wildlife habitat, and water 

resources will all be adversely impacted if either alternative A, B, or D as proposed, is selected in the final decision for at least two reasons. One, all of 

The FLPMA directs BLM yield (Section 102(a)(7))implement laws, regulati

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Commentor Comment C

these alternatives leave open too much of the decision area to damage by OHVs, through motorized recreation designations either as "open" or as "designated routes only" . Secondly, these alternatives also provide for mineral exploration and extraction of coal, oil and gas, for the most part at the least stringent standard throughout the southern region ofthe Kanab District, which virtually guarantees future damage to biological, archaeological, visual, water, and paleo resources that have been identified elsewhere within the Draft RMP, to be of high caliber. 

land uses and to resolve plans. The BLM’s Land U

be made for each resourHandbook “H-1601-1”). Salternatives analyzed dualternative is formulateddecisions and inconsistea compatible mix of uses Draft RMP/EIS discloses 

Richard Csenge Lastly in the Vermillion Cliffs region, motorized recreation should be strictly 

limited to existing routes and trails in the Hog Canyon Trail System. Trails should not be extended into the North Fork ofHog Canyon, where incursions are already taking place. Nor should motorized use be allowed to impact hikers who have ascended the Squaw Trail from Kanab City. This trail, along with others, which cannot be negotiated by OHVs, provide those who favor quiet sports a place close to Kanab City, where they can recreate without being disturbed by dust and noise from ATVs. 

OHV use in Hog Canyon designated by an interdisK of the Draft RMP/EIS. motorized use, but actuaco-managed for both nonmaintain access to routedesignated right-of-way t

Richard Csenge To manage OHV use properly, there must be a transportation system that 

identifies designated routes and trails . No lands should be simply left open for 

cross country travel. The number ofmiles of routes should be small; three to five hundred miles at most. 

The action alternatives oidentifies designated rou

Robert Aiken The road to Moquith Mountain and the road to Hells Dive Canyon. Are RS 2477 

roads and should be open for the public to use. 

The Lamb’s Point route cIn consultation with the TRMP/Final EIS. The Proposed RMP/EIS access for development The RMP does not adjud

claimed ROWs. The BLM 

elements of this RMP thracknowledged administr

Robert Aiken On the South side of the Virgin River, you are proposing to close the Rock Creek 

accesses road. This road has been in existence for over 30 years, and is considered a RS2477 road claimed by Kane County. 

The Rock Canyon route RMP/EIS. The Proposed 

identified way open to OThe RMP does not adjud

claimed ROWs. The BLM 

elements of this RMP thracknowledged administr

Robert Aiken The road to Thompson Point, in "Alternative B" is proposed to be closed. This will An adjustment was mad

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Commentor Comment C

eliminate all the accesses for individuals to see the beautiful views along the rim to the point. We have made several visits to area and enjoy the views and the wildlife in the area. In our visits we have not seen any other ATV operators. People with handicaps and limited mobility will not be able to enjoy the area. 

development of a public-

Ross Tocher BLM's preferred "Alternative B" looks backward to the era of ORVs, when BLM 

should be looking forward. It is ill-advised and damaging to the resource to suggest an ORV route network of 1,387 miles in Alternative B - many routes only a mile apart, many in areas of high value for wilderness and wildlife habitat. Alternative B would produce a route density of 1.6 miles of DRV routes for every square mile of public lands. That should be corrected in the final plan by severely reducing the ORV route network. 

Appendix K of the Draft 

criteria used to identify athe commentor raises weduplicative routes, envirosensitivity, and current aproposed routes is discu

Ross Tocher At the very least, BLM should exclude DRVs from wilderness study areas (WSA) 

and "wilderness characteristics" areas (WCA), because these represent a rare resource that is vital to southern Utah's tourist economy. I believe the following areas should have a high priority for closure to DRVs: • Parunuweap Canyon and its tributary canyons, a complex that connects with Zion National Park and attracts many visitors for its wild character. The areas shaded pink in Map 3-15 should receive the same protection, as these are among the most easily 

accessible parts of Parunuweap, bordering on main tourism routes US Highway 89 and State Route 9. • Moquith Mountain WSA and WCA, a diverse area 

including pine forests and part ofthe Coral Pink Sand Dunes. An "open" area of 1,100 acres for ORV free play within the WSA (in Alternative B) would be inappropriate. The Moquith Mountain loop ORV route should be closed. • Areas close to Kanab city need more protection for their wild character, because these are the most accessible to visitors staying in Kanab, via US 89. Among them are Vermilion Cliffs, including Hog Canyon - an area BLM has unwisely excluded from the WCA; Upper Kanab Creek, including Elkheart Cliffs, with riparian habitat and perennial streams; and canyons in Moquith Mountain WCA on the west side ofUS 89. These areas are an asset to the tourist economy of Kanab, but ORV traffic could turm them into a liability. 

The IMP allows for open ways in WSAs during the opened or closed. ChaptOHV ways and routes in characteristics. The Propmanagement of several characteristics. These arRMP/Final EIS. 

Russell Howe First, I believe that putting a 25 person (group size) limit is a mistake. This would 

surely limit many family activities, (reunions, events, etc.) as well as scouting events, group rides, camping parties, etc. In my own extended family we frequently visit parts of our beautiful state in large camping groups, and would no longer be able to visit this affected region. 

The special recreation pdetermining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Russell Howe I believe that the BMP User Stats are not correct, and that Table 3.26 should be 

eliminated. I believe many of the proposed closing of roads should be kept open to large groups of familys, friends, and friendly organizations. These roads include Rock Canyon, Spur, The Poverty, Flat Road, Virgin River Access Road (The Barracks). Also the Hell Drive, Ed Lamb Point Road (Moquith Mountain), Vermillion Route, Willis Canyon (Thompson Point) and Black Mesa Route (Black Mesa). Also the Sheep Springs, Four Mile Creek, and Kanab Creek have existing 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

machine made roads which have been in service for many years. Discrepancies in actual u

decision area that does npopular use areas/trails accurately determine the As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition used among federal ageThe routes in Sheep SprProposed RMP. 

Russell Regentine BLM is establishing new WSAs without the authority to do so. The BLM has long ackno

requiring a one-time wildlands is authorized by FL

2006, the Utah District C

lands it determined to ha

similar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” meanpublic land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and objectnecessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those 

100 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

impairment standard, an§202 land management 

Russell Regentine Please disclose the difference in management prescriptions between "non-WSA 

lands with wilderness characteristics" and WSAs in the Final Environmental Impact Statement (FEIS). 

The difference between 60) and WSAs is discussRMP/Final EIS includes wilderness characteristicto the IMP. 

Russell Regentine The 1999 inventory found lands that contain extensive OHV trails to have 

"wilderness characteristics." If the presence of OHV use did not impact the presence or absence of "wilderness characteristics," then by what rationale is the BLM proposing to significantly reduce OHV trails in these areas? 

The Proposed RMP/Finaseveral non-WSA areas RMP/Final EIS, motorize

Sam Hamp Utah 4x4 Club 

first off I would like to say that I believe the following roads to be established roads and as such are covered under RS2477: Rock Canyon Spur on the map "The Barracks", The Poverty Flat Road on map "The Barraks," Virgin River Access Rd on map "The Barraks," Hell Drive on map "Moquith Mountain", Ed Lamb Point Rd on map "Moquith Mountain", Vermillion Route on map "Thomson Point", Willis Canyon on map "Thomson Point" and Black Mesa Routes on mapo "Black Mesa. 

The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Samuel & Janet Smith We have noticed that the road to Thompson Point, in "Alternative B", is proposed 

to be closed. This will eliminate all the accesses for individuals to see the beautiful views and vistas offered as the road winds its way out to Thompson Point. For the past 8 years our family and visitors have traveled to the point to enjoy the vista overlooking the Shinarump Cliffs, the White Sage Flats and beyond; the Kaibab Plateau. We have taken numerous photos ofour family from this location. We have enjoyed this area very much. From there we are able to hike to the white rock outcroppings and enjoy other explorations as we hike along the Vermillion Cliffs which overlooks our home below. In our many visits we have only seen other OHV operators, all of which have been locals from this area. 

An adjustment was maddevelopment of a public-

Samuel & Janet Smith We are equally distressed at the proposed closing of access into Willis Canyon. 

That is where we take our Grandchildren, visiting from the City, and teach them of the importance of conservation, respecting the land as an obligation for them 

to remember. We have visited and picnicked along Willis Creek on many occasions. Here we have rarely seen others, and have not disturbed the land other than passing over the deep sand to reach our favorite locations. 

The Willis Canyon route 

Samuel & Janet Smith I would also like to make a comment on the proposed closure ofthe Moquith 

Mountain and the road to Hells Dive Canyon. Hells Dive Canyon has some ofthe premier Indian Pictographs and Grinding Stones in this area, to close access off from the general public would be very disappointing. We would suggest that the B.L.M. use this area as an interpretive site, somewhat like the one in Indian Canyon where people could go and enjoy these great sites without damaging them. This should be a relatively easy project with help coming from both the 

The Proposed RMP/EIS access for development 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Hiking and O.H.V. community. This would also keep another Kane Co. RS 2477 road open for public use. 

Samuel & Janet Smith The view off the end of Moquith Mountain is one of the most spectacular views 

that are available of the Arizona Strip. It is the only place that a person can look off the Vermillion Cliffs to see this magnificent view that reaches to the confluence of the Kanab Creek and the Grand Canyon to the south. This is also a very long hike, 10 to 15 miles, through the deep sand; that I'm sure is not for the general public or senior citizens. Without the use of an OHV many of us senior citizens will be denied the opportunity to enjoy many areas of public lands. 

The route the commentocrosses the state line intTribe, the Lamb’s Point r

Scott Howe U4WDA, TLCA 

I do not support the requirements for the special recreation permits. These requirements are unreasonable and severly limit the possibility of group events. Group events are a crucial part of responsible recreation where as people can learn from others proper off highway recreation habits & show group support for areas. Groups provide the possibility for service projects that help to manage public land. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Sedona Thomason I feel that the roads should not be closed because what about emergencies? I 

guess what I really mean is that if you have the roads closed are you going to let emergency vehicles through, example if there is a fire are you going to let fire trucks through or let the forest burn down? I feel very strongly on the subject of roads being closed down or even blocked, most people will break down gates if there is a serious emergency. So the Route Designations Map 2 - 19 Alternative D is the best choice where only a few roads down by Kanab Creek is closed. 

There are exclusions baare defined in 43 CFR 83

Seth Bowers U4WDA 

3) Sheep Spring, four Mile Creek, and Kanab Creek are machine made roads that have been maintained since the late 1800's. This feat in its own negates these areas as wilderness. 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

Seth Bowers U4WDA 

1) The limit of special rec permits to 25 is unreasonable. My family reunions would not be allowed under this rule. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Seth Bowers U4WDA 

2) Table 3.26 is grossly distorted. Data collected is flawed by the BLM's own admission. The table should be removed in its entirety. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff 

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Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition used among federal age

Shane Baird The first comment is that I believe Alternative D is the best choice except for the 

roads to Poverty I think they should stay open, because the community and I plan to hunt there. 

The Proposed RMP/EIS 

identified way open to O

Shirley Fujimoto McDermott, Will & Emery 

Thus the BLM should prepare a Final EIS and revised RMP to encourage and facilitate the siting of this infrastructure on federal lands in the Kanab Resource Area. 

Page 2-26 of the Draft R

permits, and leases. The case-by-case basis." 

Shirley Fujimoto McDermott, Will & Emery 

By contrast, the BLM should not adopt Alternative C. The BLM should also not adopt the proposal under Alternatives B and D to require communication site plans for all existing communications sites before any new type os uses or new facilities would be authorized on these sites. 

This requirement prevencolocation of existing fac

Spencer Decker I am extremely concerned with the BLM plans to open up this area to additional 

roads and ORV trails. There is plenty of space in the region to accomodate both hikers, canyoneers and ORV recreation, but they cannot effectively exist on top 

of each other. 

Motorized and non-motoplanning process. The Dresource values are protmotorized access and re

Steven Edmunds Special recreation permits - do not reduce the size of the groups - you will be 

requiring my family to seek permits for annual family reunions. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Steven Edmunds The use statistics are wrong - these statistics in table 3-26 should be removed or 

replaced with accurate data. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails 

accurately determine the 

As cited in Section 4.1.6

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

best available data was Visitor-days are calcuatestandard BLM definition used among federal age

Steven Edmunds Sheep Springs Road, Four Mile Creek and Kanab Creek are man made roads 

with many man made fixtures, such as corrals, tanks, spurs. 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

Susan Hand Areas of Critical Environmental Concern I am confused that the KFO seems to 

acknowledge that the proposed ACECs are justified, and yet Alternative B disregards staff recommendations. Since an ACEC designation is based on unique resources (ecological, biological, historical, or cultural), it seems incongruous that the BLM not designate what it has clearly identified. The Coral Pink Sand Dunes of the Moquith Mountian WSA, the Vermilion and White Cliffs, and Purunaweap Canyon are worthy of ACEC designation, but have been overlooked. 

There is no requirement preferred alternative. Thpotential ACECs be carrone alternative in the DR

potential ACECs. The raforward into the PRMP/F

The BLM Manual 1613.2of each alternative, the m

meets the planning criterpreferred alternative reflemanagement of ACECs.for the various alternativcomparison of estimated leads to development an

Should BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being propsuch as wilderness and w3. The manager has con

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either because of exposuarea is designated or thecan be taken to protect tviable condition. BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources wanother use which would authorized officer must fother use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

Susan Hand My first suggestion is that the BLM extend the public comment period. The 

placement over the holidays, coupled with simultaneous comment periods for five 

other Utah RMP's, almost seems designed to limit public understanding and participation, which is counter to the intended purpose. Other unforeseen distractions have further divided the public's attention. We may well live under the 

final plan for decades to come, so it is critical that it be developed carefully. 

The BLM provided the pRMP/EIS, as required by 1610.2(E)). The standard accordance with CEQ re

the BLM planning and N

provides a 90-day comm

review and comment on available, free of charge CD, and online. In additigroups or individuals to ecomment efforts. Finally, facilitate review of the Ka

Susan Hand The area of the Vermilion Cliffs between Kanab and Johnson Canyon. The 

subdivisions in this area were established as equestrian developments, and many residents ride their horses on adjacent BLM lands. ATV's and horses are generally not compatible. Many property owners object to the trespass, dust noise, erosion, and scarring created by the proximity of motorized recreation to the subdivisions along this narrow corridor. 

Appendix K of the Draft 

criteria used to identify afuture. The Proposed RM

Susan Hand I'm especially disappointed by the motorized activity which has been allowed on 

the Dry Lake Bed adjacent to the Coral Pink Sand Dunes. Proximity of the 

The development and lodecisions that will be con

105 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

campground to the WSA has resulted in repeated and extensive OHV use within the closed area, even though it is signed. The RMP should create a more appropriate campground and close the Dry Lake Bed. 

Susan Hand Parunaweap, Motorized Canyon RMZ. I strongly disagree with the placement of 

an OHV touring route in a WSA! There are many opportunities available elsewhere, and motors are simply not compatible with management guidelines established for WSA's. On the other hand, I applaud the closure of the Barracks and Poverty Flat routes. 

The Parunuweap SRMA the inventoried way is op

Susan Hand Upper Squaw Trail. This is the most popular hiking trail in our community, and the 

one that most visitors are directed to. The ridge which is the primary destination of this trail should not be open to OHV use. The KFO provides few developed hiking trails, and it seems a shame to sacrifice any of them. Please protect this 

important resource from unnecessary user conflicts. 

OHV use in Hog Canyon designated by an interdisK of the Draft RMP/EIS. system due to resource 

Susan Hand Oil and Gas Leasing I appreciate the more restrictive guidelines for oil and gas 

leasing in the vicinity of Kanab as imposed by Alternative B. This is especially important to protect our community watershed. It would seem that the watershed for Zion National Park and the town of Springdale--indeed any community watershed--are equally deserving of protection. 

Kanab and Fredonia spearound their water systeField Office lands to prot

during the public scoping 

SUWA The DRMP fails to adequately assess the impacts of the proposed management 

alternatives on air quality. The DRMP fails to include any quantitative information, analysis or models to assist the decision-maker on this issue. 

The quantification of potemission sources requireapplication of dispersion about those sources, suclarge uncertainty. This ucompromise the reliabilitanalysis will be conducte

SUWA To rectify this, once BLM has determined that certain areas in the Kanab Field 

Office contain the requisite relevant and importance values - which the Kanab Field Office has already done - the agency must prioritize the designation ofthose areas as ACECs over other competing resource uses. 

There is no requirement preferred alternative. Th

potential ACECs be carrone alternative in the DRpotential ACECs. The raforward into the PRMP/F

The BLM Manual 1613.2of each alternative, the mmeets the planning criterpreferred alternative reflemanagement of ACECs.for the various alternativcomparison of estimated leads to development an

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Commentor Comment C

Should BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being propsuch as wilderness and w3. The manager has coneither because of exposuarea is designated or thecan be taken to protect tviable condition. BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources wanother use which would authorized officer must fother use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

SUWA BLM's treatment of proposed ACECs in the DRMP/EIS does not comply with 

either FLPMA's mandate or the agency's own internal guidance. 

Appendix H of the Draft evaluate proposed ACECCFR 1610.7-2, and BLM 

SUWA BLM has improperly ignored or discounted the threats to special places from oil 

and gas development and off-road vehicle use, and thus failed to designate 

Section 4.4.1 of Chapter probability of irreparable 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

and/or failed to incorporate sufficient protections for proposed ACECs. H of the Draft RMP/EIS i

proposed ACECs. The p1610.7-2, and BLM Man

SUWA However, the Kanab DRMP fails to support designation of ACECs to protect 

these values. BLM has identified approximately 89,780 acres of lands with wilderness characteristics. 

Appendix H of the Draft evaluate proposed ACECCFR 1610.7-2, and BLM 

SUWA That BLM has determined that 60,600 acres meet the relevance and importance 

criteria for ACEC designation, BLM must give priority to the designation of these ACECs in all alternatives, not merely Alternative C. 

There is no requirement preferred alternative. Th

potential ACECs be carrone alternative in the DRpotential ACECs. The raforward into the PRMP/F

The BLM Manual 1613.2of each alternative, the m

meets the planning criterpreferred alternative reflemanagement of ACECs.for the various alternativ

comparison of estimated 

leads to development anShould BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being propsuch as wilderness and w3. The manager has coneither because of exposuarea is designated or thecan be taken to protect tviable condition. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

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BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources wanother use which would authorized officer must fother use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

SUWA SUWA also contends that the values found to relevant and important extend to 

acreage beyond the 6,100 in the potential ACEC. We urge the BLM to reevaluate the extent of these values and designate a larger acreage. (Parunuweap Canyon) 

Appendix H of the Draft evaluate proposed ACECCFR 1610.7-2, and BLM the commentor raises weand therefore the ACEC 

SUWA Recommendation: The Kanab RMP should reflect certain aspects of the GSENM 

RMP for consistency purposes as well as to provide both the Kanab planning area and the GSENM the proper protection needed to ensure long-term preservation of the outstanding values of this landscape. The RMP should also provide measurable goals, objectives, and desired future conditions that recognize the area's special virtues of ruggedness, remoteness, and wildness. 

The Kanab Field Office hRMP/EIS and the Propoare included on the BLM 

SUWA Recommendation: The Kanab RMP should be consistent with the management 

of the National Parks in the area and should provide management objectives and prescriptions that protect and do not impair the conservation values of the adjacent and nearby National Parks. This should include, but is not limited to, the air quality and visibility impairment of the Parks from actions occurring within the planning area. 

The BLM has coordinateproviding opportunities foprocess. These coordinapage 5-5. 

SUWA The BLM must more fully quantify this risk, as well as the potential for mineral 

recovery (and the likely amounts to be recovered) and compare them to the gains to the environment from the most well-balanced alternative, Alternative C. 

The Mineral Potential Rescenario for mineral devinformation is incorporatthe impacts from mineraUnder FLPMA’s multiplevalues and uses on publobjectives for each of tho

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

accomplish those objectnecessarily manage evemany different values an

SUWA However, the Kanab Draft RMP evaluates an unjustifiably inflated reasonably 

foreseeable development scenario of ninety wells over a twenty-year period - or 4.5 wells per year. Id at 3-90, 4-198. This rate is nearly four times the historic average for the Kanab Field Office, including surface lands managed by the U.S. Forest Service. Although oil and gas development may be subject to fluctuations, the reasonably foreseeable development scenario significantly exceeds the historical reality ofthe planning area. 

The commentor does noreasonable foreseeable not only based on historieconomic trends and advthe best available data to 

SUWA One shortcoming common to every alternative analyzed in the Kanab Draft RMP 

is that the BLM has not endeavored to match oil and gas leasing stipulations with actual known geologic reserves of oil and gas and areas of historical development. 

BLM is not required to dereserves of oil and gas. 

protect other resources a

SUWA The BLM provides no justification for this figure. Inexplicably, the RFD actually 

excludes the past twenty years from its calculations, seemingly for no other reason than because recent figures have been low. 

The commentor does noreasonable foreseeable not only based on histori

economic trends and advthe best available data to 

SUWA Kanab Draft RMP at 3-90, 4-198. This RFD scenario is arbitrary, capricious, and 

unrealistic. No twenty-year period in the history of the planning area has ever seen such a high rate of development. 

The commentor does noreasonable foreseeable not only based on historieconomic trends and advthe best available data to 

SUWA The BLM must develop a new reasonably foreseeable development scenario that 

is historically accurate and actually tied to productive oil and gas fields. The present method completely ignores historical trends and declining production. None of the alternatives close certain. environmentally sensitive areas that should be closed, which hold little or no oil and gas production potential and are mostly unleased. 

The commentor does noreasonable foreseeable not only based on histori

economic trends and advthe best available data to 

SUWA The BLM has never had before it the possibility of totally abandoning oil and gas 

leasing in the Kanab planning area, something it is required to do. See Bob Marshall Alliance, 852 F.2d at 1228. 

Chapter 2 of the Proposeno oil and gas leasing al

SUWA The BLM must take a hard look at whether any actual trade off exists between 

the preferred alternative and the additional protections of an alternative that include all of the closures and stipulations found in Alternative C as well as the additional closures and stipulations recommended above. The Kanab Draft RMP already states that none of the current alternatives would result in any changes to the RFD. 

Alternative C emphasizeimpacts upon natural resdescribed in Chapter 4. T

SUWA The BLM should modify the alternatives, particularly Alternative C, so that they The resources the comm

110 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

will close additional environmentally sensitive areas to leasing - or to surface occupancysince such closures are unlikely to limit feasible oil and gas production in the planning area. The BLM should either close to leasing or impose no surface occupancy restrictions on the entire area south of U.S. 9 and west of U.S. 89. Though no current leases exist in this area, it is an extremely environmentally sensitive and deserving of protection from these damaging activities. The area contains the following important resources: three WSAs and additional non-WSA lands with wilderness characteristics, an area of relict vegetation, critical habitat of the Mexican spotted owl, crucial and high value mule deer habitat, elk habitat, crucial desert bighorn sheep habitat, and numerous proposed ACECs. Kanab Draft RMP at Maps 2-39,3-4,3-8,3-10,3-11,3-12,3-15,318. Furthermore, the National Park Service has expressed concern that leasing in this area could damage the Navajo Aquifer; the BLM should not offer for lease any lands overlying the Navajo Aquifer because ofthe resulting degradation that could occur in Zion National Park. See Letter from Martin C. Ott, Superintendent, Zion National Park, National Park Service, to Barbara Sharrow, Acting Field Office Manager, Kanab Field Office (Jan. 4, 2002) (attached as Attachment RR). The BLM should also close to leasing or place no surface occupancy restrictions on all lands east of U.S. 89 and south ofthe road running from Glendale to the Skutampah road. No current leases exist in this area, it contains non-WSA lands with wilderness characteristics, is home to areas ofrelict vegetation and fragile soils, contains crucial and high value mule deer habitat, contains elk habitat, and has numerous proposed ACECs. Kanab Draft RMP at Maps 2-39,3-4,3-10,3-11,3-15,3-18. In addition, all lands containing critical habitat for the Mexican spotted owl on the western edge ofthe planning area should either be closed to leasing or restricted to no surface occupancy (T39-43S R8-9W). See id. at Map 3-8. Furthermore, the BLM should either close to leasing or place no surface occupancy stipulations on greater sage-grouse brooding areas and winter range. See id. at Map 3-9. 

Mexican spotted owl habPlan from oil and gas deleasing, big game habitahabitat has no surface oWSA lands with wildernePlan with no surface occUnder FLPMA’s multiplevalues and uses on publobjectives for each of thoaccomplish those objectnecessarily manage evemany different values an

SUWA Motorized routes should not be designated within lands with identified wilderness 

characteristics. 

Motorized routes in non-necessarily contrary to thChapter 4 of the Draft RMwilderness characteristic

SUWA This management strategy should apply to both non-WSA lands identified as 

possessing wilderness characteristics by the BLM and non-WSA lands with wilderness characteristics included in wilderness proposals that have been introduced before Congress (i.e. the UWC ARWA proposal). 

BLM is not required to plands proposed by indivipending before Congres

SUWA However, SUWA and others maintain that some wilderness quality lands have 

yet to be appropriately identified as possessing wilderness characteristics by the BLM. 

As part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and high

of the high-standard app

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Commentor Comment C

findings, particularly the inventory maintenance. 

SUWA There also remain some areas that the BLM has yet to conduct an appropriate 

on-the- ground inventory, and has instead relied on aerial photos (which tend to exaggerate impacts because vegetation patterns from old impacts are far more visible from the air than on the ground), where as most of these impacts cannot be found on the ground by experienced field workers, and would certainly be unnoticeable to most visitors. 

As part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

SUWA Based on our review, SUWA contends that BLM has only performed a cursory 

assessment of these wilderness character units and a more complete and detailed evaluation and inventory of these units is warranted. 

As part of BLM’s wildernperformed a combination inspections, Interdisciplin

BLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

SUWA These observation are based on on-the-ground inventories and other records. In 

sum, BLM must review the new information that SUWA has provided, and conduct on-the-ground wilderness inventories and reviews for these areas. 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

SUWA The recent WCR arbitrarily excludes or fails to identify many natural and 

wilderness-character- quality BLM lands contiguous with the Dixie National Forest. 

The process used to evadescribed beginning on 3

consideration, they needadministratively endorse

SUWA The Kanab and Utah BLM bases this arbitrary exclusion on the fact that the 

Forest Service has not yet "administratively endorsed" their portion of the roadless area for wilderness designation, therefore, the area would have to meet the size requirements as a "stand alone unit." This arbitrary practice requires that lands within the Forest Service must be currently endorsed for wilderness designation in order for the adjacent Kanab BLM lands to meet the wilderness character and size requirement. 

The process used to evadescribed beginning on 3

consideration, they needadministratively endorse

SUWA Therefore, the exclusion of this natural area, adjoining and contiguous with the 

larger Forest Service roadless area is not justified. 

The process used to evadescribed beginning on 3consideration, they needadministratively endorse

SUWA SUWA did supply the Kanab BLM with supplemental and new information for the 

Black Hills wilderness character unit previously, this information remains valid and BLM will need to correctly identify the area as retaining a wilderness 

As part of BLM’s wildernperformed a combination inspections, Interdisciplin

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Commentor Comment C

character for all RMP planning purposes. BLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

SUWA BLM needs to correct this omission and correctly include natural lands and 

identify the true extent of naturalness. 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

SUWA This (Heaps Canyon Wilderness Character Unit) has not been correctly identified 

by the Kanab BLM. 

As part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

SUWA BLM will need to correct this oversight and continue to expand its wilderness 

characteristic boundary north as shown by the supplemental map until it encounters a significant impact. 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

SUWA The submission of information did not get incorporated within the planning 

process and was not assessed during the recent WCR. SUWA's wilderness character comments remain valid and highlight the full extent of wilderness characteristics not identified by the BLM. (Orderville Canyon Wilderness Character Unit) 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

SUWA None of this public information has yet been addressed or have these concerns 

and situation here been properly completed during its recent WCR. The comments remain valid and highlight where the full extent of wilderness characteristics are not identified by the BLM. (Orderville) 

As part of BLM’s wildernperformed a combination inspections, Interdisciplin

BLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

SUWA In spite of having this information, it appears the BLM has yet to address these 

concerns during the recent WCR or within the DRMP/EIS. The comments remain 

As part of BLM’s wildernperformed a combination 

113 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

valid and continue to demonstrate the full extent of wilderness characteristics not identified by the BLM. (Parunuweap Canyon) 

inspections, InterdisciplinBLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

SUWA The recent WCR is unjustified by the overly exclusion of the natural areas. 

(Parunuweap Canyon) 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

SUWA This area exemplifies the failure of the BLM to identify wilderness values and 

characteristics -- by an outright arbitrary separation of natural areas. (Vermillion Cliffs) 

As part of BLM’s wildernperformed a combination inspections, InterdisciplinBLM GIS data, and high

of the high-standard appfindings, particularly the inventory maintenance. 

SUWA A. The Public Comment Period is Far Too Short to Allow for a Fully Informed 

Response to the Draft Plan PR.P 

The BLM provided the pRMP/EIS, as required by 1610.2(E)). The standard accordance with CEQ rethe BLM planning and Nprovides a 90-day commreview and comment on available, free of charge CD, and online. In additigroups or individuals to ecomment efforts. Finally, 

facilitate review of the Ka

SUWA B. The Kanab DRMP/EIS fails to acknowledge the public will regarding land 

management preferences. 

The BLM has involved thpublic scoping meetingsincorporated into the Kandeveloped to address thalternatives significantly 

number and mileage of r

SUWA The proposed designation of only 3,800 acres of ACEC when 60,600 acres have 

been found eligible falls far short of FLPMA's mandate that BLM give "priority" to this resource. 

There is no requirement preferred alternative. Thpotential ACECs be carrone alternative in the DR

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potential ACECs. The raforward into the PRMP/FThe BLM Manual 1613.2of each alternative, the mmeets the planning criterpreferred alternative reflemanagement of ACECs.for the various alternativcomparison of estimated leads to development anShould BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being propsuch as wilderness and w3. The manager has coneither because of exposuarea is designated or thecan be taken to protect tviable condition. BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources wanother use which would authorized officer must f

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other use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

SUWA Certain elements of the RMP, most strikingly the travel plan and OHV 

designations, fail the UUD standard. By several measures, the proposed travel plan and OHV designations will harm natural resources by increasing cumulative dust and decreasing air quality; unnecessarily fragmenting wildlife habitat; causing unnecessary damage to riparian areas, floodplains and cultural resources; reducing naturalness in areas with identified wilderness characteristics; and, impairing Wilderness Study Areas. 

The BLM analyzed the imin Chapter 4 of the DRMmandate, that there wou

Also, as a matter of clari

a management standard 

SUWA In the context of this RMP, the decisions made with regard to travel planning 

must more fully analyze all effects of travel planning and other planning so that all cumulative and site specific environmental and social impacts are adequately analyzed. 

The commentor does nocumulative impact analyRMP is sufficient for an Rincluded in Section 4.6 o

SUWA NEPA requires BLM to "rigorously explore and objectively evaluate" a range of 

alternatives to proposed federal actions, and the lack of an alternative that adequately protects natural and cultural resources is a fatal flaw to this plan. See 40 C.F.R. §§ 1502.14(a) and 1508.25(c). 

The BLM used the scopireasonable range of altealternatives identified by 

(including the No Action considers various levels the public the ability to fuprescription or action. Tacomparative form the ma

SUWA For this Draft RMP, the consideration of more environmentally protective 

alternatives consistent with FLPMA's requirement that BLM "minimize adverse impacts on the natural, environmental, scientific, cultural, and other resources and values (including fish and wildlife habitat) ofthe public lands involved," is lacking given the dearth of analysis, the limited range of alternatives, and the 

omission ofthe Vermilion Cliffs Heritage Proposal as an alternative. 43 U.S.c. §1732(d)(2)(a). 

The Vermilion Cliffs HeriRMP/EIS on pg. 2-32 as analysis. Components oaction alternatives. Altealternative. 

SUWA The Travel Plan included in this EIS is a key example of the aforementioned 

citations, with each alternative posing significant resource harms and no alternative that mitigates those harms (i.e. no alternative not designating routes within WSAs or WC areas). 

Alternative C emphasizeAlternative C of the Draft 

SUWA This type of analysis is wholly lacking with regard to travel planning, as well as 

many other aspects of the Kanab Draft RMP. 

The comment is general 

alternatives and analysis 

SUWA BLM's cursory dismissal ofthe Vermilion Cliffs Heritage Proposal is a clear 

indication of the BLM's refusal to entertain a responsible "opposing view" in the planning process. SUWA's comments about BLM's capricious dismissal ofthe 

In the Kanab Draft RMP/preservation of natural reproduction and extractio

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Vermilion Cliffs Heritage Proposal are included in these comments immediately below. 

protects and preserves hfull consideration to the Vthat a desirable BLM Tramotorized and motorized Draft RMP/EIS on pg. 2-from detailed analysis, cconsideration and analys

SUWA Our review of the draft RMP and EIS show that much more work must be done 

on these documents before they can be formalized. We found significant deficiencies in both the analysis of the current condition and the analysis ofthe impacts ofthe proposed alternatives. 

The comment is general 

alternatives and analysis 

SUWA One of the most obvious and consequential flaws in the document is its failure to 

assess the ongoing impact of existing ORV use in the Kanab Field Office. 

The impacts of travel on RMP/EIS, including the NThe Transportation Sectbaseline (current situatio

baseline issues surroundexisting land use plan fo

having 1,479 miles of noanalysis, however, it is aallowed in the majority ocountry OHV use are deaction alternatives limit tuse are considered part consider the impacts to v

SUWA The DRMP must include BLMs, USFWS's and the Utah Dept. of Natural 

Resources' monitoring data, trend analysis, and any other available documentation of he Welsh's milkweed and the impacts of ORV use on this federally listed species. This information is necessary in order for the decision maker and the public to ascertain if the requirements of the Endangered Species Act are being met if ORV use is allowed in Welsh's milkweed habitat. 

The data the commentor 

of the species (Draft RM

SUWA Because hard information on visitation was missing from the AMS and Affected 

Environment section of the Draft RMP, the BLM has created a potentially false impression that the Kanab Field Office is a location in which ORV use is more 

popular than every other recreation pursuit, which contradicts information gathered by BLM, itself - for the Moquith sand dunes where motorized use 

appears to be heaviest - that indicates that over 90% of the visitors to the sand dunes are non-motorized users. 

The Draft RMP/EIS is ba

(RMIS) data collected by Draft RMP/EIS, "It is imponly estimates and do nospecific activities in specfacilities such as traffic cis focused on areas of ga result of the remote nafrequent monitoring. In a

designated and there is amount of recreational u

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recreation data is noted to compile baselines and The data reference by thdunes are non-motorized collected by BLM or the that 83% of the visitors tdoes not directly correlatdue to the fact that visitoto the State Park which hBLM portion of the sand on observation and profe

SUWA 1. We reiterate that the BLM's failure to analyze and present information about 

the impacts of existing ORV use violates its NEPA duties. 

The impacts of travel on RMP/EIS, including the NThe Transportation Sectbaseline (current situatio

baseline issues surroundexisting land use plan fo

having 1,479 miles of noanalysis, however, it is aallowed in the majority ocountry OHV use are deaction alternatives limit tuse are considered part consider the impacts to v

SUWA 2. ORV impacts to vegetation are largely ignored. For example, Chapter 4's 

discussion of this impact is limited to two paragraphs, neither of which is 

quantitative in nature and which do not assess the probability of ORVs introducing and facilitating the spread of non-native species. However, the plan admits on p. 4-41 that "areas open to cross-country OHV use (1,100 acres)" would be more likely to experience surface disturbance, but fails to mention that this disturbance takes place in a WSA. 

Impacts to vegetation rethe Draft RMP/EIS. The refute the existing analysdirectly contribute to intro

species. The IMP allows inventoried ways in WSA

SUWA 3. Chapter 4's discussion of soils at 4-16 to 4-24 lacks well-considered, informed 

decisions about broad-scale uses with long-term impacts - such as the designation of thousands of miles of ORV routes. 

The Transportation Sectbaseline (current situatiosurrounding OHV on exi

use plan for the Field Offmiles of non-paved routeroutes are described in Care already in use are coreasonable to consider tlinear surfaces. 

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As stated on page 4-20 omiles of designated routefrom increased erosion balready been impacted." 

SUWA The DRMP/EIS never considers or analyzes whether current or proposed ORV 

use levels are sustainable over the long term. 

The current use and projplanning process. The ra

motorized recreation. 

SUWA However, the BLM never quantifies this assertion with analysis of how close 

many of the proposed routes are to known sites. Also, there is no analysis of the likelihood that route designation will harm unknown sites. 

Cultural resources were consultation is being conresource inventory requi

the affect and nature of tnature of historic propertAppendix K. 

SUWA Yet nowhere in the document is the estimated amount of soil lost to ORV use 

quantified. This information gap should be filled by inclusion of the best available data and methodology. 

As described in Chapter Kanab RMP. In addition, information to incorporat

SUWA However wouldn't decisions to limit grazing based on riparian area destruction 

also impact ORV decisions? As would decisions to protect areas based on visual resources, or wildlife? Please provide an explanation for this approach. 

Limiting a resource use fnecessarily require limitilivestock grazing do not RMP/EIS, riparian areas(VRM) were considered 

SUWA The DEIS generally provides little or no discussion of cumulative impacts or the 

effects connected activities have on various resources. 

The commentor does nocumulative impact analyRMP is sufficient for an Rincluded in Section 4.6 o

SUWA For example, the plan provides for high levels of both grazing and ORV use in 

canyon bottoms where riparian areas and cultural sites are also prevalent. Yet the plan does little more than acknowledge the combined effects of these two intensive uses, both of which are associated with long-term impacts such as decreased water quality and quantity, native plant loss, soil erosion and diminished enjoyment by non-motorized recreationists. 

The levels of grazing and during the scoping perio

livestock grazing or OHV Livestock grazing and Oriparian areas. Monitorinaffect riparian area healtcould be taken to protect impaired. 

SUWA There is no attempt to break dow the assessment by alternative, timeline for 

meeting PFC, or any real quantitative analysis. 

There is not a requiremePFC. This is an impleme

SUWA The BLM should identify the areas in which ORV use is also permitted (where 

trails would be designated) and each stream's PFC rating, and discuss the combined effects of grazing and ORVs on these riparian areas. 

The impacts to riparian a4. The BLM analyzed eaand potential uses of eacAppendix K, to determin

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would affect setting, recrThis information was usein chapter 4 addressed tdoes not require analysis 

impacts of the identified RMP/EIS on pages 4-18

SUWA This pre-determined approach has infected the rest of the draft plan with an 

assumption that demand for ORV use is high and impacts relatively low. It has affected the development of alternatives, as well, with a complete lack of a proposal which addresses the needs of non-motorized visitors. For example, how many routes designated in the plan are for ORVs and how many trails are proposed for hikers? 

Motorized and non-motoplanning process. The D

resource values are protmotorized access and rein the RMP, however this motorized use (e.g., equplanning. 

SUWA The BLM avoids dealing with a range of important issues by declaring some 

beyond the scope of this plan. The issues of public education, enforcement/prosecution, vandalism and volunteer coordination are not addressed, but are critical to adequately analyzing the feasibility of implementing travel planning decisions and DRV route designations. 

The issues the comment

of this plan. 

SUWA Indeed, there are only 274 miles of difference between the routes designated in 

Alternatives B, C and D - not a meaningful difference in light of the 1,300+ miles of designated ORV routes and over 5000 miles of route total when combined with other dirt roads and trails on all lands. Thus, the DRMP/EIS violates NEPA's requirement that the agency provide a reasonable range of alternatives for the public to consider, and for the agency to analyze in order to make a fully informed decision. 

A range of alternatives wThe process used to ideAppendix K. By alternativconcerns and issues and 

SUWA As discussed below, SUWA maintains that BLM has the authority and the 

responsibility pursuant to FLPMA § 202 to fully analyze and adopt an alternative that would designate new wilderness study areas. BLM's failure to fully consider and analyze such an alternative is fatal to its analysis. 

The BLM does not have planning process. The BLM’s authority for mcharacteristics is derived 

This section of BLM’s orto manage public lands fsection constrains the Se“achieve integrated conssciences.” (FLPMA, Secmakes it clear that the tefor every acre of public lause of the land for some large enough to provide (FLPMA, Section 103(c) Secretary of the Interior 

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resource use, including wresources in a way that pThe BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District Clands it determined to hasimilar to the manner in 

SUWA The DRMP/EIS fails to provide an alternative avoiding potential environmental 

effects of designating particular routes. 

A range of alternatives wThe BLM analyzed each 

potential uses of each roK, to determine route idesetting, recreation activitinformation was used in chapter 4 addressed the 

does not require analysis 

impacts of the identified RMP/EIS on pages 4-18

SUWA Although the DRMP/EIS includes a description of the various recreational 

opportunity "focus areas" for which recreation can be managed, it is impossible to decipher the acreages within the various classifications under the various alternatives as key information is omitted from the maps and charts. Based on a review of the maps, however, the alternatives fail to provide adequately for quality, dispersed non-motorized recreational opportunities, especially nonstructured, primitive and unconfirmed recreation which is not afforded by narrowly defined Recreational Management Zones (RMZs) that cater to specific niche recreation. 

Motorized and non-motoplanning process. The Dresource values are protmotorized access and rein the RMP, however this further described in futurSpecial Recreation ManaThe Proposed RMP has with wilderness characteacres) and WSAs (53,90primitive, and unconfined 

SUWA The BLM has not fully considered and analyzed the Vermilion Cliffs Heritage 

Proposal or meaningfully incorporated it into any of the alternatives. 

The Vermilion Cliffs HeriRMP/EIS on pg. 2-32 as 

analysis. Components oaction alternatives and in system (Appendix K). 

SUWA Because BLM has never fully evaluated the no-leasing alternative there is no 

earlier analysis that BLM can rely upon for this analysis. BLM must therefore fully analyze and consider the no-leasing " alternative, which would provide for no more leasing in the Kanab Field Office - as opposed to simply the maintenance of 

the status quo of making lands available for leasing in the no-action alternative - in the EIS accompanying the Kanab RMP. 

Chapter 2 of the Proposeno oil and gas leasing al

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SUWA Further, if BLM continues to exclude designation of new WSAs from 

consideration in the DRMP/EIS, it risks violating both FLPMA and NEPA, and jeopardizing the validity of the entire planning process. 

The BLM does not have planning process. The BLM’s authority for mcharacteristics is derived 

This section of BLM’s orto manage public lands fsection constrains the Se“achieve integrated conssciences.” (FLPMA, Secmakes it clear that the tefor every acre of public lause of the land for some large enough to provide (FLPMA, Section 103(c) Secretary of the Interior resource use, including wresources in a way that pThe BLM has long ackno

requiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to ha

similar to the manner in 

SUWA Contrary to its own guidance, it appears that the BLM has provided no 

"definitions and additional limitations for specific roads and trails;" no "criteria" for 

the selection of specific roads and trails like those described in the Guidance; provided no "guidelines" for the management, monitoring and maintenance of the trails, and lastly, there are no "indicators" to guide future planning such as the result of monitoring data or other information. Thus, the travel plan violates the BLM's own rules for designating trails. 

Appendix K describes thsystem. The appendix alchanging route designat

SUWA 2-3 Based on our examination of the maps, DRMP/EIS and discussions with BLM 

personnel involved in the RMP and travel plan development it is clear that the BLM did exactly what the Guidance warned against. Instead of actively choosing routes based on sensible criteria like the need for access, desired future condition and the protection of natural and cultural resources, the BLM simply "inherited" roads and trails from county maps and from off-road vehicle advocates. 

Appendix K describes thtransportation system. T

which routes should be iincluded a review by the Appendix K including ac

and desired future condi

SUWA As noted above, the DRMP/EIS does not demonstrate a full range of travel types 

and modes, or other limitations sufficient to protect the resources at risk from 

Motorized and non-motoplanning process. The D

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ORV use. In particular, while BLM proposes to designate nearly 1,400 miles of ORV routes, there appears to be zero miles of hiking trail proposed in the DRMP. And because of the obvious public safety and other conflicts present, allowing hikers to use ORV trails is not a solution. (2.3) 

resource values are protmotorized access and rein the RMP, however this 

motorized use (e.g., equplanning. 

SUWA To address these insufficiencies, the BLM must provide specific information on 

the purpose and need for the routes incorporated in each alternative, the potential impacts on other resources, and the potential conflicts with other users and the justification for designating the route with the proposed range of uses. The public should then have an opportunity to comment so that this input can be taken into account before issuance of a Proposed RMP/Final EIS. 

A range of alternatives w

The BLM analyzed each potential uses of each roK, to determine route idesetting, recreation activitinformation was used in chapter 4 addressed the 

does not require analysis 

impacts of the identified RMP/EIS on pages 4-18The public was provided January 10, 2008. Hundalternatives. The Proposand BLM review. 

SUWA However, the preferred alternative would designate only a small fraction of 

acreage (6%) evaluated by the BLM to meet the relevance and importance criteria. This is a violation of FLPMA's mandate that "priority" be given to designation of ACECs. 

There is no requirement preferred alternative. Thpotential ACECs be carrone alternative in the DR

potential ACECs. The raforward into the PRMP/F

The BLM Manual 1613.2of each alternative, the mmeets the planning criterpreferred alternative reflemanagement of ACECs.for the various alternativ

comparison of estimated 

leads to development anShould BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m

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1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being propsuch as wilderness and w3. The manager has coneither because of exposuarea is designated or thecan be taken to protect tviable condition. BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources wanother use which would authorized officer must fother use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

SUWA This ACEC must be designated if the BLM fulfills its FLPMA obligations to "give 

priority" to ACEC designation. The BLM well describes both the relevance and importance of this potential ACEC in Appendix H. (Vermillion Cliffs) 

There is no requirement preferred alternative. Thpotential ACECs be carrone alternative in the DR

potential ACECs. The raforward into the PRMP/F

The BLM Manual 1613.2of each alternative, the m

meets the planning criterpreferred alternative reflemanagement of ACECs.

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for the various alternativcomparison of estimated leads to development anShould BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being propsuch as wilderness and w3. The manager has coneither because of exposuarea is designated or thecan be taken to protect tviable condition. BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources wanother use which would authorized officer must fother use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

SUWA This ACEC must be designated if the BLM fulfills its FLPMA obligations to “give 

priority" to ACEC designation. The BLM well describes both the relevance and 

There is no requirement preferred alternative. Th

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Commentor Comment C

importance of this potential ACEC in Appendix H. (Welsh’s Milkweed) potential ACECs be carr

one alternative in the DRpotential ACECs. The raforward into the PRMP/F

The BLM Manual 1613.2of each alternative, the mmeets the planning criterpreferred alternative reflemanagement of ACECs.for the various alternativcomparison of estimated leads to development anShould BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being propsuch as wilderness and w3. The manager has coneither because of exposuarea is designated or thecan be taken to protect tviable condition. BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources w

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another use which would authorized officer must fother use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

SUWA The BLM must take a hard look at resource damage (direct, indirect and 

cumulative) that may be incurred with each route. 

The process used to desAppendix K was used to chapter 4 addressed the does not require analysis 

impacts of the identified RMP/EIS on pages 4-18

SUWA This ACEC must be designated ifthe BLM fulfills its FLPMA obligations to "give 

priority" to ACEC designation. The BLM well describes both the relevance and importance of this potential ACEC in Appendix H. (White Cliffs) 

There is no requirement preferred alternative. Thpotential ACECs be carrone alternative in the DRpotential ACECs. The raforward into the PRMP/F

The BLM Manual 1613.2of each alternative, the m

meets the planning criterpreferred alternative reflemanagement of ACECs.for the various alternativcomparison of estimated leads to development an

Should BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being prop

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such as wilderness and w3. The manager has coneither because of exposuarea is designated or thecan be taken to protect tviable condition. BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources wanother use which would authorized officer must fother use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

SUWA BLM must take a hard look at resource damage that may be incurred with each 

route. (White Cliffs) 

The process used to desAppendix K was used to chapter 4 addressed the 

does not require analysis 

impacts of the identified RMP/EIS on pages 4-18

SUWA This ACEC must be designated if the BLM fulfills its FLPMA obligations to "give 

priority" to ACEC designation. The BLM well describes both the relevance and importance of this potential ACEC in Appendix H. (Parunuweap Canyon) 

There is no requirement preferred alternative. Thpotential ACECs be carrone alternative in the DR

potential ACECs. The raforward into the PRMP/F

The BLM Manual 1613.2of each alternative, the m

meets the planning criterpreferred alternative refle

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management of ACECs.for the various alternativcomparison of estimated leads to development anShould BLM choose not provides direction in this potential ACEC in the prfor the decision not to prforth. Such reasoning m1. Special management because standard or routhe Relevance and Impodamage/degradation. 2. The area is being propsuch as wilderness and w3. The manager has coneither because of exposuarea is designated or thecan be taken to protect tviable condition. BLM ACEC guidance (AProcedures Guidelines, to exercise discretion nobut that decision has to bmanager decides to provspecial management, the management proposed. Record of Decision and allocate the resources wanother use which would authorized officer must fother use; that the public of use appropriate with Athe present and future neto such other use will incminimize, mitigate or resrequirements will be spe

SUWA The BLM must take a hard look at resource damage that may be incurred with The process used to des

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each route (including direct, indirect, and cumulative impacts). (Parunuweap Canyon) 

Appendix K was used to chapter 4 addressed the does not require analysis 

impacts of the identified RMP/EIS on pages 4-18

SUWA The BLM's reasonably foreseeable development (RFD) scenario is arbitrary and 

capricious and ignores historic development trends in the planning area. 

The commentor does no

reasonable foreseeable not only based on historieconomic trends and advthe best available data to 

SUWA Throughout the environmental consequences section, the BLM fails to perform 

an adequate analysis for recreation management pursuant to NEPA. 

The BLM performed an adescribed in Chapter 3, tKanab RMP. In addition, information to incorporat

SUWA The DRMP/EIS Failed to Analyze the Impacts ofClimate Change to the 

Resources of the Kanab Field Office. This oversight amounts to a failure to take 

the necessary "hard look" at the challenge of resource management in the Kanab Field Office. 

A growing body of scientchange will result from thatmosphere. While uncemagnitude and regional 

evidence supports the viemissions will lead to climthe PRMP/FEIS. The EPA has not develoglobal climate change. WBLM will analyze potentiprepared for site-specific Chapter 4 of the PRMP/

SUWA The BLM should have discussed all of these predicted effects of climate in 

Chapter 3's assessment of existing conditions and in Chapter 4's discussion ofthe impacts of the various alternatives. A strong argument can be made that over the life of the RMP, no other factor will affect the resources of the Kanab Field Office more than climate change; it must figure as a prominent aspect of the future management ofthe area and BLM must demonstrate that it has begun to grapple with the management challenges that climate change presents. 

A growing body of scientchange will result from thatmosphere. While uncemagnitude and regional evidence supports the viemissions will lead to climthe PRMP/FEIS. The EPA has not develoglobal climate change. WBLM will analyze potentiprepared for site-specific Chapter 4 of the PRMP/

SUWA We have noted elsewhere that the EIS has not discussed the cumulative effects A growing body of scient

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of various uses like ORV recreation and grazing on, for example, riparian areas. These cumulative effects should also be considered in the context of climate change and how these uses act synergistically to impact the resources of the Kanab Field Office. 

change will result from thatmosphere. While uncemagnitude and regional evidence supports the viemissions will lead to climthe PRMP/FEIS. The EPA has not develoglobal climate change. WBLM will analyze potentiprepared for site-specific Chapter 4 of the PRMP/

SUWA NEPA requires BLM to "rigorously explore and objectively evaluate" a range of 

alternatives to proposed federal actions. See 40 C.F.R. §§ 1502.14(a) and 1508.25(c). Further, an agency violates NEPA by failing to "rigorously explore and objectively evaluate all reasonable alternatives" to the proposed action. City of Tenakee Springs v. Clough, 915 F.2d 1308, 1310 (9th Cir. 1990) (quoting 40 C.F.R. § 1502.14). This evaluation extends to considering more environmentally protective alternatives and mitigation measures. See, e.g., Kootenai Tribe of Idaho v. Veneman, 313 F.3d 1094, 1122-1123 (9th Cir. 2002) (and cases cited therein). 

The CEQ regulations (40 alternatives, which would quality of the human envin the case (CEQ 40 Momanagement prescriptiodetermine a reasonable 

concerns, and alternativeessential in this process 

alternatives identified. 

SUWA The BLM should not designate routes open to motorized use based on the 

existence of unproven claims under R.S. 2477. 

The RMP does not adjudclaimed ROWs. The BLM elements of this RMP thracknowledged administr

SUWA This DRMP/EIS does not provide equal recreational opportunities for nonmotorized uses - or even try to move toward some semblance of balance. Motorized and non-moto

planning process. The D

resource values are protmotorized access and re

SUWA Under the plain language and intent of these provisions, the BLM has not 

provided a reasonable range of alternatives for the designations of SRMAs and RMZs to sufficiently address the aforementioned increasing damage caused by ORV use, including conflicts between recreationists. 

The BLM used the scopireasonable range of altealternatives identified by (including the No Action 

considers various levels the public the ability to fuprescription or action. 

SUWA The Kanab Field Office has failed to take a hard look at the impacts of motorized 

uses in designated SRMAs. For example, the DRMP/EIS discusses potential impacts to soils from the designated SRMAs in the preferred alternative (B) 

The impact analysis of O4.2.5 of the Draft RMP/E

SUWA BLM should develop and choose an alternative that manages a significant portion 

of the planning area as non-motorized. BLM should also take the requisite hard 

Under the Proposed RMmanagement zones for n

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Commentor Comment C

look at impacts from the designated SRMAs and lack of SRMAs before moving forward. This hard look should naturally include the new alternative with more specific non-motorized use in SRMAs in order to be in compliance with NEPA, the CEQ regulations, and case law. 

non-WSA lands with wildRMP. Under FLPMA’s multiplevalues and uses on publobjectives for each of thoaccomplish those objectnecessarily manage evemany different values an

SUWA BLM should choose Alternative C rather than the preferred alternative in order to 

better protect the planning area from damage caused by large events. The factors weighed before an SRP is issued should be further defined, with clear guidelines. The Kanab Field Office should also consider using the model provided by the Price Field Office DRMP/EIS for classification of SRPs to show what uses may be appropriate/inappropriate in what areas. 

The criteria recommende

Draft RMP/EIS on page to changing nature of the location of the gathering

outside of WSAs could losimilar gathering near a 

SUWA There are several factors the BLM should always take into account before an 

SRP is issued. The DRMP/EIS for management of a particular area provides the ideal forum to list such factors by which each SRP should be weighed in future actions. At a minimum, the DRMP/EIS should address the following : • Duration of permit - all permits should be limited to a temporary and short term activity. SRPs should only be issued on a one-time basis and should not be extended to last for an inordinate amount of time. For example, a ten-year SRP would be an abuse of discretion on the agency's behalf. • Number of vehicles permitted -the DRMP must include a limit on the number of vehicles, and description of the type of vehicles that would be considered for specific areas in which SRPs would be considered in order for the decisionmaker to assess the potential for damage to environmental and cultural resources. • Type of vehicles - the BLM should delineate these categories and the number permitted by type before an SRP is needed. Different categories of vehicles (e.g., kayaks, motorized boats, mountain bikes, dirt bikes, ATVs, high clearance jeeps ("rock crawler")) have different impacts and require different management prescriptions. However, the current DRMP/EIS does not define what constitutes a ''vehicle'' for the purpose of SRPs • Number of persons permitted - a threshold should be set for how many people within a group will trigger the need to apply for an SRP. Even without vehicles, large group activities can have a significant impact on environmental and cultural resources. Thus, management of such events will need greater attention/restrictions in order to mitigate these impacts. • Location of SRPs - the DRMP/EIS should specifically identify areas that are not appropriate for the issuance of SRPs. Such areas should include Wilderness, Wilderness Study Areas, non-wilderness study area lands with wilderness characteristics, riparian areas, and any lands that currently are being evaluated or managed for their primitiveness and sense of solitude. Conversely, there should also be locations 

The Federal regulations govern the issuance of SHandbook H-2930-1, an

SRPs on various categolevel when issuing a SR

be considered when issu

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identified where SRPs may be acceptable. This can be done through the designated of SRMAs/ERMAs, using the ROS as a baseline. • Number of permits per year - there should be a cap on how many SRPs may be issued within a specific area. This can be done through the designated of SRMAs/ERMAs, using the ROS as a baseline. Limiting the number of SRPs will help the Kanab Field Office implement its policy of better prioritizing uses associated with SRPs by only permitting activities that fit squarely with the best management of each area. 

SUWA Vast tracks of BLM lands were arbitrarily and/or capriciously omitted from WSA 

designation for various reasons not in keeping with FLPMA's mandate. These errors and omissions made it impossible for the BLM to fully account or the extent of the wilderness resource during its FLPMA mandated wilderness inventories. 

The BLM does not have planning process. The BLM’s authority for mcharacteristics is derived 

This section of BLM’s orto manage public lands fsection constrains the Se“achieve integrated conssciences.” (FLPMA, Secmakes it clear that the tefor every acre of public lause of the land for some large enough to provide (FLPMA, Section 103(c) Secretary of the Interior resource use, including wresources in a way that pThe BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District Clands it determined to hasimilar to the manner in 

SUWA We are deeply troubled that BLM, by condoning trespass and impairment to our 

public wild lands, is taking the extreme position that the federal government will tolerate damage to our public lands and that those who damage our public lands can do so without fear that BLM will enforce the law. Such a position is contrary to law and BLM policy and must be reversed. 

Law enforcement is outs

enforcement presence is require a specific plannin

SUWA Recommendation: We strongly urge BLM to take immediate action to enforce the 

law and remove the illegal Kane County road signs from the wilderness study areas and other public lands (this would also apply to any Garfield County signs if that county posts such signs). In addition, the RMP should state that BLM shall 

Law enforcement is outsenforcement presence is require a specific plannin

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immediately remove all signs that conflict with BLM's travel management decisions. 

SUWA The BLM should adopt the approach to management set out in IM ID-2008-016, 

including creating a baseline of conditions in the WSAs, setting out a detailed monitoring program, incorporating standards for determining if use of these ways is impairing wilderness values, and committing to take measures to end any such impairment immediately, including through closure and restoration of ways. 

The IM cited by the comlands in Idaho and not URMP. 

SUWA The range of alternatives analyzed in the RMP Draft EIS is insufficient. There's 

almost no variability among the four alternatives presented, in terms of the proportion of the planning area being open for both motorized recreation and for oil and gas development. The so-called protective alternative is the only one with a notable difference and even this alternative opens the majority of the planning area for oil and gas drilling and off-road motorized recreation. 

The CEQ regulations (40 alternatives, which would 

quality of the human envin the case (CEQ 40 Momanagement prescriptiodetermine a reasonable 

concerns, and alternativeessential in this process alternatives identified. 

SUWA Recommendations: The BLM must measure and account for changes in nonmarket values associated with the level of off-road motorized recreation, oil and 

gas drilling and other development proposed in this RMP. To do otherwise omits a very important socioeconomic impact that is the direct result of management actions. The BLM must assess the non-market economic impacts on the owners of the lands in the Kanab Field Office - all Americans. This analysis must include 

the passive use values of undeveloped lands such as the lands with wilderness characteristics. 

The non-market values tBLM. The studies of whwilderness, the results olands”. Even if the studithe impacts are irrelevancurrent planning effort. Tare generalizable to nonFLPMA Section 202, (c) “In the development and the extent it is available their resources, and otheThe BLM does recognize managing for wilderness 

SUWA Recommendations: The BLM must collect and analyze actual data on the 

economic impacts of the alternatives, including Alternative E. Some suggested analyses and sources of data can be found in "Socio-Economic Framework for Public Land Management Planning: Indicators for the West's Economy" (attached). 

The commentor offers no 

does the commentor proThe commentor suggestmethodologies outlined iManagement Planning, psources described in this The Economic Profile SyBLM, aggregates many opublication. Similarly, B

sources as are included 

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The Wilderness Society understandably focused other hand, must take a mandate. 

SUWA Recommendation: The BLM must collect accurate data on actual recreation use 

of the Kanab Field Office, including data on the impacts (environmental, social and economic) of recreation use. Until an accurate assessment of actual use and impacts can be made the BLM should err on the side of caution and restrict offroad motorized use. 

The commentor offers no 

does the commentor proThe Draft RMP/EIS is ba(RMIS) data collected by Draft RMP/EIS, "It is imponly estimates and do nospecific activities in specfacilities such as traffic cis focused on areas of ga result of the remote nafrequent monitoring. In a

designated and there is amount of recreational u

recreation data is noted to compile baselines and An adequate range of altanalyzed in the Draft RM

SUWA Recommendations: BLM must develop recreation management directives which 

reflect the proportional use of the area by non-motorized and/or non-OHV users. BLM must collect and analyze more thorough and accurate data on the costs of off-road motorized recreation in order to make an accurate assessment of the impacts of the alternatives. BLM must recognize that increasing off-road motorized recreation implies the need for increased restrictions, and increased law enforcement, not opening more land for open cross-country travel. 

The comment does not p

support this assertion. Timpacts of recreational uvehicles. A discussion of Social and Economic En

SUWA The use of IMPLAN is insufficient to predict future economic impacts from the 

management of the Kanab Field Office lands. While the IMPLAN model can be useful as a tool to develop static analyses of the regional economy, the agency and local communities must be aware of the shortcomings and poor track record of the model as a predictive tool. IMPLAN models do not consider the impacts of many important variables that affect regional growth in many rural communities, especially in the West. Attributes such as natural amenities, high quality hunting, fishing and recreational opportunities, open space, scenic beauty, clean air and clean water, a sense of community, and overall high quality of life are not measured or accounted for in IMPLAN models, however these amenities are associated with attracting new migrants as well as retaining long-time residents. 

IMPLAN is a regional ec

accounting of the flow of The model was used to d

the Draft RMP/EIS. The RMP/EIS was complimesocial attributes the com

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Many residents of Western communities (both longtime and new) earn retirement and investment income, and while it is technically possible, most IMPLAN models completely fail to consider the important economic role of retirement and investment income. 

SUWA Recommendations: The BLM must collect and analyze credible data on all 

sectors of the economy, especially investment and retirement income and recreation (including nonmotorized recreation). These sectors, along with the various sectors which depend indirectly on the protection of public lands from motorized recreation and development must then be included in a quantitative assessment of the impacts of land management decisions. 

The commentor’s premis

to public lands to such afrom relocating to, or staassertion that the BLM’s unsupported by any speThe commentor’s assertplanning area is completagrees that some retireemaintains that its planninactually preserve and enThe BLM is unaware of aand its components in a which could predict chanaction alternatives. 

SUWA The Kanab draft RMP fails to address these threats adequately, therefore 

violating Endangered Species Act. requirements that federal agencies must avoid jeopardizing and promote conservation of listed species. 

The proposed plan provimanagement prescriptionotices have already undto implementing the propcompleted and any additbe included as committenecessary section 7 con

SUWA The draft RMP fails to provide adequate protection for suitable Utah prairie dog 

habitat (both unoccupied and occupied) by failing to curtail land uses deleterious to prairie dogs and their habitat. The primary land uses at issue are livestock grazing, oil and gas drilling and exploration, and OHV use. 

The current managemenconservation measures aFWS. Section 7 consultpast and it was determinthe necessary protection managed according to thmanagement for "desired special-status species" (currently (2008) being reUSFWS. As noted in the "Implement Recovery Plincrease populations and federally listed species, bpotential habitat." 

SUWA Th BLM preferred alternative travel plan includes high route density across the Appendix K of the Draft 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

planning, and wanton designation of redundant routes devoid of clear purpose and need to the very real detriment of non-motorized recreation and resource preservation. 

criteria used to identify roUnder FLPMA’s multiplevalues and uses on publobjectives for each of thoaccomplish those objectnecessarily manage evemany different values an

SUWA The DRMP/EIS does not present this information with respect to the differing 

travel networks under consideration in the DRMP/EIS. There is no way for a reviewer to identify the basis for the specific route designations proposed or confirm that the BLM has ensure that these designations comply with the legal and policy obligations set out above. 

Appendix K of the Draft 

criteria used to identify rodesignated by an interdisK of the Draft RMP/EIS. 

SUWA In order to justify the suitability of the proposed route network, the BLM must 

provide information on the reasons for designating the routes (i.e., destination, use), impacts of the routes on other resources, how those impacts can otherwise be mitigated or avoided, and the manner in which designation of the route for the proposed use is consistent with the agency's obligations under its regulations and 

policy. 

The routes were designalisted in Appendix K of th

includes a description of in the route system. 

SUWA The Kanab Field Office should ensure that scenic value is a resource that will be 

conserved and must establish clear management direction describing areas inventoried and possessing high scenic importance with clearly defined objectives that limit surface disturbance within important viewsheds. 

The BLM has designated the DRMP/EIS. The scemanagement classes by 

SUWA The East Fork of the Virgin River, through Parunuweap Canyon, has been found 

eligible with the classification of "wild" (Segment 37-40a). DRMP/EIS 2-104. The preferred alternative would downgrade this classification to "scenic," perhaps to allow the BLM to add some facilities along the primitive way through this section. However, this section is already within a WSA, and as such, should be managed to the IMP standard. SUWA urges the BLM to classify this section as ''wild,'' which is appropriate within a WSA. 

Appendix G of the Draft classifying this segment segment could create co

SUWA We emphasize that continued motorized use in WSAs (i.e. "open" areas and on 

"ways" BLM proposes to designate as official ORV routes) can damage wilderness suitability and therefore should be prohibited in this DRMP under both the interim management policy and the ORV regulations. 

The IMP allows for contiphase. The IMP does nodescribes impacts from t

SUWA The proposed "open" ORV designation within the sand dunes portion of the 

Moquith Mountain WSA is inimical to IMP management. BLM must account for soil, riparian, wildlife, vegetative, and T&E species impacts at the dunes which according to the IMP should cause the BLM to stop this use - not propose to legitimize it in the RMP. BLM must also take into account its own surveillance 

reports and other documentation regarding impacts to wilderness values in the WSA, and ensure that concerns which flow from those documents are 

The IMP allows for open ways in WSAs during the opened or closed. ChaptOHV ways and routes in characteristics. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

addressed. 

SUWA The DRMP/EIS provides for designation of "routes" in the WSAs. DRMP/EIS, 

p.2-43. In order to comply with the IMP, any designations should refer only to ''ways,'' rather than routes. 

The Proposed RMP/Fina

in WSAs. 

SUWA These portions of the RMP set out an appropriate summary of the standards for 

managing WSAs and how those standards should apply to permitting continued use of ways in WSAs. However, the analysis and management approach set out 

in the RMP do not comply with these standards. 

The RMP is in compliancways and trails or within impairment criteria. The ways or use off of the waanalysis in Chapter 4 of to wilderness characterisdisqualify these lands fro

SUWA This conclusion is not supported and is contradicted by the analysis of impacts in 

the DRMP/EIS and accepted science. Further, there is no acknowledgment of the important benefits to biological or environmental characteristics from closing WSAs to ORV use in the RMP's description of management of WSAs. 

The OHV open area in thuse since during the initibeen in use without impainventoried. Chapter 4 of environmental and biologThese closures are the r

resource uses, including 

SUWA Recommendations: Leaving any portion of WSAs open to cross-county ORV use 

violates the BLM's obligations under both the IMP and the ORV regulations to protect wilderness suitability. There should be no open areas in the WSAs. 

The OHV open area in thuse since during the initibeen in use without impainventoried. 

SUWA In order to ensure ongoing protection of the wilderness characteristics in the 

WSAs, the Preferred Alternative should provide for the WSAs to be managed to protect wilderness characteristics in the event that all or part of any WSA is released by Congress. 

The WSAs are managed 

designate these areas aIn the event Congress rere-evaluated on a case-b

SUWA Despite the accepted and readily available scientific study and methods, the 

Kanab DRMP/EIS fails to conduct a sufficiently detailed analysis of fragmentation, which impairs the consideration of impacts of the various 

alternatives and prevents an informed comparison. 

Based on reasonably for

for other potential land u

fragmentation contained sufficient to describe the 

SUWA As in the discussion special status species, there is no analysis of the actual 

fragmentation of habitat that is likely to occur using standard metrics or a thorough discussion of individual species. While the data provided is relevant, it is not sufficient. Without this information, the BLM cannot fully assess the direct, indirect and cumulative impacts of the management alternatives, as required by NEPA. 

Based on reasonably for

for other potential land u

fragmentation contained sufficient to describe the 

SUWA In order to comply with the requirements of NEPA to conduct a thorough analysis 

of impacts of the management alternatives and to facilitate meaningful public participation and review of the DRMP/EIS, the BLM must thoroughly analyze the specific impacts of habitat fragmentation on affected species and provide a 

Based on reasonably forfor other potential land u

fragmentation contained sufficient to describe the 

138 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

comparison of the management alternatives, as described in detail above. This analysis should include the impacts of ORVs and motorized routes, as well as roads. 

SUWA The DRMP/EIS should be revised to give sufficient weight to the benefits to 

wildlife, including special status species, from managing areas to maintain wilderness characteristics, including by reducing fragmentation. The management alternatives, including the Preferred Alternative, should include managing more lands outside WSAs to maintain wilderness characteristics. 

The Proposed RMP has non-WSA lands with wild

Theodore Roosevelt Conservation Partnership 

Given the nature of leasing and the need for upfront comprehensive planning) it needs to be known during the RMP process how the Kanab Field Office will establish plans for mitigation) including detailed fish and wildlife monitoring and the use of adaptive management strategies to prevent, minimize or mitigate 

impacts of oil and/or gas exploration and development for future parcels offered for leasing, 

The Kanab Field Office w

and wildlife monitoring aminimize or mitigate impfuture parcels offered for proposed lease parcel. 

Theodore Roosevelt Conservation Partnership 

Therefore, we recomment that the Kanab field office should extend the comment period for the Kanab RMP DEIS to provide the public with adequate opportunity to express their concerns and recommendations. 

The BLM provided the pRMP/EIS, as required by 

1610.2(E)). The standard accordance with CEQ rethe BLM planning and N

provides a 90-day comm

review and comment on available, free of charge CD, and online. In additigroups or individuals to ecomment efforts. Finally, facilitate review of the Ka

Theodore Roosevelt Conservation Partnership 

We believe that the RMP is not adhering to Executive Order 13443, issued on Aug. 16, 2007 and Instructional Memorandum No. 2008-06 issued Nov. 12, 2007. (Available at: http://www.blm.gov/nhp/efoia/wo/fy08/IM2008-006.htm) 

The BLM is clearly adheIM is not a planning levestate, local and tribal govnon-profit organizations development of site specimportant that the BLM idongoing or under consid

coordinated approach to the missions, policies an

Theodore Roosevelt Conservation Partnership 

Under CEQ NEPA regulations, BLM must make use of all the best available scientific information to assess the effects of land management actions, including cumulative effects from existing, proposed, or foreseeable development projects in the resource management area. Referenced below are peer-reviewed scientific studies on the impacts on sage grouse, elk, and mule deer from vehicle traffic, roads, and oil and gas development. The information from these studies 

The BLM has use the bealternatives and analsyis could be considered. Adby the commentor, could 

139 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

should be incorporated into the FEIS. 

Theodore Roosevelt Conservation Partnership 

Given the long-term nature of energy development, the BLM should include a plan in the FEIS for compensating hunters for the loss of big game that might occur as a result of energy development. 

BLM manages public lancould adversely affect otRMP/EIS timing limitatiogame habitat. 

Theodore Roosevelt Conservation Partnership 

The Kanab DEIS fails to adequately address oil and gas development and how it can be conducted in a way that does not unnecessarily impact fish and wildlife and their habitats. 

Please see Appendix C 

oil and gas leasing and oSection 4.2.6 for the discwildlife and fisheries reso

Theodore Roosevelt Conservation Partnership 

We recommend that all areas of crucial fish and wildlife habitats available for oil and gas leasing and without NSO stipulations should have upfront planning prior to leasing to ensure that subsequent developments will be conducted 

responsibly. 

The Kanab Field Office w

and wildlife monitoring aminimize or mitigate impfuture parcels offered for proposed lease parcel. 

Theodore Roosevelt Conservation Partnership 

The DEIS fails to provide a commitment to adequate fund wildlife management, monitoring, and restoration for oil and gas development projects. In times of increasing pressure from energy development on our federal public lands, fish and wildlife management needs more funding, not less. 

The impact analysis assland use plan. Additionaon national priorities, ava

Theodore Roosevelt Conservation Partnership 

The BLM fails to show how it will work to maintain wildlife objectives set by the UT Division of Wildlife Resources (UT DWR). Any determination of areas available for leasing and the appropriate development of those leases should be done with careful consideration of wildlife management objectives set by the UT DWR. 

The Draft RMP/EIS Sectcooperatively with other Conservation and Develand wildlife species." Thmanagement objectives, 

is described in the Draft 

Thomas Forsythe Beyond that, anyone wishing to enjoy the viewpoints and landscape of the area 

below Thompson Point can do so on the one recognized Kane County road. No further motorized access is either necessary or warranted. This could be accomplished by including this area in the Kanab Community SRMA - NonMotorized Trails RMZ 

The Proposed RMP/EIS The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Thomas Forsythe The only actual road in this area comes off of Zion Rd and leads to a Kane 

County Water Conservancy water tank. None of the other trails are even claimed by Kane County. This even includes the former right of way for the highway - a road the county abandoned when Johnson Canyon was extended south to join Hwy 89. Notwithstanding that this former road now crosses private property, it remains on the BLM map as open to motorized use. The most egregious example of this affront to private property rights is the spur that leads across a pristine piece of high desert land near the water tower. This route crosses private property and dead ends at the boundary between the private land and public land. 

Routes in the area below interdisciplinary team ac

RMP/EIS. Changes were Proposed RMP/Final EIS

Thomas Forsythe During this more careful review, it should also be considered that this area Routes in the area below 

140 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

contains three spurs that lead to the base of Thompson point within 1/4 of a mile. 

These spurs lead to what is essentially the same viewpoint as the single Kane County road in the area. They provide no additional recreational opportunity than what is available through riding the well maintained county road. 

interdisciplinary team acRMP/EIS. Changes were Proposed RMP/Final EIS

Thomas Forsythe Furthermore, each of these spurs has become the launching pad for additional 

spurs, some of which I witnessed being created by rambunctious neighborhood teenagers who destroyed vegetation and destabilized sensitive hillsides in their efforts at 'finding their own way.' Once those trails were established, the children moved on to destabilize new areas, leaving behind dead foliage and new two tracks that the BLM now appears intent on legitimizing despite their lack of 

destination and their redundant nature. 

Routes in the area below interdisciplinary team acRMP/EIS. Changes were Proposed RMP/Final EIS

Tim Peterson Please establish and implement a schedule to completely survey your field office 

for cultural resources. In areas of known conflict, protection of cultural resources should take precedence over other activities including off-roading. 

Setting a schedule for cowould require an long-tedecisions are outside the Cultural Resource Decispriority for proactive Secconflict. Concerning cultu

comply with its Section 1and BLM IM-2007-030 (CHighway Vehicle Design2007-030, cultural resou

vary depending on the eexpected density and nainformation. A. Class III inventory is nuse of an existing route; an open area or travel roarea open. B. Where there is a reas

concentrate or expand tradversely affected, Clason areas where adverse C. Proposed designationrequire Class III inventorSection 106 prior to desiwith Section 106 will also as staging areas or similD. Class II inventory, or probability model, followspecific projects, may be information is currently a

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

The SHPO concurrence Proposed RMP/Final EIS 

Tim Rasmussen Sheep Springs Road, Four Mile Creek Road and Kanab Creek are all areas with 

existing roads. These roads are machine-made and should not be considered a wilderness area. 

As part of BLM’s wildern

performed a combination inspections, InterdisciplinBLM GIS data, and highof the high-standard appfindings, particularly the inventory maintenance. 

Tim Rasmussen Do not limit group sizes to 25 vehicles. We often travel with groups larger than 

this and it would limit our enjoyment of this sport. 

The special recreation pdetermining if the permit

listed on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Tim Rasmussen Some of the statistics used for the RMP are flawed, such as Table 3-26 and 

should be eliminated. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

Timothy Zimmer The SRMA proposals should not exclude any user categorically. The SRMA boundaries a

the BLM land use plannirecreation investment, wand where recreation is 

have high levels of recre

Timothy Zimmer I reviewed Table 3-26 and agree with the “U4WDA” group that this cannot be 

based on reality since these areas are fairly remote and not used predominately by the specific user groups it implies. I would like to see the raw data or surveys that supposedly generated this mythical table, especially since it was contradicted in 4.1.6. 

Table 3-26 in the Draft Rinformation system (RMI

page 3-78 of the Draft Rin Table 3-26 are only esany given year for specif

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

visitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the As cited in Section 4.1.6best available data was Visitor-days are calcuatestandard BLM definition used among federal age

Tobin Gardner Please don't limit the group size to 25. The special recreation p

determining if the permitlisted on page 2-80. If a 25 people. On a case-byafter evaluation of possib

Tobin Gardner I believe the RMP user stats are not correct. Table 3.26 should be elimited. Table 3-26 in the Draft R

information system (RMIpage 3-78 of the Draft Rin Table 3-26 are only esany given year for specifvisitation monitoring facimonitoring by BLM staff Discrepancies in actual udecision area that does npopular use areas/trails accurately determine the 

As cited in Section 4.1.6best available data was Visitor-days are calcuate

standard BLM definition used among federal age

Tobin Gardner The roads I pray will remain open include: Rock Canyon Spur, (The Barracks) the 

Poverty Flat Road, (The Barracks) Virgin River Access Rd, (The Barracks) Hell Dive, (Moquith Mountain) Ed Lamb Point Road, (Moquite Mountain) Vermillion Route, (Thompson Point) Willis Canyon (Thompson Point) Block Mesa Route (Block Mesa). Sheep Springs, Four Mile Creek, and Kanab Creek all have existing machine made roads that have been around for many many years. It would be a shame to see this beautiful land closed. 

The routes in Sheep SprProposed RMP. 

Tom Carter In general, I would like to point out that it is counter productive to designate OHV 

routes without adequate oversight and enforcement since otherwise there is no way to enforce these plans. Therefore, I propose that all OHV operators who 

The commentor's recom

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Commentor Comment C

wish to operate within the resource area be required to apply for an annual use permit and the revenues created be used to fund enforcement of use of designated routes. Otherwise, the proposed plan exists only on paper and there would be no way to know if the designated routes and closed areas are being observed by OHVers. This population has an history of not obeying regulations and is not accountable either as individuals or by organizational ties. 

Tom Carter I live below the Thompson Point Archeological site located above my residence 

where I have hiked to observe the unique and irreplaceable Petroqlyphs over the past 10 years. And I have witnessed the steady illegal intrusion by OHVs into this area, creating a worn entry road that has at this time been developed to a point just below the arc site and has continued below as well making a illegal loop around the mesa that shelters the site. I suggest that barriers be constructed to block entry and that the two track illegal road be re- vegetated. 

An adjustment was maddevelopment of a public-

Tom Grant There should be more time in this comment period to address the areas of 

extreme importance to the future of this area. 

The BLM provided the pRMP/EIS, as required by 

1610.2(E)). The standard accordance with CEQ rethe BLM planning and N

provides a 90-day comm

review and comment on available, free of charge CD, and online. In additigroups or individuals to ecomment efforts. Finally, facilitate review of the Ka

Tom Grant The Squaw Trail. Under the proposed plan "B" the top of this trail would be 

opened to ATV traffic. Although it is currently closed, I see regular evidence of ATV use. This includes tracks not limited to an old road heading out to the "bench" and the Kanab Overlook, but tracks all over the top of the plateau, without regard to any trails. 

OHV use in Hog Canyon designated by an interdisK of the Draft RMP/EIS. system due to resource 

Tony Wright All of the roads that lead down to the Virgin River, below the Barracks, in 

"Alternative B", are proposed to be closed. This will eliminate all the accesses for anyone to see the beautiful Virgin River as it winds its way down the canyon through the White Cliffs. 

The Rock Canyon route RMP/EIS. The Proposed identified way open to O

Tony Wright You may say that hikers will visit this area. But they will have to travel about 15 to 

20 miles in an O.H.V. before being able hike to the river on the Poverty side of the Virgin River. It would eliminate the general public from seeing one of the best Indian Pictographs in our area, because of the hike into them, about 3 miles one way. 

The Proposed RMP/EIS 

identified way open to Oin the Proposed Plan du

Tony Wright On the south side of the Virgin River, you are proposing to close the Rock Creek 

accesses road. This road has been in existence for over 30 years, and I 

The Rock Canyon route RMP/EIS. The Proposed 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

personally traveled down this road in 1972 with a group of 10 people who were camping and sightseeing in the area in our O.H.V.'s. This is also, considered a RS2477 road claimed by Kane County. It is my understanding that a RS2477 road cannot be closed except by court order and there have been no cases in the court, to date, that have changed this ruling. 

identified way open to OThe RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Tony Wright This is the access that hikers use when they travel down Fatmans Misery 

Canyon to the Virgin River, they then travel up stream and come out at their 

O.H.V.'s at Rock Creek for the trip home. This closure would make them hike another 4 to 5 miles in the deep sand. It would also keep any handicaped people from seeing the great site off of the end of this road down to the Virgin. 

The Proposed RMP/EIS identified way open to O

Tony Wright I have heard from an employee of the B.L.M. that the Rock Creek road is being 

closed because there has been some damage to the area out on the end. Wouldn't it be better to put up a fence around the end of the road, so that people can not go any further than where the road ends? This seems like a better alternative than to close the road to everyone, who would like to enjoy it. 

The Rock Canyon route RMP/EIS. The Proposed identified way open to O

Tony Wright Hells Dive Canyon has some of the premier Indian drawings and Grinding Stones 

in this area, and to close them off from the public would be a crime. I would suggest that the B.L.M. use this area as an interpretive site, somewhat like the one in Indian Canyon where people could go and enjoy these great sites without damaging them. This should be a relatively easy project with help coming from both the Hiking and O.H.V. community. This would also keep another Kane Co. RS 2477 road open for public use. 

The Proposed RMP/EIS access for development The RMP does not adjud

claimed ROWs. The BLM elements of this RMP thracknowledged administr

Tony Wright All of the roads that lead down to the Virgin River, below the Barracks, in 

“Alternative B”, are proposed to be closed. This will eliminate all the accesses for any one to see the beautiful Virgin Riveras it winds its way down the canyon through the White Cliffs. You may say that hikers will visit this area. But they will have to travel about 15 to 20 miles in an O.H.V. before being able hike to the river on the Poverty side of the Virgin River. It would eliminate the general public from seeing one of the best Indian Pictographs in our area, because of the hike into them, about 3 miles one way. 

The Barracks/Rock Cany

the Draft RMP/EIS. The an identified way open to 

Tony Wright On the south side of the Virgin River, you are proposing to close the Rock Creek 

accesses road. This road has been in existence for over 30 years. This is the access that hikers use when they travel down Fatmans Misery Canyon to the Virgin River, they then travel up stream and come out at their O.H.V.’s at Rock Creek for the trip home. This closure would make them hike another 4 to 5 miles in the deep sand. 

The Barracks/Rock Cany

the Draft RMP/EIS. The an identified way open to 

Tony Wright Hells Dive Canyon has some of the premier Indian drawings and Grinding Stones 

in this area, and to close them off from the public would be a crime. I would suggest that the B.L.M. use this area as an interpretive site, somewhat like the one in IndianCanyonwhere people could go and enjoy these great sites without 

The Proposed RMP/EIS access for development 

145 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

damaging them. 

Tracy Hiscock The BLM RMP fails to implement the five Areas of Critical Environmental 

Concern (ACEC), that were nominated for the plan under the Federal Land Policy and Management Act (FLPMA), Title II, Section 202(c)3. 

Section 4.4.1 of Chapter probability of irreparable 

H of the Draft RMP/EIS i

proposed ACECs. The p1610.7-2, and BLM Man

Tracy Hiscock Clearly, this BLM RMP does not fulfill the legal requirements of either the 

National Environmental Policy Act (NEPA) or the Federal Lands Policy and Management Act (FLPMA). 

The Kanab RMP complielayers of adequacy revieState of Utah, and coope

Tracy Hiscock Many of the already existing ORV routes in the area lead to or go through 

archeological sites. By allowing such routes to continue, and by failing to assess the impact of motorized vehicles driving over these irreplaceable and scientifically 

important cultural resources, the BLM RMP falls short of fulfilling the legal requirements of NEPA and FLPMA. Furthermore, the existence of such routes also tempts motorized users to violate the Archeological Resources Protection Act. 

Cultural resources were consultation is being conresource inventory requi

the affect and nature of tnature of historic propertAppendix K. 

Tracy Hiscock It is my concern that the BLM has failed in its duties under these laws. The RMP 

will be in place for many years to come. It is the duty of the agency to follow the law, responsibly managing these lands and protecting them for future generations. 

The Kanab RMP complielayers of adequacy revieState of Utah, and coope

Tracy Hiscock Adequately fund resource protection and law enforcement programs. The agency 

already fails to control ORV use in Wilderness Study Areas or wilderness quality lands. 

Law enforcement is outsenforcement presence is require a specific plannin

Tracy Hiscock By adequately planning the ORV designated routes to avoid environmentally 

sensitive areas, • By improperly allowing construction of ORV staging areas, signs and routes without following federal rules imposed by the National Environmental Policy Act (NEPA), and • By failing to designate any areas as closed to ORV use and, consequently, primarily for hiking or equestrian use. This ignores a huge population of public land users to accommodate a smaller group of ORV users. 

Motorized and non-motoplanning process. The D

resource values are protmotorized access and rein the RMP, however this motorized use (e.g., equplanning. 

Tracy Hiscock The BLM RMP recognizes and allows use of numerous short, spur routes which 

lead to the boundaries of legislatively protected areas such as Wilderness Study Areas, Zion National Park, Bryce Canyon National Park, and Grand Staircase/Escalante National Monument, where continued motorized travel onto such adjacent lands is prohibited. All such spurs should be closed under the RMP because they only create opportunities for illegal behavior resulting in resource damage. 

The Proposed RMP has coordination with federal 

Tyler Kokjohn The draft plan also fails to include any meaningful discussion of monitoring and 

assessment methods that would support all adaptive management efforts. Instead we are informed that implementation or activity-level decisions “could be 

Identifying monitoring anplanning. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

adapted.” In addition, “future activity-level plans would follow NEPA guidelines and involve the public.” These are serious oversights in the draft and are not in accord with planning requirements detailed by the BLM itself. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page2-72, Section 2.4.1: We do not support Alternative B for the Moquith Mtn, Dunes RMZ. A requirement for research and monitoring of OHV impacts to both Welsh's milkweed and Coral Pink Tiger Beetle should be included in all alternatives. Research and monitoring is necessary to ensure accurate assessment of impacts, particularly from ongoing OHV use, and development and implementation of effective conservation management strategies. 

The BLM is required by Reiterating such a requirthe Conservation AgreemBeetle and the Welsh’s Mmonitoring and researchRMP/EIS by reference. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-72, Section 2.4.1: Alternative A indicates that the Sand Spring area would be designated closed to OHV use. Please clarify if Alternative B would maintain or expand use at Sand Spring. Also please clarify the extent and location of the conservation areas that are referred to in Alternative B. 

The Sand Spring area wroutes and not identifying 

RMP/EIS does not identcross country OHV use. from OHV use along rouVermilion MFP amendmUSFWS. These areas arthe administrative record 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-38, Section 2.4.1: Management of Riparian Areas (first row): Does the 

BLM have a list of "small" or "isolated" riparian areas that are considered suitable 

for divestiture? If so, it may be appropriate to list those under consideration in the document. Riparian areas, even ones that are small and/or isolated, are important for many species of Utah wildlife. Divestiture of these features should not result in their loss or degredation or result in the degradation of water quality within and downstream of the riparian areas. 

The wording in the Propo

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-38, Section 2.4.1: Management of Riparian Areas (3rd row): "As opportunities arise..." This statement implies that recovery and rehabilitation would not be considered a priority, and only occur as opportunities arise. Consider providing a stronger standard and commitment in the RMP toward restoration of riparian communities, particularly because of their high value to wildlife species throughout the State. 

The first sentence of the 

"prioritize rehabilitation emisunderstands the folloBLM would work with othworking with the holders "cooperative proposals." 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-39, Section 2.4.1, 2nd row: Reword as, "Do not allow new surface disturbing activities within a minimum buffer of 330 feet..." Protection of wildlife species, particularly during nesting or breeding seasons may require a larger spatial buffer than 330 feet. Similar wording should be added to all alternatives, and throughout the document. 

Language described by tPolicy (IM-UT-2005-091)for riparian zones. Mitigacase-by-case basis to bethe policies and proceduuses. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-40, Section 2.4.1: Management of Riparian Areas (last row): Remove the 

wording "to the extent possible" from the commitment to maintain sufficient water 

at springs. Many wildlife species rely heavily on spring habitats, and these features should always be retained. 

The language in the Draoften outside the BLM's 

adjudicating water rights

U.S. Fish and Wildlife Page 4-20, Section 4.2.2: In the Recreation (outside OHV use section), 1st The use of these termino

147 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Service, Utah Field Office 

sentence: replace "could result in soil compaction" with "would result in soil compaction." Simlarly, in the second sentence, replace "could" with "would." Check the entire document for similar terminology changes. 

writing of the impact anaadequate. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-20, Section 4.2.2: The RMP states: "Motorized activities in SRMAs could 

increase use on routes, which could indirectly protect nearby soils..." However, Alternative B indicates that the Dunes RMZ would be open use for OHV, rather 

than restricted to routes. Please provide more support of the reasoning behind this statement. 

The Draft RMP/EIS lang

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-10, Section 2.2.1, 3rd bullet: "...in managing listed species and their habitat." Add "sensitive species" or "special status species" to this sentence. 

The Proposed RMP/Fina

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-10, Section 2.2.1: Management Actions, Special Status Species Conservation and Habitat Enhancement, last line: Rewrite to read, "Apply lease notices and conservation measures to activities occurring in special status species habitat." 

The Proposed RMP/Fina

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-10 through 2-14 and Appendix M, Section 2.2.1, Special Status Species: Conservation measures included for the threatened, endangered, and candidate species should be the same as those included in the June 19, 2007 Biological Opinion for the Existing Utah BLM Resource Management Plans. It appears that Appendix M includes the correct measures. However, the wording on pp. 2-10 through 2-14 is sometimes inconsistent with Appendix M, and not as complete. This makes the document confusing upon initial reading. Recommend including either all of Appendix M up front in Chapter 2, or referring to Appendix M without attempting to include partial measures in Chapter 2. 

The Chapter 2 managembeen revised to reduce dConservation Measures 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-10 and 3-30, Section 2.2.1, Bald Eagles: The bald eagle has been delisted. However, eagles are still provided protection under the MBTA and Bald and Golden Eagle Act. We recommend moving the eagle discussion to the Fish and Wildlife or Migratory Bird section of the document. To ensure continued species conservation, we also recommend a commitment to the conservation measures agreed to in the aforementioned June 2007 biological opinion. 

The Proposed RMP/Fina

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-11, Section 2.2.1, Bald Eagles: The document states that monitoring will 

occur in order to document the impacts to bald eagles in their breeding or wintering areas. The RMP should also clearly commit to avoiding or minimizing impacts that monitoring detects. 

Management actions to developed during the imconditions. The Draft RMmeasures for migratory bTreaty Act of 1918 and t

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-11, Section 2.2.1, Bald Eagles: The "Utah Field Office Guidelines for Raptor Protection from Human and Land Use Disturbances" recommends a 1.0 mile buffer around bald eagle nests between January 1 and August 31. Although a 0.5 mile buffer may be appropriate for temporary activities at other times of the year, the 1.0 mile buffer should be used for permanent surface disturbances and during the bald eagle nesting season. 

The Chapter 2 managembeen revised to reduce dConservation Measures 

148 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

U.S. Fish and Wildlife Service, Utah Field Office 

Pge 2-11, Section 2.2.1, Utah Prairie Dog: The 1st sentence should require species occupancy and distribution information that is complete, available, and current. This is how it is stated in Appendix M, but needs to be written correctly in the document as well. All of Appendix M measures needed to be completely integrated into the document. 

The Chapter 2 managembeen revised to reduce dConservation Measures 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-13, Section 2.2.1: A comprehensive and ongoing monitoring program is a critical element in determining the status and conservation needs for the Siler pincushion cactus. We recommend establishing monitoring plots to assist with successful species management. 

Identification of monitorinoutside the scope of this 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-13. Section 2.2.1: In an effort to conserve and recover Welsh's milkweed, we recommend establishment of a designated conservation area for Welsh's milkweed on BLM lands. Consideration should be given to managing portions of the Coral Pink Sand Dunes as a SRMA and other portions as an ACEC with applicable recreational use closures to protect the species habitat from motorized use. Management should consider the shifting nature of the sand dunes and ensure that the designation of a protected area is large enough or adaptive to changing habitat conditions. 

An ACEC is not required OHV use in approximate

milkweed. Additionally, tuse. The decisions regarin the 2000 Vermilion Maforward into the proposethis management. Sectiwith the BLM manageme

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-13, Section 2.2.1: Monitoring for the past 10 years has shown that populations of the CPSD tiger beetle are in decline. Drought has probably been a primary factor in this decline. The RMP should clearly state that BLM will cooperate and facilitate recommendations from the CPSD tiger beetle Conservation Agreement technical team for ongoing monitoring, research, and conservation measures for this species. The 370 acre conservation area should continue to be monitored; adaptive management strategies may be appropriate given the shifting nature of the sand dunes. 

The Conservation Agree

RMP/EIS in Chapter 1 (p

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-15, Section 2.2.1, 1st paragraph: We recommend including the USFWS Raptor Guidelines as a Management Action in addition to the BLM BMPs. 

The Draft RMP/EIS specthe BMPs included in Ap

Guidelines For Raptor P(USFWS 2002) and provbuffers, if an established the BMPs, or specific elebe attached as Conditionpotential to adversely aff

become unsuitable for n

can be applied to any suactivities, where raptor n

Wildlife Service “Guidelinbuffers for BLM-authoriznesting raptors is ensureraptor species, as well athe highest level of prote

species would continue t

149 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Modification of the bufferconsidered pending resuService. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-15, Section 2.2.1, Wildland Fire Ecology: There should be an objective that includes protection and enhancement of threatened and endangered species and their habitats. 

Protection of threatened 

and wildland fire ecology FONSI/DR for the Utah LManagement and assocresource protection meacontained in the Draft RM21). 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-17, Table 2-1: Sagebrush: Areas with more than 30% sagebrush cover are described as "dense sagebrush" and are to be treated with fire and/or mechanical or chemical methods to reduce the canopy cover. Consideration should be given to species that desire greater densities of sagebrush cover and to maintaining a diversity of habitats. As such, some areas should have more than 30% sagebrush cover. 

The Draft RMP/EIS cont

2005 FONSI/DR for the Management and assocresource protection measagebrush habitats. Adddocumentation prior to im

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-44, Section 2.4.1: The Sand Hills located North of Kanab and East of highway 89 is designated as critical habitat for Welsh's milkweed. Restrictive protections, including OHV management, should be considered for this area, in order to prevent adverse modification of the critical habitat. It is difficult to determine from the RMP if such protections are established in Alternative B. 

The language on page 2Federally Listed and CanWelsh's milkweed designroutes in the Sand Hills pAlternatives B, C, or D. Timpacted by the presenc

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-44, Section 2.4.1, Special Status Species (1st row): "...a case-by-case basis..." We recommend evaluating surface disturbing on a landscape level (not only case-by-case project activities) to ensure the development and implementation of successful, long-term conservation and recovery strategies for special status species. 

The RMP makes landsca

completed to address lanfor the life of the plan (20 special status species is supported by the Ninth CKempthorne (No. 05-350

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-44, Section 2.4.1, Special Status Species Conservation and Habitat 

Enhancement (3rd row): For listed species, compensation of 1:1 for lost habitat is likely to be insufficient in most cases. Compensation would usually be greater than 1:1 due in part to the fact that the result would be a net habitat loss to the 

species even with mitigation. 

The Proposed RMP has action: "The BLM will apbasis where it can be peperformed offsite, or, in a

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-45, Section 2.4.1, Special Status Species Conservation and Habitat 

Enhancement (third row): For bald eagle nests, we recommend the seasonal 1.0 

mile buffer be implemented in accordance with the U.S. Fish and Wildlife Service (Service) Raptor Guidelines and the June 2007 Biological Opinion for the Existing Utah BLM Resource Management Plans. The seasonal buffers for the other raptor species are appropriate for temporary surface disturbing activities. Permanent disturbances, particularly those that ensue human activities, should be precluded year-round within the spatial buffers. 

The Draft RMP/EIS inclu2-10. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-47, Section 2.4.1, Last Row (Federally Listed and Candidate Plants): Please define the term "moderate constraints." BLM should recognize the potential that closed or NSO stipulations may be appropriate or necessary in special status plant species habitats. Alternative B should alow for major constraints (NSO) in special status plant habitat. 

Appendix C in the Propoexamples of surface stipstipulation is associated 

H-1601-1). 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-49, Section 2.4.1, Special Status Species and Fish and Wildlife Management Action sections: See Attachment 1 to this spreadsheet (FWS Species-Specific Recommendations for Use in BLM RMP Plannin Efforts, May 2003). Although these were prepared for the Price, Richfield, and Vernal Field Office areas, many of the recommendations are applicable to the Kanab Field Office area. We recommend incorporating applicable guidelines (particularly those for "All Species" into Alternative B, as the Preferred Alternative. Incorporation of these measures will also help to strengthen the management direction for migratory birds. 

The Draft RMP/EIS alrea

in the commenter's reco2003 document have beof the recommendations by the USFWS and the BAppendices B and M. Fin

plan level decisions. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-100, Section 2.4.1: Please check the acreage for Welsh's milkweed, Coral Pink Sand Dunes critical habitat throughout the document. Number stated on p. 2-13 is 790 acres. All of Coral Pink Sand Dunes is critical habitat for Welsh's milkweed. OHV use in sand dunes open to cross country use is indicated as 1,100 acres on page 2-111. A rough, but not accurate, estimate of Coral Pink Sand Dunes acreage outside of the state park is 1,280 acres. In addition, critical 

habitat for Welsh's milkweed includes the acreage encompassing the Sand Hills areas. Jointly both areas are indicated to contain 4,000 acres on page 3-34. Also, please indicated critical habitat acreage involved in Moquith Mountain SRMA, in particular Dunes RMZ p. 2-71. 

Most of the designated cCoral Pink Sand Dunes the RMP. The language Welsh's milkweed critica

clarify the relationship w

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-32, Section 3.2.6: Translocation of Utah prairie dogs should be listed as a 

specific management activity. The translocation program is mentioned on p. 3-33, but it's authorization under the RMP is not clearly stated. Additionally, "control of plague vectors" needs to be included as an authorized UPD activity in this plan. These two management activities for UPDs (translocation and control of plague vectors) should be documented in all sections related to the species. 

The Draft RMP/EIS specon page 2-46. Additionalpage 2-47. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-33, Section 3.2.6: The Coral Pink Sand Dunes tiger beetle (Cicindela albissima) has been determined to be a full species, not a subspecies of the tiger beetle Cicindela limbata (Morgan Knisley and Vogler 2000). 

The Draft RMP/EIS has 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-34, Section 3.2.6: The RMP states that the 2000 Vermilion Management Framework Plan amendment addresses management and protection of the Welsh's milkweed. Pleae clarify what conservation measures are included in this current RMP revision, and retained in the preferred alternative. 

All decisions from the 20RMP revision. All the deare described in Chapte

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-34, Section 3.2.6: Please update the document to include the most current available information. The area described in 2000 by Hreha and Meyer is no longer considered the most viable of all known populations. This population comprised less than 10 individuals in 2007, a loss of more than 90% of previously 

The Draft RMP/EIS has 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

known population levels. A monitoring program should be renewed at this past thriving population to determine if seedling recruitment still occurs, and if measures should be implemented to recover the population. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-34, Section 3.2.6: Please update the document with the most recent best available information. Monitoring in 2003 is not the most recent monitoring, nor is a comparison of stems between 2002 and 2003 (i.e., 2 years), a good indication of trend. Data collected by BLM should also include statistical verification for long-term trends. 

The BLM has use the be

alternatives and analysis Milkweed through 2005. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-34, Section 3.2.6: Please provide a brief summary regarding Welsh's milkweed populations in Arizona. 

The Arizona populations document. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-39, Section 3.2.6: Recent evidence indicates that the southern 

leatherside chub (Lepidomeda aliciae), the species in the Kanab FO area, is one of two taxa formerly known as leatherside chub (Snyderichthys copei) and qualifies as a unique species (Johnson and Jordan 2000, Dowling et al. 2002, Belk et al. 2005, Johnson et al. 2004). 

The Draft RMP/EIS has 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-39, Section 3.2.6:Other populations of Bonneville cutthroat trout exist within the KFO area. Refer to the Conservation Agreement for additional populations of introduced, reintroduced and core populations in the Southern Bonneville GMU: Upper Sevier, East Fork Sevier, and Upper Virgin HUC. 

Upon reviewing the ConCutthroat Trout in the StThree-Mile Creek. Other not on lands administere

U.S. Fish and Wildlife Service, Utah Field Office 

Page 3-84, Section 3.3.4: The document indicates that OHV use is resulting in 

impacts to resources at the Sand Hills and Coral Pink Sand Dunes areas. We therfore recommend that the RMP allow for the development and implementation 

of adaptive management strategies, including potential OHV use restrictions, in sensitive wildlife and plant habitats. Open use on all parts of these areas seems contra-indicated, as resources are already at risk. 

As noted in the Draft RM

2000 Vermilion MFP amcarried forward in the Prproblems in the Sand HiOHV use. None of the acOHV use to identified rouas described in Chapter 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-3, Table 4-2: The table does not include the Migratory Bird Treaty Act or EO 13186; these should be added to the table. 

Migratory birds found in 3-50 of the Draft RMP/EHandbook (BLM-H-1790

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-49 through 4-58, Section 4.2.5: Effects throughout the section are described generally, without relating to individual species. The exception appears to be the consistent reference and discussion for the Greater sage-grouse. It seems inconsistent that other special status species are not discussed more fully 

in the same manner that the Greater sage-grouse is discussed. Please provide 

full descriptions of effects to all special status species; use of species subheadings would assist readibility of the document. 

A Resource Managemenlevel; subsequent NEPA completed prior to implethat scoping be used to danalyzed in depth in the eliminate from detailed s1501.7). During the scopwere raised as an issue specifically identified as addressed it to a greater 

152 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-49, Section 4.2.5: This section should reference tables 3-12 (page 3-30), 3-13 (page 3-34, and 3-14 [migratory birds], which identify "species needing special conservation actions" (page 3-48)). Referencing these tables and the species within would provide readers with a consistent point of reference. 

The purpose of Chapter of the various resources context for the analysis ostatus species section of Chapter 4 is duplicative, described in CEQs NEPA migratory bird species arTherefore, creating such 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-50, Section 4.2.5, Impacts common to all Alternatives: The entire section is awkward -- it is difficult to discern if all activities/species have been evaluated for each alternative. Habitat alteration, fragmentation and/or loss is discussed relative to fire, ROW developments, and cultural resources, but fails to mention any other potential activity affecting habitat. For example, 48% of all acres would be open to oil and gas development under the preferred alternative, Therefore, it would be appropriate to list oil and gas development as an activity that would cause habitat loss, fragmentation and/or alteration. We recommend reorganizing by using subheadings for activities. 

The Draft RMP/EIS Cha

repetition of impacts from resource, use, or designalternative decisions from repetition and subsequeexample, organization usimpacts of potentially proprotective impacts from munder the ACEC section where the protective maresources. The commenimpacts under the Commdecisions vary to a great habitat alteration, fragmeresulting from potential oon page 4-58. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-51, Section 4.2.5: 2nd paragraph states, "...special status wildlife could seek alternative habitats." This section should also clarify that "alternative habitats" may be unsuitable or already occupied. 

The Draft RMP/EIS lang

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-56, Section 4.2.5, Alternative A: Only OHV use and Veg treatments are 

mentioned as activities that can cause displacement. There are other activities 

that should be included in this section -- e.g., grazing, recreation, oil and gas. 

The analysis on page 4-

potential to displace spe

dispersed recreation usegrazing, vegetation treat

defined in the glossary o

development and explor

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-57, Section 4.2.5, Alternative B, Habitat Alteration, Fragmentation, and/or Loss: This section appears to only evaluate impacts from OHV, oil & gas, forest/woodland products, and locatable minerals. Impacts to special status species and their habitats should be clearly described for all activities occurring on BLM lands. 

This section of the Spec

describes habitat alteratiimpact analysis describe (pages 4-57 to 4-60). Thdescribed on pages 4-49 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-57, Section 4.2.5, Alternative B, Habitat Alteration, Fragmentation, and/or Loss: The first paragraph states, "Managing OHV use...as limited to 1,387 miles...would minimize surface disturbances to special status species." We 

An analysis of the Alternand habitats is contained 

153 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

generally agree that less off-road use would reduce impacts to habitats. However, the document does not thoroughly evaluate 1) if/what special status species/habitats occur in the areas that will be open to OHV use, and 2) if/what effects will occur to those species/habitats. Please provide a thorough evaluation for each Alternative in Ch. 4. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-58, Section 4.2.5, Alternative B, Habitat Alteration, Fragmentation, and/or Loss: The 4th paragraph states, "...stipulations on disturbance in special status species habitats would decrease the potetnial for the impacts..." While this may be true, the section should also clearly describe the types of impacts that will still occur, e.g. habitat fragmentation. 

The impact analysis of o58 refers to the habitat fr53 to 4-56 of the Draft R

impact analysis for Alternthe comparison of the alt

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-59, Section 4.2.5, Alternative B, Displacement: "Impacts from dispersed recreation activitiy, mineral exploration and development, and ROW development would be the same as described in alternative A..." The Alternative A, Displacement, section does not include evaluations of these activities. See previous comment to 4.2.5 -- using activity subheadings would help clarify these sections. 

The analysis on page 4-such as cross-country Oand/or surface disturbansurface disturbance inclu

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-70, Section 4.2.6: There is virtually no discussion on the impacts to migratory birds from management actions. Activities requiring vegetation removal in particular warrant some discussion. BMPs to reduce impacts to migratory birds, including seasonal buffers and habitat mitigation, should be developed and included in the RMP (see ATTACHMENT 1 recommendations). These may include commitments to develop and implement a standardized rigorous program to collect data on species identified in the BHCAs; and work with UDWR and others to develop a comprehensive monitoring program. Suveys should be completed one breeding season prior to land disturbing activities. Conservation measures should minimize habitat loss/fragmentation, prevent loss of eggs and nestlings, reduce indirect effects (e.g., introduction of noxious weeds), and avoid surface disturbing activities during the passerine breeding season (May 15 - July 15). 

The impacts to migratory Fish and Wildlife Habitat 

the Draft RMP/EIS alrearecommendations to inclFinally, several of the rec

U.S. Fish and Wildlife Service, Utah Field Office 

Page 4-72, Section 4.2.6, Displacement (third paragraph): Oil on feathers of 

incubating birds will also kill developing embryos when adults are incubating eggs...it's not just ingestion; pits should be netted and propertly maintained to 

exclude migratory birds. 

The Draft RMP/EIS lang

U.S. Fish and Wildlife Service, Utah Field Office 

Page AB-4, Appendix B, Unoccupied Nests (last paragraph): The document states that "empirical evidence would suggest that the 3-year non-use standard has been effective in conserving raptor species." We recommend the Kanab FO retain the seven-year non-use standard for nest protection as stated in the Raptor Guidelines. This seven year standard may be adjusted on a site-specific basis, depending on raptor species and other site-specific factors. The Utah Field Office has produced a white paper, “Elapsed Time between Raptor Nest Uses” (Megown and Romin, 2006) that reviews recent literature and expert knowledge 

The 3-year non-use stanuse standard before decsimilar standard that has administrative areas withyear non-use standard hyear standard has been under the MBTA or the E

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

to assess raptor nest reuse frequency. The paper finds that of the 19 raptor species examined regarding nest occupancy, half (10) of them have data that 

show the elapsed time between nest uses can be 7 or more years. Golden eagles, bald eagles, and peregrine falcons in particular can have especially long periods (i.e. 10-20 years) of nest non-use followed by successful nesting. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page AB-8, Appendix B: The purpose of monitoring active raptor nests is more than simply documenting the impacts of an activity on the behavior and survival of raptors. The purpose of monitoring is to avoid impacts to raptors, particularly "take" of raptors (e.g., survival) which is an unlawful activity under the Migratory Bird Treaty Act. If monitoring detects an impact on bird behavior, especially one that might result in "take" the activity should be suspended or modified so that the impacts are removed. 

The paragraph on page impacts, but recognizes projects that could potenapplying BMPs and the r

the following language to behavior, especially one or modified so that the im

U.S. Fish and Wildlife Service, Utah Field Office 

Page AL-4, Appendix L: "The U.S. Fish and Wildlife Service has completed a biological opinion on the Proposed Action..." This sentence is confusing because formal section 7 consultation has not been initiated for this RMP. In addtion, this entire section seems contradictory with Appendix M. Species-specific conservation measures were developed during section 7 consultation on the existing RMPs (not the RMP revisions). In an effort to streamline section 7 consultation on the RMP revisions, we have recommended that BLM incorporate the same conservation measures into the RMP revisions. The Kanab RMP appears to include these conservation measures in Appendix M; therefore Appendix L should be deleted or updated to reflect the correct conservation measures. 

Appendix L of the Draft Rthe FONSI and Decision Fuels Management (200FONSI which amended tincorporated into the Kanwas completed for the 20opinion. Appendix M incl7 consultation on the eximeasures have been ap

consultation will be cond

U.S. Fish and Wildlife Service, Utah Field Office 

Page AM-1, Appendix M: Conservation measures should be developed and incorporated for federally listed plant species, including the Welsh's milkweed and Siler pincushion cactus. The Service is available to work with the BLM to develop these conservation measures. 

Lease notices for the Sildeveloped and are includ

These measures will be RMP. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page AM-12, Appendix ML: Lease Notices should be developed and included for KFO Federally-listed plant species, such as Welsh's milkweed and Siler pincushion cactus. Stipulations for plants have been developed for plant species at the Vernal BLM Field Office (for example, a 100 foot buffer is now required 

between surface pipelines and plant locations, rather than 10 foot indicated in the past). Attached are the two updated plant lease notices now used by Vernal Field Office (Attachment 2 and 3). The Service is available to work with BLM to develop these lease notices. 

The Draft RMP/EIS inclu

that would be included oFederally listed and candlisted species that would Additional protections woimplementation level to a

U.S. Fish and Wildlife Service, Utah Field Office 

Page AM-13, Appendix M: Include the Range-Wide Conservation Agreement and Strategy for Bonneville Cutthroat Trout (Oncorhynchus clarki utah) (2004). 

The Bonneville CutthroaConservation Agreemenin the Proposed RMP/FE

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-6: Restrictions on visually obtrusive developments VRM Class I and II is defined as limiting development and protecting special status species (page 4-61). Critical habitat for Welsh's milk-weed at the Sand Hills in Alternative B is 

As a multiple use agencythe variety of natural, cu

The BLM uses VRM Cla

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

VRM Class III. In Alternative C, a VRM Class II is indicated. We recommend implementing a Class I or II designation for all alternatives at Sand Hills, to ensure long-term conservation and recovery of Welsh's milk-weed. 

RMP/EIS describes the imanagement decisions, a result of other resource to protect special status resource management p

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-9: It is unclear if the Kanab Community, OHV RMZ encompasses Kanab Creek and, if so, what protections would be established for the stream and riparian area. Nearby upland landscape impacts also could affect these habitats. This reach of Kanab Creek is a historic site for the Kanab ambersnail and provides riparian habitat important for many species. We recommend appropriate buffers be established to protect the stream and riparian corridor from surfacedisturbing activities (including OHV use). 

The Kanab Draft RMP/Edisturbing activities withi

Kanab Community OHV surface disturbing activitsurface uses and disturbdisclosed in section 4.2.4water resources in the D

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-13: The Kanab Community, OHV RMZ is located near Sand Hills, which provides habitat for the listed Welsh's milkweed. The document should evaluate the potential for the OHV RMZ open area to influence OHV use in the Sand Hills. We further recommend establishing OHV impact monitoring at Sand HIlls. 

As noted in the Draft RM

2000 Vermilion MFP Amcarried forward in the Prthe problems in the Sand country OHV use. None limiting OHV use to idenprotected, as described 

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-13; page 4-57 thru 4-61: Alternative B includes open OHV use in Coral Pink Sand Dunes and limited trail use in the Sand Hills. We recommend BLM evaluate areas that support dense concentrations of Siler pincushion cactus and Welsh's milkweed for effects from OHV use, and consider OHV restrictions or removal in these areas if warranted. The RMP should specifically commit to ongoing monitoring and evaluation of OHV impacts to these species. We further recommend designating a conservation area at Coral Pink Sand Dunes that is closed to off-road vehicle use, in accordance with the Welsh's milweed Recovery Plan. 

In Alternative B of the Dr

concentrations of or habpincusion habitat is limitemilkweed from OHV use milkweed conservation aclosed to OHV use in the consultation with the USadequate protection of th

U.S. Fish and Wildlife Service, Utah Field Office 

Maps 2-17, 2-20, 2-24, 2-30: We recommend that Welsh's milkweed critical habitat areas (the Coral Pink Sand Dunes and Sand Hill) and areas occupied by Siler pincushion cactus be designated as no surface occupancy. We recommend these areas be closed to mineral material disposals and have no new rights-ofway. 

Welsh's milkweed critica

in the Proposed RMP/Finand gas leasing due to Wpincusion cactus have bAppendix 9 of the Propo

U.S. Fish and Wildlife Service, Utah Field Office 

Map 2-34: The mineral leasing status is unclear for the areas that support Siler pincushion cactus and Welsh's milk-weed. We recommend that these areas be designated either closed or NSO to provide protection for these species. 

Map 3-18 of the Draft RM

Field Office. There are nmilkweed habitat. 

U.S. Fish and Wildlife Service, Utah Field Office 

Map 3-4: The map showing "Areas with fragile soils or relict vegetation" should include Welsh's milkweed and Siler pincushion cactus habitats. Please revise accordingly. 

The Siler pincushion cacidentified relict vegetatio

U.S. Fish and Wildlife Service, Utah Field 

Page 2-42, Section 2.4.1, Vegetation Restoration Treatments (first row): Under the preferred alternative, up to 80% of the total acres would be treated over the 

The management action 

22,300 acres a year is d

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Office life of the plan (4% x 20 years). This time frame (20 years) may not allow 

sufficient time for vegetative communities to develop a full range of age classes and diversity, depending in part on the habitat type. This is especially true for long-lived species and for maintaining old growth. Consider removing the minimum requirement for vegetation treatments and allowing managers to implement appropriate acreages given habitat and climatic circumstances. 

vegetation treatments. ADraft RMP/EIS, the treatamount of acres that wo

on the ecological threshoon the research describesummarized in Table 3-8 year planning window fodisturbance regimes. 

U.S. Fish and Wildlife Service, Utah Field Office 

Page 2-43, Section 2.4.1: Alternative B, consider adding the following factor: "Restore special status species habitats to achieve long-term conservation and recovery objectives." 

The Proposed RMP/Fina

U.S. Geological Survey 

Vegetation treatment actions have been well thought out in this draft RMP/EIS. Specifically, Table 2-1 (pp 2-16 to 2-19) nicely summarizes actions by major vegetation group. It is suggested that the final document add language that restricts seeding operations to microsites with the greatest probabilities of success. Significant time and resources have been invested in failed seeding projects on arid lands; some of these failures might have been prevented by better tailoring of treatment prescriptions by site quality. The public would also benefit if the final RMP/EIS discussed whether BLM plans to aggressively suppress wildfire, when possible, on sagebrush sites to minimize mortality to sage plants that had previously been subjected to frequent fire. This is important because most sage species cannot tolerate frequent, repeated fire. 

Detailed fire decisions arManagement Plan Envirseeding operations are a 

site-specific NEPA analyRMP/EIS are designed tconditions over the life o

U.S. Geological Survey 

The Fire Regime Condition Classes (FRCC's) may not be as well defined for sage biome and other arid lands as they are for coniferous forests. It would benefit the public if the final RMP/EIS identified target vegetation descriptions in addition to FRCC's metrics of when to implement various treatments. (p. 2-16) 

The Draft RMP/EIS chapheading contains descripthe Kanab Field Office. CSusceptible to Fire” headcommunities respond to decision in chapter 2 are treatment decisions on taflexibility needed to apply budgetary factors. 

U.S. Geological Survey 

Impacts on Soil Resources, pages 4-16 - 4-24 There are numerous references to soils. It would benefit the public if the final RMP/EIS identified the soils datasets that were used in the assessment. 

The soil data used is fou

BLM used site write-up afor areas not covered by 

Utah Archeological Research Institute 

We suggest that all these areas be combined and placed in one ACEC, and it should include all BLM administered lands in the entire Cottonwood Canyonj drainage system from highway 89 on the east to the Coral Pink Sand Dunes on the west and the Arizona border on the south, and that it should be established for protection of archaeological resources. 

The proposed Cottonwoarchaeological sites withthe proposed Parunuweacultural resource sites in Canyon and Moquith Moprotections by inclusion Cottonwood Canyon are 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

corridors, and would be Additionally, cultural resostatutes. Establishment owould not further protect attention and possible adare important Basketmakis true for most of the soestablishment of a culturunduly emphasize the imimportance of others. Thsouthern half of the KFO most historically importalocated on private lands of cultural resource sites as possible for research BLM is limited in its abilitbudgetary constraints. Eas an important part of thfor public use is specificabudgetary and personneare monitored on an as-pimportance or susceptibi

Utah Archeological Research Institute 

No roads should be closed without consultation with all Native American Tribes. The BLM's policy should be in complete compliance with the American Indian Religious Freedom Act; Executive Order 13007: Indian Sacred Sites; Executive Order 13175: Consultation and Coordination with Indian Tribal Governments and all other federal laws, regulations and executive orders that recognize the "unique relationship" between the federal government and Indian tribes, (see also Advisory Council on Historic Preservation Policy Statement, dated November 17, 200, regarding relationships with Indian tribes). 

BLM is committed to con800.2 and described in Bimplementation level act

consultation. 

Utah Archeological Research Institute 

The above statements are not meant to imply or indicate that we advocate roads leading directly to archaeological sites. We have found that where roads lead directly to archaeological sites, vandalism and loss of artifacts always occurs. We recommend that all roads end at least 1/4 mile from rock art sites and that the best measure of protection is having no roads leading to archaeological sites. 

While having no roads lewould likely benefit a largthe presence of cultural and practical, roads are before the site is encounmonitor the site as frequpossible. Cultural resouridentification process, ididentification is an implemnetwork could be considlevels/types of use, as d

Utah Archeological On pages ES-11 you state "Impacts from increasing levels of cross-country OHV The Proposed RMP/Fina

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Research Institute use would affect long-term condition of soils, water quality, and vegetation 

communities" you need to add something to the effect that this action also adversely impacts archaeological resources. On page 1-9, under recreation, you state: "In certain parts, increased visitor use is affecting soil, water, vegetation, and wildlife" You need or add: and is adversely impacting prehistoris archaeological resources. 

Utah Archeological Research Institute 

On Page 2-25 the DRMP/DEIS would "regulate rock climbing within 300 feet of cultural sites. Climbing routes that impact cultural resource sites would generally not be allowed, and climbing routes designed to access cultural resource sites would not be allowed unless under permit for scientific investigation." We request that that this distance be increased to 500 feet from rock art sites. We ask for this change because it has been determined that the rock art was placed in specific locations to interact with shadows created by the sun and nearby rock formations as it travels throughout the year. In one instance, a large rock appears to have been placed on a ledge to cast a shadow on a specific element or elements in a prehistoric panel at a specific time, or perhaps times of year, thus creating a clendrical function to the site. Rock climbers can intentionally or unintentionally move, or even remove such a rock, which might be seen to them as an obstacle. We ask that every effort be made to keep the surroundings of rock art sites as intact as possible so research in this respect can continue without adverse impacts occurring, which would make such research impossible. 

The 100 yards (300 feet) for protection in regards sites in the Kanab decisiAmerican southwest, the close proximity to the roc

commentor presents no restriction is needed to pthe BLM stands by the efor cultural sites. 

Utah Archeological Research Institute 

On page 2-56 it is stated under Prioritize New Field Inventories that the areas to be surveyed are 100 feet (30 meters) (depending on topography) on either side from the centerline of designated OHV routes and 100 feet (30 meters) (depending on topography) on either side from the centerline of a road. This is not acceptable and needs be modified. This assumes direct impacts, however most of the damage comes from indirect impacts where a feature that might contain an archaeological site is visible from the road or tail, like a rockshelter, a cave, a cliff face where there may be rock art, or a concentration of stones. You need to include in the survey any area or feature that is visible from the road or trail that might contain archaeological sites, because I can guarantee you that if any of these features are present, people will stop and walk over to them, even if they are more than a mile away. We know, because we do it all the time. 

Priority areas for proactiva high potential for impa

potential structural sites, are and would be inventoexpanding all such invenquestion is not always poresources. Expanding th

Utah Archeological Research Institute 

Is the difference between a Class I, II and III cultural resource inventory explained in the DRMP/DEIS: If so, there should also be a reference here (page 2-56) explaining these designations. 

The Draft RMP/EIS Glosclasses. 

Utah Archeological Research Institute 

We also would like to note an error on page 3-58, which states, "Archaeological investigations started with the Harvard-sponsored Claflin-Emerson expeditions in the late 1920s led by Noel DARI comments Page 6 Morss". This is not correct. The Claflin Emerson Expedition was led in 1929 & 1930 by Henry Roberts and in 1931 by Donald Scott (Gunnerson 1969) and they were sponsored by Claflin and Emerson - two businessmen. Morss was a minor participant in the ClaflinThe Proposed RMP/Fina

textual recommendations 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Emerson Expeditions. 

Utah Archeological Research Institute 

We would like to suggest that you add to this statement something to the effect that: when a new hypothesis needs to be tested, as in the case of determining the meaning and purpose of rock art, if the rock art has been removed or the surroundings damaged, scientific studies will likely no longer be possible. (Rock art sites must be preserved in place.) 

There are no known casremoved for study elsewtheft or vandalism, or as unavoidable impacts (sufuture would be determinsite use allocation and o

Utah Archeological Research Institute 

No discussion is present regarding the distinction between OHV and licensed passenger vehicles. Here again you combine OHVs and commercially produced licensed passenger vehicles (e.g., Ford, Toyota, Jeep, etc.) in one category. It appears that you have the belief that you cannot close an area to OHV crosscountry travel without also closing the existing roads in these areas to all motor vehicles. You need to realize that the two are separate issues and make this distinction clear in all discussions throughout the DRMP/DEIS. In addition, why can't you close an area to all OHVs and limit travel only to commercially manufactured licensed passenger vehicles? The absence of defining and separating motorized vehicles into at least two classes is the most frustrating and annoying feature of the DRMP/DEIS. In addition, there are other related questions: Why can't you close an area to all cross-county motorized travel and leave all the roads open? We do not see this option in any of the alternatives. Why not? Aren't there enough alternatives? Perhaps you should have more than just four. Because of these issues, we do not believe that the Draft Resource Management Plan and Environmental Impact Statement develops a satisfactory procedure that adequately protects rock art and other archaeological sites in KFO managed lands. 

OHV area designations acountry OHV use, limited route identifications are a

identification of specific rdifferentiate between OHroutes (43 CFR 8340.0-5RMP/EIS. There is no reThe Draft RMP/EIS Alterroutes or close areas to areas, all motorized use identified routes, with miThe impacts to cultural rdescribed in the Draft RMnotes that some impacts mitigated. 

Utah Archeological Research Institute 

Therefore, there are no nonwilderness study lands with wilderness characteristics. They do not exist. The land was already studied and determined to be lacking in wilderness characteristics. Therefore, we ask that this section be deleted because the determination has already been made. 

The BLM has long acknorequiring a one-time wildlands is authorized by FL2006, the Utah District C

lands it determined to hasimilar to the manner in authority for managing laderived directly from FLP

BLM’s organic statute giv

public lands for multiple the Secretary’s authority consideration of physicaSection 202(c)(2) (43 U.term “multiple use” mean

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Commentor Comment C

public land, and that the for some or all of these rprovide sufficient latitude 103(c) (43 U.S.C. §1702to use land use planning wilderness character maprovides uses for currenPlanning Handbook (H-1preserve wilderness chasolitude, and outstanding Include goals and objectnecessary to achieve theconditions of use that wocharacteristics.” Finally, BLM’s authority to manaconfusion by distinguishiFLPMA §603 and those impairment standard, an§202 land management 

Utah Archeological Research Institute 

Is there some reason that there has to be four alternatives? What if there are six viable alternatives? What if there are fifteen viable alternatives? Do you combine them or just leave some out? Confining management strategies to four different options restricts management alternatives, and thus it is not an adequate approach to effectively manage our public lands. 

BLM has provided a reas

Draft RMP/EIS analyzes alternative, except for Althe identified purpose anbegan early in the RMP through February 2005) coordination with our coo

Utah Archeological Research Institute 

It makes no logical sense to manage public lands for activities that seldom take place while ignoring activities participated in by the greater number of people. We ask that management alternatives be given priority that support the interests of the majority of the people utilizing the BLM Lands in the Kanab Field Office area, as long as the resources can be protected, and that this information be an integral part of the final RMP/EIS. 

The commentor provided decision area. The alternduring the scoping proce

information in developing of those alternatives (cha

Utah Archeological Research Institute 

We ask that you please include a section with alternatives on target shooting. We further ask that the preferred alternative ban all target shooting with gunpowdered projectiles on public lands. 

Eliminating target shootinot required to include a 

decisions is an implemen

Utah Archeological Research Institute 

It would be appropriate for the BLM as part of this management plan to formally commit to getting all of the eligible archaeological sites in the KFO area listed on the NRHP. Therefore, we formally request that you please do exactly that. The Cottonwood Canyon drainage would be a good place to start. 

The BLM integrates the with its responsibilities foFLPMA to ensure that thaccount. In addition, Na

compliance with Nationafor BLM managers to me

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Commentor Comment C

Until 1980, Section 106 otheir undertakings only oPlaces. However in 198consider an undertakingin the National Register. process, outlines specific protect sites both listed asurface disturbing activitSection 106 and site-speThe Draft RMP/EIS Cultuwould receive priority for 110 cultural surveys are Field Office. 

Utah Archeological Research Institute 

Regarding section 1.4 on page 1-15 under Planning Criteria, there is no discussion about archaeological resources (field inventories, identification, protection). Should not the existence of archaeological resources play a significant role in these plans? See page 2-21 through 2-22, Objectives under Cultural Resources. 

The planning criteria do considered in the plannin

"planning criteria are the devleopment of the RMPissues raised by the comcurrent resource informa(identification of sites are#16 (management actionof the Draft RMP/EIS anissues). Cultural resourcthroughout the managem

Utah Archeological Research Institute 

Additionally, we see no evidence of a cost analysis associated with each alternative. If you or we are to choose an alternative, is not the cost an important factor? We would like to see an estimate of the costs of implementing each alternative 

The CEQ Guidelines for 

does not require prepararegulations state that “If choice among environmeproposed action, it shall statement as an aid in ev1502.23 Cost-benefit anFLPMA requires that BL103(c) of FLPMA defines . . harmonious and coord

permanent impairment oenvironment with considand not necessarily to theconomic return or the gimplementation schedule priorities, available workf

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Commentor Comment C

evaluate costs and bene

is not central to the plannmultiple-use planning altAfter selection of an altemanagement actions maThe BLM’s National Planimplementation of land ucost/benefit analysis, but improving resource condshould receive relatively to Facilitate Implementat

Utah Archeological Research Institute 

We do not see a clear distinction between licensed passenger vehicles and OHVs on roads or an adequate and accurate discussion of these distinctions. Throughout nearly all of the DRMP/DEIS there is no discussion in each alternative distinguishing and separating OHV travel from that of licensed passenger vehicles. Whenever you discuss topics like Motorized Use of Routes, you need to differentiate OHV travel from that of licensed passenger vehicles. Furthermore, there is little discussion of existing roads verses designated roads. 

The BLM does not differpassenger vehicle use onot separated in the Dravehicle classes. 

Utah Archeological Research Institute 

Therefore, we ask that is distinction be made in the DRMP/DEIS and appropriate discussions and actions be added to all sections discussing OHV use. 

The BLM does not differpassenger vehicle use onot separated in the Dravehicle classes. 

Utah Archeological Research Institute 

In addition, why can't you close an area to all OHVs and limit travel only to commercially manufactured licensed passenger vehicles? The absence of defining and separating motorized vehicles into at least two classes is the most frustrating and annoying feature ofthe DRMP/DEIS. 

The BLM does not differpassenger vehicle use onot separated in the Dravehicle classes. 

Utah Archeological Research Institute 

So, if an area is closed to OHVs, it is also closed to all motorized transportation on all roads? This is unreasonable. You need to clarify this in all areas of the DRMP/DEIS where OHVs are discussed. This is discussed in more detail below. 

There are exclusions baare defined in 43 CFR 83

Utah Rivers Council However, the Council respectfully disagrees with failing to include several rivers 

in that recommendation and with the classification of two segments in the preferred alternative. The Council supports all of the following rivers as suitable to become Wild and Scenic Rivers with the classifications listed: *North Fork Virgin River segment 48-49: Wild *North Fork Virgin River segment 46-47: Recreational *Orderville Gulch and Esplin Gulch: Wild *Meadow Creek and Mineral Gulch: Wild *East Fork Virgin River segment 36-37a: Scenic *East Fork Virgin River segment 371-41: Wild *Paria River: Wild *Kanab Creek segment 7-8: Wild *Kanab Creek segment 8-9: Wild *Kanab Creek segment 9-10: Scenic *Bob Creek: to be determined *Tiny Creek: to be determined 

Appendix G of the Draft 

review process including 

well as the Suitability Cocomplied with all applicaScenic Rivers Study Pro

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Utah Rivers Council The Council urges the Kanab Field Office to give these segments the 

classification that they were given in the Draft Evaluation Report, which is the same as that given in Alternative C on page 2-104 for segment 37-40a. 

The BLM’s wild and scenRivers – Policy and ProgManagement), section .3been tentatively classifieprovide for designation aDuring the alternative prtrip to the East Fork Virgfindings of the inventory. were revised to be three which was originally clascrossings than were origadjusted to “recreationaltrip continued along the routes came close to the segment. As a result, the into two segments, with the last route and the plamodified to “scenic” to co

Utah Rivers Council But then the Draft goes on to muddle the clear language of the Wild and Scenic 

Rivers Act by finding segment 37-40a of the East Fork Virgin River "wild" in alternative C and "scenic" in alternative B. Similarly, segment 36-37 of the East Fork Virgin River was found to be "scenic" in the Draft Evaluation Report and "recreational" respectively in Alternative B of the Draft RMP. All of these segments are downgraded in the preferred Alternative, Alternative C of the Draft RMP. 

The BLM’s wild and scenRivers – Policy and ProgManagement), section .3been tentatively classifieprovide for designation aDuring the alternative prtrip to the East Fork Virgfindings of the inventory. were revised to be three which was originally clascrossings than were origadjusted to “recreationaltrip continued along the routes came close to the segment. As a result, the into two segments, with the last route and the plamodified to “scenic” to co

Utah Rivers Council The tentative classification given to East Fork Virgin River segments 36 through 

41 in the 2005 Draft Evaluation Report is based on the actual development and accessibility to the river at the time of the study. Thus, this is the classification that these segments should be given in the suitability determination. Downgrading the classification of these segments is not consistent with current 

development and simply opens them up to future threats that may negatively 

The BLM’s wild and scenRivers – Policy and ProgManagement), section .3been tentatively classifieprovide for designation aDuring the alternative pr

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Commentor Comment C

harm the outstanding values of these rivers. trip to the East Fork Virg

findings of the inventory. were revised to be three which was originally clascrossings than were origadjusted to “recreationaltrip continued along the routes came close to the segment. As a result, the into two segments, with the last route and the plamodified to “scenic” to co

Utah Rivers Council The Council requests that the Kanab Field Office respond to and incorporate all 

of the comments on the Draft Evaluation Report, and make those publicly available. 

The BLM’s ID Team revithe review period for the Eligibility. The Draft RMPincluding the integration 

review. There is no legal responses to public comRiver Eligibility. 

Utah Rivers Council Regardless of the Kanab Field Office's eventual or potential designations of river 

segments, the identification of all qualifying sections is required and should be 

completed objectively without predecisional influences. We kindly request that the Kanab Field Office properly revaluate the eligibility of those streams found 

ineligible in the 2005 Draft Evaluation Report, including but not limited to: North Fork Virgin River segment 46-47, Bob Creek, Tiny Creek, and all segments of Kanab Creek. Additionally, we request that the Kanab Field Office fully disclose 

the results of the revaluation to the public. 

The BLM Kanab Field OProtect the Wild Rivers oof rivers potentially eligibScenic Rivers. This inforremarkable values for vacases, however, an interthe information or, more a rationale is provided in All streams in the decisiodesignation as a Wild anevaluation process for dedesignation. 

Utah Rivers Council The Council requests that those streams dismissed from being evaluated for 

eligibility due to their being ephemeral be reconsidered in the evaluation based on this and a more appropriate evaluation of ORVs. These rivers are not limited to the following: *Fisher Canyon *Robinson Creek *Sink Valley Wash *Trail Canyon *Pugh Canyon *Maranger Canyon *Oak Canyon *Dairy Canyon *Dry Wash *Peterson Wash *Butler Wash *Bunting Canyon 

All streams in the Kanab designation as a Wild anevaluation process for dedesignation. However, pInstruction Memorandum ephemeral (flow lasting o

Utah Rivers Council However, the Kanab Field Office did not follow this regarding the eligibility of 

segment 46-47 of the North Fork Virgin River. For example, in their evaluation of the North Fork Virgin River, when looking at ORVs, "Wildlife -Spotted Owl designated critical habitat is present; however, checkerboard ownership makes management difficult." Checkerboard ownership is not something that should be 

Language in Table AG-2 better reflect the ID Team 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

considered in the eligibility phase. Furthermore, this segment possesses spotted owl habitat, which means that this segment has a wildlife value. 

Utah Rivers Council The Council concurs with the Kanab Field Office that all segments of the East 

Fork of the Virgin River are suitable to become a Wild and Scenic River. However, the Council respectfully disagrees with the Kanab Field Office regarding classification of the segments. The Council recommends the East Fork Virgin River be found suitable with the following classifications: *East Fork Virgin River segment 36-37a: Scenic *East Fork Virgin River segment 371-41: Wild 

The BLM’s wild and scenRivers – Policy and ProgManagement), section .3been tentatively classifieprovide for designation aDuring the alternative prtrip to the East Fork Virgfindings of the inventory. were revised to be three which was originally clascrossings than were origadjusted to “recreationaltrip continued along the routes came close to the segment. As a result, the into two segments, with the last route and the plamodified to “scenic” to co

Utah Rivers Council This change in classification of segment 37-40a makes no sense based on the 

development and accessibility to the river. As stated in the Draft RMP, classification of a river segment is based on the type and degree of human development associated with the river and adjacent lands at the time of inventory.12 

The BLM’s wild and scenRivers – Policy and ProgManagement), section .3been tentatively classifieprovide for designation aDuring the alternative prtrip to the East Fork Virgfindings of the inventory. were revised to be three which was originally clascrossings than were origadjusted to “recreationaltrip continued along the routes came close to the segment. As a result, the into two segments, with the last route and the plamodified to “scenic” to co

Utah Rivers Council Therefore, instead of downgrading the classification of the entire segment from 

Wild to Scenic it could be resegmented in order to better reflect the reality on the ground. The Council requests the E Fork Virgin River be resegmented from point 38 upstream to where the road leaves the corridor, point 37a, as Wild, then have 

The BLM’s wild and scenRivers – Policy and ProgManagement), section .3been tentatively classifie

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

the next part of the segment upstream to 37 as Scenic. provide for designation a

During the alternative prtrip to the East Fork Virgfindings of the inventory. were revised to be three which was originally clascrossings than were origadjusted to “recreationaltrip continued along the routes came close to the segment. As a result, the into two segments, with the last route and the plamodified to “scenic” to co

Utah Rivers Council The preferred alternative proposes to designate a road along the East Fork of the 

Virgin River, specifically along segment 36-37a. This proposed road crosses the river numerous times during its course along the East Fork Virgin River.13 We request that this entire proposed road along the river corridor be closed in order to protect the outstanding values of the East Fork of the Virgin River. 

The Draft RMP/EIS analinteract with the East FoAlternative C. Alternative preparing the Proposed 

Utah Rivers Council Therefore, the Council requests that the Kanab Field Office close the proposed 

road that follows the East Fork of the Virgin River in order to be consistent with the intention of the Wild and Scenic Rivers Act and protect the values for which the East Fork Virgin River is being recommended as suitable to become a Wild and Scenic River. With the closure of the proposed road we request that the East Fork Virgin River be found suitable and classified as follows: *East Fork Virgin River segment 36-37a: Scenic *East Fork Virgin River segment 37a-41: Wild 

The Draft RMP/EIS analroute. The routes that intclosed under Alternative in preparing the Propose.51(c), “the basic distinctare the...extent of shoreAppendix G, the East Fo

the entire segment, incluclose the route, the physdevelopment would rema

determined the even with a recreational classificat

Utah Rivers Council The Council reiterates the same concerns that we expressed in comments 

submitted to the Kanab Field Office on the Draft Evaluation Report in a letter dated January 27, 2006. The Council respectfully disagrees with the Kanab Field Office's determination that Kanab Creek is not eligible. The Council strongly recommends that the entire length of Kanab Creek be found eligible for wild and scenic status as classified below: *Segment 7-8 from the falls to the BLM boundary in the northeast corner in section 32- Wild *Segment 8-9 from the falls at T.40S., R.6W., Sec.35 to T.41S., R.6W., Sec.33 - Wild *Segment 9-10 - from point 9 to the Highway 89 crossing - Scenic 

The BLM Kanab Field OProtect the Wild Rivers oof rivers potentially eligibScenic Rivers. This inforremarkable values for vacases, however, an interthe information or, more a rationale is provided in All streams in the decisiodesignation as a Wild anevaluation process for de

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

designation. 

Utah Rock Art Research Association 

The area proposed under alternative C should be expanded eastward to include all public lands adjacent to Kanab and should include areas west of Three Lakes Canyon. This region has significant early Basketmaker Anasazi and Pueblo III archeological sites including a bird-headed Basketmaker Style rock art panel that is reminiscent of rock are found in the Grand Gulch region. These cultural resources need to be proactively managed through an archeologically focused ACEC including cultural resource inventories, nominations to the Nation Register, interpretation and education facilities near well known sites, physical monitoring, and being closed to surface occupancy and natural resource leasing in this area. 

The proposed Cottonwoarchaeological sites withthe proposed Parunuweacultural resource sites in Canyon and Moquith Moprotections by inclusion Cottonwood Canyon are corridors, and would be 

Additionally, cultural resostatutes. Establishment owould not further protect attention and possible adare important Basketmak

is true for most of the soestablishment of a culturunduly emphasize the imimportance of others. Thsouthern half of the KFO 

most historically importalocated on private lands 

of cultural resource sites as possible for research BLM is limited in its abilitbudgetary constraints. E

as an important part of th

for public use is specificabudgetary and personneare monitored on an as-pimportance or susceptibi

Utah Rock Art Research Association 

We believe the region from the Arizona state line north to the East Fork of the Virgin River and from Kane County line to Yellowjacket Canyon Road should be included in the ACEC. There are rock art sites south of the Virgin River of an unusual style not found anywhere else. This is an archeologically unique area within the state of Utah and requires special attention to documentation and protection. 

The proposed Cottonwoarchaeological sites withthe proposed Parunuweacultural resource sites in Canyon and Moquith Moprotections by inclusion Cottonwood Canyon are corridors, and would be 

Additionally, cultural resostatutes. Establishment owould not further protect attention and possible ad

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

are important Basketmakis true for most of the soestablishment of a culturunduly emphasize the imimportance of others. Thsouthern half of the KFO most historically importalocated on private lands of cultural resource sites as possible for research BLM is limited in its abilitbudgetary constraints. Eas an important part of thfor public use is specificabudgetary and personneare monitored on an as-pimportance or susceptibi

Utah Rock Art Research Association 

We are concerned about the process used to identify cultural resource management associated with this RMP. Only 10% of the area has been subjected to detailed cultural inventories. Most of this 10% survey area is based on "compliance with Section 106 of the NHPA, meaning the surveys are conducted as needed to identify cultural resources in a project-specific context and generally are not statistically valid samples of the region." (Page 3-60) Cultural resource decisions on the remaining 90% are the result of known sites and professional judgment (4-96) based on a small survey sample that is not statistically valid. Professional judgment in this context sounds a lot like guessing. It is our understanding that Section 106 (16 U.S.C. § 470t) obligates the BLM to consider the effects of management actions on cultural resources listed or eligible for listing to the National Register of Historic Places. Section 110 of the NHPA requires the BLM to manage and maintain those resources in a way that gives "special consideration" to preserving archaeological and cultural values. Section 110 also requires the BLM to ensure that all historic properties under the jurisdiction or control the agency are identified, evaluated, and nominated to the National Register of Historic Places. Id. § 470h-2(a)(2)(A). How can the BLM claim to be honoring their legal responsibilities when they are not using real data regarding archeological sites to make management decisions? We do not support a decision-making process which is not based on actual rock art and archeological site inventories. 

In preparing the PRMP/Dthe basis for the cultural Section 106 and 110 inv

information available. Aproposals will require codocumentation. Future pof funding and resources

Utah Rock Art Research Association 

We believe the only OHV road that should provide access to this area is the current trail that starts from Highway 237 and proceeds through Elephant Gap to the rim of the East Fork of the Virgin River and then proceeds east along the river 

The process used to desand uses that the commcriteria in Appendix K wa

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

to Mount Carmel. The many other trails in this area, both east and west and on the north side of the river, should be closed. This will provide the most appropriate level of protection for the area rich in archeology and wilderness resources. 

analysis in chapter 4 addidentification. The impac

chapter 4 of the Draft RM

Utah Rock Art Research Association 

As a result we believe that the proliferation of OHV routes in the area needs to be carefully considered. Those that provide direct access to important cultural resource sites should be closed at least one quarter mile from sites eligible for NRHP status. 

As noted in the Draft RMthe impact analysis is tha

allocations contained in tof actions and analyses that individuals can inadvprescriptions, none of wh

prescriptions. Impacts fro

prescriptions contained ipresence is an Administrplanning decision to impraises were considered ito develop the alternativeimpacts associated with 

Vaughn Bussma The Plan does not solve the damage caused by hunters in their ATVs and trucks, 

a problem expressed by the BLM representatives at the meeting. More postings and restrictions will not change the way that they behave. More enforcement of existing rules during hunting will be necessary. 

Law enforcement is beyo

Vaughn Bussma Much of the land designated as closed for ATV riders under Plan B will become 

inaccessible to the many Utahns in my elderly age group who can no longer hike the trails. 

FLPMA does not require 

designated recreational However, the accessibilithe Draft RMP/EIS). 

Walter Fertig ACEC designation: The Field Office resource staff did a good job of evaluating 

the merits of the proposed ACECs in the planning area, but oddly, their recommendations are being bypassed in the preferred alternative B. ACECs are valuable chiefly for drawing attention to areas of unusual biological, ecological, cultural, or historical interest. Ideally, BLM would develop management prescriptions to ensure these values are maintained, but at a bare minimum the ACEC designation identifies that such a value exists so that future actions and proposals can be dealt with in ways to minimize impacts. Ignoring the assessment that all ofthe proposed areas meet ACEC requirements and the specious reasoning that the areas are already protected by other management tools makes Alternative B's dismissal ofall but the existing Cottonwood Canyon ACEC seem arbitrary and counter to the BLM's resource management mandate. Besides, if the areas are already adequately protected without the ACEC designation, no harm is done by making them ACECs! 

Appendix H of the Draft evaluate proposed ACECCFR 1610.7-2, and BLM 

Walter Fertig Oil and gas leasing: Alternative B is an improvement over the existing condition 

in which nearly all BLM lands in the immediate vicinity of Kanab are open to oil 

An arbitrary buffer arounGSENM would be contra

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

and gas leasing under standard terms and conditions. While Alternative B would impose more stringent leasing constraints (such as No Surface Occupancy), the preferable solution would be to close these areas to leasing entirely, as proposed in Alternative C. These areas have very low oil and gas potential and have higher significance to the local community as a watershed and for scenic values. Likewise, the Kanab FO should consider lease closure in the areas adjacent to Zion National Park (especially near the NE corner of the park) within the watershed for Springdale. Alternative B leaves much of this area open to leasing subject to moderate constraints, while Alternative C would close these areas of minor oil and gas probability to leasing. 

The Draft RMP/EIS prov

of the Draft RMP/EIS reppurpose and need and oThe range of alternatives the public scoping period process in coordination wcomment period. The Drclassifications, right-of-widentified OHV routes, Wwilderness characteristicdisturbing activities and Springdale/Virgin waterswithin WSAs, WC areasclosed to oil and gas leaand Fredonia specifically their water collection sysrequested BLM to manacollection systems. This period. 

Walter Fertig Recreation management: I commend the Kanab FO for adopting "Special 

Recreation Management Areas" as a planning and management tool. This is something that should have been done a long time ago to minimize conflicts between competing (and sometimes incompatible) uses and represents what multiple use management ought to be. The trick, of course, is that delineation of the areas is fair to all and management is enforced. 

The SRMA boundaries athe BLM land use plannirecreation investment, wand where recreation is have high levels of recre

Walter Fertig Welsh's milkweed: Adoption of the Welsh's milkweed ACEC would help ensure 

that this Threatened species does not decline further. Unfortunately, its habitat at Coral Pink sand dunes overlaps with much of the area being proposed for crosscountry ATV recreation. The closure of 790 acres to ATV use at the extreme north end ofthe dunes is a good start (though this area doesn't cover the largest milkweed populations), but enforcement will remain a significant issue. 

The ACEC proposal was determined that existing damage to the relevant aThe management decisimanagment) were the sconsultation with FWS. this NEPA document. 

Walter Fertig BLM monitoring data and independent research that I've been associated with 

indicate that the milkweed population is reasonably stable at Coral Pink (with weather-related fluctuations in numbers of stems). Data from the late Brent Palmer and my own team, however, show that flowering and fruit production are being depressed in areas where mature stems are run over. Vehicle damage tends to promote the production of new, vegetative stems (without flowers) through compensatory growth. Unfortunately, damage to flowering stems from vehicles results in the loss of fresh seeds to contribute to the seed bank and spread to new areas. We found flowering and seeding rates to be double inside the Coral Pink sand dunes tiger beetle exclosure compared to areas open to ATV 

The BLM has use the be

alternatives and analsyis could be considered. Adby the commentor, could outside the scope of the 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

travel in Coral Pink state park and BLM lands. This finding presents a management opportunity for the BLM - use ofa set of 5-10 short-term removable exclosures located over known patches of milkweed. These exclosures would remain in place for 2-5 years, giving the plants inside the opportunity to flower and set seed during that time (more than one year would be best to ensure that seed production isn't lost due to drought). After the allotted time, the exclosures would be removed and placed over different milkweed patches. At any given time the same amount of area would be in an exclosure (and the area outside open to recreation use), but the areas protected by exclosure would shift over time to increase the output of seed and allow new patches to develop. Exclosures could be as small as 20 x 20 feet and would need to be adequately marked to reduce impacts from collision. 

Walter Fertig Travel management: Again, I commend the BLM Kanab FO for eliminating crosscountry travel by vehicles (except for designated routes). This will be a big step 

towards reducing resource damage to soils and native vegetation, which in turn negatively affects wildlife and livestock. Developing a system of designated routes for ATVs is a good step to ensuring that these recreationalists have a place to pursue their activities. I do think BLM could have done a better job in evaluating what roads and trails should be part ofthe designated route system. Essentially the BLM maps are an inventory ofroads and trails, not a plan for managing travel, as many of these roads were not established using any erosionreducing standards. The maps provided in the draft RMP depict a lot of redundant roads (roads that parallel each other and go to the same destination). BLM ought to develop a more public process to evaluate the necessity of some of these redundant roads - roads that reduce the visual appeal of our area, reduce cover for wildlife and livestock, and increase soil loss. Having roads and trails available for use is important, but I see little value in creating road densities that are so high that they impede other uses. 

Appendix K of the Draft criteria used to identify athe commentor raises weduplicative routes, envirosensitivity, and current a

Walter Fertig My main quibble with the proposal in Alternative B is that a larger area ofCoral 

Pink Sand Dunes should be off-limits to ATV travel to protect the federally Threatened Welsh's milkweed (Asclepias weishU) and other BLM Sensitive species. Coral Pink State Park already offers ATV recreation, and the area obligated to the rare species is unnecessarily small. The dune area needs to be shared among various interests more equitably. 

The Welsh's milkweed cremains closed to OHV iin consultation with the Uadequate protection of th

Walter Fertig Vegetation treatments: I think setting numeric goals of 51% or 76% or more of 

lands at a state of "potential natural community" is an unrealistic management expectation. Potential natural community is essentially the "climax" state for a specific vegetation type and is more of an abstraction than a biological/ecological reality. A better (and more realistic) goal would be to manage BLM lands to have a mix of seral states - including early, mid, and late successional and PNC conditions. This would allow for the maximum diversity of wildlife and plants, provide a mixture of habitats for forage and cover, and improve fire/fuel 

The Draft RMP/EIS was on the rehabilitation deciother resources dictate oof PNC)." 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

management. The BLM should develop vegetation management plans to ensure this range of natural variability using existing grazing allotment boundaries, or develop vegetation management zones analogous to those proposed for recreation management. 

Walter Fertig Wilderness Study Areas: WSA management remains driven by needs to maintain 

wilderness characteristics until such time that Congress designates these areas as official Wilderness Areas, or releases them. These were areas BLM itself identified as having wilderness potential and qualified for Wilderness designation when they were selected. Developing travel corridors through these areas goes against the spirit of WSA management and would seem to put the BLM in violation of its own WSA policy. This needs to be reassessed before the final decision is made on the RMP. 

The IMP allows for contiphase. The IMP does no

and enforcement are iss

Wayne Cox I strongly disagree with the proposed road closures in the Barracks and Poverty 

BLM areas. These roads have existed for decades and should remain open to the public. I have traveled these roads my whole life, with my father and siblings, and now with my own family. For many people, these roads are the only access to certain areas along the Virgin River. I feel there are many benefits to leaving these roads open. 

The Proposed RMP/EIS identified way open to Oconsidered in the range RMP/EIS has been mod

Western Watersheds Project, Inc. 

BLM has provided no science to show that livestock grazing reduces spread or severity of fire . To the contrary, if BLM had troubled itself to look, livestock grazing increasesfire severity. Where is the science to support the myth that grazing cheatgrass reduces cheatgrass? 

BLM resource specialist decrease fine fuel loadinareas with a cheatgrass 

Chapter 2. 

Western Watersheds Project, Inc. 

The Kanab FO should conduct a capability analysis to determine the areas that might be available for livestock grazing, excluding steep slopes >30%, low forage production <200 lbs/areas, ecosystems converted by wildfire or invasive weeds, and the ability of sensitive soils to respond following impacts (arid elevations, reclamation, soil chemistry, drought). 

According to the Land URMP/EIS identifies lands considered the following 

characteristics. c. Soil, vpresence of undesirable infestations. e. The presmanagement or protectioManagement Areas (SRmanagement options ba

Western Watersheds Project, Inc. 

The DEIS does not present an allotment by allotment summary of current monitoring information that describes the trend or condition as compared to the existing RMP. 

The Rangeland Health Acomparison to the four fuassessments were summ

chapter 3 (see section 3the current assessment functioning at risk. The oare located in the Kanab describes the regulatory 

attain to one of the standgrazing. 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Western Watersheds Project, Inc. 

This failure must be corrected to meet the intent of NEPA and in order to provide a comparison of the impacts of livestock on riparian and upland areas, water quality, soils and wildlife under proposed stocking rates as compared to conditions in the absence of livestock. Otherwise, no true evaluation of the impacts of livestock grazing can be claimed. 

The BLM did consider an 

grazing, but did not analy2.3.2). NEPA does not resimply for the sake of anthe BLM to develop a reaalternative, the preferred the issues raised during alternatives to address thby NEPA, the Draft RMPEach alternative, except satisfying the identified palternatives began early period (April 2004 througthe process in coordinaticomment period. 

Western Watersheds Project, Inc. 

The Preferred Alternative ignores the ecological impacts of off-road vehicles and allows their use on major portions of the RA, including thousands of miles of roads and trails. 

BLM has provided a reasan alternative means of resolving issues raised dbegan early in the RMP and was further develop

our cooperating agencieDEIS. Chapter 4 discloseand route identification. 

Western Watersheds Project, Inc. 

The lack of an alternative that eliminates off-road vehicles and the lack of analysis of impacts of OHVs violates the intent of NEPA. 

BLM has provided a reasan alternative means of resolving issues raised dbegan early in the RMP and was further developour cooperating agencieDEIS. Chapter 4 discloseand route identification. 

Western Watersheds Project, Inc. 

There is no analysis of the impacts of the hundreds of water developments for livestock, the miles of fences and their impacts on wildlife, the loss of riparian and wetland areas due to water developments nor the thousands of acres of watershed and plant community degradation that occur around livestock water developments. There is no analysis of the watershed impacts from livestock grazing including the degree of loss of ground cover, the accelerated rate of erosion compared to natural conditions with intact plant and biological crust communities, the loss of ground water and watershed storage or the impacts on the Colorado River System and its endangered species. The Colorado River Salinity Control Act is not addressed in regards to livestock, erosion, sedimentation and salinity. 

Chapter 4 of the Draft RMvegetation resources fro

analyzed in the Draft RMAs stated in Chapter 2 odesigned to achieve and opportunities for erosion

174 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Western Watersheds Project, Inc. 

The DEIS/RMP have failed to meet the intent of FLPMA for sustainable uses that do not impair productivity, have failed to "accelerate restoration" and have abrogated BLM's responsibility for effectiveness monitoring that is meaningful and without bias. 

Identifying monitoring anplanning. 

Western Watersheds Project, Inc. 

Resource alternatives provided within the DEIS/RMP are not compliant with the BLM Land use Planning Handbook planning guidance which directs the identification and analysis of specific rmanagement actions. 

The BLM Land Use Plandevelopment of the Draf

Western Watersheds Project, Inc. 

Therefore, in lieu of adequate data and analysis, OHV activities and other surface disturbing activities such as recreation, livestock grazing, travel routes, oil/gas and mineral extraction, must be analyzed for elimination or significantly restricted use on public lands within the following sensitive areas: 

As is typical in programmextent possible. The BLMreasonable range of alte

for Alternative A, represepurpose and need, and oin the RMP process startFebruary 2005) and was with our cooperating agealso required by FLPMA standards. The term “muof the public lands and thcombination that will bespeople.” This direction inareas. The Alternatives iwould be open to all typewould be open to uses in resources are provided iof sensitive resources. 

Western Watersheds Project, Inc. 

The Kanab FO should at a minimum, analyze alternatives including No Action (status quo), No ATVs, Dirt Bikes or Snowmobiles, or the new experimental playtoys, Personal Aerial Vehicles, and the level of use allowed in the current set of alternatives. Some of the science regarding this issue is presented in the following paragraphs. 

As is typical in programmextent possible. The BLMreasonable range of alte

for Alternative A, represepurpose and need, and oin the RMP process startFebruary 2005) and was with our cooperating agealso required by FLPMA standards. The term “muof the public lands and thcombination that will bespeople.” This direction inareas. The Alternatives iwould be open to all typewould be open to uses in resources are provided i

175 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

of sensitive resources. 

Western Watersheds Project, Inc. 

BLM must review all this information in its analysis in order to meet its obligation under NEPA to take a "hard look" at the effects of its actions. 

NEPA does not require aor opposing the analysis technical and scientific re

BLM’s ID Team member

analysis. Unless the com

RMP/EIS analysis, the Breferences into the Prop

Western Watersheds Project, Inc. 

Recreation management actions within Chapter 2 pg 2-80, should change requirements of a 200' buffer in riparian areas as stipulation for recreation SRPs to require 330 in accordance with UT Riparian Policy and Utah Guidelines for Recreation Activities. 

The riparian limitation fothe surface disturbance is a less intrusive activity vegetation, exposing the 

of surface disturbance). camping from Tread Ligh

Western Watersheds Project, Inc. 

Indeed the entire riparian discussion and definitions need clarification with respect to riparian and/or wetland resources. 

The information in Table inventoried decision area

Office has not been invewas used. CEQ regulatio(NEPA) require agencies 

environmental impact stainformation, if that informalternatives (43 CFR 150specific data is used to t

Western Watersheds Project, Inc. 

Proper data is available through current technology regarding geographic information systems digital imagery, data sources such as the National Hydrographic Dataset (NHD) and US Geologic Survey (USGS) water resources data, as well as site-specific field assessments for Standards of Rangeland Health and Riparian Databases. 

The information in Table inventoried decision area

Office has not been invewas used. CEQ regulatio(NEPA) require agencies 

environmental impact stainformation, if that informalternatives (43 CFR 150specific data is used to t

Western Watersheds Project, Inc. 

The DEIS/RMP needs to demonstrate through proper analysis that riparian/wetland resources and other sensitive values including dependent wildlife species habitats, are adequately identified and protected from proposed resource uses and impacts. 

The Draft RMP/EIS utilizThe 2006 habitat dataseutilized for planning and 

datasets were also used crucial habitats. AdditionAppendix B of the Draft determined to be the moand negative environme

Western Watersheds Additionally, clarification needs to be provided that all riparian/wetland resources BLM recognizes these re

176 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

Project, Inc. (both lotic and lentic systems) are protected by the Executive Order (EO) 11990 

(wetland protection), EO 11988 (floodplain management), and Section 404 of the 

Clean Water Act. 

RMP/EIS. The Utah Ripato Utah BLM riparian lan

Western Watersheds Project, Inc. 

Where is BLM's analysis showing the relationship of livestock and OHV activities to water pollution, stream damage and loss of aquatic habitat in ALL livestock or motorized accessible areas? 

The impacts to riparian/wanalyzed in section 4.2.4 

Western Watersheds Project, Inc. 

Despite an improper capability and suitability analysis, the DEIS failed to quantify and analze the impacts of livestock grazing within riparian/wetland areas which are critical and sensitive ecosystems within the western landscape. 

The impacts to riparian/wanalyzed in section 4.2.4 

Western Watersheds Project, Inc. 

Claims of streams and riparian areas in PFC ignore that PFC is a minimal classification that does not address the wildlife habitat attributes of these most important areas, water quality or instream habitat for fish. In addition, springs, seeps and wetlands condition and trend are not described. 

Proper Functioning Cond

riparian areas. The StanFundamentals for Rangelands. 

Western Watersheds Project, Inc. 

The RMP/EIS has failed to take a hard look at the issue of livestock grazing, instead, putting off decisions to some uncertain time in the future, while impacts, which are massive across the Resource Area, continue. BLM has not provided for enforceable permit terms and conditions. 

Evaluation and adjustmeseason of use, changes beyond the scope of this 

Determining the conditiothe grazing permit renewmonitoring data is analyzprovide for the sustained permit renewal. Kanab Fmanagement practices fRangeland Health as noconditions are not in the that all permits have NEP

Western Watersheds Project, Inc. 

The Draft RMP/EIS failed to analyze the role and values of predators in controlling rodent populations and fulfilling their role in a healthy ecosystem. 

The role and values of pscope of the Draft RMP/

Western Watersheds Project, Inc. 

The definition of sensitive or fragile soils must be expanded to include those soils with moderately high to high soil erosion potential from wind or water, soils with potential for biological crusts, soils on steeper slopes and soils where ground cover is below potential. 

Fragile soils were define

soils that are most fragile even with management aflora cover type in their oRemoval of any vegetatiDraft RMP/EIS chapter 4definition of fragile soils. crusts in the Kanab Field Therefore, biological soil Draft RMP/EIS as in the 

Western Watersheds Project, Inc. 

The DEIS/RMP should provide or reference more specific details concerning motorized and non- motorized designations and designated travel routes including the total and percentage of acres and their condition within: .each stream drainage or subbasin; aoverlapplnq livestock grazing allotments, 

The process used to desand uses that the commImpacts to all resources are contained in Chapter 

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

aoverlapplnq special designation area (ACECs, WSAs etc) asensitive areas such as fragile soils, sensitive wildlife habitats .and those acres of sensitive values affected by motorized and non-motorized and travel route proposals. 

Western Watersheds Project, Inc. 

BLM has not adequately analyzed the direct, indirect and cumulative effects of the RA's road and trail network, the huge number of closed roads and trails that continue to be used illegally by ATVs and dirt bikes, and the incidence of newly created, illegal routes. There has been no analysis of road density effects. 

The BLM analyzed each potential uses of each roK, to determine route idesetting, recreation activitinformation was used in chapter 4 addressed the 

does not require analysis 

impacts of the identified RMP/EIS on pages 4-18

Western Watersheds Project, Inc. 

BLM in relying on the State of Utah to list streams in its TMDL process, is abrogating its responsibility to manage so that water quality standards are met. A copy of thatJ vJfirT review is included as Appendix 3. 

Chapter 2 of the Draft RMwater quality. Additionallcontinue to actively partiadministered by the Utah 

Western Watersheds Project, Inc. 

Pronghorn protection stipulations within Chapter 2 page 2-50 identify May 15 to June 15 as protection periods during fawning. However, based on local phenology, protective periods are too late to protect spring forbs necessary for successful fawning and lactation. Authorization should require rest from livestock grazing which extend from March 15 to June 15 for adequate protection of forage cover and other habitat requirements. 

Based on local plant phepronghorn habitat neces

Western Watersheds Project, Inc. 

There was no meaningful analysis of the benefits of roadless areas (WSA, Wilderness, potential, conservation/refugia, research natural areas) to wildlife, and how those benefits to wildlife will be diminished by the visual and sound presence of these machines across the landscape. 

Section 4.2.5 and sectio

analysis. 

Western Watersheds Project, Inc. 

The same goes for protection of sage grouse nesting and brood rearing areas. Where are the criteria for sage grouse habitats as regards maintaining forb, grass and shrub canopy cover and height that are ecologically necessary? Where are important wildlife areas that support sensitive species or those listed or proposed for listing under the ESA. 

As stated on page 2-14 o

Division of Wildlife ResoNational Sage-Grouse Hlocal sage-grouse workinsage-grouse populations for aiding in the manage

Western Wildlife Conservancy 

We categorically reject the philosophically unsophisticated idea enthroned in the federal bureaucracy that all values reduce to the varied preferences of human beings. To the contrary, we maintain that both biotic and a-biotic nature possess irreducible intrinsic value. In our view that human beings (including especially the employees of the Bureau of Land Management) have a moral duty to recognize and protect these values while giving proper weight to instrumental values, such as accessible mineral deposits, and various recreational values. Among these latter, those types of recreation that are most conducive to appreciation of the intrinsic values of the land, wildlife and cultural resources, which are typically 

Motorized and non-motoplanning process. The Dresource values are protmotorized access and re

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Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

least destructive to these resources and least obnoxious to quiet recreationists, ought to be accorded the highest priority. Note: This excludes ATV, ORV and OHV recreation. In our opinion, the Kanab RMP, especially under the “preferred” alternative, gives far too much weight to mineral exploration, livestock grazing and motorized recreation at the expense of intrinsic values and the experiences of quiet recreationists. It’s as if a fine acoustic guitar were given to a tribe of people who could conceive of no better use for it than firewood. 

William Hughes First, the Hog Canyon SRMA needs to have language added that would allow for 

possible expansion of the road system in the future. This is a tool that might be valuable in the future. 

Appendix K of the Draft 

criteria used to identify afuture. 

William Hughes Second, an SRMA should be added for the John R. Flat area per the suggestion 

of Kane County officials. 

Much of the John R. Flat 

Zion National Park Because of this we strongly suggest that as part of the Preferred Alternative for 

the Final Resource Management Plan (FRMP), BLM lands adjacent to the park (within 2-miles of the park boundary - refer to attached Map) be designated as Visual Resource Management (VRM) Class I. 

An arbitrary 2-mile buffemultiple-use mandate as reasonable range of alterepresents an alternate mof resolving issues raisealternatives began early scoping period and was coordination with our cooThe Draft RMP/EIS manexclusion areas, oil and 

Scenic Rivers, ACECs, nWSAs near the park inclresource uses address t

Zion National Park In additional we ask that these same lands be designated exclusion areas for all 

right-of-way and communication sites (e.g., cell phone towers) to protect these scenic vistas. 

An arbitrary 2-mile buffemultiple-use mandate as reasonable range of alterepresents an alternate mof resolving issues raisealternatives began early scoping period and was coordination with our cooThe Draft RMP/EIS manexclusion areas, oil and 

Scenic Rivers, ACECs, nWSAs near the park inclresource uses address t

Zion National Park Second, to protect the scenic integrity along the Highway 9 corridor from Mt. 

Carmel Junction to the east entrance of the park and from integral vistas within the park, it is important that the BLM designate the corridor and vistas within the 

An arbitrary 2-mile buffemultiple-use mandate as reasonable range of alte

179 
Public Comments and Responses - Kanab Draft RMP/EIS 

Commentor Comment C

view-shed from the park as VRM Class II. represents an alternate m

of resolving issues raisealternatives began early scoping period and was coordination with our cooThe Draft RMP/EIS manexclusion areas, oil and Scenic Rivers, ACECs, nWSAs near the park inclresource uses address t

Zion National Park In addition to Class II VRM designation, we ask as part of the Preferred 

Alternative for the FRMP that this corridor be designated as avoidance areas for all right-of-way and communication sites (e.g., cell phone towers) to protect the scenic vistas. 

An arbitrary 2-mile buffemultiple-use mandate as 

reasonable range of alterepresents an alternate mof resolving issues raisealternatives began early scoping period and was coordination with our cooThe Draft RMP/EIS manexclusion areas, oil and 

Scenic Rivers, ACECs, nWSAs near the park inclresource uses address t

Zion National Park As part of the Preferred Alternative for the FRMP, we strongly request that BLM 

lands within 2-miles of the park be closed to OHV use. This includes closing any roads that dead-end at the park boundary (refer to attached Map). 

An arbitrary 2-mile buffemultiple-use mandate as 

reasonable range of alterepresents an alternate mof resolving issues raisealternatives began early scoping period and was coordination with our cooThe Draft RMP/EIS manexclusion areas, oil and 

Scenic Rivers, ACECs, nWSAs near the park inclresource uses address t

Zion National Park As part of the Preferred Alternative for the FRMP, we strongly request that areas 

immediately adjacent to and near the park (within 2-miles of the park boundary - refer to attached Map) be designated: • closed to oil and gas leasing - designation should apply to both Federal surface/Federal minerals and . private surface/Federal minerals (split-estate); • closed to coal leasing; • withdrawn from locatable mineral entry; • closed to mineral material disposal; and • closed to nonAn arbitrary 2-mile buffe

multiple-use mandate as reasonable range of alterepresents an alternate mof resolving issues raisealternatives began early 

180 
Public Comments and Responses - Kanab Draft RMP/EIS 

181 

Commentor Comment C

energy mineral leasing . scoping period and was 

coordination with our cooThe Draft RMP/EIS manexclusion areas, oil and 

Scenic Rivers, ACECs, nWSAs near the park inclresource uses address t

Zion National Park In order to minimally protect the watersheds to help mitigate the influx of nonnative plant species into the park, we again ask as part of the Preferred 

Alternative for the FRMP that all lands, within 2-miles (at a minimum) of the park boundary be (refer to attached Map): • closed to all surface disturbing activities; and • that any restoration use only plant species native to the area. 

An arbitrary 2-mile buffemultiple-use mandate as reasonable range of alterepresents an alternate mof resolving issues raisealternatives began early scoping period and was coordination with our cooThe Draft RMP/EIS manexclusion areas, oil and 

Scenic Rivers, ACECs, nWSAs near the park inclresource uses address t

Zion National Park As part of the Preferred Alternative for the FRMP, we ask that the KFO designate 

specific roads and/or trails for mountain bike use. 

The route identification pnew routes. Appendix K, Draft RMP/EIS outlines tprocess is an implementmotorized route identificaaddress route/trail identifexplained in Appendix K
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 1

Land Ownership

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40

T

42

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43

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

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Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83) Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

BLM Wilderness Area

Bankhead-Jones Land Use Lands

Bureau of Land Management (BLM)

National Park Service (NPS)

Private

e[

Anazasi

Historical

Site

Box Death Hollow Wilderness

e[

Escalante Petrified

Forest State Park

Dixie National Forest

Dixie National Forest Bryce Canyon

National Park

Garfield County

Kane County

Dixie National Forest

e[

Coral Pink Sand

Dunes State Park

e[ Kodachrome

Basin State Park

Glen Canyon

National

Recreation Area

Ê

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

State

US Forest Service (USFS)

USFS Wilderness Area

State, County, City, Wildlife, Park

and Outdoor Recreation Areas
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 2

Mule Deer Habitat

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

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Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Ê

Summer

Winter

Year-long

Crucial

Substantial

Mule Deer Transition Areas

Water

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

State Highway

Source: Utah Division of Wildlife Resources 2006 0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Season Habitat Value

Surface disturbing activities are not excluded in these areas. All timing and controlled surface use

limitations are subject to waivers, exceptions, and/or modification identified in Appendix 3.
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 3

Elk Habitat

T

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

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Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Ê

Summer

Winter

Year-long

Crucial

Substantial

Water

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

State Highway

Source: Utah Division of Wildlife Resources 2006 0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Season Habitat Value

Surface disturbing activities are not excluded in these areas. All timing and controlled surface use

limitations are subject to waivers, exceptions, and/or modification identified in Appendix 3.
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 4

Pronghorn Habitat

T

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40

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

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Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Ê

Summer

Winter

Year-long

Crucial

Water

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

State Highway

Source: Utah Division of Wildlife Resources 2006 0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Season Habitat Value

Surface disturbing activities are not excluded in these areas. All timing and controlled surface use

limitations are subject to waivers, exceptions, and/or modification identified in Appendix 3.
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 5

Priority Areas for

Vegetation Treatment

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40

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42

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

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Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Ê

Water

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

State Highway

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Proposed RMP

Livestock Grazing Treatment

Wildlife Priority

Soils/Watershet

Areas by Allotment

Treatment Areas

Priority Treatment Areas
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 6

Visual Resource

Management

Proposed RMP

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40

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42

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

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Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Class II Kilometers

Class III

Class IV

Class I Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

!( Towns

Ê
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 7

Non-WSA Lands Managed

For Wilderness

Characteristics

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42

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

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Panguitch

Hatch

Alton

Glendale

Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

(/89

§ ̈¦15

Orderville

Canyon

Parunuweap Canyon

Moquith

Mountain

Upper Kanab Creek

East of Bryce

Ê

Non-WSA lands managed for Wilderness Characteristics

Land Acquired through West Desert Land Exchange Act of 2000

Existing Wilderness Study Areas

BLM Wilderness Area

§ ̈¦15

Interstate Highway

U.S. Highway

State Highway

Water

!( Towns Kanab Field Office

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Paria Canyon-Vermilion

Cliffs Wilderness

Proposed RMP
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 8

Special Recreation

Management Areas

Proposed RMP

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

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Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

Escalante

Kanab Community, Non Motorized RMZ

Kanab Community, OHV RMZ

North Fork Virgin River

Moquith Mtn, Non-Dunes Wooded RMZ

Moquith Mtn, Dunes RMZ

Ê

Orderville Canyon

Paria Canyon, Canyon RMZ

Paria Canyon, Uplands RMZ 0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 9

Off-Highway Vehicle

Area Designations

Proposed RMP

T

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

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?{

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Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Closed

Limited to Designated

Open

Kanab Field Office

Interstate Highway

Water

!( Towns

State Highway

U.S. Highway

Ê

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Roads and Trails
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 10

Route Designations

Proposed RMP

T

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38

39

40

T

42

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Closed

Limited

Open

BLM Managed Lands

Kanab Field Office

Interstate Highway

Water

!( Towns

State Highway

U.S. Highway

Ê

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 11

Right-Of-Way

Restrictions

Proposed RMP

T

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38

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40

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42

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

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?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Excluded from wind and

solar energy development

Avoidance

Exclusion

Seasonal Avoidance

BLM Managed Lands
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 12

Locatable Minerals -

Recommended

Withdrawals

Proposed RMP

T

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40

T

42

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Areas Recommended for

BLM Managed Lands

Wtihdrawal from Locatable

Mineral Entry
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 13

Areas Available for FLPMA

Section 203 Sales

Proposed RMP

T

31

S

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T

42

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Lands Available for

BLM Managed Lands

FLPMA Section 203 Sales
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 14

Oil and Gas Leasing

Proposed RMP

T

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T

42

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R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Kanab Field Office

Interstate Highway

U.S. Highway

!( Towns

Water

State Highway

Closed to Leasing

Open to Leasing Subject to

Major Constraints

Open to Leasing Subject to

Moderate Constraints

Open to Leasing Subject to

Standard Terms and Conditions

Ê
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 15

Areas Available for

Further Coal Leasing

Consideration

Proposed RMP

T

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42

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43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Known Recoverable Coal

Federal Coal Suitable for

Federal Coal Unsuitable for

Resource Area

Further Consideration

Further Consideration
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 16

Mineral Materials

(Salable) Disposal

Proposed RMP

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Closed to Mineral

BLM Managed Lands

Minerals (Salable)
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 17

Areas of Critical

Environmental Concern

Proposed RMP

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Cottonwood Canyon ACEC

BLM Managed Lands
(/89

(/89

(/89

(/89

§ ̈¦15

(/89

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

Ê

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Orderville/

Esplin Gulch

Meadow Creek/

Mineral Gulch

North Fork

Virgin River

Paria River

Suitable Wild and

Scenic Rivers

Map 18

Proposed RMP

East Fork

Virgin River

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

Scenic

Wild 0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers
(/89

(/89

(/89

(/89

§ ̈¦15

(/89

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

Ê

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

General Surface

Disturbance Restrictions

Map 19

Proposed RMP

Kanab Field Office

Interstate Highway

U.S. Highway

Water

!( Towns

State Highway

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

No Surface Disturbing Actions

Seasonal Limitations

Wilderness Study Areas

BLM Wilderness Area
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 20

EPCA Analysis

Proposed RMP

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Kanab Field Office

Interstate Highway

U.S. Highway

!( Towns

Water

State Highway

Ê

Closed to Leasing

No Surface Occupancy

Standard Leasing Terms

*There are some CSU areas overlaid by seasonal limitations,

but for purposes of this analysis the seasonal limitations take

precedence.

Cumulative Timing Limitations <3 Months

Cumulative Timing Limitations 3-6 Months

Cumulative Timing Limitations 6-9 Months

Cumulative Timing Limitations >9 Months

Controlled Surface Use*
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 21

Surface Geology

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Source: Utah Geological Survey

P2: Kaibab, Toroweap, Hermit

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

Tr1 : Moenkopi

J1: Carmel-Entrada

K1 : Dakota, Tropic, Cedar Mountain

K2 : Straight Cliffs

K3 : Wahweap, Kaiparowits

J2: Morrison

JTr: Glen Canyon Group

(Kayenta, Moenave, Navajo, Wingate)

Tr2 : Chinle

Tma, Tmb, Tmr, Tmv, Tov, Tpb,

Tpr, Tvu: Tertiary Volcanic Rocks

Qb: Volcanic Rocks (Mostly Basalt)

T5 : Sevier River

T4 : Brianhead Group

T1 : Claron

QT, Qa, Qao, Qe, Qg, Qls:

Quaternary Deposits

TK : Canaan Peak, Grand Castle, Pine Hollow

Ê
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 22

Physiographic Sub-Units

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

(/89

Province

Sub-Unit

Grand Staircase

Henry Mountains

Kaiparowits Plateau - Escalante Bench

Slickrock

Southern High Plt. - Lava covered

Southern High Plt. - Limestone Capped

Circle Cliffs -

Teasdale Anticlines

Ê

Source: Utah Automated

Geographic Reference Center

Stokes 1986

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Colorado Plateau

Basin & Range -

Colorado Plt. Transition

Tushar Volcanic

Lake

Powell

§ ̈¦15

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 23

Precipitation

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Source: Utah State

University Climate Center

Ê

0-8

8-12

12-16

16-20

20-24

24-32

32+

Average Annual Rainfall (inches)

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

!( Towns
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 24

Areas with Fragile Soils

or Relict Vegetation

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Fragile Soils

Relict Vegetation

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

!( Towns
East Fork

Sevier River

(16030002)

East Fork

Sevier River

(16030002)

Upper Sevier

River

(16030001)

Upper Sevier

River

(16030001)

Kanab Creek

(15010003)

Kanab Creek

(15010003)

Escalante

River

(14070005)

Escalante

River

(14070005)

Upper Sevier

River

(16030001)

Upper Sevier

River (16030001)

Escalante

River

(14070005)

Escalante

River

(14070005)

Kanab Creek

(15010003)

Kanab Creek

(15010003)

East Fork

Sevier River (16030002)

East Fork

Sevier River

(16030002)

Upper Virgin River

(15010008)

Upper Virgin River

(15010008)

Escalante

River (14070005)

Escalante

River

(14070005)

Lower Lake

Powell

(14070006)

Lower Lake

Powell

(14070006)

Fremont River

(14070003)

Fremont River

(14070003)

Paria

River

(14070007)

Paria

River

(14070007)

Upper

Lake

Powell

(14070001)

Upper

Lake

Powell

(14070001)

Paria River

(14070007)

Paria River

(14070007)

Fremont River

(14070003)

Fremont River

(14070003)

Ft. Pierce

Wash

(15010009)

Ft. Pierce

Wash

(15010009)

Escalante

Desert

(16030006)

Escalante

Desert

(16030006)

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 25

Fourth-Order

Watersheds

(Hydrologic

Sub-Basins)

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡

?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

?|

?|

?|

?y ?y

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

(/89

Garfield County

Kane County

Ê

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Lake

Powell

Watershed Boundaries

Interstate Highway

State Highway

U.S. Highway

Water

!( Towns

Kanab Field Office

Source: National Hydrography Dataset

§ ̈¦15
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 26

Vegetation Communities

and Associations

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Aspen

Desert Scrub

Mixed Conifer

Non-Vegetated

Oak and Mountain Shrub

Pinyon-Juniper Woodland

Ponderosa Pine

Sagebrush Steppe

Other Water

!( Towns

Interstate Highway

U.S. Highway

State Highway

Kanab Field Office
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 27

Inventoried Riparian/

Wetland Areas

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

$ Proper Functioning Condition

" Functioning at Risk

# Non-Functioning

Riparian/Wetland areas

BLM land

Kanab Field Office

Water

!( Towns

Interstate Highway

U.S. Highway

State Highway
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 28

Mexican Spotted Owl

Critical Habitat

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Mexican Spotted Owl

BLM managed land

Kanab Field Office

Water

!( Towns

Interstate Highway

U.S. Highway

State Highway

Critical Habitat
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 29

Greater Sage-Grouse

Brooding and Winter

Habitat

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Source: Utah Division of Wildlife Resources 2006

Ê

Greater Sage-Grouse

Greater Sage-Grouse

Winter Range

Brooding Areas

Surface disturbing activities are not excluded in these areas. All timing and controlled surface use

limitations are subject to waivers, exceptions, and/or modification identified in Appendix 3.

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 30

Desert Bighorn

Sheep Habitat

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Source: Utah Division of Wildlife Resources 2006

Ê

Habitat Value

Crucial

High

Season

Year-long

Surface disturbing activities are not excluded in these areas. All timing and controlled surface use

limitations are subject to waivers, exceptions, and/or modification identified in Appendix 3.

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 31

Paleontological Resource

Potential

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Source: Utah BLM

Ê

Paleontologic Sensitivity*

High

Medium

Low

No Data !( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

*Please note that the dataset used to create

this model lumps the Kayenta, Moenave, Navajo,

and Wingate formations into the Glen Canyon

Group labeled here as Medium. The Navajo and

Wingate Formations rate as Medium while the

Moenave and Kayenta should rate as high.
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 32

Non-WSA Lands

Inventoried for

Wilderness

Characteristics

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale

Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Land Acquired through West

Evaluated Areas Determined

Non WSA Lands with

Existing Wilderness Study Areas

BLM Wilderness Area !( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

Desert Land Exchange Act of 2000

not to have Wilderness Characteristics

Wilderness Characteristics

Orderville

Canyon

Parunuweap Canyon

Canaan

Mountain

Moquith

Mountain

Upper Kanab Creek

East of Bryce

North Escalante Canyons

Carcass Canyon

Black Hills

Wide Hollow

Little Valley Canyon

Heaps Canyon

Vermilion

Cliffs

Paria/Pine Hollow

Paria Canyon-Vermilion

Cliffs Wilderness
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 33

Livestock Grazing

Allotments

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Source: Utah BLM

Ê

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

Allotments Administered by

the Kanab Field Office:

Kanab Field Office

Allotments Administered by Others:

Arizona Strip Field Office

Cedar City Field Office

Dixie National Forest

Richfield Field Office

St. George Field Office

National Monument

Grand Staircase - Escalante
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 34

Inventoried Routes

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Ê

Inventoried Routes

BLM Managed Lands

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 35

Oil and Gas

Development Potential

and Existing Oil and

Gas Leases and Fields

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Source: BLM 2005e

Ê

High Development Potential

Moderate Development Potential

Low Development Potential

Restricted Land (Low Development Potential)

Existing Oil & Gas Leases

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

Oil & Gas Potential
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 36

Coal Development

Potential

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Source: BLM 2005e

Ê

High Development Potential

Moderate Development Potential

Low Development Potential

Restricted Land (Low Development Potential)

Coal Outcrop

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

Coal Potential

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 37

Gypsum Development

Potential

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Source: BLM 2005e

Ê

Low Development Potential

Restricted Land

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

Gypsum Potential

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

(Low Development Potential)
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 38

Sand and Gravel

Development Potential

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Source: BLM 2005e

Ê

!( Sand and Gravel Pit or Prospect

High Development Potential

Moderate Development Potential

Restricted Land

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

Sand and Gravel Potential

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

(more than 3 miles from highway)

(less than 3 miles from highway)

(Low Development Potential)
!(

!(

!(

!(

!(

#*

#*#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

#*

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 39

Stone and Clay

Development Potential

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Source: BLM 2005e

Ê

#* Stone Mine or Prospect

Moderate Stone Development Potential

!( Clay Mine or Prospect

Restricted Land (Low Development Potential)

Moderate Clay Development Potential

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway

Sand and Gravel Potential

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers
North Fork

Virgin River

Orderville

Canyon

Parunuweap

Canyon

Canaan

Mountain

Moquith

Mountain Paria Canyon-Vermilion

Cliffs Wilderness

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 40

Wilderness and

Wilderness Study Areas

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y ?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Ê

Wilderness Study Areas

BLM Wilderness Area

Land Acquired through Utah

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway 0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

West Desert Land Exchange Act of 2000
Zion Park Mt. C armel

Johnson Cy n Alton Amphithea et r

Coral Pink San d

Dunes

Markag unt

Brianhead - Panguitch Lak e

Northe r n

Route

Armij o Route

Highway 12

Highway 12

Highway 12

No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Proposed Resource Management Plan - Final Environmental Impact Statement

Kanab Field Office, UT

Map 41

Byways, Backways,

and Historic Trails

T

31

S

32

33

34

35

36

37

38

39

40

T

42

S

43

44

R 9W 8 7 6 5 4 1/2 4 3 2 R 1W R 1E 2 3 4 5 6 7 8 9 R10E

?¦

?¡ ?Ñ

?¡

?y

?{

?|

Panguitch

Hatch

Alton

Glendale

Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

Garfield County

Kane County

Garfield County

Kane County

?|

?|

?|

?y

?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

§ ̈¦15

(/89

Ê

Scenic Backways

Scenic Byways

Old Spanish Trail

!( Towns

Kanab Field Office

Interstate Highway

U.S. Highway

Water

State Highway 0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers
No warranty is made by the Bureau of Land Management as to the accuracy, reliability, or

completeness of this data for individual use or aggregate use with other data.

GRAND STAIRCASE - ESCALANTE

NATIONAL MONUMENT

Bureau of Land Management

U.S. Department of the Interior

Kanab Draft Resource Management Plan - Draft Environmental Impact Statement

Kanab Field Office, UT

T

27

S

31

32

33

35

38

39

T

42

S

43

44

R 11W 5 4 1/2 R 4W 2 1 R 1E 2 3 4 5 7 9 10 11

12 14 17 18 R19E

?¦

?¡

?¡ ?Ñ

?y

?{

Panguitch

Hatch

Alton

Glendale

Orderville

Mt Carmel Jct

Kanab

Tropic

Big Water

Escalante

Boulder

?|

?÷

?y

Lake

Powell

Projection: UTM, Zone 12 North

Datum: North American Datum of 1983 (NAD83)

Kanab Field Office, GIS Program

(/89

(/89

(/89

(/89

(/89

e[ Anazasi

Historical

Site

Box Death Hollow Wilderness

e[

Escalante Petrified

Forest State Park

Dixie National Forest

Dixie National Forest

Bryce Canyon National Park

Garfield County

Kane County

e[

Coral Sand Dunes

State Park

e[Kodachrome

Basin State Park

Glen Canyon National Recreation Area

Zion

National

Park

Garfield County

Kane County

?y

13 15 16 8

?|

?|

?¡10 9 8 7 6

?m

§ ̈¦15

?§ ?¦

?Ð

(/89

?§

? ̈

?Ð

?a

?Ø

?a ?a

?|

?a

?ë

?ë

?ë

?÷

?ë

?2

Garfield County

San Juan County

Garfield County

Wayne County

Wayne County

San Juan County

Beaver County

Piute County

Beaver County

Iron County

Wash ni gton County

Kane County

40

37

36

34

30

29

28

41

Capitol Reef National Park

Navajo Indian Reservation

State

US Forest Service (USFS)

USFS Wilderness Area

Water

State, County, City, Wildlife, Park

and Outdoor Recreation Areas BLM Wilderness Area

Bankhead-Jones Land Use Lands

Bureau of Land Management (BLM)

Private

National Park Service (NPS)

Indian Reservation

Kanab Field Office

Interstate Highway

Water

!( Towns

Socioeconomic Study Area

Major Road

0 2.5 5 10 15 20 25

Miles

0 5 10 20 30 40 50

Kilometers

Socioeconomic

Study Area

Map 42

Ê