Chapter 1 • Purpose and Need

© Cameron Rognan
BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 3

Chapter 1: Purpose and Need

1.0 INTRODUCTION

The Bureau of Land Management’s 

(BLM) St. George Field Office (SGFO) 

administers approximately 629,000 surface acres of public lands in Washington 

County, Utah. These lands are located 

at the convergence of three distinctive 

ecoregions, the Mojave Desert, Great 

Basin, and Colorado Plateau, where many 

native plants and animals have evolved 

into unique species, some found nowhere 

else on earth. Important evidence of 

Earth’s geologic history and past human 

cultures is also preserved on public lands 

in Washington County, making these 

some of the most sensitive lands managed by BLM.

The Beaver Dam Wash National 

Conservation Area (Beaver Dam Wash 

NCA) and the Red Cliffs National 

Conservation Area (Red Cliffs NCA) are 

located within the administrative boundaries of the SGFO. Congress established 

the two NCAs when, on March 30, 2009, 

President Barack Obama signed into law 

the Omnibus Public Land Management 

Act of 2009 (16 U.S.C. 7202, Public 

Law 111-11). Title I, Subtitle O of the 

Omnibus Public Land Management Act 

concerns public lands managed by BLM 

in Washington County, Utah (Appendix 

A), and is hereinafter referred to 

as OPLMA.

The two NCAs were created to “conserve, 

protect, and enhance...the ecological, 

scenic, wildlife, recreational, cultural, historical, natural, educational, and scientific resources" of the public lands (OPLMA 

Sections 1974 and 1975). In October of 

2009, Congress modified the boundaries 

and reduced the acreage of the Beaver 

Dam Wash NCA by 5,000 acres, through 

a “legislative rider” to the 2010 Interior 

and Environment Appropriations Bill 

Conference Agreement. The change was 

made to exclude a designated utility corridor from the NCA, to facilitate management of the corridor for future utility 

line developments.

This chapter provides detailed information on the purpose and need for this 

land use-level planning process; the purpose and significance of the new NCAs; 

and the planning and management 

issues, identified by BLM, other federal 

agencies, state and local governments, 

Indian tribes, and the public, considered 

in development of the land use plans.

INTRODUCTION

What Are National 

Conservation Areas?

National Conservation Areas 

(NCAs) are Congressionallydesignated units of 

public land, managed by 

BLM within its National 

Landscape Conservation 

System, known as National 

Conservation Lands. 

National Conservation 

Lands also include National 

Monuments, Wilderness and 

Wilderness Study Areas, Wild 

and Scenic Rivers, National 

Scenic and Historic Trails, 

and other areas designated 

by acts of Congress or 

Presidential Proclamation 

(under the authority of the 

Antiquities Act of 1906) 

to be administered for 

conservation purposes. 

BLM is the only agency in 

the country that manages 

National Conservation Areas.

Photo 1-1 Navajo Sandstone Cliffs of the Red Cliffs NCA
4 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 5

1.1 PURPOSE AND NEED FOR 

RESOURCE MANAGEMENT 

PLANS FOR THE NCAS AND 

AN AMENDMENT TO SGFO 

RESOURCE MANAGEMENT PLAN

The purpose of this planning process is to 

satisfy specific mandates from OPLMA 

that directed the Secretary of the Interior 

(Secretary), through BLM, to develop 

comprehensive plans for the long-term 

management of Beaver Dam Wash NCA 

and Red Cliffs NCA. The legislation also 

required BLM to take actions and make 

land use allocations on public lands in 

Washington County that require the St. 

George Field Office Record of Decision 

(ROD) and Resource Management Plan

(RMP approved in 1999, amended in 

2001) be amended. The three planning 

efforts were initiated concurrently, thereby facilitating the preparation of a single 

Environmental Impact Statement (EIS) to 

disclose the environmental consequences 

of implementing the two new land use 

plans and an amendment to the current 

SGFO RMP.

1.1.1 Beaver Dam Wash NCA 

Resource Management Plan

Section 1975 (d) (1) of OPLMA mandates the Secretary, through BLM, to 

develop a comprehensive (resource) 

management plan for the Beaver Dam 

Wash NCA to achieve the following 

Congressionally-defined purpose:

To conserve, protect and enhance for 

the benefit and enjoyment of present 

and future generations the ecological, 

scenic, wildlife, recreational, cultural, 

historical, natural, educational, and 

scientific resources of the Beaver 

Dam Wash National Conservation 

Area. (OPLMA Section 1975 (a))

Land use planning goals, objectives, and 

management decisions approved in the 

RMP for the Beaver Dam Wash NCA 

must be consistent with the purposes, 

authorized uses, and other mandates 

from OPLMA. The mandates of OPLMA 

emphasize conservation, protection, 

enhancement, and restoration of public 

land values as the designation purposes 

for the NCA. 

Regarding authorized uses, OPLMA at 

Section 1975 (e) (2)specifies that “the 

Secretary shall only allow uses of the 

National Conservation Area that the 

Secretary determines would further 

the purpose” for which the NCA was 

designated. OPLMA Section 1975 (g) 

(1) specifically restricts allowable uses 

by withdrawing the public lands of this 

NCA, subject to valid existing 

rights, from:

All forms of entry, appropriation, and 

disposal under the public land laws;

Location, entry, and patenting under 

the mining laws; and

Operation of the mineral leasing, 

mineral materials, and geothermal 

leasing laws.

At Section 1975 (e) (3), Congress addressed motorized vehicle access and 

travel in the Beaver Dam Wash NCA 

by designating three areas (labeled 

“Designated Road Areas” on the legislative map of the NCA) where motorized 

vehicle travel is permitted only on the 

roads identified on that map. In areas 

outside of the “Designated Road Areas”, 

motorized vehicle travel is limited to 

roads to be designated by BLM through 

a planning process. There is an exception 

from the motorized travel restrictions 

in the Act for cases where motorized 

vehicles are needed for administrative 

purposes or to respond to an emergency.

1.1.2 Red Cliffs NCA Resource 

Management Plan

Section 1974 (d) (1) of OPLMA mandates the Secretary, through BLM, to 

develop a comprehensive (resource) 

management plan for the Red Cliffs NCA 

to achieve the following Congressionallydefined purposes:

To conserve, protect, and enhance for 

the benefit and enjoyment of present 

and future generations the ecological, 

scenic, wildlife, recreational, cultural, 

historical, natural, educational, and 

scientific resources of the National 

Conservation Area; and

To protect each species that is located in the National Conservation 

Area; and listed as a threatened or 

endangered species on the list of 

threatened species or the list of endangered species published under...

the Endangered Species Act of 1973. 

(OPLMA Section 1974 (a))

Land use planning goals, objectives, and 

management decisions approved in the 

RMP for the Red Cliffs NCA must be 

consistent with the purposes, authorized 

uses, and other mandates from OPLMA. 

The mandates of OPLMA emphasize 

conservation, protection, enhancement, 

and restoration of public land values as 

the designation purposes for the NCA.

Regarding authorized uses, the OPLMA 

Section 1974 (e) (2) specifies that “the 

Secretary shall only allow uses of the 

National Conservation Areas that the 

Secretary determines would further 

the purpose” for which the NCA was 

designated. OPLMA Section 1974 (g) 

(1) specifically restricts allowable uses 

PURPOSE AND NEED FOR NCA RMPS AND AMENDMENT PURPOSE AND NEED FOR NCA RMPS AND AMENDMENT

Paleontological Resource 

Preservation 

Paleontological Resource 

Preservation became law 

on March 30, 2009, as part 

of the Omnibus Public 

Lands Act of 2009, whereby 

Congress recognized the 

value of paleontological 

resources as a natural legacy 

and an irreplaceable part of 

America’s heritage.

What is a Resource 

Management Plan?

Land use plans for BLMmanaged public lands are 

referred to as Resource 

Management Plans or RMPs. 

They establish management 

goals, objectives, and desired 

outcomes for public lands 

and resource values. The 

measures needed to achieve 

these goals and objectives are 

shown as authorized uses and 

management actions.

Photo 1-2 Wildlife Resource: Mule Deer in the Beaver Dam Wash NCA Photo 1-3 Scientific Resource: A Kayentapus Dinosaur Track in the Red Cliffs NCA
6 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 7

by withdrawing the public lands of this 

NCA, subject to valid existing 

rights, from:

All forms of entry, appropriation, and 

disposal under the public land laws;

Location, entry, and patenting under 

the mining laws; and

Operation of the mineral leasing, 

mineral materials, and geothermal 

leasing laws.

1.1.3 Amendment to SGFO RMP

For BLM to satisfy other mandates 

from OPLMA, the SGFO RMP must be 

amended through a land use planning 

process. Each of these mandates is described in detail below, with information 

on how the Amendment was drafted to 

address the Congressional requirements.

1.1.3.1 Designation of Areas of Critical 

Environmental Concern

Section 1979 (a) (1) and (2) of OPLMA, 

directs the Secretary, through BLM, to 

“identify areas located in the County 

where biological conservation is a priority; and undertake activities to conserve 

and restore plant and animal species and 

natural communities within such areas.”

Satisfying this legislative mandate from 

OPLMA could be accomplished through 

the administrative designation of new 

areas of critical environmental concern 

(ACECs) on public lands, to direct special 

management attention to biological 

resources and natural communities that 

meet one or more of the following criteria 

for both relevance and importance (BLM 

Manual 1613.1): 

Relevance: An area meets the “relevance” 

criteria if it contains one or more of the 

following:

▶ A fish and wildlife resource (including but not limited to habitat for 

endangered, sensitive, or threatened 

species, or habitat essential for 

maintaining species diversity).

▶ A natural process or system (including but not limited to endangered, sensitive, or threatened plant 

species, rare, endemic, or relic 

plants or plant communities which 

are terrestrial, aquatic, or riparian or 

rare geological feature).

Importance: The resource, system, or 

process described above must have substantial significance and value in order to 

satisfy the importance criteria. This generally means that the resource, system, or 

process is characterized by one or more 

of the following:

▶ Has more than locally significant 

qualities that give it worth, consequence, meaning, distinctiveness, or 

cause for concern, especially compared to any similar resource.

▶ Has qualities or circumstances 

that make it fragile, sensitive, rare, 

irreplaceable, exemplary, unique, 

endangered, threatened or vulnerable to adverse change.

▶ Has been recognized as warranting 

protection in order to satisfy national priority concerns or to carry out 

the mandates of the Federal Land 

Policy and Management Act.

Pursuant to the Federal Land Policy and 

Management Act of 1976 (43 U.S.C. 1701 

et seq., PL 94-579, FLPMA) at Section 

202 (c) (3), the identification, evaluation, and designation of ACECs must be 

accomplished through a land use planning process. In order to administratively designate new ACECs for relevant 

and important biological resources and 

natural communities, SGFO RMP must 

be amended.

1.1.3.2 Management of Priority 

Biological Conservation Areas

BLM could also amend the SGFO RMP 

to achieve biological conservation objectives, as directed by OPLMA, by identifying priority biological conservation areas 

and proposing management decisions for 

those areas where biological resources 

are in need of protection, but do not 

meet one or more of the criteria for both 

relevance and importance required for 

ACEC designation. Changes to existing 

PURPOSE AND NEED FOR NCA RMPS AND AMENDMENT

goals, objectives, and management decisions from the SGFO RMP for specific 

areas of public lands in Washington 

County can only be made through land 

use planning, requiring that the SGFO 

RMP be amended.

During this planning effort, BLM solicited input from federal agencies, state 

and local governments, Indian tribes, 

and the public, to identify public lands 

in Washington County where biological 

conservation is a priority and where new 

ACECs should be designated or other 

special management applied to conserve 

and restore plant and animal species and 

natural communities.

1.1.3.3 Off-Highway Vehicle Area 

Designations

Section 1977 (b) (1) of OPLMA, directed 

the Secretary, through BLM, to “develop 

a comprehensive travel [and transportation] management plan” (TMP) for 

public lands in Washington County. 

Prior to the development of this plan, 

the SGFO RMP must be amended to 

modify certain existing off-highway 

vehicle (OHV) area designations (open, 

limited or closed), to be in compliance 

with the Code of Federal Regulations 

(CFR) at 43 CFR 8340.0-5, (f), (g), and 

(h) respectively and 43 CFR 8342.1 (a-d) 

and related agency policies. Area designations provide the framework within 

which individual route designations are 

made, as BLM prepares the legislativelymandated travel management plan for 

public lands in Washington County. 

Draft RMPs for the new NCAs and a 

Draft Amendment to the SGFO RMP 

have been prepared to satisfy BLM’s 

specific land use planning mandates from OPLMA. A single Draft 

Environmental Impact Statement (Draft 

EIS) has been completed to disclose the 

potential environmental consequences 

of implementing the goals, objectives, 

and management decisions of the draft 

plans, in compliance with the National 

Environmental Policy Act of 1969 (42 

U.S.C. 4321 et seq.) (NEPA) relating to 

major federal actions.

1.2 PLANNING AREAS AND MAPS

1.2.1 Beaver Dam Wash NCA

The Beaver Dam Wash NCA (Photo 1-4) 

is located in the southwestern corner of 

Washington County, bounded on the 

west by the Nevada state line and by the 

Arizona state line on the south (Map 

1-1). The public lands of the NCA remain 

relatively remote and isolated, as Old 

Highway 91 is the only paved roadway 

through the Beaver Dam Wash NCA.

The NCA is within an ecological transition zone between the hot, arid Mojave 

Desert and the cooler Great Basin Desert. 

Desert shrubs grow at the lower elevations of the NCA and provide critical 

habitat for the desert tortoise and other 

wildlife typically associated with the 

Mojave Desert. Joshua trees and dense 

stands of blackbrush cover the foothills of the Beaver Dam Mountains, the 

dominant landform of the eastern NCA. 

Surface water flows seasonally in Beaver 

Dam Wash, a prominent feature of the 

NCA, sustaining riparian vegetation that 

provides important habitat for seasonal 

migratory birds and permanent wildlife 

residents of this NCA.

PLANNING AREAS AND MAPS

What is a Comprehensive 

Travel and Transportation 

Management Plan 

(TMP)?

A TMP is an implementation 

or “activity” level plan that 

addresses access needs for 

all public land uses, taking 

into account BLM’s legal 

requirements to protect 

sensitive natural and cultural 

resources. 

In the TMP, every route on 

public lands in Washington 

County will be designated as 

open, closed, or limited to 

motorized vehicle travel. In 

open areas, motorized crosscountry travel is permitted. 

Closed areas are not available 

for any motorized travel, 

while in limited areas 

motorized travel is restricted 

to designated routes and 

trails.

Joshua Tree

The iconic Joshua tree, Yucca 

brevifolia, is a member of the 

Agave family. In the mid19th century, as Mormon 

immigrants made their 

way west, they named the 

tree after the biblical figure, 

Joshua, as the outstretched 

branches resembled a figure 

in prayer. (NPS 2014)

Photo 1-4 Joshua Tree Dominated 

Landscape in the Beaver Dam Wash NCA
LINCOLN CO

WASHINGTON CO

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8 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 19

MAP 1-1

Approximately 5 miles of the legislativelydepicted alignment for the Northern 

Route of the Old Spanish National 

Historic Trail (OST) crosses north-south 

through the NCA, generally following Old 

Highway 91 (Map 1-1). In 2002, Congress 

designated several branches of the OST 

as America’s 15th National Historic Trail 

(Public Law (P. L.)107-325) through an 

amendment to the National Trail System 

Act. This designation acknowledged the 

significant role that this trail network 

played in the exploration and settlement 

of the Intermountain West and southern 

California. Trail branches cross northern 

New Mexico, southwestern Colorado, 

nearly the entire length of Utah, southern 

Nevada, and southern California.

The Beaver Dam Wash NCA is com-

prised of approximately 63,480 acres of 

BLM-administered surface acres. Within 

the boundaries of the NCA are state and 

private lands; acreage totals for all lands 

are shown in Table 1-1. Management 

goals, objectives, and actions proposed 

in the RMP apply only to the BLMadministered public lands of the NCA. 

Acquired lands would be managed con-

sistent with RMP decisions.

1.2.2 Red Cliffs NCA

The Red Cliffs NCA is comprised of 

approximately 44,859 acres of BLMadministered surface acres in southcentral Washington County (Map 1-2). 

Within the boundaries of the NCA are 

state and private lands; acreage totals 

for all lands are shown in Table 1-2. 

Management goals, objectives, and ac-

tions proposed in the RMP apply only to 

the BLM-administered public lands of 

the NCA. Acquired lands would be man-

aged consistent with RMP decisions.

In contrast to the remote and unde-

veloped setting of Beaver Dam Wash 

NCA, the public lands of Red Cliffs 

NCA are within the annexation zones of 

Washington County’s five largest cities: 

Hurricane, Ivins, Santa Clara, St. George, 

and Washington. Residential and rural 

residential subdivisions, light industrial 

areas, commercial and retail businesses, 

and I-15 abut the southern, western and 

eastern boundaries of the NCA. More 

than 130 miles of designated hiking, 

mountain biking, and equestrian trails 

are available for public use in the Red 

Cliffs NCA. The Red Cliffs NCA also 

includes the Red Cliffs Recreation Area, 

a developed recreation fee site that BLM 

has managed for camping and day use 

since the mid-1960s.

Two designated Wilderness areas are 

totally or partially within the bound-

aries of the Red Cliffs NCA. The ap-

proximately 11,668 acre Cottonwood 

Canyon Wilderness, included in the 

National Wilderness Preservation System 

(Wilderness System) in 2009 through 

OPLMA, is located entirely within 

the Red Cliffs NCA. It shares a com-

mon boundary with a portion of the 

Cottonwood Forest Wilderness, man-

aged by the Pine Valley Ranger District 

of the Dixie National Forest, also added 

to the Wilderness System by OPLMA. 

Approximately 8,321 acres of the 18,689 

acre Red Mountain Wilderness, included 

in the Wilderness System in 2009, are 

located within the Red Cliffs NCA. 

Hikers, backpackers, and equestrians 

PLANNING AREAS AND MAPS

“The richest values 

of wilderness lie not 

in the days of Daniel 

Boone, nor even in the 

present, but rather in 

the future.”

–Aldo Leopold, 

Conservationist, 

1887-1948

Agency or Entity Acre

BLM 63,480

Private 2,127

State of Utah 6,492

Total 72,099

Agency or Entity Acre

BLM 24,870

BLM Wilderness Areas 19,989

Private 2,631

State of Utah 13,735

Total 61,225

Table 1-1 Surface Acre Administration in 

Beaver Dam NCA

Table 1-2 Surface Acre Administration in 

Red Cliffs NCA
Red Cliffs

National Conservation

Area

M o u n t a i n s R e d

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S o u t h H i l l s

White Hills

Boomer Hill

Canyon

Municipal Airport

Bloomington

RadioTower

Webb

Gag ni g Station

Hospital

College Dixie

Black Ridge

South Black Rocks

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Warner

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East Valley

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Washington Hollow

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Harr si bu gr Bench

Sandstone Mountain

Sand Dunes

Sand Dunes

Sand Dunes

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1902

1085

935

1104

903

1227

1004

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1016

1002

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Leeds

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Washington

St. George

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some misalignment of data layers.

No warranty is made by the BLM for use of

the data for purposes not intended by the BLM.

Note: Decisions in this document

only apply to BLM lands

10 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 11

MAP 1-2

enjoy outstanding primitive recreation, 

opportunities for solitude, and natural 

quiet within the Cottonwood Canyon 

and Red Mountain Wilderness areas, just 

minutes from the most urbanized areas 

of Washington County.

The public lands of the Red Cliffs NCA 

comprise approximately 70% of the land 

base of the approximately 62,000 acre, 

multi-jurisdictional Red Cliffs Desert 

Reserve (Reserve). The Reserve was 

established by Washington County’s 

multi-species Habitat Conservation Plan 

(HCP), approved by the United States 

Fish and Wildlife Service (USFWS) 

in 1995. In 1996, BLM, USFWS, the 

State of Utah, Washington County, 

and the City of Ivins signed an HCP 

Implementation Agreement that specified the obligations and responsibilities 

of the governmental entities that managed lands within the Reserve.

The Reserve’s land base encompasses 

designated critical habitat for the 

federally-listed threatened Mojave 

desert tortoise (Photo 1-5) within the 

Upper Virgin River Recovery Unit. 

This recovery unit was identified as the 

smallest and most at-risk recovery unit 

within the desert tortoise’s range by the 

Mojave Desert Tortoise Recovery Plan

(USFWS 1994, revised 2011). Since its 

establishment in 1995, the multi-agency 

management of the Reserve’s land base 

has emphasized the protection of habitat and tortoise populations, through 

restrictions on land uses and human 

activities. In 1996, Washington County 

was issued an Incidental Take Permit 

(ITP) authorizing the development or 

“take” of approximately 12,264 acres 

of non-federal lands in critical habitat 

and the loss of 1,169 tortoises, based on 

the mitigation afforded by restrictive 

management of the Reserve and other 

commitments made through the HCP 

and Implementation Agreement.

1.2.3 Amendment to the SGFO RMP 

The planning area for the Amendment to 

the SGFO RMP includes the surface acres 

managed by the SGFO in Washington 

County (Map 1-3). Other federal, state, 

and tribal-managed lands, as well as 

private property, occur within the planning area and those acres are displayed in 

Table 1-3. Management goals, objectives, 

and actions proposed in the amendment 

to the SGFO RMP apply only to BLMadministered public lands.

In Washington County, the Southern 

Basin and Range and Colorado Plateau 

physiographic provinces converge, 

separated by a transition zone bounded 

on the east by the Hurricane Fault and 

on the west by the Gunlock Fault. This 

convergence of major landforms creates 

the scenic vistas that typify southwestern 

Utah. Zion National Park and the Pine 

Valley Mountains of the Dixie National 

Forest define the eastern and northern 

boundaries of the county. To the west lie 

the valleys and mountains of Nevada, 

while the undeveloped expanses of the 

Arizona Strip are visible immediately to 

the south. Elevations range from approximately 2,200 feet at the Arizona state line 

PLANNING AREAS AND MAPS

Mojave Desert Tortoise

Gopherus agassizii has a 

lifespan of 50 to 80 years and 

can reach the size of a large 

dinner plate. Over ninety-five 

percent of its time is spent 

underground to escape the 

heat of summer and the cold 

of winter. The desert tortoise's 

underground home is a deep 

(three to six feet) burrow, 

which they dig themselves. 

Winters are spent in a torpid 

state (not a true hibernation) 

in the burrow, but come 

spring they are most active, 

seeking food and water. 

Agency or Entity Acre

BLM 628,790

Indian Reservation 28,830

State 88,700

NPS 141,990

USFS 423,130

Private 262,440

Total 1,573,880

Photo 1-5 Mojave Desert Tortoise, 

Federally-Listed Threatened Species

© Cameron Rognan

Table 1-3 Surface Acre Administration in 

Washington County, Utah
U T A H

A R I Z O N A

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A D A V E N

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t National Conservation Area Boundary

Planning Area BoundaryState BoundaryWild and Scenic RiversOld Spanish National Historic Trail

BLM Wilderness AreaBureau of Land Management (BLM)Indian Reservation (IR)National Park Service (NPS)State

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0 2 4 6 1 Miles0 2 4 6 1 Kilometers

This product may not meet BLM standards

for accuracy and content. Different data

sources and input scales may cause

some misalignment of data layers.

No warranty is made by the BLM for use of

the data for purposes not intended by the BLM.

Note: Decisions in this document

only apply to BLM lands

12 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 13

to nearly 10,400 feet in the Pine Valley 

Mountains. The Virgin River and its 

many tributaries flow through the county.

Three distinctive floristic provinces—

the Mojave Desert, Great Basin Desert, 

and the Colorado Plateau—also merge 

here in Washington County. Plant and 

animal species from each province, 

many at the extremes of their natural 

ranges, have adapted and thrived in this 

biologically rich and diverse ecological 

transition zone (ecotone). A number of 

native plants have evolved in this unique 

environmental setting and grow nowhere 

else on earth.

1.3 PLANNING GUIDANCE

1.3.1 Purpose, Significance, and 

Mission Statements for the NCAs

Purpose, significance, and mission statements are presented for the Beaver Dam 

Wash and Red Cliffs NCAs, to clarify 

why these public lands were designated 

by Congress and to guide the preparation 

of the RMPs.

As the Amendment to the SGFO RMP 

addresses only two planning issues, these 

statements are not included here, as they 

would be more appropriately developed 

when a full RMP revision is initiated in 

the future.

1.3.1.1 Beaver Dam Wash NCA 

Purpose: To conserve, protect, enhance, and restore the ecological, scenic, 

wildlife, recreational, cultural, historical, natural, educational, and scientific 

resources of the Beaver Dam Wash NCA, 

for the benefit and enjoyment of present 

and future generations. As Congress did 

not specifically define the resource values 

that give significance to this NCA, BLM 

resource professionals identified a number of the natural and cultural resources 

within NCA that are unique and scientifically important. These are but a few of 

the resource values that make the public 

lands of the NCA worthy of inclusion in 

BLM’s system of National Conservation 

Lands and include the following:

▶ Ecological diversity created by the 

convergence of the Mojave Desert 

and Great Basin ecoregions;

▶ Geologic resources, such as the 1.7 

billion year-old Precambrian strata 

of the Beaver Dam Mountains, the 

oldest exposed rocks in southwest 

Utah;

▶ Caves and karsts with unique 

geological, biological, cultural or 

recreational values;

▶ Joshua Tree National Natural 

Landmark, exemplifying this iconic 

Mojave Desert vegetation community, at the northern extreme of its 

range;

▶ Habitats critical for at-risk native species, including the Mojave 

desert tortoise; Gila monster; 

Southwestern willow flycatcher; and 

many species of bats, reptiles (Photo 

1-6), raptors, and migratory birds;

▶ Archaeological sites that preserve 

evidence of Archaic, Ancestral 

Puebloan, and Southern Paiute occupations and land uses;

▶ The Northern and potential Armijo 

Routes of the OST, the early 19th 

century pack trail followed by traders, explorers, and settlers as they 

crossed the arid lands of the Mojave 

Desert. This trail was recognized by 

Congress through designation as a 

National Historic Trail in 2002;

▶ Historic period Euro-American 

heritage resources, including 19th 

century wagon roads and telegraph 

MAP 1-3 PLANNING GUIDANCE

Southwestern Speckled 

Rattlesnake

The Crotalus mitchellii 

pyrrhus displays a variety of 

body colors that allow the 

snake to blend into its local 

environment. Colors range 

from off-white, yellow, gray, 

tan, pink, pale orange, to 

brown. Snakes from dark 

lava bed environments can be 

almost all black. The tail rings 

of the speckled rattlesnake 

contrast with the body color, 

with the terminal rings being 

black. (California Herps 

2014)

Photo 1-6 Southwestern Speckled Rattlesnake 

in the Beaver Dam Wash NCA, Utah BLM 

Sensitive Species

© Cameron Rognan
14 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 15

lines, the early 20th century 

Arrowhead Trails Highway, and 

features constructed by the Civilian 

Conservation Corps during the 

Great Depression of the 1930s.

Significance: The NCA resources are 

significant from a regional and national 

perspective because they afford:

▶ Opportunities for scientific studies 

of geologic processes and paleo-environments of the earliest periods of 

Earth’s history, through the exposed 

geologic units of the Beaver Dam 

Mountains (Photo 1-7);

▶ Opportunities for habitat restoration and population translocations 

in critical habitats for the threatened 

Mojave desert tortoise and other 

at-risk species of the Beaver Dam 

Slope;

▶ Opportunities for re-introductions 

of native aquatic and riparian species at Welcome Spring and in the 

Beaver Dam Wash;

▶ Opportunities for habitat restoration and protection of crucial 

seasonal ranges and migration 

corridors for mule deer and desert 

bighorn sheep;

▶ Opportunities to continue Mojave 

Desert plant and animal studies in 

the Woodbury Desert Study Area;

▶ Opportunities for solitude, natural quiet, dark night skies, and 

primitive, unconfined recreation 

within a large area of remote and 

substantially undisturbed public 

lands;

▶ Opportunities for the public use, 

interpretation, and high quality 

vicarious visitor experiences along 

the Northern and potential Armijo 

Routes of the Old Spanish National 

Historic Trail;

▶ Opportunities for conservation, 

protection, restoration, scientific 

study, public use, and interpretation 

of an array of prehistoric and historic period archaeological sites that 

document the broad span of human 

history in southwestern Utah;

▶ Opportunities for sustainable 

outdoor recreation and resource 

interpretation on public lands that 

enhance the quality of life for local 

residents and visitors and help to 

sustain the economic health of 

local communities;

▶ Opportunities for broad-based scientific, academic, and community 

partnerships, volunteer programs, 

youth and veteran training and 

employment initiatives, developed 

to enhance public appreciation and 

citizen stewardship of the NCA 

resources and values.

Mission: The mission for BLM management of the Beaver Dam Wash NCA is to 

conserve and protect the ecological, geological, cultural, and biological resources 

of the public lands; to assist the recovery 

and delisting of federal and state-listed 

species; to restore native species habitats and populations within functional 

ecosystems that support species’ resilience to climate change; and to enhance 

opportunities for scientific research, 

environmental education, sustainable 

recreational uses, and citizen stewardship 

of the public lands.

1.3.1.2 Red Cliffs NCA

Purpose: To conserve, protect, enhance, and restore the ecological, scenic, 

wildlife, recreational, cultural, historical, natural, educational, and scientific 

PLANNING GUIDANCE

resources of the Red Cliffs NCA for the 

benefit and enjoyment of present and 

future generations. As Congress did not 

specifically define the resource values 

that give significance to this NCA, BLM 

resource professionals identified a number of the natural and cultural resources 

within NCA that are unique and scientifically important. These are but a few of 

the resource values that make the public 

lands of the NCA worthy of inclusion in 

BLM’s system of National Conservation 

Lands and include the following:

▶ Massive exposures of the Jurassicage Kayenta Formation and Navajo 

Sandstone that preserve scientifically important dinosaur tracks and 

trackways, bone beds, plant fossils, 

and silicified wood;

▶ Rich ecological diversity resulting 

from the convergence of three major ecoregions: the Mojave Desert, 

Colorado Plateau and Great Basin; 

▶ Critical habitats that sustain high 

densities of the threatened desert 

tortoise and other Mojave Desert 

species;

▶ Critical habitat for the endangered 

Shivwits milkvetch, a small native 

plant that grows only in Washington 

County on specific soil types;

▶ The Virgin River, Quail, and Leeds 

Creeks that provide aquatic habitat 

for the threatened and endangered 

native fish of the Virgin River 

system;

▶ Riparian zones along these streams 

that support diverse native species 

and migratory birds;

▶ Scenic landscapes of the Red 

Mountain and Cottonwood Canyon 

Wilderness areas that provide outstanding opportunities for solitude, 

natural quiet, primitive and unconfined recreation, and high quality 

wilderness experiences;

▶ Archaeological sites that preserve 

evidence of Archaic, Ancestral 

Puebloan, and Southern Paiute occupations and land uses;

▶ Mid-19th century (Photo 1-8) and 

later historic period sites and features relating to the Euro-American 

settlement of southern Utah, including wagon roads, irrigation systems, 

farmsteads, mining sites, and the 

early 20th century Arrowhead Trails 

Highway.

Significance: The Red Cliffs NCA resources are significant from a regional 

and national perspective because they 

afford:

▶ Opportunities for scientific study 

of Early and Middle Jurassic age 

paleo-environments;

▶ Opportunities for conservation, 

protection, restoration, scientific 

study, public use and interpretation of an array of Jurassic-age 

PLANNING GUIDANCE

“A vision without a 

task is but a dream; a 

task without a vision is 

drudgery; a vision with 

a task is the hope of the 

world.”

–Church inscription, 

Sussex England, 1730

"The voyage of 

discovery lies not in 

finding new landscapes, 

but in having new 

eyes.”

–Marcel Proust, French 

Novelist, 1871-1922

Photo 1-8 Orson B. Adams House, Mid-19th Century Pioneer Homestead, Red Cliffs NCA

Photo 1-7 Fossil, Beaver Dam Wash NCA
16 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 17

paleontological resources, including 

scientifically important plant fossils, 

bone beds, and track sites;

▶ Opportunities for restoration of 

critical habitats for the threatened 

Mojave desert tortoise and other atrisk native species of this ecoregion.

▶ Opportunities for restoration and 

protection of crucial seasonal ranges 

and migration corridors for 

mule deer;

▶ Opportunities to reintroduce native 

desert bighorn sheep to former 

habitats in the Red Mountain and 

Cottonwood Canyon Wilderness 

areas;

▶ Opportunities for scientific research 

in City Creek and Paradise Canyon, 

where research on the Mojave desert tortoise has been ongoing since 

the 1950s;

▶ Opportunities for solitude, natural 

quiet, dark night skies, primitive 

and unconfined recreation in the 

Red Mountain and Cottonwood 

Canyon Wilderness areas, just 

minutes from the largest cities in 

Washington County;

▶ Opportunities for conservation, 

protection, restoration, scientific 

study, public use and interpretation of an array of prehistoric and 

historic period archaeological sites, 

documenting the broad span of human history in southwestern Utah 

(Photo 1-9, Photo 1-10);

▶ Opportunities for sustainable 

outdoor recreation on public 

lands that enhance the quality of life for local residents 

and visitors and help to sustain 

the economic health of local 

communities;

▶ Opportunities for broad-based 

scientific, academic, and community partnerships, volunteer 

programs, youth and veteran 

training and employment initiatives, developed to enhance 

public appreciation and citizen 

stewardship of the NCA resources 

and values. 

Mission: The mission for BLM management of the Red Cliffs NCA is to conserve and protect the ecological, geological, cultural, and biological resources of 

the public lands; to assist the recovery 

and delisting of federal and state-listed 

species; to restore native species habitats 

and populations; to sustain functional 

ecosystems that support species’ resilience to climate change; and to enhance 

opportunities for scientific research, 

environmental education, sustainable 

recreational uses, and citizen stewardship 

of public lands.

1.3.2. Planning Criteria/Legislative 

Constraints

The Code of Federal Regulations at 43 

CFR 1610 requires BLM to develop planning criteria to guide the land use planning process. Planning criteria are the 

legal, regulatory or policy constraints that 

relate to management issues or themes. 

They also help to guide the development 

of alternatives and, ultimately, the selection of the agency’s preferred alternative. 

Planning criteria ensure that RMPs are 

tailored to the identified issues and that 

unnecessary data collection and analyses 

are avoided. Appendix B provides the 

PLANNING GUIDANCE

planning criteria developed by BLM for 

this planning effort. 

1.3.3 Related Federal Laws, 

Regulations, Policies, and Programs

Many federal laws and their implementing regulations, as well as agency programs and policies, apply to the management of public lands and their natural 

and cultural resources. For a more complete listing of those federal laws, regulations, and policies that were considered 

during the development of the Draft 

NCA RMPs and Draft Amendment/Draft 

EIS, the reader is referred to Appendix C. 

Described below are those federal laws, 

implementing regulations, and agency 

policies that most directly relate to the 

BLM’s land use planning process for the 

NCAs and other public lands managed by 

the SGFO. 

1.3.3.1 Federal Laws 

Omnibus Public Land Management Act 

of 2009

Through this legislation at Title I, Subtitle 

O, Congress identified the purposes for 

each NCA, identified allowable land 

uses, and noted specific planning documents that BLM could consider when 

developing an RMP for Red Cliffs NCA. 

At Section 1974 (d) (3), the Secretary, 

through BLM, is authorized to “incorporate any provision of ”:

■Washington County Habitat 

Conservation Plan (dated February 

23, 1996);

■SGFO RMP (dated March 15, 1999, 

as amended);

■Red Cliffs Desert Reserve Public 

Use Plan (dated June 12, 2000, as 

amended).

Title II, Subtitle A at Section 2002 (a) 

of OPLMA established BLM’s National 

Landscape Conservation System and 

provided a vision for how the components of this system should be managed, 

specifically the direction to “conserve, 

protect, and restore” the system’s components for the “benefit of current and 

future generations.”

Wilderness Act of 1964

This act governs the management of designated wilderness areas, including the 

Cottonwood Canyon and Red Mountain 

Wilderness areas, located partially or 

entirely within the Red Cliffs NCA. 

In 2009, through OPLMA at Section 

1972, Congress added both areas to the 

National Wilderness Preservation System.

National Trails System Act of 1964

This legislation governs the management 

of the Old Spanish National Historic 

Trail, which crosses Beaver Dam Wash 

NCA. The National Trails System Act 

established a national system of trails 

and identified National Historic Trails as 

“extended trails which follow as closely as 

possible and practicable the original trails 

or routes of travel of national historic 

significance. Designation of such trails 

or routes shall be continuous, but the 

established or developed trail, and the acquisition thereof, need not be continuous 

on site. National historic trails shall have 

as their purpose the identification and 

protection of the historic route and its 

historic remnants and artifacts for public 

use and enjoyment” (Sec. 3(a) (3)).

PLANNING GUIDANCE

Archaeological Resource 

Protection

The Archaeological Resources 

Protection Act was enacted 

in 1979 " ... to secure, for the 

present and future benefit 

of the American people, the 

protection of archaeological 

resources and sites which are 

on public lands and Indian 

lands, and to foster increased 

cooperation and exchange 

of information between 

governmental authorities, the 

professional archaeological 

community, and private 

individuals ...." (Sec. 2(4)(b))

What is a National 

Historic Trail?

A National Historical Trail is 

a Congressionally designated 

trail that is an extended, longdistance trail, not necessarily 

managed as continuous, that 

follows as closely as possible 

and practicable the original 

trails or routes of travel of 

national historic significance. 

The purpose of a National 

Historic Trail is the 

identification and protection 

of the historic route and 

the historic remnants and 

artifacts for public use and 

enjoyment. A National 

Historic Trail is managed to 

conserve, protect, and restore 

the nationally significant 

resources, qualities, values, 

and associated settings of the 

areas through which such 

trails may pass, including the 

primary use or uses of the 

trail.

Photo 1-9 North Creek Grey Jar Recovered 

from Red Cliffs NCA

Photo 1-10 Ancestral Puebloan Artifacts 

Recovered from Red Cliffs NCA
18 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 19

Federal Land Policy and Management 

Act

The “enabling” legislation for BLM is the 

Federal Land Policy and Management 

Act of 1976 (43 U.S.C. 1701 et seq., 

Public Law 94-579, FLPMA). At Section 

302 (a), FLPMA directs that public lands 

are to be managed under the principles 

of multiple use and sustained yield, “...

except that where a tract of such public 

land has been dedicated to specific uses 

according to any other provisions of law, 

it will be managed in accordance with 

such law.” 

The designation language from OPLMA 

modifies FLPMA’s principles of multiple 

use and sustained yield to emphasize the 

conservation, protection, and enhancement of public land values, in the Beaver 

Dam Wash and Red Cliffs NCAs. The 

designation language narrows the scope 

of the RMPs for the NCAs, as many land 

uses or activities can no longer be authorized on public lands in these units.

The Wilderness Act and the designation 

language from OPLMA related to the 

Cottonwood Canyon and Red Mountain 

Wilderness modify FLPMA’s principles of 

multiple use and sustained yield, as these 

public lands are now dedicated to the 

protection of these areas and the preservation of their wilderness character.

The mandates of FLPMA, and federal 

regulations at 43 CFR 1610, provide 

specific direction for BLM’s land use 

planning process. FLPMA directs BLM 

to prepare RMPs to protect the scientific, scenic, historical, ecological, 

environmental, air and atmospheric, 

water, and cultural resource values of 

the public lands; and to use an interdisciplinary approach in the development 

of management alternatives. Section 

202 of FLPMA directs BLM to consult 

with American Indian Tribes, coordinate with other federal agencies, state, 

and local governments, and encourage 

public participation during the land use 

planning process.

National Environmental Policy Act of 

1969 (42 U.S.C. 4321 et seq.) (NEPA)

The National Environmental Policy Act 

(NEPA) of 1969, implemented through 

federal regulations promulgated by the 

President’s Council on Environmental 

Quality (CEQ), requires federal agencies 

to evaluate their actions, programs, and 

plans; consider alternatives; and disclose 

the environmental consequences of major federal actions that could significantly 

affect the quality of the human environment. The development, amendment, 

revision, and implementation of RMPs 

constitute major federal actions that are 

subject to the requirements of NEPA. 

CEQ regulations at 40 CFR 1500-1508 

provide direction on the content and 

procedural aspects of NEPA and the required environmental analysis. The most 

comprehensive level of analysis is an 

Environmental Impact Statement (EIS); a 

single Draft EIS has been prepared to satisfy the NEPA requirements, CEQ regulations for implementing NEPA, and the 

requirements of BLM’s NEPA Handbook, 

H-1790-1 for the new NCA RMPs and 

the Amendment to the SGFO RMP.

PLANNING GUIDANCE

1.3.3.2 Federal Regulations

Management alternatives in the new 

RMPs and Amendment incorporate the 

Utah Standards for Rangeland Health and 

Guidelines for Grazing Administration 

(BLM 1997) (Appendix D-hereinafter 

referred to as Utah Standards and 

Guides) developed by the Utah Resource 

Advisory Council, in compliance with 

federal regulations at 43 CFR 4180.1. 

These address the fundamental attributes of healthy rangelands: productive 

soils, properly functioning riparian and 

wetland areas, diverse native vegetation communities, and habitats that can 

sustain native and special status species 

and assist the recovery and delisting of 

threatened and endangered species.

1.3.3.3 Programs and Policies

National Landscape Conservation 

System (National Conservation Lands)

was administratively authorized in 2000, 

through a Secretarial Order signed by 

Secretary of the Interior Bruce Babbitt, to 

create a special system of BLM-managed 

public lands with a dominant conservation mission. This Order directed BLM 

to ensure that the National Conservation 

Lands are managed to protect the values for which they were designated, 

including, where appropriate, prohibiting uses that are inconsistent with those 

values. If consistent with such protection, appropriate multiple uses may be 

allowed. National Conservation Lands 

include landscapes, rivers, and trails designated by act of Congress or Presidential 

Proclamation.

In 2009, through OPLMA, Congress 

permanently established the National 

Conservation Lands “to conserve, protect, and restore nationally significant 

landscapes.” Secretarial Order 3308, 

signed by Secretary of the Interior Ken 

Salazar on November 15, 2010, established a new directorate called the 

National Landscape Conservation System 

and Community Partnerships within 

BLM’s organizational structure.

A series of program-specific manuals 

have been developed and approved by the 

BLM Director that specify general policy 

and guiding principles for the management of National Conservation Lands. 

These new manuals are described in 

detail below, as they represent new guidance that was considered by the Planning 

Team during development of NCA management goals, objectives, and actions.

BLM Manual 6100-National Landscape 

Conservation System Manual (dated July 

13, 2012) provides guiding principles for 

the management of all units of BLM’s 

National Conservation Lands. These include management to conserve, protect, 

and restore public lands and resource values, as an integral part of larger, nationally significant, landscapes. Management 

of each unit is to be based on the best 

available science and inventory data collected for the ecological, natural, cultural, 

scenic, and recreational values of the 

public lands. These units are also to be 

managed to engage diverse partners, local communities, volunteers, youth, and 

veterans in shared “citizen stewardship” 

of the public lands.

PLANNING GUIDANCE

How Does FLPMA apply 

to NLCS units?

Land use planning decisions 

for NLCS units must be 

consistent with the purposes 

and objectives of the 

designating act of Congress 

or Presidential Proclamation, 

issued under the Antiquities 

Act of 1906. When FLPMA’s 

multiple use and sustained 

yield principles are not 

consistent with the Act of 

Congress or Presidential 

Proclamation for an NLCS 

unit, the designating language 

supersedes the FLPMA 

mandates at Section 302. (a). 

“Our values are etched 

in the landscape. That is 

our enduring legacy.“

–Bruce Babbitt, 

Secretary of the Interior 

1993-2001

Photo 1-11 Buckskin Hollow, Red Cliffs 

NCA

Photo 1-12 South Bulldog Knolls, Beaver 

Dam Wash NCA
20 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 21

BLM Manual 6220-National Monuments, 

National Conservation Areas, and Similar 

Designations (dated July 13, 2012) guides 

management of public lands that have 

been designated by Congress or through 

Presidential Proclamation as NCAs and 

National Monuments (NM) or similar designations, such as Outstanding 

National Areas, Forest Reserves, or 

Cooperative Management and Protection 

Areas. The policy for management of 

these units is consistent with that articulated for the National Conservation 

Lands as a whole: conservation, protection, and restoration of significant landscapes and resource values, by ensuring 

that authorized uses of public lands are 

compatible with the purposes of designation. The Manual also emphasizes the use 

of inventory data and the best available 

science to frame management strategies 

for the special designation areas. 

This Manual addresses specific land 

use allocations, such as rights-of-way 

(ROWs), designated transportation and 

utility corridors, and discretionary uses 

proposed for NCAs, NMs, and similar 

designations. Through land use planning, 

this Manual directs that, to the extent 

possible, BLM should avoid granting new 

ROWs in these units and should evaluate the relocation of existing ROWs that 

are not consistent with the purposes of 

designation. It also directs that (subject 

to applicable law), through land use 

planning and project-specific decisions, 

BLM should designate NCAs and NMs 

as ROWs Exclusion or Avoidance areas. 

New transportation or utility corridors 

should not be designated in RMPs developed for these units if the corridors 

would be incompatible with the designating authority or the purposes for which 

the unit was designated. 

New facilities, including structures and 

roads, should only be authorized or developed in these units if they are required 

by law; needed for public health and 

safety; or are necessary for the exercise 

of valid existing rights or other non-discretionary uses. And, these facilities must 

further the purposes for which the NCA, 

NM, or other special designation area 

was designated.

BLM Manual 6340-Management of 

Designated Wilderness Areas (dated July 

13, 2012) provides general policies for the 

administration and management of units 

that have been included by Congress in 

the National Wilderness System, under 

the authority of the Wilderness Act of 

1964 (16 U.S.C. 1131 et seq.) and the 

specific acts of Congress that designate 

BLM wilderness. The objectives of the 

policy are to manage designated wilderness areas for the public purposes of 

recreational, scenic, scientific, education, 

conservation and historic use, while preserving wilderness character.

BLM Manual 6280-National Scenic and 

Historic Trails Management (dated 

September 14, 2012) provides specific policy direction relating to the 

management of trails that have been 

Congressionally-designated to the 

National Trails System, under the authority of the National Trails System Act of 

1968, as amended (16 U.S.C. 1241-1251). 

PLANNING GUIDANCE

Management direction for designated 

National Historic Trails, such as the Old 

Spanish National Historic Trail (Photo 

1-13), includes the establishment of a 

trail Management Corridor that protects 

trail traces, remnants, artifacts, associated 

historic sites, and the associated setting of 

the historic trail, and the development of 

management alternatives to provide for 

public use, interpretation, and volunteer 

opportunities for trail stewardship.

Other policy documents were also 

used as guidance for the RMPs and 

Amendment. These include (but were not 

limited to) BLM’s Handbook H-1601-1, 

Land Use Planning; BLM Manual 8100, 

Cultural Resource Management; BLM 

Handbook H-8410-1, Visual Resource 

Management; BLM Manual M-1626, 

Travel and Transportation Management; 

and BLM Handbook H-8342.

1.3.4. Relationship to Other Plans

Section 202 of FLPMA at Subsection 

(c)(9) provides that “land use plans of 

the Secretary under this section shall 

be consistent with State and local plans 

to the maximum extent he [sic] finds 

consistent with Federal law and the 

purposes of this Act.” Regulations at 43 

CFR 1610 require that RMP decisions be 

consistent with the officially-approved or 

adopted resource-related management 

plans of other federal, state, and local 

governments to the extent those plans 

are consistent with the purposes, policies, 

and programs of federal laws and regulations applicable to public lands and the 

purposes of FLPMA. 

The following resource management 

plans for contiguous federal lands were 

reviewed for consistency with proposed 

management goals, objectives, and decisions in the RMPs or Amendment to the 

SGFO RMP:

■BLM-Arizona Strip District RMP 

(2oo8);

■BLM-Ely (Nevada) District RMP 

(2008);

■BLM-Kanab Field Office RMP 

(2008);

■Dixie National Forest Land and 

Resource Management Plan (1986);

■Zion National Park General 

Management Plan (2001).

Program-specific or activity-level plans 

that were reviewed for consistency 

included:

■Dixie National Forest Motorized 

Travel Plan (2009);

■Red Cliffs Desert Reserve Public 

Use Plan (approved by Washington 

County Commissioners, June 12, 

2000, BLM Decision Record signed 

June 29, 2001).

The approved plans of state and local 

government entities that were reviewed 

for consistency (to the extent those plans 

are consistent with the purposes, policies, and programs of federal laws and 

regulations applicable to public lands), 

included: 

■Gunlock State Park Resource 

Management Plan (2006);

■Mohave County General Plan (1995, 

revised 2010);

■Sand Hollow State Park Resource 

Management Plan (2010);

■Snow Canyon State Park Resource 

PLANNING PROCESS

"A policy is a 

temporary creed liable 

to be changed, but 

while it holds good it 

has got to be pursued 

with apostolic zeal."

–Mahatma Gandhi, 

Indian Leader, 

1869-1948

"...the longest 

crookedest, most 

arduous pack mule 

route in the history of 

America..."

–Hafen and Hafen, The 

Old Spanish Trail, 1954

Photo 1-13 Old Spanish National Historic 

Trail, Beaver Dam Wash NCA
22 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 23

Management Plan (1998);

■Washington County General 

Management Plan (2010, amended 

2012).

The following Habitat Conservation 

Plans, Recovery Plans, and Conservation 

Strategies include habitat management 

recommendations that are also relevant 

to the planning process:

■Recovery Plan for Siler Pincushion 

Cactus (1986);

■Recovery Plan for Dwarf Bearclaw 

Poppy (1985);

■Recovery Plan for Shivwits 

Milkvetch and Holmgren Milkvetch 

(2006);

■Recovery Plan for the California 

Condor (USFWS 1996);

■Recovery Plan for Mexican Spotted 

Owl (1995, revised 2012);

■Recovery Plan for the 

Southwestern Willow Flycatcher 

(2002);

■Recovery Plan for the Mojave 

Population of the Desert Tortoise 

(1994, revised 2011);

■Recovery Plan for the Virgin River 

Chub and Woundfin (1979, revised 

1985);

■Recovery Plan for Virgin River 

Fishes (1995);

■Utah Comprehensive Wildlife 

Conservation Strategy (UDWR 

2005);

■Virgin Spinedace Conservation 

Agreement and Strategy (1995);

■Virgin River Resource Management 

and Recovery Program (USFWS 

2000);

■Washington County Habitat 

Conservation Plan (1996).

The Biological Opinion (ES/6-UT98-F-005) and Incidental Take Statement 

that resulted from consultations with 

the USFWS under Section 7 of the 

Endangered Species Act for the Proposed 

SGFO RMP (BLM 1998) contains terms 

and conditions for authorized activities 

on public lands that remain in force until 

formal consultations have been completed for the new RMPs and Amendment to 

the SGFO RMP.

The Biological Opinion (ES/6-UT01-F-003) that resulted from Section 7 

consultation on impacts to the threatened 

Mojave desert tortoise related to the 

implementation of the Public Use Plan 

for the Red Cliffs Desert Reserve (2001) 

on public lands remains in force until 

consultation for the Proposed Red Cliffs 

NCA RMP has been completed with 

the USFWS.

1.4 PLANNING PROCESS

Congress, through OPLMA, directed 

BLM to complete comprehensive management plans for the two NCAs and 

undertake other actions that required an 

amendment to the SGFO RMP.

The BLM planning process is dynamic 

and strives to ensure that land use plans 

and implementation-level decisions 

remain consistent with applicable federal laws, regulations, Executive and 

Secretarial Orders, and agency policies. 

This process involves public participation, decision-making, implementation, plan monitoring, evaluation, and 

PLANNING PROCESS

adjustments, through plan maintenance, 

amendment, and revision. This process 

allows for adjustments to be made to 

RMPs, based on changed circumstances, 

emerging issues, and new information that influences decision-making. 

Modifying land use plans through maintenance or issue-focused amendments 

on a regular basis minimizes the need for 

major revisions. 

The planning process follows the procedural requirements of NEPA and involves 

the following steps:

▶ Scoping-the scoping process is 

intended to identify issues and 

concerns from interested and affected public, agencies, tribes, and 

organizations to frame the scope 

of the land use plan and environmental analysis. A Notice of Intent 

(NOI) was published in the Federal 

Register on May 10, 2010, alerting 

the public that BLM was initiating 

a land use planning process and 

opening a 90 day public scoping period. The results of this process are 

contained in two scoping reports 

that are available on the web at: 

www.blm.gov/r1ld.

▶ Draft RMPs and Draft Amendment/

Draft EIS-the draft plans and 

analyses are the products of an 

interdisciplinary BLM planning 

team (Planning Team) comprised of 

resource specialists and managers. 

The Planning Team immediately 

gathered background data, evaluated legal, regulatory, and policy 

requirements, and reviewed public 

comments submitted during scoping. This process resulted in the 

identification of issues, as well as 

goals and objectives for public land 

resource values and land uses in 

each NCA, to frame the development of a range of management 

alternatives. The Draft EIS includes 

the analysis and comparison of 

impacts associated with implementation of the management alternatives. During the development of 

the drafts, the Cooperating Agencies 

were afforded opportunities to 

participate in the process through 

meetings and informal contacts.

▶ Public Review and Comment on the 

Draft RMPs and Draft Amendment/

Draft EIS-the 90 day public comment period affords the public an 

opportunity to review the drafts and 

environmental analysis and provide 

written comments on the alternatives and impacts analysis.

▶ Development of Proposed RMPs 

and Proposed Amendment/Final 

EIS-the Planning Team reviews the 

comments submitted on the draft 

plans and Draft EIS and incorporates changes into the Proposed 

RMPs and Proposed Amendment/

Final EIS. This document includes a 

response to public comments, identifying how they were addressed 

in the analysis and whether the 

comments resulted in changes to the 

draft plans.

PLANNING PROCESS

Dwarf Bearclaw Poppy

Arctomecon humilis is 

narrowly endemic to 

Washington County. This 

member of the poppy family 

grows only on gypsiferous 

soils found in the upper layers 

of the Moenkopi Formation. 

Blooming occurs from midApril through May, and is 

quite conspicuous against the 

otherwise barren soils.

Kit Fox

Vulpes macrotis is nocturnal, 

and leaves the den at 

sundown to hunt. Dens 

usually start out with one 

entrance, but over a period of 

years, several other entrances, 

tunnels, and a birthing 

chamber may be added. A 

kit fox litter usually consists 

of four to seven pups that 

emerge from the den in late 

spring or early summer.

Photo 1-14 Dwarf Bearclaw Poppy, 

Federally-Listed Endangered Species

Photo 1-15 Kit Fox Pups, Utah BLM 

Sensitive Species

© Cameron Rognan
24 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 25

▶ Publish Proposed RMPs and 

Proposed Amendment/Final EISthese documents are published 

for a 30 day public protest period. 

The protest procedures (at 43 CFR 

1610.5-2) provide the public an 

administrative remedy for the 

BLM-Utah State Director’s (State 

Director) proposed RMP decisions. The BLM Director determines through the protest process 

whether the State Director followed 

established procedures, considered 

relevant information in reaching 

proposed decisions, and whether 

the proposed decisions are consistent with legal, regulatory, and 

policy requirements. The Proposed 

RMPs and Proposed Amendment 

also receive a Governor’s consistency review determination as it relates 

to relevant state plans and policies. 

▶ Publish approved RMPs and approved Amendment and Records of 

Decision (RODs)-this is the final 

step in BLM’s land use planning and 

NEPA processes. If changes were 

made to the Proposed RMPs or 

Proposed Amendment as a result of 

plan protests, they are incorporated 

in the RODs; these are signed by the 

State Director. Implementation of 

the approved RMPs and approved 

Amendment begin after signing of 

the RODs.

Land use planning is a dynamic and 

adaptive process, particularly when 

conservation, protection, and restoration 

of habitat for a large number of threatened, endangered, and candidate species 

must be a primary focus for public lands 

management. The new RMPs for the two 

NCAs must be able to quickly respond 

to changing environmental factors, new 

scientific data, and changing land use 

patterns. Management of the NCAs will 

incorporate the principles of adaptive 

management, through an emphasis on 

monitoring of management practices and 

support for research studies to increase 

the understanding of natural processes 

and complex ecosystems. The adaptive 

management process is described in 

greater detail in Chapter 2.

Agency policy requires the preparation of 

an Implementation Strategy for each new 

RMP. This strategy establishes priorities, 

3 to 5 year timelines, and budget requirements needed to successfully implement the land use plans. Other agencies, 

partners, and the public are encouraged 

to be involved in the development of the 

Implementation Strategies.

PLANNING PROCESS

During implementation of the management actions in the approved RMPs and 

approved Amendment, additional site or 

activity-specific NEPA analyses, generally Environmental Assessments (EAs), 

are developed with appropriate levels of 

public involvement. Monitoring protocols are developed and implemented, to 

determine the success of the management action in achieving the stated goals 

and objectives. Amendments or revisions 

to the RMPs would be completed, as 

needed, to respond to changing circumstances, including new legal and regulatory requirements, similar to the passage 

of OPLMA which drove the current 

planning process.

1.4.1 Implementation-level 

Decisions

Resource management plan decisions 

and implementation decisions reflect 

two distinct steps in the planning process. Appendix C in the BLM Handbook 

H-1601-1 (BLM 2005) provides program 

specific guidance to separate land use plan 

decisions from implementation decisions. 

The Draft RMPs for the two NCAs 

provide broad decisions dealing with 

proposed management actions, special designations, and allowable uses. 

These types of decisions are referred to 

as plan decisions, which represent the 

majority of decisions in this document. 

Implementation decisions are tied to a 

specific location and are used to implement plan decisions. Unlike plan decisions, implementation decisions are not 

subject to protest under BLM’s planning 

regulations. Implementation decisions 

are subject to various administrative remedies, particularly appeals to the Office of 

Hearings and Appeals (Interior Board of 

Land Appeals), under 43 CFR 4.410. 

Most implementation-level decisions 

are developed, following adoption of 

an RMP, with subsequent, site-specific 

environmental analyses. However, in 

some cases implementation decisions are 

proposed within the Draft RMPs for the 

two NCAs. Implementation decisions are 

specifically labeled as “Implementation 

Actions” within the alternatives tables in 

Chapter 2. When implementation-level 

decisions are included in the impacts 

analysis for an RMP, further NEPA 

analysis is generally not required to 

begin implementation of these decisions. 

Implementation decisions may require 

supplementary rule making and this process is described below in greater detail.

Subsequent management actions taken 

by the BLM to implement the guidance 

found within this RMP may be “tiered” 

to the impact analysis done within this 

document (BLM 2008a). This allows the 

BLM to narrow the focus of subsequent 

implementation-level environmental 

assessments (EA) because the implementation-level EA need not reanalyze effects 

that were already fully analyzed in the 

broader RMP. Instead, the analysis for the 

implementation-level EA may focus on 

the effects of the individual action that 

were not covered within the RMP. 

1.4.2 Supplementary Rules

In some instances, decisions from the 

approved RMPs or Amendment could 

restrict or prohibit an activity on public 

lands. Often the restriction or prohibition 

is already standard on public land and 

there is no requirement for supplementary rule making to enforce the decision 

from the approved RMP or Amendment. 

However, to make some decisions enforceable, a public process is required, as 

outlined in 43CFR 8365.1-6. This process 

requires that specific steps be taken to ensure that interest groups and public land 

users are adequately informed of newlyproposed rules before they go into effect. 

The first step of the process is the publication of a proposed set of rules and providing for public review and comment. 

Proposed supplemental rules, closures, 

and restrictions orders for uses of public lands will be included the Proposed 

RMPs/Amendment that are released for 

PLANNING PROCESS

Gila Monster

Heloderma suspectum is the 

largest lizard native to the 

United States weighing up 

to two pounds and reaching 

twenty inches in length. Its 

tail is plump compared to 

other lizards and is used 

to store fat. The beaded 

appearance of their salmon 

pink and black skin is caused 

by tiny embedded disks of 

bone, called osteoderms.

"Within the lives of 

Southern Paiutes, 

there is an inherent 

understanding that 

all things are placed 

on this land with the 

breath of life, just as 

humans. This land is 

considered to be their 

home, just as it is for 

man, and it is taught 

that one must consider 

that rocks, trees, 

animals, mountains 

and all other things 

are on the same level 

as man. Each has a 

purpose in life, and 

the one who created 

every living thing 

on this earth placed 

all living things here 

to interact with one 

another...It is said that 

the plants, animals, and 

in fact, everything on 

this land, understand 

the Paiute language, 

and when one listens 

closely and intently 

enough, there is 

affirmation and a sense 

of understanding."

-Kaibab Paiute Tribal 

Member

Photo 1-16 Gila Monster in Red Cliffs NCA, Utah BLM Sensitive Species

© Cameron Rognan
26 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 27

public review during this planning process. Information will be provided in the 

Proposed RMPs about the supplementary 

rule-making process and how the public 

can provide comments on the proposed 

rules. The Federal Register Notices, press 

releases, and public meetings associated 

with the release of the Proposed RMPs/ 

Amendment will serve as public notification of the opportunity to review and 

comment on the proposed supplementary rules contained in those plans.

1.4.3 Collaboration

OPLMA, FLPMA, and NEPA direct BLM 

to coordinate land use planning efforts 

with other federal agencies, state and 

local governments, and Indian tribes, as 

well as seeking public input throughout 

the process. Collaboration with other entities was accomplished through regular 

written and oral communications, meetings, and data sharing. A brief discussion 

of two collaborating groups, Cooperating 

Agencies and American Indian Tribes, is 

presented below. 

1.4.3.1 Cooperating Agencies

CEQ requirements at 40 CFR 1501.6 

and 1508.5 implement the NEPA mandate that federal agencies responsible for 

preparing analyses do so in cooperation 

with state and local governments and 

other agencies with jurisdiction by law 

or special expertise (42 U.S.C. 4331 (a) 

and 4332 (2)). At the start of scoping, 

BLM invited the State of Utah, county 

governments in adjoining areas of Utah, 

Nevada, and Arizona, and tribal governments of those American Indian Tribes 

that claim cultural affiliation to the 

planning areas to become Cooperating 

Agencies in this planning process. 

Washington County, UT, Mojave County, 

AZ, and the State of Utah, through the 

Governor’s Public Land Policy and 

Coordination Office (PLPCO), signed 

Memoranda of Understanding with BLM 

to participate as Cooperating Agencies in 

this planning process.

1.4.3.2 Tribal Governments

Consultations have been and will continue to be conducted on a government-togovernment basis with American Indian 

Tribes that claim cultural affiliation to the 

public lands of Washington County. In 

May of 2010, BLM initiated consultations 

relating to this planning process with the 

following Tribes and Bands:

▶ The Hopi Tribe

▶ The Navajo Nation

▶ The Pueblo of Zuni

▶ The Paiute Indian Tribe of Utah

Shivwits Band 

Cedar Band

Indian Peaks Band

Kanosh Band

Koosharem Band

▶ The Kaibab Band of Paiutes

▶ The Las Vegas Paiute Tribe

▶ The Moapa Band of Paiutes

▶ The Pahrump Band of Paiutes

▶ The Havasupai Tribe 

▶ The Hualapai Tribe

PLANNING PROCESS

1.5 PUBLIC SCOPING

Scoping is required by NEPA in the early 

stages of developing an EIS, to identify 

issues and concerns to be addressed in 

the new RMPs and the Amendment to 

the SGFO RMP. This process is summarized below with greater detail provided 

in Chapter 5 of this document. 

A formal scoping period was initiated 

through the publication of an NOI to 

prepare the RMPs in the Federal Register 

on May 10, 2010 (Vol. 75, No. 89: pages 

25876-25877). The NOI identified preliminary planning issues to be considered, announced the dates and locations 

of public scoping meetings and established the 60 day period during which the 

public could identify issues and provide 

comments on the long-term management of resource values and public uses 

in the NCAs. The public was also invited 

to identify areas and provide nominations for ACECs where the conservation 

of biological species was a priority. Input 

was also requested relating to the OHV 

area designations that were to be proposed through the Amendment to the 

SGFO RMP.

Three public scoping workshops were 

held in June of 2010, in St. George, 

Hurricane, and Salt Lake City, Utah, and 

in Mesquite, Nevada, resulting in nearly 

2,000 comments being received during 

scoping (Photo 1-17).

As Congress, through OPLMA, had 

directed that comprehensive travel 

management planning for public lands in 

Washington County be completed very 

quickly, BLM initiated scoping for this 

implementation level planning in May 

of 2010, holding public scoping meetings concurrently with the RMP scoping 

public meetings, at the locations shown 

above. Scoping has continued on an informal basis since 2010 relating to travel 

management planning.

1.6 PLANNING AND 

MANAGEMENT ISSUES

Planning issues are defined as matters of 

controversy or dispute over public land 

conditions, resource management activities, or allowable land uses that are welldefined and for which alternatives can be 

developed for a specific planning area. 

These issues may be a concern expressed 

by the public, state/local governments 

or other stakeholders and may include 

concerns about potential serious deterioration of public lands, significant impacts 

or conflicts, or uses that may not be in 

the best public interest. They provide a 

framework for the development of alternatives in the Draft RMPs for the Beaver 

Dam Wash and Red Cliffs NCAs and the 

Draft Amendment to the SGFO RMP. 

Based on the scoping comments received 

and their subsequent analysis and evaluation, ten planning issues were identified 

as being within the scope of these Draft 

RMPs and Draft Amendment/Draft EIS. 

As they relate to the NCAs, these issues 

center on the larger question of just how 

PUBLIC SCOPING

"Never doubt that 

a small group of 

thoughtful, committed 

citizens can change the 

world; indeed, it's the 

only thing that 

ever has."

–Margaret 

Mead, Cultural 

Anthropologist, 

1901-1978

"To make democracy 

work, we must be a 

nation of participants, 

not simply observers.”

–Louis L’Amour, 

Author, 1908-1988

Photo 1-17 Public Scoping Workshop, 

Hurricane, Utah
28 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 29

PLANNING AND MANAGEMENT ISSUES PLANNING AND MANAGEMENT ISSUES

much and what types of human uses 

should be allowed, in light of the mandates from OPLMA relating to resource 

conservation, protection, and restoration. 

In addition to the issues that emerged 

from public scoping, the Planning Team 

identified the need to eradicate invasive 

species and restore fire-damaged vegetation communities that provide habitat for 

federally-listed and at-risk native species 

as a management concern. The planning 

issues and management concerns that are 

considered through this planning process 

are briefly described below.

1.6.1 Planning Issues Common to 

Beaver Dam Wash and Red Cliffs 

NCAs

1.6.1.1 How will the ecological resources of the NCAs be conserved, protected, and restored? 

Specific comments addressed the need 

to protect fragile soils and air quality, by 

limiting land uses in the NCAs. Others 

expressed concerns about fire-damaged 

habitats in the Mojave Desert and the current and future condition of the vegetation communities that support native species under the predicted climate change 

scenarios. Achieving the Congressionallydefined goals of ecological conservation 

in the NCAs could be accomplished 

through diverse management strategies, 

including restrictions on land uses, scientific research, and public education.

Restoring damaged ecosystems in the 

Mojave Desert is an ongoing management concern, as these provide cover, 

forage, and breeding areas for native 

species. Changing climatic conditions 

and the prevalence of invasive annual 

grasses (Photo 1-18) have altered the 

natural fire regime of the Mojave Desert. 

Management alternatives that identify 

possible strategies to prevent further firerelated impacts and restore native species 

are provided in Chapter 2 for each NCA.

1.6.1.2 How will cultural and paleontological resources be conserved and 

protected in the NCAs?

Many in the public provided scoping 

comments that expressed concerns about 

the preservation of important archaeological and paleontological sites in the NCAs, 

recognizing the scientific, traditional, 

and educational values of these resources. 

Some public comments identified the 

need to include management restrictions, 

such as ROW Exclusion areas and motorized vehicle route designations, to ensure 

that these fragile heritage resources would 

be conserved and protected. Others 

recommended managing and interpreting certain types of sites, such as rock 

art localities or dinosaur trackways, for 

public use, so that the public could learn 

more about these resources and appropriate site etiquette when visiting them 

(Photo 1-19).

1.6.1.3 How will native plant and animal 

species and their habitats be managed 

in the NCAs?

Native plant and animal species found in 

the two NCAs have adapted to the unusual environmental conditions created 

by the convergence of the Mojave Desert, 

Great Basin, and Colorado Plateau ecoregions in Washington County. Nine native 

species found in the NCAs are already 

listed under the Endangered Species Act 

(ESA), due to population declines that 

have been attributed primarily to habitat 

loss or degradation.

During scoping, the public commented 

on the importance of management 

actions and land use restrictions in both 

NCAs to protect and assist the recovery 

of the Mojave desert tortoise, and other 

special status species. Some individuals commented that their quality of life 

was higher because they were able to see 

native species in their natural habitats, 

when visiting the Beaver Dam Wash and 

Red Cliffs NCAs.

1.6.1.4 How will recreation uses be 

managed in the NCAs?

Outdoor recreation on public lands in 

the NCAs was identified as a very important issue, comprising 21% of the 

public comments received during scoping. Concerns were expressed about 

what types of opportunities, such as 

commercial, competitive, and organized 

recreation activities, might be authorized 

in each NCA and what impacts diverse 

recreation uses would have on the many 

sensitive resource values of each NCA. 

Management alternatives address the 

need to provide for sustainable and appropriate public recreation opportunities, 

while conserving and protecting sensitive 

resource values of the NCAs. “In the middle 

of difficulty lies 

opportunity.”

–Albert Einstein, 

Theoretical Physicist, 

1879-1955

"Good stewardship 

of the environment 

is not just a personal 

responsibility, it is a 

public value...Our duty 

is to use the land well, 

and sometimes not to 

use it [at] all. This is 

our responsibility as 

citizens, but more than 

that, it is our calling as 

stewards of the earth."

–George W. Bush, 43rd 

President of the United 

States, 1946-

Photo 1-18 Invasive Species in a Fire-Damaged Vegetation Community, Red Cliffs NCA Photo 1-19 Interpreted Remnants of the 1950s-era Hollywood Movie Set, Red Cliffs NCA
30 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 31

1.6.1.5 What types of recreation facilities should be developed in the NCAs?

The two NCAs are very different with 

regard to the types and intensity of recreation uses that are ongoing today. Annual 

visitation to Beaver Dam Wash NCA 

today numbers approximately 12,000 

visits, with the primary activities being 

large and small game hunting, sport and 

technical rock climbing (Photo 1-20), 

and motorized vehicle touring, especially 

on ATVs on backcountry routes. There 

are no developed trails, trailheads, or 

campgrounds in the NCA, so for these 

visitors, dispersed recreation activities, 

open space, and the scenic vistas of the 

desert landscape are the primary factors 

that make Beaver Dam Wash NCA attractive to recreationists.

Public comments related to recreation in 

Beaver Dam Wash NCA identified the 

potential for conflicts between motorized and non-motorized recreational 

user groups. Some commenters included 

recommendations about how to minimize those conflicts that included area 

closures, non-motorized and motorized 

route designations, developing trails, 

staging and trailhead facilities, improved 

maps, and signage. Another focus of 

some public comments was the need to 

manage increased recreation demand, 

while still maintaining high quality recreation experiences, as more visitors from 

outside of the local area became aware of 

the values of the NCA. 

By contrast, the Red Cliffs NCA is 

already a very popular destination for 

local residents and visitors. The Red Cliffs 

Recreation Area, located in the eastern 

portion of the NCA, is a designated fee 

collection site, with a small developed 

campground, day use facilities, designated trails, and interpreted points 

of interest.

In 2012, over 150,000 hikers, mountain 

bikers, and equestrians used the more 

than 100 miles of designated, shareduse trails. A majority of the trail system 

within the NCA is within the municipal 

annexation boundaries of St. George, 

Hurricane, Santa Clara, Ivins, and 

Washington. The trails are “in the backyards” of the many residential housing 

developments that ring the boundaries 

of the NCA. Local residents value the 

recreation opportunities and open space 

that the NCA affords them.

Many public comments focused on the 

need to maintain public access to high 

quality non-motorized trails in the NCA, 

while still protecting sensitive resources. 

Management alternatives in Chapter 2 

provide a range of options to address this 

important planning issue.

1.6.1.6 How will livestock grazing be 

addressed in the NCAs?

Domestic livestock grazing is currently 

authorized in both NCAs: portions of 

five active grazing allotments overlap 

the boundaries of the Beaver Dam Wash 

NCA (Photo 1-21), while three allotments include public lands within the 

Red Cliffs NCA, along its northwestern 

boundary. However, a majority of the 

authorized grazing use ended on public 

lands in the Red Cliffs NCA in the mid1990s, with the purchase of the federal 

grazing permits by Washington County 

PLANNING AND MANAGEMENT ISSUES

and the closure of the allotments to grazing by BLM, through the SGFO RMP. 

OPLMA provided the following legislative direction concerning livestock grazing for the Beaver Dam Wash and Red 

Cliffs NCAs (Sections 1974 and 1975 at 

(e) Management): 

Grazing.—The grazing of livestock 

in the National Conservation Area, 

where established before the date 

of enactment of this Act, shall be 

permitted to continue—(A) subject 

to—(i) such reasonable regulations, policies, and practices as the 

Secretary considers necessary; and 

(ii) applicable law (including regulations); and (B) in a manner consistent with the purposes described in 

subsection (a). 

Scoping comments reflected the public’s 

divergent views about livestock grazing 

in the NCAs, but most particularly in the 

Beaver Dam Wash NCA. Some commenters requested that grazing continue 

to be an authorized use of the public 

lands in the NCAs, pointing to its role 

in the history and economy of the local 

area. Others indicated that livestock help 

to reduce wild fires by consuming invasive annual grasses that fuel fires in the 

Mojave Desert.

Those members of the public who oppose 

livestock grazing on public lands commented that this land use is not compatible with the conservation and protection purposes of the NCAs. Those in the 

middle supported eliminating livestock 

grazing only in environmentally sensitive 

areas. Commenting parties cited impacts 

on water quality, riparian areas, and 

cultural resources, as reasons why grazing should not be allowed. Some written 

comments identified competition for 

forage between domestic livestock and 

native species, like the Mojave desert tortoise, as the primary reason why livestock 

grazing should not continue to 

be authorized.

Washington County, a Cooperating 

Agency in this planning effort, has 

endorsed the continuation of livestock 

grazing on public lands, through a 

Resolution (No. R-2011-1555) passed 

by the County Commission on April 19, 

2011. Domestic livestock grazing has 

been evaluated within the context of the 

overall ecological health of the NCAs 

and a range of management alternatives 

relating to grazing is included in Chapter 

2 for each NCA.

PLANNING AND MANAGEMENT ISSUES

“The non-motorized 

recreational 

opportunities within 

the Red Cliffs NCA are 

outstanding 

and unique."

–Comment from 

Public Scoping

"Don't squat with your 

spurs on."

–Will Rogers, Cowboy 

and Humorist, 

1879-1935

Photo 1-20 Woodbury Road Crags, Beaver 

Dam Wash NCA

© Todd Goss

Photo 1-21 Livestock, Beaver Dam Wash NCA
32 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 33

1.6.1.7 What land uses should be authorized in the NCAs?

Many written comments expressed opposition to the granting of new ROWs for 

utilities or other purposes in the NCAs, 

as construction of these facilities could 

negatively impact native species habitats, 

cultural resources, and the scenic qualities of the areas. 

Several utility companies and local 

community representatives provided 

comments identifying the need for new 

ROWs through Red Cliffs NCA to support anticipated regional growth and 

development. Specific Congressional 

direction relating to development of utilities in Red Cliffs NCA was included in 

OPLMA Section 1974 (h). This section 

states that: 

Nothing in this section prohibits authorization of the development of utilities within the [Red Cliffs] National 

Conservation Area if the development 

is carried out in accordance with—(1) 

each utility development protocol 

described in the habitat conservation 

plan; and (2) any other applicable law 

(including regulations).

The utility development protocol referenced above identifies mitigation 

measures to lessen the environmental 

impacts on critical habitat and populations of Mojave desert tortoise that 

can occur during the construction and 

maintenance of power transmission lines 

or water conveyance pipelines and access 

roads needed to service these utilities. 

This protocol, however, does not address 

the mitigation of development impacts 

on the many other resource values 

that Congress identified for conservation, protection, and enhancement in 

the NCAs, through OPLMA. A range 

of management alternatives relating to 

ROWs and other land uses is included in 

Chapter 2, for each NCA.

No Congressional direction regarding 

utility development was provided for 

Beaver Dam Wash NCA in OPLMA.

1.6.1.8 How will transportation and access be managed in the NCAs?

Transportation and access (or travel 

planning) emerged from the scoping 

process as an issue of primary concern 

for the public, both within the NCAs 

and on other public lands managed by 

the SGFO. Some commenters indicated 

that limiting motorized vehicular access 

would provide the best protection of 

NCA values. Others expressed the opinion that all existing routes should remain 

open for recreational and resource uses. 

The Draft RMPs will provide a range of 

alternatives relating to OHV area designations, but will not provide a similar 

range for individual route designations 

in the NCAs. These will be developed in 

the TMP that is currently being prepared 

by BLM for all routes and trails on public 

lands in Washington County. A Draft 

TMP, supported by a NEPA analysis, will 

be made available for public review and 

comment shortly after the Draft RMPs 

and Draft Amendment/Draft EIS have 

been released for review.

1.6.2 Planning Issues Specific to Red 

Cliffs NCA

1.6.2.1 Should a “northern transportation route” be designated through the 

NCA?

OPLMA at Section 1977 (b) 2 (A) directs 

that the Secretary shall, while developing 

the comprehensive travel management 

plan for Washington County and “in 

consultation with appropriate Federal 

agencies, State, tribal, and local governmental entities (including the County 

and St. George City, Utah), and the public, identify one or more alternatives for a 

northern transportation route in 

the County.”

The Washington County Commissioners, 

joined by the Utah Department of 

Transportation (UDOT), the Dixie 

Metropolitan Planning Organization 

(DMPO), the City of St. George, and 

other municipal governments, formally 

requested that BLM evaluate multiple 

alternative routes for a multi-lane road 

(the “northern transportation route”) 

through the Red Cliffs NCA. All of the 

alternative routes would cross the NCA; 

one of the routes would primarily cross 

lands managed by the US Forest Service, 

Pine Valley Ranger District of the Dixie 

National Forest.

The stated need for this proposed 

multi-lane road (previously labeled the 

Northern Corridor, Great Northern 

Corridor, and, most recently, the 

Washington Parkway in local transportation plans) would be to reduce projected 

traffic pressure on existing roads in the 

greater St. George metropolitan area 

(Photo 1-22). A study commissioned 

by this group indicated that construction of a new multi-lane road (identified as Option #3 through the NCA in 

that study), in combination with other 

traffic-reducing measures, would afford 

measurable traffic congestion relief, based 

on projections of travel demand in 2040 

(Horrocks Engineers 2011).

During public scoping, many written comments addressed the potential 

conflicts that would be associated with 

the construction of a new multi-lane road 

through the NCA and recommended that 

BLM not authorize this proposed land 

use. Members of the public cited the apparent conflict with the Congressionallydefined purposes of conservation, protection, and enhancement of resource values 

on the public lands of the NCA. Other 

public scoping comments addressed the 

potential impacts on cultural resources 

or recreational uses, as reasons not to 

authorize the proposed new multi-lane 

road through the NCA. (Refer to Scoping 

Report (United States Department of 

Interior (USDOI) 2010).

Others noted that authorizing this proposed new multi-lane road through the 

NCA would result in the loss of acres of 

designated critical habitat and impacts 

on populations of threatened and endangered species. It could also violate commitments made by BLM, Washington 

County, the State of Utah, and other entities, through the HCP Implementation 

Agreement as they relate to managing the 

PLANNING AND MANAGEMENT ISSUES PLANNING AND MANAGEMENT ISSUES

“Step with care 

and great tact, and 

remember that life’s a 

great balancing act.”

–Dr. Suess, Author, 

1904-1991 "I may not have gone 

where I intended to go, 

but I think I have ended 

up where I needed 

to be."

–Douglas Adams, 

Author and Humorist, 

1952-2001

Photo 1-22 St. George Metropolitan Area 

Abutting Red Cliffs NCA
34 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 35

lands within the boundaries of the NCA 

and Red Cliffs Desert Reserve to protect 

listed species and habitats.

Some commenters noted that development of this proposed multi-lane road 

through the NCA could invalidate 

Washington County’s Incidental Take 

Permit for desert tortoise populations 

and critical habitat (Photo 1-23), issued 

by the USFWS under Section 10 of the 

Endangered Species Act in 1996. This 

permit has allowed growth and development to occur in an orderly and predictable manner on private lands in desert 

tortoise habitat in Washington County 

since 1996.

In compliance with the legislative mandate of OPLMA Section 1977 (b) 2 (A), 

and acknowledging Washington County’s 

role as a Cooperating Agency, BLM has 

proposed in one management alternative 

in the Draft RMP to designate a new utility and transportation corridor through 

the Red Cliffs NCA that could accommodate any of the route alignments for a 

“northern transportation route” submitted by Washington County. The supporting Draft EIS evaluates the potential 

environmental consequences of selecting 

this alternative on the resource values of 

the NCA.

1.6.3 Issues Outside of the Scope of 

this Planning Process

1.6.3.1 Managing public lands in the 

Beaver Dam Wash and Red Cliffs NCAs 

for mining, oil and gas development, 

and sale of mineral materials

OPLMA Sections 1974 (b) and 1975 (b) 

withdrew the public lands of the two 

NCAs from location, entry, and patenting under the General Mining Law of 

1872 and from operation of the mineral 

leasing, mineral materials, and geothermal leasing laws, subject to valid existing rights on the date of NCA designation, March 30, 2009. No oil and gas 

or geothermal leases were in effect and 

no mineral material sites were located 

in either of the NCAs on that date. A 

small number of locatable mining claims 

were active when the two NCAs were 

designated. To develop these claims, 

the claimholders must comply with the 

regulatory requirements outlined in the 

Code of Federal Regulations at 43 CFR 

3809 and 3715. As the legislative withdrawals mandated by OPLMA preclude 

the management of public lands in the 

Beaver Dam Wash and Red Cliffs NCAs 

for locatable, leasable, and salable minerals, these issues are beyond the scope of 

this planning process.

1.6.3.2 Selling or exchanging public lands in the Beaver Dam Wash 

and Red Cliffs NCAs or elsewhere in 

Washington County

During scoping, comments were received from the public stating that BLM 

needed to sell or exchange additional 

public lands in Washington County, to 

assist future growth and development. 

OPLMA Sections 1974 (b) and 1975 (b) 

specifically withdrew the public lands of 

the two NCAs from all forms of entry, 

appropriation, and disposal under the 

public land laws. It is, therefore, outside 

of BLM’s legal authority and the scope of 

this planning process to develop management alternatives in the draft RMPs that 

address the sale, exchange, and appropriation of public lands within the Beaver 

Dam Wash and Red Cliffs NCAs.

Approximately 18,000 acres of public 

land (outside of the NCAs) were identified as available for transfer out of federal 

ownership, through sale or exchange, in 

the SGFO RMP (1999). Sales, exchanges, 

leases, and conveyances of the identified 

acres have been ongoing since 1999, in 

conformance with this management decision, but not all of the acreage has been 

transferred from federal ownership. 

The Amendment currently being 

prepared for that RMP is focused on 

two planning issues in response to the 

legislative mandates of OPLMA. It is 

outside of the scope of the amendment 

planning process to develop management 

alternatives that address the sale or 

exchange of additional public lands in 

Washington County.

1.6.3.3 Eliminating or changing 

Congressional designations related 

to motorized vehicle travel in Beaver 

Dam Wash NCA

Congress, through OPLMA Section 1975 

(e) (3) A and B, addressed motorized 

vehicle travel in the Beaver Dam Wash 

NCA (Photo 1-24) by designating three 

geographic areas, labeled “Designated 

Road Areas,” where such travel (except for 

emergency and administrative purposes) 

was to be permitted only on the roads 

displayed on the legislative map. In areas 

outside of the “Designated Road Areas,” 

motorized vehicle travel was to be limited 

to roads that would be designated by BLM 

through a public travel planning process.

During scoping, some commenters 

recommended that BLM remove the 

motorized vehicle travel restrictions, or 

add additional roads, above and beyond 

those identified by Congress within the 

PLANNING AND MANAGEMENT ISSUES PLANNING AND MANAGEMENT ISSUES

“Conservation is a state 

of harmony between 

men and land."

– Aldo Leopold, 

Conservationist, 

1887-1948

Tread Lightly!

Travel responsibly

Respect the rights of others

Educate yourself

Avoid sensitive areas

Do your part

Photo 1-23 Critical Mojave Desert Tortoise Habitat, Red Cliffs NCA Photo 1-24 Designated Road Area, Beaver Dam Wash NCA
36 Chapter 1 BDWNCA • RCNCA • SGFO RMP Amendment BDWNCA • RCNCA • SGFO RMP Amendment Chapter 1 37

Designated Road Areas, as available 

for public motorized vehicle travel. As 

BLM does not have the legal authority to change the designations made by 

Congress, including the addition of other 

roads within the Designated Road Areas, 

this issue was not carried forward for 

consideration in the development of the 

RMP for Beaver Dam Wash NCA.

1.6.3.4 Designating new ACECs for 

resource values other than priority 

biological species on public lands managed by the SGFO

A small number of nominations for 

proposed ACECs did not address priority biological species or included additional acreage of public lands, in order 

to include sensitive cultural resources or 

other resource values within the boundaries of the nomination. The Amendment 

to the SGFO RMP is being prepared to 

address the specific legislative mandate of 

OPLMA at Section 1979 that addresses 

the conservation and restoration of priority biological species and natural communities. Nominations for new ACECs for 

resource values received during scoping, 

other than priority biological species, will 

be retained for ACEC evaluation and potential designation when a full revision of 

the SGFO RMP is undertaken in the future. In the interim, BLM will determine 

if the areas nominated contain values that 

satisfy the criteria for both relevance and 

importance and whether those values are 

in need of special management at this 

time. If so, BLM will implement interim 

protective measures.

1.6.3.5 Evaluating and Analyzing new 

Wild and Scenic River Proposals 

The Amendment of the SGFO RMP 

was legislatively mandated by sections 

of OPLMA and limited in scope to two 

issues: changes to the OHV area designations (Open, Closed, Limited) approved through the current RMP; and 

identification of areas of public land in 

Washington County “where biological conservation is a priority”, pursuant 

PLANNING AND MANAGEMENT ISSUES

to section 1979 of OPLMA. Evaluating 

and analyzing new proposals for Wild 

and Scenic Rivers was not directed by 

OPLMA and is, therefore, outside of the 

scope of this planning process. 

Through OPLMA, Congress designated 

11 short segments of tributaries of the 

Virgin River on public lands that flow 

into and out of Zion National Park to 

the National System of Wild and Scenic 

Rivers. One suitable river segment under 

the administration of the St. George Field 

Office was not designated to the national 

system, but will continue to be managed in accordance with BLM Manual 

6400-Wild and Scenic Rivers-Policy and 

Program Direction for Identification, 

Evaluation, and Management (2012).

1.6.3.6 Resolving Revised Statute 2477 

claims

Federal Revised Statute (RS) 2477, contained in the Mining Law of 1866 (Act of 

July 28, 1866, chapter 262, 8, 14 Stat. 252. 

codified at 43 U.S.C. 932), was intended 

to facilitate settlement of the Western 

states by granting counties and states a 

ROW for the construction of highways 

across unreserved public lands. In 1938, 

as part of the recodification of statutes, 

R.S.2477 became 43 U.S.C. 932 until its 

repeal in 1976 through the passage of 

FLPMA. Since that time, determining 

which routes are the responsibilities of 

the counties because they were developed 

across public lands under the authority of 

R.S.2477 has been a contentious issue for 

federal agencies in the West. Resolution 

of R.S.2477 claims is a legal matter that 

cannot be resolved through BLM’s land 

use planning process. Management 

decisions in approved RMPs do not 

extinguish any valid ROWs and do not 

alter the legal rights of states and counties to assert and protect R.S.2477 claims. 

Similarly, no RMP decisions extinguish 

or alter the rights of states and counties 

to challenge in federal court or other 

appropriate venue any use restrictions 

imposed by the RMP that they believe 

abrogate their rights under R.S.2477.

PLANNING AND MANAGEMENT ISSUES

“If you don’t know 

where you are 

going, you’ll end up 

someplace else.” 

–Yogi Berra, Former 

Major League Baseball 

Player and Manager, 

1925-

“In the hopes of 

reaching the moon 

men fail to see the 

flowers that blossom at 

their feet.“

–Albert Einstein, 

Theoretical Physicist, 

1879-1955

Photo 1-26 Utility Terrain Vehicle (UTV) Recreating on Public Lands

Photo 1-25 Utah Agave, Red Cliffs NCA