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CONTACT INFORMATION:
Email: Arizona_Strip@blm.gov Diana Hawks, Planning Team Leader
BLM Arizona Strip District Office 345 East Riverside Drive
St. George, Utah 84790

Subject Line: Arizona Strip RMP Comments

SAMPLE LETTER

Dear Ms. Hawks:

Thank you for the opportunity to comment on the Arizona Strip Draft Resource Management Plan (RMP).

Arizona is world-renowned for its natural treasures such as the Grand Canyon-Parashant and Vermilion Cliffs National Monuments, and the Arizona Strip – all an integral part of the greater Grand Canyon ecosystem. As National Monuments, the Bureau of Land Management (BLM) is required to manage these areas in accordance with their scientific and historical importance. Furthermore, Arizona residents, and millions of people from throughout the nation and the world, cherish these wild open lands, and the opportunity to hike, learn, and explore in a vast area of beauty, history, and solitude.

Accordingly, I want to point out some weaknesses in your analysis, and urge you to strengthen the plan in several key areas:

Roads and ORVs can cause a range of impacts such as spreading invasive weeds, allowing vandals to access cultural sites, and harming wildlife such as the threatened desert tortoise. The BLM’s preferred alternative simply does not consider these impacts, especially in the face of the region’s explosive population growth over the next 20 years. There’s nothing wrong with providing road access to the Monuments, but the preferred alternative leaves way too many ORV routes open. Redundant roads that divide wildlife habitat or damage archaeological sites should be removed, and I ask you to instead adopt the conservation community’s proposal of 630 miles in Grand canyon-Parashant and 191 miles in Vermilion Cliffs.
To date, less than 3 percent of the lower, contiguous United States is protected as congressionally designated, “roadless” wilderness, not nearly enough space to assure long-term survival of many native animals, such as pronghorn antelope, mountain lions, desert tortoise, and bighorn sheep. The Arizona BLM has the authority to recognize and preserve “wilderness character,” and should take full advantage of this authority to preserve the “naturalness, solitude, and opportunities for primitive and unconfined recreation” on all of the nearly one million acres of wilderness-quality lands inventoried and proposed by the Arizona Wilderness Coalition.
While the Monument proclamations withdrew GCPNM and VCNM from oil and gas or mining development, the BLM’s “preferred alternative” for the Arizona Strip leaves 96 percent of the non-monument lands open to oil and gas development, including Areas of Critical Environmental Concern (ACECs), such as those established to protect the habitat of the threatened desert tortoise. Seventy-five percent is open to uranium mining, and the only areas restricted or closed are those where the BLM has legal requirements for wilderness, threatened and endangered species, or riparian areas. This makes no sense, since the plan itself acknowledges that, "known oil and gas resources are not significant within the Planning Area, and no economic occurrences of oil or gas have been encountered to date." P. 3-129.
The Draft RMP does not protect essential habitat and other resources from grazing impacts: The BLM did not even consider eliminating grazing in the planning area, even though numerous public comments suggested analyzing this reasonable alternative and the Monuments’ mission statements emphasize sustainable ranching operations. The DRMP/DEIS does not address the impacts of livestock on soils, fire regimes, or non-native species invasions. The DRMP/DEIS proposes recreational use restrictions in the habitat of special status plants and limits hiking and biking in the areas where these plants occur. However, the same areas are not protected from livestock, despite the fact that these plants are federally-listed imperiled species. None of the alternatives propose complete exclusion of the riparian areas and the preferred alternative only closes one riparian pasture of one allotment for the benefit of recreational users. Any areas that are critical for desert tortoise survival and recovery should be made off-limits for livestock grazing until the desert tortoise populations improve and stabilize.
In the name of fire and fuels management, the BLM is proposing significant forest thinning that includes the use of chain-saws and potentially the use of heavy equipment in Wilderness Areas. Even though fire conditions described in the DEIS do not support the need for heavy treatments, the BLM plans to treat 50% of the available ponderosa pine habitat and the Park Service plans to treat 75% of the ponderosa pine in Parashant National Monument. While we support the restoration of natural processes, such as fire, we believe the BLM and NPS need to develop a vision for Wilderness that looks at the minimum amount of intervention necessary. Instead, the proposed action contains no discussion of environmental impacts to Wilderness Characteristics from fire and fuels treatments, and no alternative in the Environmental Impacts to Wilderness Characteristics section mentions fire and fuels management.
The proposed plan purports to use “monitoring” to alleviate damage to wildlife and cultural resources, however it does not present any detail about what form this monitoring will take. Law enforcement rangers will never be able to effectively alleviate even a small proportion of the damage because there are currently only 3 law enforcement rangers for the entire 3 million acres of the Arizona Strip – an area approximately 3 times the size of Rhode Island. In this era of diminishing budgets, the BLM must be realistic about how and whether it will truly alleviate impacts. If monitoring is the preferred tool, the BLM should present detail about how that monitoring will occur – how, where, and at what scale – and have it fir within a realistic budget.

Please re-assess your proposal, and present a new alternative that will truly protect some of Arizona’s most important natural assets—these diverse Monuments, and these flagship parts of BLM’s National Landscape Conservation System.

Thank you again for the opportunity to comment on this important plan.

Sincerely, [Your name and address]

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