Grand Staircase-Escalante National Monument Analysis

The document, authored by Bureau of Land Management officials, suggests that the designation of a national monument in 1996 led to more archaeological finds and less vandalism.

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Attachments:

Nikki Moore
randal_bowman@ios.doi.gov
mnedd@blm.gov; kathleen_benedetto@ios.doi.gov; jruhs@blm.gov; Peter Mali; cmcalear@blm.gov; Sally Butts;
tjfisher@blm.gov; kbail@blm.gov; aaron.moody@sol.doi.gov; mrallen@blm.gov; eroberso@blm.gov; salt
GSENM Executive Summary and Initial Data Request
Friday, May 19, 2017 6:59:42 PM
attachedFile.html
CLEAN_Executive Summary for GSENM_Ruhs edits Mali edits_5.19.2017.docx
InitialDataRequestRelatedtoReviewofNationalMonuments_GSENM.docx
attachedFile.html
Additional Information Requested on Grand Staircase-Escalante NM.docx
attachedFile.html

Hi Randy,
We have completed our review?of the initial responses provided in response to the?April 26,
2017?Executive Order 13792 and initial?data request. The executive summary and detailed
response for the requested items are attached and will be uploaded to the respective Google
Drive folder for the Grand Staircase-Escalante National Monument in addition to the
supporting data and documents.
Per your request, I have also attached the additional information in a word document below
and will shared the google docs that provide the supporting data and information.?
Please let me know if you have any questions.
Hope you have a great weekend!

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Executive Summary of Review of National Monuments under EO 13792 (April 26, 2017)
Key Information about Grand Staircase Escalante National Monument
Grand Staircase-Escalante National Monument (GSENM), established by Presidential Proclamation on
September 18, 1996, was the BLMas first national monument. Prior to designation, the area was
managed by the BLM and continues to be following designation. The BLM manages for multiple use
within the Monument (hunting, fishing, recreation, grazing, and valid existing rights such as oil
production, etc.), while protecting the vast array of historic and scientific resources identified in the
Proclamation and providing opportunities for scientific study of those resources. The resources
identified in the Proclamation include geologic features of exposed stratigraphy and structures,
renowned paleontological sites, archaeological sites that demonstrate extensive use of the area by
ancient Native American cultures with thousands of recorded cultural sites, a rich expanse of human
history, and five life zones of outstanding biological resources. Overall, multiple use activities are
allowed in GSENM that are compatible with the protection of resources and objects identified in the
Presidential Proclamation. Multiple-use activities are subject to decisions made in current and future
BLM resource management planning efforts which include public participation. National Monuments
and other conservation areas managed by the BLM continue to allow for multiple uses according to the
Federal Land Policy and Management Act (depending on proclamation language).
Summary of Public Engagement Prior to Designation
GSENM was designated in 1996 without public engagement. However, the area in southern Utah had
long been considered, discussed and evaluated for the possibility of providing greater recognition of and
legal protection for its resources. In 1936, the National Park Service (NPS) considered making a
recommendation to President Roosevelt to designate a 6,968 square mile aEscalante National
Monumenta (which also extended to portions of Bears Ears National Monument). A second NPS
proposal proposed a 2,450 square mile National Monument (Background folder-Google Drive). In the
late 1970s, under the authority of Section 603 of the Federal Land Policy and Management Act of 1976
(FLPMA), the BLM evaluated the area for its wilderness characteristics. The Section 603 process
ultimately led to the establishment of more than a dozen wilderness study areas (WSAs), totaling about
900,000 acres, in the area that is now GSENM.
Summary of Public Scoping in Development of Resource Management Plan
GSENMas Monument Management Plan included substantial outreach, public scoping and comment
periods according to land use planning regulations and policies. Over 6,800 individual letters were
received during the public scoping period. Similar public outreach efforts are underway for the
Livestock Grazing Monument Management Plan Amendment and Environmental Impact Statement.
Summary of National Monument Activities since Designation
In the 20 years since Grand Staircase-Escalante National Monument was designated, a wealth of
scientific knowledge has been discovered, with significant archaeological, paleontological, biological,
ecological and geological discoveries on the Monument. The Kaiparowits Plateau contains a plethora of
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paleontological specimens: twelve new dinosaur species have been discovered since designation. The
scientific research and discoveries were outlined and highlighted through a series of three aLearning
from the Landa Symposiums, in 1997, 2006 and 2016 (Symposium folder on Google drive). A
Monument Management Plan was completed in 2000, ensuring continued management of multiple uses
and valid existing rights. Recreational use, including commercial Special Recreation Permits has
increased substantially. GSENM provides visitor services and information at four visitor centers in
neighboring towns to support the increasing visitor and commercial use on the Monument and to foster
tourism in gateway communities. A summary of GSENM activities for 2016 can be found in the
Monument Manageras Report in the Background folder on the google drive.
Summary of Activities in Area for Five years Preceding Pre-Designation
Prior to the 1996 designation of GSENM, the public land was managed by the Bureau of Land
Management, within two resource areas: the Kanab Resource Area and the Escalante Resource Area.
The lands were used primarily for scientific study, primitive recreation and livestock grazing. Overall
permitted livestock grazing use within the Monument is at roughly the same level now as it has been
since the early 1990s. When the Monument was designated, there were 106,645 total Animal Unit
Months (AUMs), with 77,400 of these active. Today, there are 106,202 total AUMs and 76,957 are
active. In 1999, an adjustment in AUM levels was made to resolve riparian resources issues and address
recreation conflicts. In October 1991, the Utah Statewide Wilderness Study Report was submitted to
Congress. Within that recommendation, 881,997 acres within 16 WSAs were included within the area
that would become GSENM (47 percent of the Monument). Under Section 603 of FLPMA, the BLM
manages WSAs so as not to impair the suitability of such areas for preservation as wilderness.
Summary of Available Economic Information since Designation
Visitors to GSENM generated $60,637,361 expenditures creating additional 1,024 non-federal jobs
within the region for a total economic output of $91,476,382 (reference FY 2016 Economic Snapshot).
Economic research by external parties has been completed and includes GSENM-specific information in
several reports including the 2016 Economic Snapshot-Grand Staircase-Escalante National Monument,
the 2011 and 2014 Headwaters Economic Report, and a 2004 research paper by Dr. Steven Burr,
Director of the Institute for Outdoor Recreation and Tourism at Utah State University. In addition, a
Socioeconomic Baseline Report was completed for the Livestock Grazing Plan Amendment EIS in
2015. These documents, along with additional economic research, are provided in the Economic
subfolder in Google Drive.
Summary of Any Boundary Adjustments since Designation
Since designation, there have been two congressional boundary adjustments as well as an exchange of
all of the State of Utah School and Institutional Trust Lands Administration (SITLA) lands within the
Monument boundaries. When the Monument was designated, it encompassed 1,878,465 acres. In 1998,
H.R. 3910, the Automobile National Heritage Area Act (Public Law 105-355), resulted in a boundary
change to 1,884,011 acres, a net gain of approximately 5,546 acres. In 2009, H.R. 377, the Omnibus
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Public Land Management Act (Public Law 111-11), directed a boundary change and purchase for the
Turnabout Ranch, resulting in the removal of approximately 25 acres from GSENM. The Utah Schools
and Land Exchange Act of 1998 exchanged State/SITLA lands within the boundaries of GSENM. The
federal government received all State inholdings in GSENM (176,699 acres) while the State received
$50 million in cash plus $13 million in unleased coal and approximately 139,000 acres, including
mineral resources. The federal government received additional State holdings within other NPS and US
Forest Service units as part of the same exchange.

3
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Call for Data Related to Review of National Monuments under EO 13792 (April 26, 2017)
1. Documents Requested
a. Resource Management Plans/Land Use Plans
i.
The Monument Management Plan (MMP) and Record of Decision (ROD) is
located within this Drive
folder (1.GSENM_mgmt_plan.pdf).
ii. The entire GSENM RMP (DEIS/FEIS/ROD) can be accessed here:
https://eplanning.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&current
PageId=94418
iii. The Livestock Grazing EIS/Plan Amendment has been initiated. The DEIS
has been reviewed by the BLM Utah State Office and BLM Washington Office and is
nearing public release: https://eplanning.blm.gov/epl-frontoffice/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&current
PageId=100826
iv. The MMP has also been amended for Greater Sage Grouse habitat
conservation (2015), for an electrical transmission line Right-of-Way to support local
communities (2011), and for an update to fire management (2005).
b. Record of Decision
i.
The 1999 MMP and ROD is located within this Drive folder
(1.GSENM_mgmt_plan.pdf).
c. Public Scoping Documents
i. Grand Staircase-Escalante National Monumentas (GSENM) Management Plan
included substantial outreach, public scoping and comment periods according to
land use planning regulations and policies. See Federal Register Notices in Drive
folder (1.c.Federal Register, Volume 64 Issue 145 (Thursday, July 29, 1999).pdf).
ii. Public Comments and Responses for the MMP FEIS are located within this Drive
folder (1.c.GSENM_FEIS_Comments.pdf).
iii. See also Scoping Report for Livestock Grazing EIS
(1.c.GSENM_GrazingEISScopingRpt_Final.pdf) and
at: https://eplanning.blm.gov/epl-frontoffice/projects/lup/69026/89803/107384/2014.05.21_GSENM_ScopingRpt_Final
_508.pdf.
iv. GSENM worked with multiple agencies, tribes and communities and individuals
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and responded to more than 6,800 letters commenting on the 2000 MMP.
Nearly all site-specific NEPA analyses include public comment periods.
Additionally, GSENM has offered multiple opportunities for public engagement
in the Livestock Grazing Plan Amendment/EIS including:
aC/ Development of a Situation Assessment by National Riparian Service Team
aC/ Hosted 12 public scoping meetings and/or workshops
aC/ Hosted 3 Socio-economic workshops
aC/ Five newsletters developed along with a aFact Sheet Seriesa
aC/ Press releases published in five Utah newspapers
aC/ Maintained Project website with project updates
aC/ Hosted a Biological Soil Crust Forum
aC/ Public Release of Draft Alternatives
aC/ The inclusion of two Action Alternatives in the PDEIS that were derived from
external sources
aC/ Hosted 27 Cooperating Agency Meetings; 12 Forage Team Meetings
aC/ Outreach to local tribes
aC/ Monument Advisory Committee Input
aC/ Joint BLM/NPS Programmatic Agreement for Cultural Resources
aC/ Broad Consulting Party Process
aC/ Other meetings: County Coordination, State of Utah, Earthfest
GSENM demonstrates a commitment to continued public engagement in land use
planning processes.
d. Presidential Proclamation
i. Proclamation 6920 of September 18, 1996 is in this folder
(1.d.Presidential_Proclamation_6920.pdf).
2. Information on activities permitted at the Monument, including annual levels of activity
from the date of designation to the present
Designation date for GSENM is September 18, 1996.
a. Recreation - annual visits to site

2

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i.

To protect Monument resources and objects and to provide economic
opportunities in the local communities, major facilities including the four visitor
centers are located in the gateway towns of Kanab, Cannonville, Escalante, and
Bigwater.
ii. GSENM provides a large variety of multiple-use recreation opportunities
including traditional hiking and camping, hunting, fishing, horseback riding,
mountain biking, as well as motorized activities for off-highway vehicles.
iii. Commercial recreation activities (Outfitter and Guides) have risen since
Monument designation (2.a._GSENM Commercial_SRP.pdf).
iv. In 2016, 926,235 million visitors came to GSENM.
GSENM uses the Recreation Management Information System (RMIS) to report
visitor use, which is calculated using data from multiple traffic counters, permits
and visitor counts in the four Visitor Centers. BLMas Recreation Management
Information System (RMIS) is generally accepted as the agencyas official record,
however, RMIS was not available until 1999. Prior to 1999, GSENM aggregated
data from the Kanab and Escalante offices. (See:
2.a.GSENM_RecreationData_Excel.xls and
3.a.GSENM_Recreation_MMP_DEIS_Tables.pdf)
b. Energy - annual production of coal, oil, gas and renewables (if any) on site; amount of
energy transmission infrastructure on site (if any)
i. All Valid Existing Rights for leasable minerals including coal, and oil and gas are
continued.
ii. No new leases have been issued since designation. GSENM has no commercial
renewable energy.
iii. The annual production of oil and gas in the GSENM is currently limited to lands in
or adjacent to the Upper Valley Unit (UVU) in the north-central area of the
GSENM (Attachments: 2.b.Upper Valley Unit Map.pdf; 2.b.Upper Valley GSE
Production.pdf; 2.b.Upper Valley Wells in GSENM.xls; and
2.b.UDOGM_O&Gprod_data_Upper Valley.pdf). GSENM shares the Upper Valley
Oil Field with the Dixie National Forest; this field accounts for all oil and gas
production in GSENM. Attached documents disclose production for the Upper
Valley Field. Four wells within the GSENM are currently producing oil and a small
amount of gas. The UVU was approved in 1962 and production from the wells
peaked in 1972 at 183,133 barrels. In the last 20 years (1997-2016) production
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iv.

v.
vi.

has slowly declined from about 65,828 barrels of oil and no gas annually to
45,538 barrels of oil and 2,357 thousand cubic feet (mcf) of gas. There is no
other oil and gas production in GSENM, or Kane and Garfield Counties.
No coal lands have been explored or coal produced within the GSENM since the
September 18, 1996 designation. Existing coal leases were voluntarily
exchanged for Federal payments totaling $19.5 million (not adjusted for
inflation) (2.b.GSENM Coal Lease Cancellation Payments.pdf)
34 oil and gas leases (45,894 acres) are in suspension while a Combined
Hydrocarbon Lease (CHL) conversion application is processed.
Information related to energy transmission infrastructure and lands and realty
actions is included in the table below:
Grand Staircase-Escalante National Monument
Existing Rights-of-Way/Permits/Authorized
09/25/1996 a 05/15/2017

Existing Withdrawals: PSR, PWR, Bureau of Reclamation, Forest Service
Wilderness, Power Site, National Park Service, In Trust for Indians

17

Road ROWs

19

Misc. Roads and Associated Uses - Sec 107 Federal Aid Hwy, Revised Statute
2477, Mineral Material Sites

0

Power Transmission Lines and Power Facilities

20

Communication Sites a Telephone, Telegraph, Radio Transmission, Global
Positioning Systems

15

Water ROWs, Irrigation Facilities

14

Oil and Gas Pipelines, Oil and Gas Facilities

5

4

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Other FLPMA ROWs, Perpetual Easements, Federal Facilities

2

Airport

0

Permit - 302 FLPMA a Misc.

0

Permits Film - 302 FLPMA (popular location (closed))

54

c. Minerals - annual mineral production on site
i. Mineral materials
a No new Free Use, commercial, or over-the-counter permits have been
issued since Monument designation.
a Valid existing permits, including those in Title 23 (3 Federal Highway
Rights of Way), continue to be recognized until permit expiration.
a Significant quantities of gravel and riprap from existing pits continue to
be provided for Federal Highways projects, primarily to Utah Department
of Transportation.
a According to UGS Circular 93, January 1997, aA Preliminary Assessment of
Energy and Mineral Resources within the Grand Staircase-Escalante
National Monumenta (2.c.UGS Circular 93 GS Energy and Mineral
Resources.pdf) there were five small mining operations on unpatented
mining claims, four of which were active alabaster quarries and one, a
suspended operation for petrified wood. Annual production of the
alabaster was about 300 tons worth $500 per ton ($150,000/yr). These
claimants failed to pay the required annual filings and therefore, the
claims were terminated. The BLMas decision to close the claims was
upheld by IBLA in March 2008. Since that time, there have been no
mining law operations within the monument.
ii. Locatable Minerals
a No new mining claims were issued after Monument designation, however
existing claims and active mines were allowed to continue. (List of active
mines in MMP DEIS located within this Drive folder 2.c. MMP_DEIS Table
3.10_Locatables.pdf).
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d. Timber - annual timber production on site (in board-feet, CCF, or similar measure)
i. No commercial timber production pre/post Monument designation.
ii. GSENM does allow continued firewood cutting in two forestry product areas.
e. Grazing - annual grazing on site (AUMs active and billed)
i. Grazing on the Monument Fact Sheet (2.e_GSENM Grazing EIS Fact Sheet 05-082017.pdf).
ii. Grazing AUMs/ Active and billed (2.e._GSENM Grazing AUMs).
iii. When the Monument was designated, there were 106,645 total AUMs, with
77,400 of these active. Today, there are 106,202 total AUMs and 76,957 are active. In
1999, an adjustment in AUM levels was made to resolve riparian resources issues and
address recreation conflicts. In the current Livestock Grazing EIS/Plan Amendment
process the current prefered alternative will have a slight reduction with 105,765 AUM
but an increase of total acres for grazing within the monument.
f. Subsistence - participation rates for subsistence activities occurring on site (fishing,
hunting, gathering); quantities harvested; other quantifiable information where
available
i. Subsistence activities are those that provide the bare essentials for living: food,
water, and shelter. The Federal Subsistence Management Program provides
opportunities for subsistence way of life in Alaska on federal public lands and
waters. There are no formal subsistence programs outside of Alaska. There are
no known true subsistence activities occurring on GSENM or prior to its
designation. GSENM does provide for the collection of certain natural materials
by Native American Indians, under BLM permit. RMIS data provides the number
of permitted/guided and recreational hunting activities, fishing activities and
gathering activities (See: 2.a.GSENM_RecreationData_Excel.xls). These numbers
do not reflect the actual number of licensed hunters/fishermen. That data is
available from the State of Utah Division of Wildlife Resources. Outside of
developed recreation sites, the entire GSENM is open for hunting and fishing,
which is regulated by the State of Utah Division of Wildlife Resources.
g. Cultural - list of cultural uses/values for site; number of sites; other quantifiable
information where available
i. Archeological/cultural data is provided in the following Utah Division of State
History Maps in the google drive (2.g.1_GSENM_SiteDensity,
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ii.

iii.

iv.

2.g.2_GSENM_Inventories, 2.g.3_GSENM_ArchSites,
2.g.4_GSENM_ArchNumofSites).
Archaeological surveys carried out to date, show extensive use of places within
the monument by ancient Native American cultures and a contact point for
Anasazi and Fremont cultures. The cultural resources discovered so far in the
monument are outstanding in their variety of cultural affiliation, type and
distribution. Hundreds of recorded sites include rock art panels, occupation
sites, campsites and granaries. Cultural sites include historic and prehistoric
sites, Traditional Cultural Properties, Native American Sacred Sites and cultural
landscapes.
According to the Utah State Historic Preservation Office (SHPO), as of March 6,
2017, there are 3,985 recorded archaeological sites within the Grand StaircaseEscalante National Monument (GSENM)(2.g.4_GSENM_ArchNumofSites).
However, the GSENM staff estimates that there are more likely around 6,000
recorded archaeological sites within the GSENM, due to a records backlog. This
is with only five to seven percent of the Monument surveyed.
Cultural Values (Tribal): Prehistoric archaeological sites in the GSENM include
pottery and stone tool (lithic) scatters, the remains of cooking features (hearths),
storage features such as adobe granaries and subsurface stone lined granaries,
prehistoric roads, petroglyphs, pictographs and cliff dwellings. Historic sites
include historic debris scatters, roads, trails, fences, inscriptions, and structures.
Following the designation of GSENM, consultations were initiated with the
Native American tribes associated with the GSENM area, including the Hopi, the
Kaibab Paiute, the San Juan Paiute, the Paiute Indian Tribes of Utah, the Zuni,
and the Ute, and the Navajo. Over the past 20 years, the Hopi and the Kaibab
Paiute have been most closely associated with the Monument and most
responsive to continued consultations, as the GSENM area is central to the
historic and prehistoric territories of these two tribes. All tribes considered the
Monument area to be culturally important; the Hopi (as the modern
descendants of the Ancestral Puebloans), for example, can trace the migrations
of at least twelve clans through what is today GSENM (Bernardini 2005). The
tribal connections to this land are probably best described by an example from
the Kaibab Paiute, as related to ethnographers from the University of Arizona, as
follows (Stoffle et al 2001): aThe Southern Paiute people continue to maintain a
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strong attachment to the holy lands of their ethnic group as well as to their own
local territory. These attachments continued even though Paiute sovereignty has
been lost over portions of these lands due to Navajo ethnic group expansion,
encroachment by Euro Americans, and Federal government legislation. Despite
the loss of Paiute sovereignty over most traditional lands, Southern Paiute people
continue to affiliate themselves with these places as symbols of their common
ethnic identity. Additionally, all Southern Paiute people continue to perform
traditional ceremonies along with the menarche and first childbirth rites of
passage rituals. The locations at which these ceremonies and rituals have been or
are currently performed become transformed from secular "sites" to highly
sacred locations or places. By virtue of the transformation of locations into
sacred places, Southern Paiute people reaffirm their ties to traditional lands
because they have carried out their sacred responsibilities as given to them by
the Creator.a
v. Cultural values (Ranching) Local ranching began in the 1860s, and became a
major focus of area livelihood and increased settlement in the 1870s. Ranching
was initially small scale and for local subsistence, but the herds quickly grew so
that by the late 1800s the raising of cattle, sheep, and goats was of major
economic importance. Ranching and subsistence farming was historically the
backbone of the local economies, and this is still reflected in the views of the
modern communities surrounding GSENM. In modern times the economic
importance of ranching has somewhat diminished, but the culture of, and past
history of, livestock grazing and ranching is one of the important agluesa that
binds local communities and families in the GSENM area.
3. Information on activities occurring during the five years prior to designation
a. Recreation - annual visits to site
i. The BLM transitioned to RMIS in 1999. Data prior to 1999 is not available in the
same reporting mechanism as from 1999-Present. GSENM did report visitor use
beginning in FY97. (See: 2.a.GSENM_RecreationData_Excel.xls and
3.a.GSENM_Recreation_MMP_DEIS_Tables.pdf).
Overall visitation increased prior to designation and the projecting trends based
on the historical information would see a continued rise of visitors seeking
recreational opportunities. Just prior to designation Escalante Canyon received
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373,200 visitors in 1994, 384,800 visitors in 1995 and 456,400 in 1996.
b. Energy - annual production of coal, oil, gas and renewables (if any) on site; amount of
energy transmission infrastructure on site (if any)
i. The Upper Valley Oil Field was in production prior to designation; no other oil
and gas production existed in Kane and Garfield Counties. From 1992 until 1996,
336,313 barrels of oil were produced in the GSENM. No natural gas was
produced during that time. (2.b.Upper Valley GSE Production.pdf).
ii. No coal was produced from the GSENM in the five years preceding designation.
A regional analysis/FEIS for mining was completed in 1979 (3.b.FINAL EIS - Dev of
Coal Resources in Southern Utah Title Pages.pdf). Exploration activities and
planning for mining operations continued from the 1980as until the monument
designation.
a 64 coal leases (~168,000 acres) were committed and a plan was
submitted for Andalex Resourcesa Smoky Hollow Mine. The plan
proposed mining on 23,799 acres of the area leased in GSENM. In the
mid-1990as an EIS was initiated (3.b.4.b.Warm Springs Smoky Hollow
PDEIS December 1995_Coveronly.pdf).
a 600+ exploration drill holes were completed prior to GSENM designation
to defined the coal geology to plan for underground mines (See 3.b.BLM
1996-1997 Kaiparowits Coal Report - DRAFT.pdf
and https://pubs.usgs.gov/of/1996/OF96-539)
iii. Information related to energy transmission infrastructure and lands and realty
actions is included in the table below:

Grand Staircase-Escalante National Monument
Existing Rights-of-Way/Permits/All Dispositions
Authorized/Closed/Relinquished/Withdrawn/Expired/Terminated/Cancelled/Pending/
Rejected/Void
01/01/1991 a 09/24/1996
(In March 1999, BLM added Case Recordation components to
the LR2000 Database System; therefore, some of the
pre-LR2000 data may remain in the Status Database)
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Existing Withdrawals: PSR, PWR, Bureau of Reclamation, Forest Service
Wilderness, Power Site, National Park Service, In Trust for Indians

1

Roads ROWs

8

Misc. Roads - Sec 107 Federal Aid Hwy, RS2477, Mineral Material Sites

1

Power Transmission Lines & Power Facilities

1

Communication Sites a Telephone, Telegraph, Radio Transmission,
Global Positioning Systems

1

Water ROWs, Irrigation Facilities

0

Oil & Gas Pipelines, Oil & Gas Facilities

2

Other FLPMA ROWs, Perpetual Easements, Federal Facilities

6

Airport

0

Permit - 302 FLPMA a Misc.

25

Permits Film - 302 FLPMA (popular location (closed))

0

10

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c. Minerals - annual mineral production on site
i. The alabaster quarries were the only authorized locatable minerals operation
(dating to 06/30/1986) in the area prior to designation.
ii. Mineral materials, primarily sand and gravel and riprap, were extracted from
developed pits by counties and commercial entities for local use. There were
eight Mineral Material Cases in the monument at designation, and most were
Free Use Permits granted to the county.
d. Timber - annual timber production on site (in board-feet, CCF, or similar measure)
i. No commercial timber production pre/post Monument designation.
ii. Prior to designation, the Kanab and Escalante Resource Areas were open to
firewood cutting.
e. Grazing - annual grazing on site (AUMs active and billed)
i. Grazing on the Monument Fact Sheet (2.e_GSENM Grazing EIS Fact Sheet 05-082017.pdf).
ii.
Grazing AUMs/ Active and billed (2.e._GSENM Grazing AUMs)
iii. When the Monument was designated, there were 106,645 total AUMs, with
77,400 of these active. Today, there are 106,202 total AUMs and 76,957 are
active. In 1999, an adjustment in AUM levels was made to resolve riparian
resources issues and address recreation conflicts. The current Livestock Grazing
EIS/Plan Amendment process the current prefered alternative will have a slight
reduction with 105,765 AUM but an increase of total acres for grazing within the
monument.
f. Subsistence - participation rates for subsistence activities occurring on site (fishing,
hunting, gathering); quantities harvested; other quantifiable information where
available
i. There are no known true subsistence activities occurring on GSENM or prior to
its designation. Recreational fishing, hunting and gathering data from RMIS is
not available prior to designation.
g. Cultural - list of cultural uses/values for site; number of sites; other quantifiable
information where available
i. In the five year period prior to designation of GSENM, a total of approximately
358 cultural resource sites were documented in what was to become GSENM, or
about 72 sites/year. Following designation, approximately 3,219 sites were
documented, or about 161 sites/year. This increase reflects the increased
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funding and greater research opportunities following GSENM designation.
ii. In the five year period prior to designation of GSENM, a total of approximately
3991 acres of new cultural resource surveys were conducted in what was to
become GSENM, or about 798 acres/year. Following designation, approximately
41, 024 acres of new cultural resource surveys were conducted, or about 2051
acres/year. This increase reflects the increased funding and greater research
opportunities following GSENM designation, as well as substantial habitat
improvement projects.
4. Information on activities that likely would have occurred annually from the date of
designation to the present if the Monument had not been designated
The answers to this question are speculative. The question is best answered with
qualitative (rather than quantitative) data. As GSENM was designated 20 years ago,
the factors affecting such projections are subject to a wide range of variables (many of
which are outside of BLMas purview, such as market prices).
a. Recreation - annual visits to site
i. Research by external parties (e.g., Headwaters Economics and Pew Trust reports)
indicate that protected landscapes are a draw for visitors and do result in
increased visitation to a region. Thus, it is reasonable to conclude that visitation
would be less if the lands had not been designated as a monument.
b. Energy - annual production of coal, oil, gas and renewables (if any) on site; amount of
energy transmission infrastructure on site (if any)
Commercial speculation depends on the price of commodities.
i. Except for the Upper Valley Field, there have been no oil and gas discoveries
within the GSENM. Forty-seven exploratory wells have been drilled; exploration
activities were relatively sparse and cover an average of 57 square miles per well
(2.c.UGS Circular 93 GS Energy and Mineral Resources.pdf, page iv).
ii. An Application for a Permit to Drill (APD) was submitted for valid existing leases
within the Circle Cliffs Unit. The APD was neither approved nor rejected and the
lessee allowed the leases to terminate.
iii. Four wildcat oil and gas wells have been drilled on GSENM since designation
(1997-1999); none went into production.
iv. Since there have been no discoveries upon which to base production numbers,
estimates of the value of production vary widely. The Utah Geological Survey
(UGS) projected 2.6 to 10.5 trillion cubic feet (2.6 to 10.5 billion mcf) of coal-bed
12

DOI-2018-07 01396

v.

vi.

vii.

viii.

ix.

x.

methane may be contained in the GSENM. The UGS also projected aa|550 million
barrels of oil might be contained within tar sands of the monument.a In January
1997, it was speculated that total value of coalbed natural gas and petroleum
within the GSENM ranged between $2.02 and $18.6 billion (2.c.UGS Circular 93
GS Energy and Mineral Resources.pdf).
It is reasonable to conclude absent a national monument designation, the
opportunities for additional oil and gas exploration, discovery and development
would be based on the viability of development and the economic value and
access to distribution.
The Kaiparowits plateau, located within the monument, contains one of the
largest coal deposits in the United States. The USGS projected aan original
resourcea of 62 billion tons of coal with a geologic and mining technology
adjusted resource of 30 billion tons (https://pubs.usgs.gov/of/1996/OF96-539).
The DEIS for the Smoky Hollow Mine (3.b.4.b.Warm Springs Smoky Hollow PDEIS
December 1995_Coveronly.pdf) and the Alton coal mine producing from
adjacent private lands provide an example of the development potential.
Andalex coal leases were voluntary sold to the Land and Water Conservation
Fund (LWCF) at market value. At the time of designation, the Warm Springs
Smoky Hollow DEIS was in progress to analyze the proposed mine. Andalex
Resources may or may not have actually decided to develop the coal resources
based on varying economic projections for the project, particularly the cost of
transporting the coal.
The Utah Geological Service projected 11.36 billion tons are atechnologically
recoverablea (including 870 million tons in what was previously State of Utah
School and Institutional Trust lands (SITLA)(2.c.UGS Circular 93 GS Energy and
Mineral Resources.pdf). Recent advances in underground coal mining techniques
would likely result in the development of additional large areas of Kaiparowits
coal resources not considered minable in the 1990as.
The School Institutional Trust Lands Administration (SITLA) lands were
exchanged for cash payments and federal coal and oil and gas properties outside
the monument. Absent a monument designation, the federal/SITLA land
exchange would likely not have occurred.
Applications for rights of way and other energy transmission infrastructure may
have continue to occur within the current monument boundaries including
13

DOI-2018-07 01397

opportunities for mineral development.
c. Minerals - annual mineral production on site
i. Absent monument designation, it is likely relinquished alabaster claims may have
been relocated and additional alabaster mining claims may have been filed. For
the alabaster quarries, aOver a 30-year period, the quarries should generate $4.5
million in production.a (2.c.UGS Circular 93 GS Energy and Mineral
Resources.pdf)
ii. The Utah Geological Survey mineral report stated, aVarious types of metallicmineral deposits are known to be present in the monument (figure 14). Most of
these are small and low-grade with uncertain likelihood of significant
development.a The report addressed specific minerals with known or potential
deposits within the monument, but they determined at that time they were
probably not commercial quality due to low, often subeconomic grades and
limited tonnage. Thus, it is unlikely that metallic mining would have occurred.
(2.c.UGS Circular 93 GS Energy and Mineral Resources.pdf)
iii. There would most likely be additional mineral material sites for sand and gravel
and the existing Free Use Permits granted to Kane County most likely still be in
use.
d. Timber - annual timber production on site (in board-feet, CCF, or similar measure)
i. There is little harvestable lumber on the Monument (a little more than 1,000
acres of ponderosa). The mill harvested trees from the surrounding Dixie
National Forest. The closure of the mill in Escalante was not connected to
timber harvest on BLM lands.
e. Grazing - annual grazing on site (AUMs Active and billed)
i. Grazing/ AUMs active and billed would likely have remained the same.
ii. Grazing is and was managed by applicable laws and regulations. As stated in the
Proclamation; aNothing in this proclamation shall be deemed to affect existing
permits or leases for, or levels of, livestock grazing on Federal lands within the
monument; existing grazing uses shall continue to be governed by applicable
laws and regulations other than this proclamation.a
iii. Although grazing use levels have varied considerably from year to year due to
factors like drought, no reductions in permitted livestock grazing use have been
made as a result of the Monument designation.

14

DOI-2018-07 01398

f. Subsistence - participation rates for subsistence activities occurring on site (fishing,
hunting, gathering); quantities harvested; other quantifiable information where
available
i. No likely changes or statistically significant differences from the reported RMIS
data.
g. Cultural - list of cultural uses/values for site; number of sites; other quantifiable
information where available
i. Less inventory would have likely occurred without the Monument designation.
The Resource Areas averaged about 72 sites/year inventoried. After designation,
the average was about 161 sites/year.
ii. More vandalism would have likely occurred without Monument designation.
After designation, research, inventory and educational and interpretive outreach
programs increased. Between 1996 and 2006, GSENM presented more than 500
talks, classroom visits, field trips and other educational events relating to cultural
resources and archeology. Education, increased presence of staff and
researchers and improved management likely led to the reduction in numbers
of sites looted and rock art panels defaced.
iii. Less archeological research would have occurred without the Monument
Designation. Early GSENM efforts included initiating large, landscape surveys
which recorded and documented hundreds of sites.
5. Changes to boundaries - dates and changes in size
i. Monument Designation September 18, 1996 (1,878,465 acres).
ii. H.R.3910, Automobile National Heritage Area Act, Public Law 105-355, Nov. 6,
1998, 112 Stat. 3253. 1,884,011 acres, net gain of approximately 5,546 acres
(See 5.a.H.R.3910_Automobile National Heritage Area Act Synopsis)
iii. H.R.377, Public Law 111-11, 2009, Boundary change and purchase for Turnabout
Ranch, approximately 25 acres removed from GSENM (See
5.c.GSENM_Boundary_SaleHR3777_PL111-11_Turnabout.pdf)
iv. Utah Schools and Land Exchange Act 1998: State of Utah School and
Institutional Trust Lands Administration lands within the boundaries of GSENM
were exchanged. The Federal government received all State inholdings in
GSENM (176,699 acres) while the State Received $50 million plus $13 million in
unleased coal and approx 139,000 acres including mineral resources. The
Federal Government received additional State holdings within other National
15

DOI-2018-07 01399

Park Service and US Forest Service units. (See 5.1998_Utah school Land
Exchange_PL105-335.pdf)
v. Small acquisitions of inholdings, private land located within the Monument
boundary, have occurred since designation. The acquisitions have not resulted
in boundary adjustments, but have increased total Federal land ownership.
More information is available upon request.
6. Public Outreach prior to Designation - outreach activities conducted and opportunities for
public comment
i. No public outreach documents specifically related to the designation of Grand
Staircase-Escalante National Monument are available. However, the area in
southern Utah had long been considered, discussed and evaluated for the
possibility of providing greater recognition of and legal protection for its
resources. As early as 1936, the National Park Service (NPS) considered making a
recommendation to President Roosevelt to designate a 6,968 square mile
aEscalante National Monument.a
7. Terms of Designation
i. Refer to Proclamation for the terms of designation.
ii. GSENM has additional data describing terms of the designation
a Presidential remarks announcing the designation of GSENM (7.1_Remarks
Announcing GSENM_pg1782-2).
a Secretary of the Interior Memo to the President describing the objects and
providing a listing of Monument Objects and a bibliography of Monument object
data (7.2_8-15-96 Secretarial_Memo).
a Secretary of the Interior Memo to the BLM Director describing Interim
Management Direction for GSENM (7.3_11-6-96 Secretarial_Memo).

16

DOI-2018-07 01400

New Information Requested on Executive Order on the Review
of Designations Under the Antiquities Act
BLM-Utah Responses to Additional Questions
a) Any legislative language, including legislation in appropriations bills
There is no specific legislation regarding Grand Staircase-Escalante National Monument
(GSENM).
b) alternative options available for protection of resources applicable at each monument, such as
Native American Graves Protection and Repatriation Act, Paleontological Resources
Preservation Act, Archaeological Resources Protection Act, Historic Preservation Act and
agency-specific laws and regulations.
The following options could provide some options to protect specific resources found in
GSENM. Protection would likely occur on a site-by-site or resource-by-resource basis and
also would take a significant amount of time to accomplish under these various laws. These
laws may not provide a mechanism to protect all cultural or tribal resources in GSENM. For
example, there are no statutory protections for cultural landscapes, but such resources could
be protected under the Antiquities Act. See also the attached Stegner Center_NM vs NCA.pdf.
National Historic Preservation Act, (NHPA)
Native American Graves Protection and Repatriation Act, (NAGPRA)
Paleontological Resources Preservation Act, (PRPA)
Archaeological Resources Protection Act, (ARPA)
American Indian Religious Freedom Act (AIRFA)

c) Designated wilderness areas (name, acreage), Wilderness Study Areas (name if there is one,
acreage, type), and/or areas managed to preserve wilderness or roadless characteristics that are
not WSAs.
1. There is no designated wilderness within GSENM.
2. There are 16 Wilderness Study Areas totaling 881,997 acres within GSENM.
aC/ Phipps-Death Hollow Instant Study Area (ISA) - 42,731 acres
aC/ Steep Creek Wilderness Study Area (WSA) - 21,896 acres
aC/ North Escalante Canyons/The Gulch ISA - 120,204 acres
aC/ Carcass Canyon WSA - 47,351 acres
aC/ Scorpion WSA - 35,884 acres
aC/ Escalante Canyons Tract 1 ISA - 360 acres

DOI-2018-07 01401

aC/
aC/
aC/
aC/
aC/
aC/
aC/
aC/
aC/
aC/

Escalante Canyons Tract 5 ISA - 760 acres
Devils Garden ISA - 638 acres
The Blues WSA - 19,030 acres
Fiftymile Mountain WSA - 148,802 acres
Death Ridge WSA - 63,667 acres
Burning Hills WSA - 61,550 acres
Mud Spring Canyon WSA - 38,075 acres
The Cockscomb WSA - 10,827 acres
Paria/Hackberry and Paria/Hackberry 202 WSA - 135,822 acres
Wahweap WSA - 134,400 acres
i WSA/ISA acres listed are the total BLM-administered surface acres from the Utah
Statewide Wilderness Study Report, October 1991. GIS calculations would vary.

3. The most recent comprehensive inventory of lands with wilderness characteristics within
GSENM is Utahas statewide inventory effort in 1999. Within GSENM there are
approximately 471,700 acres of lands with wilderness characteristics. GSENM completed
a Monument Management Plan in 2000, but did not make specific land use planning
decisions regarding the management of lands with wilderness characteristics. Instead, the
MMP designates lands within the GSENM in different aManagement Zones,a to help
define permitted or excluded activities and any stipulations pertaining to them. There are
four types of Management Zones in GSENM: Frontcountry, Passage, Outback and
Primitive. Lands with wilderness characteristics that are within the Outback or Primitive
zones are managed according to goals and objectives that more closely align with
protection of wilderness characteristics
See attached maps: GSENM_PassageZone_LWC_WSA.pdf;
GSENM_OutbackZone_LWC_WSA.pdf; GSENM_FrontcountryZone_LWC_WSA.pdf;
GSENM_PrimitiveZone_LWC_WSA.pdf and GSENM_FEIS_WSAmap.jpeg.
d) Outstanding R.S. 2477 claims within a monument a type of road claimed and history
There are ~1,525 roads claimed in Garfield and Kane counties under R.S. 2477. This figure
also includes lands outside of GSENM managed by the Kanab Field Office. (See:
Statewide_RS2477_Claims_102313.pdf; Utah_RS2477Claims.pdf and
Snapshot_GSENMRS2477Claims.jpg). Between 2005 and 2012, the State of Utah and 22
counties filed 30 lawsuits seeking quiet title to over 12,000 claimed R.S. 2477 rights-of-way.
The vast majority of these claims are on BLM-administered lands, but claims are pending on
lands administered by the National Park Service and U.S. Forest Service. To date, only one
case, involving three roads, has been settled (Juab 1). Under a case management order, six
cases involving 1,500 claims statewide are currently being litigated aKane (1), Kane (2),
(3), and (4), and Garfield (1) and (2). Of the 1,500 claims, approximately half are located in
Grand Staircase Escalante National Monument. The remaining cases have been stayed,
although preservation depositions have been allowed to continue. BLM-Utah maintains
thousands of records related to R.S. 2477 claims and active or pending litigation, but some of
the information is attorney-client privileged.

DOI-2018-07 01402

e) Maps a
GSENM provided multiple maps in the initial data response (2.g.1_GSENM_SiteDensity.pdf;
2.g.2_GSENM_Inventories.pdf; 2.g.3_GSENM_ArchSites.pdf;
2.g.4_GSENM_ArchNumofSites.pdf; 2.b.Upper Valley Field Map.pdf; GSENM Background
Info subfolder- GSENM_Brochure_Map.pdf; MAP_WSA_for MMP DEIS Map.pdf;
GrandStaircaseEscalante_map.pdf; Paleo_CulturalSitesMap5-8-17.pdf; PaleoSitesMap5-817.pdf). There are also numerous maps contained within the Monument Management Plan.
We are attaching the GSENM ManagementZones_Transportation Map.pdf.
f) Cultural or historical resources, particularly Tribal, located near a monument but not within the
boundary that might benefit from inclusion in the monument
aC/ Nipple

Lake: Private inholding within GSENM. Landowner in the past has expressed
interest in selling this property. This is considered a Traditional Cultural Property
(TCP) by the Kaibab Paiute, in conjunction with the nearby Mollies Nipple land form
(a prominent, isolated rocky peak), known to the Kaibab Paiute as "Mountain that
Breathes. It is the only permanently wet meadow within GSENM, providing for a very
unique habitat. The area is very dense in cultural sites, early ancestral pueblo
occupation, and pilgrimage trails.
aC/ Vermilion Cliffs Front: Kanab Field Office (KFO) and private land near the Kanab
Creek boundary. Ancestral pueblo/archaeological record; site is contiguous with
GSENM; includes important Ancestral Puebloan (Anasazi) sites, including the earliest
studied and reported in the area
aC/ Paria River Canyon (between Vermilion Cliffs NM & GSENM; managed by KFO) Includes pilgrimage trails for Hopi & Paiute. Archaeological sites in this area contain
evidence of continued Hopi pilgrimage use long after abandonment by the Ancestral
Puebloans (Anasazi). (Note: This is also the location of Buckskin Gulch, one of the
longest continuous slot canyons in the world, and the famous "Wave" formation).
aC/ Shinarump Cliffs: KFO & private inholdings: Very dense array of Ancestral Puebloan
(Anasazi) sites, including the earliest dated pottery in the area. The archaeological
record here is equal to that at Grand Gulch.
(See: GSENM Data_call_CulturalOutsideGSENM.pdf and Stoffle et al 2001 Kaibab Paiute
Ethnographic Assessment in GSENM.pdf)
g) Other a general questions or comments
a) Discuss the full range of Proclamation objects. The initial DOI data call focuses
almost exclusively on cultural objects, but the Proclamation identifies many objects of
antiquity or historical or scientific interest to be protected. GSENM published a table of
all resources and objects in the Analysis of the Management Situation for the Livestock
Grazing Plan Amendment EIS (GSENM_AMS_Final_July2015.pdf, starting on pg.136).
Objects within GSENM include geologic stratigraphy and structures, paleontological
sites, cultural use, human history and biological resources. Each annual Manager's Report
also notes the status and trend of the identified objects. We included the 2014, 2015, and
2016 Manager's Report in the GSENM Background Info subfolder in Drive. The Science

DOI-2018-07 01403

Symposium subfolder in Drive also summarizes some of the scientific studies on
GSENM. The paleontological resources on GSENM are particularly noteworthy and
world class. See attached: Paleontology on the GSENM Titus.docx and GSENM Fossil
Map.pdf.
b) Extent of the designation: The GSENM designation was the subject of litigation. The
case concerned the designation of 1.7 million acres of federal land as a national
monument pursuant to the Antiquities Act. The court held that the President complied
with the Antiquities Act by (1) designating, in his discretion, objects of scientific or
historic value, and (2) setting aside, in his discretion, the smallest area necessary to
protect the objects. (See: Utah Ass'n of Counties v. Bush.pdf and 2004-04-19 Opinion &
Order.pdf)
In order to project the objects identified in the Proclamation, the Department must
consider the connectivity between them. This concept is particularly critical for biological
resources, but also applies to management of cultural resources and tribal
interests. Protection of isolated identified cultural sites is not synonymous with
protection of a cultural landscape (e.g., Traditional Cultural Properties, vision quest sites,
etc.) The Secretary memo to the President articulates the rationale for the GSENM
boundaries based on these factors and considerations. (See: 7.2_ 8-15-96_Secretarial
Memo.pdf in Drive)
c) Monument Advisory Committees (MACs). MACs provide for local and subject matter
expert input and advice into management objectives. The GSENM MAC includes seven
scientist positions that focus on the identified objects in the Proclamation. (See: May 11,
2017 DOI MAC Data Call.docx). For those Monuments that do not have MACs, the
RACs provide that same level of integrating multiple stakeholders in an advisory
capacity.
d) The designation of GSENM as a national monument elevates protection of the identified
objects in many ways, including:
aC/
aC/
aC/

Increased attention and public awareness of resources and objects
Expanded educational/research efforts by employees and researchers related to these
objects
Increased partnership opportunities and funding via Universities that focus on
research in Monuments

DOI-2018-07 01404

Nikki Moore
Acting Deputy Assistant Director,
National Conservation Lands and Community PartnershipsA
Bureau of Land Management, Washington DC
202.219.3180 (office)
202.288.9114 (cell)
a
A Grand Staircase-Escalante-20170519T212630Z-001.zip
a
A GSENM Data_call_CulturalOutsideGSENM.pdf
a
A GSENM Fossil Map.pdf
a
A GSENM ManagementZones_Transportation Map.pdf
a
A GSENM_FEIS_WSAmap.jpg
a
A GSENM_FrontcountryZone_LWC_WSA.pdf
a
A GSENM_OutbackZone_LWC_WSA.pdf
a
A GSENM_PassageZone_LWC_WSA.pdf
a
A GSENM_PrimitiveZone_LWC_WSA.pdf
a
A May 11, 2017 DOI MAC Data Call.docx
a
A New information requested on EO 13792 Monuments...
a
A Paleontology on the GSENM Titus.docx
a
A Snapshot_GSENMRS2477Claims.png
a
A Stoffle et al 2001 Kaibab Paiute Ethnographic A...
a

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