HIM LIBHAHY FEB 9 '99' gureau of Reclamation Denver Office IO w?iGo^> INTRODUCTION TO VOLUME Vll-B PUBLIC COMMENTS Q(4 .U? \VO kjTH Volume VII presents public comments. Due to the num- ber and magnitude of comments, the Volume is com- prised of three books, labeled as parts. Part A pre- sents copies of letters from elected officials, agen- cies, and selected organizations; Part B includes Gen- eral Comments; and Part C includes WSA Specific Comments. Part B is a set of representative General Comments and Responses applicable to Volume I and to the EIS as a whole. All topics are covered, but not all individual comments are included since many similar and dupli- cate comments were received. Also, comments and petitions expressing only a preference "for" or "against" wilderness are not included. The material in Volume Vll-B is presented in the following 23 topics: 1. Purpose of Wilderness/Multiple Use 2. Wilderness Review Process 3. Inventory and Alternatives 4. Roads, Ways, and Cherry-stems 5. Interim Management 6. In-holdings 7. Buffer Zones 8. Rationale 9. Analysis Assumptions and Guidelines 10. Air Quality 11. Geology and Topography 12. Soils 13. Vegetation 14. Water Resources 15. Mineral and Energy Resources 16. Wildlife 17. Forest Resources 18. Livestock and Wild Horses/Burros 19. Visual Resources 20. Cultural Resources 21. Recreation 22. Wilderness Values 23. Land Use Plans and Controls 24. Socio-Economics 25. Editorial 26. Maps Separate comments regarding each subject are num- bered with a decimal under each group (i.e., General Comment 2.1). Names of commentors whose com- ments were used are provided in brackets following the numbered comment in most cases. These names are representative of many commentors who made similar comments. Where applicable, individual com- ments which are related to a single, common re- sponse are identified further with small letters pre- ceding the individual comments. BLM Library Denver Federal Center Bldg. 50, OC-521 P.O. Box 25047 Denver, CO 80225 . '*• r • »* - s -OH Or < . . ^ * GENERAL COMMENTS AND RESPONSES - SECTION 1 WILDERNESS AND MULTIPLE USE INDEX 1.1 The Environmental Impact Statement (EIS) should explain the value of wilderness. Why do we need it? (P- 1) 1.2 The EIS should state that wilderness is (or is not) consistent with the multiple-use concept, (p. 3) 1.3 The analysis should point out that placing areas into the wilderness system limits motorized access to the area and does (or does not) discriminate against the young, the old, and the handicapped, (p. 5) 1.4 The Draft EIS failed to analyze the ability of local government to provide emergency services in wilder- ness areas, (p. 5) 1.5 The EIS should explain how predators would be controlled or handled inside wilderness areas and the secondary effects of that management, (p. 5) 1.6 The EIS should analyze the effect of wilderness designation on noxious weed control, (p. 7) 1.7 The EIS should state that wilderness would reduce the use of grazing AUMs. Grazing as a tool for the con- trol of noxious weeds would be lost. (p. 7) 1.8 The Draft EIS failed to analyze the increased threat of fires resulting from reduced livestock graz- ing in wilderness areas. Fires would destroy live- stock ranqe and visual resources in wilderness areas. (P.7, 1.9 Bicycles are nonpolluting and quiet. The EIS should analyze the impacts on recreational use of bicycles. (P- 7) 1.10 The EIS failed to state that wilderness designa- tion will prevent trappers from using the best trap- ping areas, (p. 8) 1.11 The Draft EIS failed to explain whether or not dogs will be allowed in wilderness areas. Dogs should not be allowed in the wilderness areas, (p. 8) 1.12 The Description of the Alternatives should state that erosion control measures are permitted in wil- derness areas, (p. 8) 1.13 The EIS is not clear on the compatibility of leases and mining claims with wilderness designation. (P- 9) 1.14 The EIS should analyze the effect of wilderness designation on recreational rockhounding. (p. 9) COMMENTS AND RESPONSES 1.1 COMMENT: The EIS should explain the value of wilderness. Why do we need it? [Local Government Responses to Wilderness, Emery County, Utah Cattle- mans Association, Rocky Mountain Federation of Mineralogical Societies, Michael Robison, Rodney Greeno, and Roger Jenkins] a. Upon closer examination, wilderness is clearly seen to be an irrevocable and irretrievable commit- ment of land and its resources to a singular purpose- that purpose being the preservation of wilderness character. All other uses of designated wilderness lands are subordinate to that purpose. b. Wilderness is not an irrevocable and irretriev- able commitment of resources, because what Con- gress designated, it can undesignate. Placing areas into the wilderness system does not change their sta- tus or alter present uses. The areas are defacto wil- derness now. They are not "locked up." Any re- sources that exist there will remain there. If there is a compelling reason to exploit these resources at a later date, the Congress will act to make that pos- sible. c. When we preserve wilderness lands we are actually retaining our greatest flexibility of any land designation. We only have the power to destroy or preserve wilderness. Once we’ve destroyed it, it's gone, period. We can reclaim, plant for cattle use, or for mankind's commercial gain, but we cannot replace wilderness. d. Wilderness is where you find it. Unlike so many other States, Utah has a considerable amount. BLM 1 GENERAL COMMENTS AND RESPONSES SECTION 1: WILDERNESS AND MULTIPLE USE should be acting to recommend the maximum amount of land for wilderness designation in order to pre- serve the maximum number of options for future gen- erations. e. Good BLM management of the public lands is a good substitute for wilderness. f. BLM has failed to demonstrate that a formal wilderness designation is necessary to ensure that the wilderness values of size, naturalness, solitude, and primitive recreation are preserved. g. Utah's BLM lands are among the most valuable ecological, scenic, and recreational lands in the U.S. They present an especially great challenge to BLM to manage for the long-term national interest, as ex- pressed in the Federal Land Policy and Management Act (FLPMA) and the Wilderness Act, and still re- spond to local preferences. BLM's tradition of decen- tralization and responsiveness to local interests has made it difficult for the State and District offices to take into account overall national goals expressed in the statutes and regulations of the last decade that are not reflected in local politics. The public lands should be administered as a pub- lic trust for the greatest benefit of the greatest num- ber of people over the longest period of time. It needs to be kept in mind that these lands are a national trust to be administered for the benefit of the entire nation. h. The national parks are historically already locked up. But we can't afford to lock up any more public lands. It is so important to our well being that we keep them open. I feel that, if these environmen- talist people can find a wilderness designation, then let them buy it on some market value. Let's let them pay taxes on it, and they can protect it forever. Setting aside millions of acres of public domain to the recreating public is a gross overreaction. The vast majority of lands under consideration is not at risk of man's imprint anyway. i. There is no need to designate the areas as wil- derness. All of the reasons for which wilderness des- ignation are sought are accomplished already by the various regulatory bodies now in place. The elements which occasioned the inclusion of these areas in BLM's study are duplicated in other parks and pro- tected areas, not only in Utah. j. The concerns of local governments should be taken into account to some extent; however, it should be remembered that we are dealing with public lands which belong to every citizen of the United States, whether the local folks like it nor not. People who feel that wilderness is a local issue and that people from other States should have no say are wrong. All tax- payers should have a say. Local county commission- ers happen to be opposed to wilderness at the moment because of a slow economy, which they blame on envi- ronmentalists. This should have no bearing on wilder- ness designation. k. Miners enjoy the scenery as much as the envi- ronmentalists do and we are not against them using our claims to hike on or camp on. Why are they so actively trying to push us out? As far as I know, only one uranium mine was ever open-pitted in most of these areas, and I know of no plans to even start another open-pit mine in the future. l. Ranchers are the best stewards of the public ranges, as our livelihood and our children's future de- pend upon preservation of the forage, watershed, and water to be shared by our livestock and wildlife. The wilderness misconception paints the picture that only through wilderness designation will the land be preserved for future generations. It is only through the rancher’s past and continued conservation concerns, using modern range techniques, that these areas of natural beauty are available today. 1.1 RESPONSE: Congress established the need for wilderness .with passage of the Wilderness Act in 1964. Background on wilderness is provided in Chap- ter 1 of the Final EIS. Refer to the response to General Comment 1.2 for a discussion on the purpose of wilderness and how it interacts with the multiple- use concept. Also, see the Draft EIS, Volume I, Appendix 2, Scoping Comment Responses 338 through 355, which discuss the need for wilderness. The Draft EIS, Volume I, Appendix 2, Scoping Comment Responses 447 through 456, discusses land use planning and how the wilderness concept relates to multiple use. The purpose of wilderness is outlined in Section 2(a) of the Wilderness Act (Public Law 88-577, dated September 3, 1964). It is the intention of the Congress of the United States to assure that "... an increasing population, accompanied by expanding 2 GENERAL COMMENTS AND RESPONSES SECTION 1: WILDERNESS AND MULTIPLE USE settlement and growing mechanization, does not occupy and modify all areas within the United States and its possessions, leaving no lands designated for preservation and protection in their natural condition, it is hereby declared to be the policy of the Congress to secure for the American people of present and fu- ture generations the benefits of an enduring resource of wilderness." Wilderness areas are to be . ad- ministered for the use and enjoyment of the American people in such manner as will leave them unimpaired for future use and enjoyment as wilderness, and so as to provide for the protection of these areas, the preservation of their wilderness character, and for the gathering and dissemination of information regard- ing their use and enjoyment as wilderness." In establishing wilderness areas, the intent of Con- gress is to set aside a place where the land and its resources are preserved in a natural condition for the use and enjoyment of present and future generations. Wilderness is not an irrevocable and irretrievable commitment of resources because wilderness can be designated and undesignated. However, wilderness designation would likely be a long-term commitment for protection of wilderness values through restric- tions of surface-disturbing activities and use of mech- anized equipment. Loss of wilderness values may be an irreversible and irretrievable commitment be- cause road building or other uses may irreparably alter the land. Also, Congressional intent for wilder- ness is for establishment of an area where natural and scientific values are protected and maintained. The overall purpose is not to provide a sanctuary for backpackers, nor is it a repository for minerals. Federal lands are part of our national heritage, owned and managed by the government for the benefit of all the people of the United States. These lands belong to all citizens of the United States and, as such, are managed for the greatest benefit of the greatest number of people. For this reason, the inter- ests of local residents, while taken into account, cannot override national interests or the laws estab- lished by Congress. State law does not preempt the laws of the United States. Various laws established by the Congress of the United States govern not only how the public lands will be managed, but also spe- cifically mandate that BLM conduct the wilderness re- view. In conducting a wilderness review, BLM is com- plying with the laws established by Congress. BLM is not designating wilderness, but is making recommen- dations to the Secretary of the Interior; these recom- mendations will be reviewed and passed on to the President of the United States and Congress. BLM is making a study of those lands that meet the criteria for wilderness and will make a report to the Sec- retary of the Interior containing a recommendation as to the suitability or nonsuitability of those lands for wilderness designation. Only Congress can designate wilderness. BLM is charged with managing the public lands according to the laws established by Congress. The wilderness review process is in compliance with those laws. 1.2 COMMENT: The EIS should state that wilder- ness is (or is not) consistent with the multiple use concept. [Utah Counties, Utah Wilderness Coalition, Utah Woolgrowers, Utah Farm Bureau Federation, Riki Darling, Tod Young, and Marc Hoshovsky] a. The EIS often states that wilderness is not com- patible with the local government concept of multiple use. The meaning of multiple use and the role of wil- derness should be better explained. No study of wil- derness values can be made beginning with assump- tions based on the so-called philosophy of multiple use. b. Wilderness designation is not needed to protect the natural and cultural values on the land. Wilderness designation will end the multiple use of resources on public lands. c. Development is not the only path towards multi- ple use. When did chaining or oil and gas development or coal strip mining become multiple use? I would call that single use because, once that activity has occurred, then there are no other options for those lands in many cases. And, in fact, wilderness is the true multiple use because with wilderness you have a designation that allows recreation, allows for hunting and wildlife observation, and allows wildlife habitat to exist in its undisturbed form. It gives opportunities for outstanding scenic beauty, for historic and cultur- al and aesthetic exchanges, as well as opportunities for solitude. We need to look at the true nature of what multiple use is, and then choose wilderness des- ignation. d. The question is not whether the land should be protected, but rather how it should be protected. Wilderness management of vast expanses of the pub- lic domain is seen by some as being the only effective means by which the resources of the lands may be preserved for future generations. 3 GENERAL COMMENTS AND RESPONSES SECTION 1: WILDERNESS AND MULTIPLE USE e. Congress has decided that wilderness should be established. The question is, how much? I could find no place in the EIS which indicated how many people in the United States presently use wilderness areas, either by numbers or percentage of the population. It would seem to me very simple to get those numbers and to predict what the population was going to be, and then decide how much wilderness was actually going to be needed instead of just guessing. 1.2 RESPONSE: The Land Use Plans section of the Final EIS states that wilderness is part of the BLM multiple use concept. See the response to General Comment 1.1. Also, see the Draft EIS, Volume I, Appendix 2, Scoping Comment Responses 338 through 355, for a discussion on the need for wilderness. See the Draft EIS Volume I, Appendix 2, Scoping Comment Responses 447 through 456, for a discussion on land use planning and how the wilderness concept relates to multiple use. Congress defines "multiple use" as: "(c) The term 'multiple use' means the man- agement of the public lands and their various re- source values so that they are utilized in the com- bination that will best meet the present and future needs of the American people; making the most judi- cious use of the land for some or all of these re- sources or related services over areas large enough to provide sufficient latitude for periodic adjustments in use to conform to changing needs and conditions; the use of some land for less than all of the re- sources; a combination of balanced and diverse re- source uses that takes into account the long-term needs of future generations for renewable and nonre- newable resources, including, and not limited to, rec- reation, range, timber, minerals, watershed, wild- life, and fish, and natural scenic, scientific and histor- ical values; and harmonious and coordinated manage- ment of the various resources without permanent impairment of the productivity of the land and the quality of the environment with consideration being given to relative values of the resources and not necessarily to the combination of uses that will give the greatest economic return or the greatest unit output." (Section 103, Public Law 94-579, FLPMA, dated October 21, 1976) The stated objective of wilderness management (i.e., to administer wilderness for the use and enjoy- ment of the American people in ways that will not impact those for future use and enjoyment as wilder- ness) clearly indicates that wilderness management is compatible with, and part of, the multiple-use con- cept. The question of "how much is enough" is subjec- tive and a definite quota cannot be established. Con- gress will ultimately make the decision. The concept of multiple use is often misconstrued to mean all uses must be allowed on all public lands. It is clearly the intent of Congress that lands be selected for management to maximize different and varying resources, not that all resources be maxi- mized on each acre of public land. Wilderness is one of the many resources on public lands and must be evaluated and considered along with all other re- sources for purposes of multiple-use management. Wilderness is not designated as a repository for minerals or a sanctuary for backpackers, but as an area where natural values are protected and maintain- ed for the use and enjoyment of present and future generations under the multiple-use concept. The Land Use Plans sections of this EIS have been revised to explain that wilderness meets the Federal Govern- ment's definition of multiple use, but conflicts with the local government position of allowing all resource uses on all public lands. Discussion of the local government's view of multiple use is required by the BLM Wilderness Study Policy, Quality Standard 6, which states that BLM guidance and plans "... shall, to the extent practical, be consistent with the officially approved and adopted resource-related policies and programs of the other entities ..." It is also required by Sec- tion 1502.16(c) of the Council on Environmental Qual- ity (CEQ) guidelines for preparation of EISs and Sec- tion 202(c)(9) of FLPMA. 1.3 COMMENT: The analysis should point out that placing areas into the wilderness system limits motorized access to the area and does (or does not) discriminate against the young, the old, and the handicapped. [Rocky Mountain Federation of Mineralog- ical Societies, Utah Counties, Utah Woolgrowers, Brett Jensen, Riki Darling, and Linelle Wagner] a. The dry and extremely rugged nature of these areas will also prohibit any extensive use by any but the most seasoned and hardy of hikers. Even travel by horseback is severely limited, as evidenced by the large numbers of wild cattle in the canyon areas of the Dirty Devil Wilderness Study Area (WSA). To so limit the use of these areas to those with the time, energy, and stamina to hike or horseback where 4 GENERAL COMMENTS AND RESPONSES SECTION 1: WILDERNESS AND MULTIPLE USE water must be carried and temperatures range from 100 degrees in the summer to below zero in the win- ter violates the wilderness criteria against discrimi- nation. Easily, 95 percent of all tourists in the south- ern Utah areas are of two classes: the elderly and the foreigner. Neither of these groups has the resources to explore the extensive areas covered by the WSAs without vehicular travel. Foreign visitors will be especially affected because most do their touring by vehicle due to extremely limited time schedules; the handicapped must also be considered. The statement was made that the handicapped who are unable to walk could be carried in. Statements like these again reflect the severe lack of comprehension of the very nature of these areas. b. That wilderness discriminates against the handi- capped and the aged is a shop-worn half-truth that no one can really take seriously anymore. There are sev- eral groups on the Wasatch Front that lead expedi- tions into wilderness areas for the handicapped or the disadvantaged. These people can and do enjoy wil- derness. They don't ask for a break. They just want a hand up. 1.3 RESPONSE: See the Draft EIS, Volume I, Appen- dix 2, Scoping Comment Responses 427 through 446. Motorized or mechanized equipment is not permit- ted in wilderness areas; however, nonmechanical access to wilderness areas is not restricted. The pur- pose of wilderness is to preserve some lands in the United States in a natural condition for present and future generations. There are no wilderness criteria that address discrimination. All BLM land use plans discriminate against some users in one way or another in order to achieve multiple use on public lands. See the response to General Comment 1.2 for a discussion on the multi- ple-use concept. Multiple use means that extraction of minerals, which is an exclusive use of the land and resources, is allowed in certain areas, ORV use is allowed in some areas, and naturalness and solitude are preserv- ed in other areas. The Volume I analysis shows that BLM's wilderness proposal would prevent mechanized access on less than 4 percent of the ways and trails in Utah. BLM recognizes that, with special provisions and assistance, the handicapped can also enjoy wilderness areas, although in fewer numbers than if motorized vehicles and mechanized access were allowed. This is not treated as a major issue for the EIS or as ration- ale for the Proposed Action. 1.4 COMMENT: The Draft EIS failed to analyze the ability of local government to provide emergency services in wilderness areas. [Utah Counties and Utah Woolgrowers] 1.4 RESPONSE: This issue is addressed in the Volume I, Appendix II, Scoping Comment and Response 440. See Volume I, Chapter 1, Issue Identification, Appendix 1, and General Comment Response Section 6 in the Final EIS for discussions on the issues of emergency services and management of in-held State and private lands. Motor vehicles could be used in wilderness areas in emergency situations. In such cases, access by routes or modes of travel not available to the general public may, when fully justified, be permitted by written authorization from BLM. The EIS assumes the use of hand or aerial techniques to control fire, unless there is an emergency situation that threatens human life, property, or high-value resources on adja- cent nonwilderness lands. 1.5 COMMENT: The EIS should explain how preda- tors would be controlled or handled inside wilderness areas and the secondary effects of that management. [Utah Woolgrowers, Jack Madsen, Utah Wilderness Association, Wayne County, Hardy Redd, Wasatch Mountain Club, George Hinde, John Veranth, et al.] a. The Final EIS should report that wilderness designation will create breeding areas for predators that will result in increased predation on areas sur- rounding the wilderness. b. The Draft EIS failed to report that wilderness designation would prevent effective predator control and predators would force the livestock industry out of business. c. The Draft EIS underestimates the limitations that wilderness designation would place on predator control and the effect of increased numbers of preda- tors on the livestock industry in the State. d. The Draft EIS incorrectly assumes that control of predators would be different under wilderness 5 GENERAL COMMENTS AND RESPONSES SECTION 1: WILDERNESS AND MULTIPLE USE management than under the Interim Management Policy (IMP). e. Present practices for predator control should be continued in wilderness areas. f. Wilderness areas are not only for recreation, but also for preservation of biological systems. Use of Compound 1080 on private lands is undesirable. The use of predator control poison baits in a wilder- ness area is totally inconsistent with the purpose of wilderness protection. 1.5 RESPONSE: Statements on methods and levels of predator control are included in the Descriptions of the Alternatives and Affected Environment. Also, see Volume I, Appendix 1, Part A, Predators, part of which reads as follows: "Predacious animals are an important part of natural life systems within wilderness. They play an important role in the natural selection and survival processes, helping to maintain critical population bal- ances of wild species. They should be able to survive and compete with other species, free from unregu- lated human interference and the traditional pursuit of sport or bounty. Where control of predators is nec- essary to protect threatened or endangered wildlife species or on a case-by-case basis to prevent special and serious losses of domestic livestock, it will be accomplished by methods which are directed at eli- minating the offending individuals while, at the same time, presenting the least possible hazard to other animals or to wilderness visitors. Poison baits or cyanide guns are not compatible. Approval of predator control actions must be con- tingent upon a clear showing that the removal of the offending predators will not diminish the wilderness values of the area because this kind of wildlife is an integral part of the wilderness, as well as an adjunct to the visitor's experience." One of the purposes of wilderness (see the re- sponses to General Comments 1.1 and 1.2, Purpose and Multiple Use) is to preserve lands in their natural condition. Predatory animals are part of that natural life system, as are a number of other animals. Domes- tic livestock, while not generally considered a wild species, are, however, permitted in wilderness areas. Grazing of domestic livestock is permitted to continue at the same level as before designation. Pro- visions are made in the law that permit the control of predators to prevent special or serious losses of domestic livestock. If increased predator populations occur in wilderness areas, it could affect livestock in close proximity of the wilderness area. Predator con- trol outside a wilderness area is unrestricted in so far as other governing laws and ordinances allow such activities. Within wilderness areas, controls are mandated which are important "in the natural selec- tion and survival processes, helping to maintain criti- cal population balances of wild species." For this reason, predator control within wilderness areas is allowed on a case-by-case basis, as need and condi- tions warrant such control. The purposes for which wilderness areas are established must be maintained according to the laws enacted by Congress. The Wilderness Management Policy (BLM Manual 8560) outlines how an area will be managed once it is designated wilderness by Congress. IMP prescribes the manner in which BLM manages WSAs while under consideration but not yet designated or released by Congress. The two policies are similar in purpose; however, there are differences. In general, IMP is not as restrictive as the Wilderness Management Poli- cy (BLM Manual 8560), since Congress specifically stated (Section 603 of FLPMA): "(c) during the period of review of such areas and until Congress has determined otherwise, the Secre- tary shall continue to manage such lands according to his authority under this Act and other applicable law in a manner so as not to impair the suitability of such areas for preservation as wilderness, subject, how- ever, to the continuation of existing mining and graz- ing uses and mineral leasing in the manner and degree in which the same was being conducted on the date of approval of this Act . . . ." Certain activities allowed to continue during the review period may not continue in the same manner once an area is designated wilderness by Congress. Predator control is one such activity; wilderness des- ignation would change the manner, degree, and methods of control. Additional information on preda- tor control activities in the WSAs has been added to the Final EIS. 1.6 COMMENT: The EIS should analyze the effect of wilderness designation on noxious weed control. [Utah Weed Control Association, Utah Farm Bureau Federa- tion, Utah Counties, et al.] 6 GENERAL COMMENTS AND RESPONSES SECTION 1: WILDERNESS AND MULTIPLE USE The Draft EIS is unrealistic in discussing noxious weeds and pests when it states that the control in a wilderness area can only be done when weeds or pests threaten human life, property, or high-value resources. The EIS should analyze the impacts of the uncheck- ed spread of noxious weeds in wilderness areas and their effect on threatened or endangered plant and wildlife species. 1.6 RESPONSE: See Volume I, Chapter 1, Issue Identification. See the responses to General Com- ments 1.1 and 1.2 for a discussion on the purpose of wilderness and the multiple use concept. See General Comment Response 1.7 for a discussion on the use of grazing to control noxious weeds. As stated, noxious weed (or pest) control is per- mitted in situations that threaten human life, property, or high-value resources including wilder- ness values. 1.7 COMMENT: The EIS should state that wilder- ness would reduce the use of grazing animal unit months (AUMs). Grazing as a tool for the control of noxious weeds would be lost. [Wayne County] 1.7 RESPONSE: Grazing in wilderness will continue in the same manner and degree as before designation; therefore, AUMs will not be reduced due to wilder- ness designation. Grazing will still be available as a tool to control noxious weeds, just as before designa- tion. This may not be an effective tool because many noxious weeds are not palatable or are poisonous to livestock. Also, see General Comment Response 18.1. 1.8 COMMENT: The Draft EIS failed to analyze the increased threat of fires resulting from reduced livestock grazing in wilderness areas. Fires would destroy livestock range and visual resources in wilderness areas. [John Wadsworth] 1.8 RESPONSE: See Volume I, Appendix 1, Part A, Grazing in National Forest Wilderness Areas, which reads in part: "The legislative history of this language is very clear in its intent that livestock graz- ing, and activities and the necessary facilities to support a livestock grazing program, will be permit- ted to continue in national forest wilderness areas, when such grazing was established prior to classifica- tion of an area as wilderness." It is clear from this statement that wilderness designation will not "reduce livestock grazing" in an area. For this reason, it is erroneous to assume that livestock grazing will be reduced and, therefore, that fire danger will increase as a result. Livestock graz- ing does reduce the amount of fuel (vegetation) in an area. This, in turn, reduces fire danger because less fuel is available to ignite and/or spread fire. Increas- ed forage production from high precipitation can significantly add to the amount of fuel available, regardless of whether livestock grazing continues at the same level. Also, see the response to General Comment 18.1. 1.9 COMMENT: Bicycles are nonpolluting and quiet. The EIS should analyze the impacts on recreational bicycling. [Composite comment from bicycle enthus- iasts.] 1.9 RESPONSE: Bicycles meet the definition of "mechanized equipment" and are prohibited in wilder- ness areas, as required by the Wilderness Act. The recreation analyses address impacts on mechanized recreation. 1.10 COMMENT: The EIS failed to state that wil- derness designation will prevent trappers from using the best trapping areas. [Utah Farm Bureau Federa- tion, et al.] Another problem that I would like to address is that of trapping. I know this might make environment- alists shudder to think of trapping, but there are many people in San Juan County that trap wild preda- tors as part of their livelihood. In the winter, the grounds that are in the WSAs are heavy with these predators and they are used a lot by the trappers. If these are locked up for single use, the trappers will have to go elsewhere. These are the very best trap- ping areas in the country. 1.10 RESPONSE: The BLM WSAs may be the best trapping areas because of limited access for trapping or hunting. Wilderness designation would maintain this situation. The effects of wilderness designation on trapping have not been analyzed in detail because trap- ping is not automatically eliminated from wilderness. Hunting, fishing, and incidental trapping is compatible with wilderness use and will be allowed under State laws and regulations. Incidental trapping means that it is not the sole source of livelihood for the trapper. FEB 9 19! Bureau of Reclamation Denver Office 7 GENERAL COMMENTS AND RESPONSES SECTION 1: WILDERNESS AND MULTIPLE USE Also, see the response to General Comment 24.6 for a discussion on trapping and local economics. 1.11 COMMENT: The Draft EIS failed to explain whether or not dogs will be allowed in wilderness areas. Dogs should not be allowed in wilderness areas. [Wasatch Mountain Club] We are concerned about dogs running loose in wilderness areas. We are particularly repulsed by packs of dogs used in the guise of hunting to chase down deer, bear, or cougar. This activity is cruel, inhumane, and exhibits no skill on the part of the hunter. Like bear baiting and cock fighting, this practice should be outlawed in a civilized society; it certainly has no place in wilderness. Allowing dogs to run free in wilderness areas conflicts with rational wildlife resource management. We urge BLM to re- quire that all dogs taken into wilderness areas be leashed or under direct control of their owners. We also urge BLM to cooperate with concerned State and Federal agencies to end unsavory hunting practices where dogs are used to harass game. 1.11 RESPONSE: The EIS does not address manage- ment of dogs in wilderness because, "The basic responsibilities of the BLM and other cooperating State and Federal agencies in the management of fish and wildlife are not altered by the Wilderness Act" (USDI, BLM, 1981a). Use of dogs for hunting in BLM- administered wilderness will be subject to applicable State and Federal regulations. Harassment of wildlife by dogs is illegal and such cases are handled by the Utah Division of Wildlife, Animal and Plant Health Inspection Service (APHIS), and local law enforcement agencies. Dogs are not specifically banned from all wilder- ness areas. However, where conflicts with wildlife are likely, they may be banned through Wilderness Management Plans prepared for designated areas. 1.12 COMMENT: The Descriptions of the Alterna- tives should state that erosion control measures are permitted in wilderness areas. [Utah Board of Water Resources] Implementation of erosion control structures and practices are discussed in the BLM Wilderness Man- agement Policy (BLM Manual 8560). In many parts of Utah, particularly the Colorado Basin, sedimentation due to erosion of natural areas is taking on increased importance. This is particularly true when the sedi- ment contains soluble salts. Since erosion control measures are largely pas- sive and do not distract from the wilderness experi- ence, wilderness designation should contain language to permit implementation of such measures in most cases. 1.12 RESPONSE: As stated in the comment, water- shed restoration is discussed in the Wilderness Man- agement Policy (BLM Manual 8560). Erosion control measures may be allowed under certain conditions, as stated in the policy: "Watershed restoration may be undertaken where deteriorated soil and hydrologic conditions caused by human beings or human influences create a serious threat or loss of wilderness values; or where, even though not human-caused, these conditions present a definite hazard to life or property, or where such con- ditions could cause serious depreciation of important environmental quality outside the wilderness. Where such dangers are not imminent, or where natural vegetation may be expected to return in a reasonable time, restoration work will not be done." 1.13 COMMENT: The EIS is not clear on the compati- bility of leases and mining claims with wilderness designation. [Utah Mining Association, Utah Wilder- ness Coalition, and Marathon Oil] a. The BLM insinuates that pre-FLPMA leases and pre-existing valid mining claims could be developed after wilderness designation. Historically, the applica- tion of IMP prevented operators from exercising any rights under pre- or post-FLPMA leases or upon valid pre-existing mining claims. Pre-FLPMA leases and pre-existing valid mining claims may provide all man- ner of rights; exercising those rights in or near a wil- derness area is often impossible, and BLM should not seriously suggest otherwise by including these rights as part of those resources that can be developed under the various alternatives. b. Mining claims will not be able to be worked if the WSAs are declared wilderness. Assessment work which is required by the government cannot be done in WSAs or wilderness areas. c. BLM correctly finds that mining claims do not conflict with wilderness designation. The current law requires that BLM manage WSAs to protect 8 GENERAL COMMENTS AND RESPONSES SECTION 1: WILDERNESS AND MULTIPLE USE wilderness values. This applies to mining claims as well. In most cases, claims are invalid; even when claims are valid, significant management problems do not occur in WSAs or in designated wilderness areas. d. Oil and gas exploration and development are not inconsistent with environmental protection and contin- ued viability of tourism and multiple uses on public lands. The drilling of oil and gas wells does not preclude the designation of wilderness, as the Draft EIS states. For example, the 1984 Wyoming Wilderness Act desig- nated the Gros Ventre as a wilderness area. This area had two wells drilled in the mid-1950s. These were reclaimed to the standards applicable at that time. With the passage of nearly 30 years, all that remains to indicate the location of these wells are dry hole markers that were required at the time. Reclamation can and does return these areas to their natural state. 1.13 RESPONSE: Management of leases and claims is explained in the Description of the Alternatives. The assumption that pre-FLPMA leases and valid min- ing claims will not be able to be worked in designated wilderness areas is not correct. The Wilderness Act of 1964 recognizes the rights of pre-FLPMA leases and claimants of valid mining claims filed before desig- nation. The exercise of these rights in some locations could impose manageability problems for BLM because such developments may legally proceed without full protection of wilderness values. These provisions are included in the Draft and Final EISs in Appendix I, Part A. Ill of I, Minerals Management, and also in Chapter 4, Unavoidable Adverse Effects of Wilderness Desig- nation and Nondesignation. BLM recognizes that energy and mineral develop- ment is a legitimate and important land use that falls within the multiple-use concept. However, the Wilder- ness Act specifies that surface-disturbing activities are not compatible with wilderness designation. Therefore, surface-disturbing activities cannot be allowed in wilderness areas unless mineral rights were established prior to FLPMA for leasable min- erals and prior to wilderness designation for locat- able minerals, unless these activities are determined to be compatible with wilderness management. 1.14 COMMENT: The EIS should analyze the effect of wilderness designation on recreational rock hound- ing. [Rocky Mountain Federation of Mineralogical Soci- eties] Rockhounds have historically entered upon public lands to collect noncommercial quantities or rocks, minerals, fossils, and gemstones for their own use. Designation of vast areas of Utah as wilderness is of great concern because rockhounding will be excluded from areas that are known to be good collecting sites. It is impractical to hike great distances in this largely desert country, to say nothing of also carrying rocks, so young and old alike are foreclosed from pursuing a legitimate recreational use of the land. 1.14 RESPONSE: Wilderness designation does not restrict recreational rockhounding activities. The use of motorized vehicles or other equipment would be prohibited in a designated wilderness area. As noted in the response to General Comment 21.1, WSAs in Utah are not generally accessible by motor vehicle. Most rockhounding at the present time must be done by nonmechanized means. Wilderness designation would continue this situation. Also, refer to the re- sponse to General Comment 1.3. 9 GENERAL COMMENTS AND RESPONSES - SECTION 2 WILDERNESS REVIEW PROCESS INDEX This section on the wilderness review process is pro- vided to answer comments on BLM's handling of the wilderness review. 2.1 BLM should educate the public. It is BLM's respon- sibility. (p. 2) 2.2 How did current wilderness areas get designated without the public’s knowledge? (p. 3) 2.3 The wilderness inventory was prepared by BLM without public comment, (p. 3) 2.4 The EIS should show the chronology and evolution of each WSA from start to finish, so its progress can be easily traced, (p. 3) 2.5 The scoping process for the EIS was inadequate. BLM has failed to respond to scoping and is ignoring vital issues, (p. 3) 2.6 Many WSAs do not qualify as wilderness, (p. 4) 2.7 The EIS should provide the rationale for recom- mendations made on the ISAs. (p. 5) 2.8 BLM is not consistent in making wilderness rec- ommendations on ISAs. BLM failed to follow the Wil- derness Inventory Handbook, which requires consider- ation of contiguous roadless areas with ISAs. (p. 5) 2.9 BLM did not do an environmental analysis or pro- vide for public review of the ISAs. (p. 5) 2.10 The Big Hollow WSA was illegally dropped from wilderness study, (p. 6) 2.11 The WSA boundaries are too choppy, (p. 6) 2.12 The criteria for wilderness have been misinter- preted by BLM. (p. 6) 2.13 Mapping acreages of wilderness character- istics is illegal, (p. 8) 2.14 The ratings of wilderness values are incon- sistent among the BLM Districts in the State, (p. 8) 2.15 WSAs should not be dropped from study with no explanation. This includes roadless areas, areas with outstanding wilderness values, and areas with miner- al conflicts, (p. 8) 2.16 The schedule and locations of public hearings were unfair, (p. 9) 2.17 Public hearings were dominated by special inter- est groups, (p. 10) 2.18 The wilderness study process and BLM favor special interest groups or are biased against wilder- ness. (p. 10) 2.19 Special interest groups seek to designate all lands as wilderness. There is enough designated wil- derness already, (p. 11) 2.20 The EIS should consider wilderness from local, regional, and national perspectives, (p. 11) 2.21 BLM is not listening to local elected officials, (p. 11) 2.22 There should be a Statewide vote on wilderness designation, (p. 13) 2.23 BLM does not have the authority to declare pub- lic land wilderness, drop areas from consideration, or regulate citizen recreation, (p. 13) 2.24 Updated and expedited RMPs are needed before wilderness recommendations are made. (p. 13) 2.25 The Draft EIS contains too much to comprehend and is larger than allowed under CEQ guidelines for preparation of EISs. (p. 15) 2.26 The Statewide EIS violates BLM's wilderness study guidelines, (p. 15) 2.27 BLM should consider a programmatic wilder- ness EIS. (p. 18) 2.28 BLM did not consult with the recreational rock- hounds. (p. 18) 1 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS 2.29 The Draft EIS demonstrates a lack of effort on BLM's part, and the EIS should be postponed, (p. 18) 2.30 Why wasn't the Navajo Nation requested to re- view the EIS? (p. 19) 2.31 BLM's time frame for investigating public com- ments is too short, (p. 19) 2.32 The Draft EIS is totally inadequate and should be reissued as a draft, (p. 19) 2.33 Exclusion of a WSA from further consideration before the USGS and Bureau of Mines mineral reports are complete is a violation of BLM wilderness regu- lations. (p. 20) 2.34 A decision on wilderness should not be made in the tar sand areas until a decision has been made on the lease conversion applications, (p. 21) COMMENTS AND RESPONSES 2.1 COMMENT: BLM should educate the public. It is BLM's responsibility. [Tim Graham, Utah Wilderness Coalition, et al.] a. I think that BLM has a responsibility to educate the public on the benefits of wilderness designation. Many people believe the myth that wilderness locks up land forever. BLM should also point out the bene- fits and/or drawbacks of wilderness as a part of the public education process. b. As part of our scoping comments, we pointed out that BLM should take an active role in publicly defending wilderness and helping to explain many of the issues being contested. The agency has published a huge Draft EIS but has not used other opportunities to reach the public and explain the lands and issues. BLM has not written articles for newspapers, sought tele- vision coverage, sponsored field trips for the media and public, prepared slide shows, or even produced a brief executive summary for the general public. Ex- cept for a 1-page press release and a 2,800-page document, BLM has done nothing to explain the pro- gram and explain the issues. It has not, for example, even bothered to explain what multiple use is-and the distortions by wilderness opponents as to what constitutes multiple use. In the EIS, BLM's scoping response is that the Utah BLM review process has exceeded the require- ments for public involvement. "BLM does not have the resources for more public education and involve- ment." The Utah BLM has found the resources to do what it chooses for the wilderness study (expensive min- eral evaluations, for example) and cites a lack of re- sources to avoid what it does not wish to do. In other States, the agency has seen the value of public out- reach during similar processes. It is a matter of will, not of resources. The BLM in Utah has simply chosen to do no more than the bare minimum. The agency has an opportunity to show the public how important pub- lic lands are and to explain the agency's mission at the same time. Wider public knowledge will lead to more support for BLM's programs among elected offi- cials and the budget to implement them. One way to take advantage of the opportunity is to open an addi- tional public comment period following the release of the Final EIS, at which time the Wilderness Study Reports will also be made available to the public. Pub- lic comment is critical to the successful completion of the wilderness review process. 2.1 RESPONSE: The Utah BLM Statewide Wilder- ness Draft EIS has been prepared in keeping with the CEQ (1978) guidelines, including scoping meetings, news releases, public hearings, and comment periods. The EIS contains a description of BLM's management, both with and without wilderness designation. Append- ix 1 of the EIS contains guidelines for specific activi- ties allowed in wilderness areas. The analysis in the EIS discusses the effects of wilderness on various resources; the overall philosophy of the Wilderness Act is described in Volume I, Introduction. Also, information on the wilderness program is available at the BLM District Offices and the public room in the Utah State Office for anyone who re- quests it. All of these steps and activities educate the pub- lic as to the results and characteristics of wilderness management. In addition, BLM features a monthly statement on wilderness in the BLM Utah Spectrum and has developed a public outreach program. Also, see the response to General Comment 1.2 for a discussion on the multiple-use concept. 2 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS 2.2 COMMENT: How did current wilderness areas get designated without the public's knowledge? [Dean T aylor] I have a map of the wilderness areas dated 1984, and the areas that they put in like Mount Naomi, Deseret Peak, one thing or another. They don’t show that they ever had any WSAs to them. I don't know how they got in. I think they're illegal. Wilderness maps in 1985 show these areas now designated as wilderness areas. Mount Naomi, Wellsville Mountain, Deseret Peak, and Mount Nebo. How did this ever happen without anyone knowing it? 2.2 RESPONSE: The wilderness areas referred to in the comment are located on lands administered by the U.S. Forest Service. Review of these areas was independent of the BLM wilderness study. These areas were designated by Congress in the Utah Wilderness Act of 1984 after a lengthy process, including Roadless Area Review and Evaluation (RARE I) and RARE II. These studies provided for public participation and comment and were well publicized. 2.3 COMMENT: The wilderness inventory was pre- pared by BLM without public comment. [Dennis Slifer, et al.] BLM did a good job of accommodating public parti- cipation for preparing the Draft EIS, but unfortu- nately this cannot be said for the wilderness inven- tory which was the critical initial phase of the whole process. There is no mention of any public involve- ment in this phase within the text, but it emerges as a major public concern. Apparently, BLM saw the in- ventory as their best chance to influence the final out- come and took every opportunity to do so. The dirty work had already been done when the public opinion was solicited. BLM left many fine roadless areas out of any consideration. I feel as a citizen I should have had the opportunity to comment on any and all road- less public lands, not just the ones BLM has selected. It is a shame that the public was left out of so many parts of the project. 2.3 RESPONSE: See General Comment Response Sec- tion 3, Inventory. The BLM inventory was publicized, and public comment periods and opportunities for appeal were provided. Details are provided in the re- sponses to General Comments 3.1 and 3.2. 2.4 COMMENT: The EIS should show the chronology and evolution of each WSA from start to finish so its progress can be easily traced. [Michael Salamacha, Kim Jennyson, Utah Wilderness Coalition, et al.] There is a need to show the chronology and evolu- tion of each WSA from the initial wilderness inven- tory proposals of 1979 to the presently determined WSAs in the Draft EIS. It should be neces-sary to show the starting acreage and boundary configuration of each WSA and clear reasons why acreage remained or was deleted along the way so a citizen can then determine in their own mind if they agree or disagree with BLM. This should be required because of the admitted subjectivity of this whole process. 2.4 RESPONSE: See the response to General Com- ment 3.1. As discussed in Volume I, Chapter 1, Intro- duction, the wilderness review process is comprised of three basic phases: inventory, study, and report- ing. The starting acreage, boundary configurations, and rationale for deleting acreage from the study are recorded in the document entitled Utah BLM Final Wilderness Inventory: Final Decision. (USDI, BLM, 1980b), or in individual decision documents and Fed- eral Register notices for accelerated inventories and an emergency withdrawal. The inventory phase is complete, and the history of the process is recorded. 2.5 COMMENT: The scoping process for the EIS was inadequate. BLM has failed to respond to scoping and is ignoring vital issues. [Utah Wilderness Coalition, et al.] a. As part of scoping, we expressed concern that BLM has added a new criterion which an issue, to be considered, must meet--that it must "be of high pub- lic concern or controversy." We have several con- cerns in this regard. First, we believe that BLM has no clear criteria for deciding which issues to consider in the document. We are also concerned that this new criteria has been used as an excuse to exclude vital issues from consideration. BLM has refused to pro- vide a copy of the documentation behind its rating sys- tem. But the evidence suggests that the rating system was actually applied to the WSAs in at least one BLM District. Is this inappropriate rating still being used by the agency and, if so, can we have documentation on it and its use? 3 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS In BLM's EIS response 520, it is stated that vital issues have not been excluded from consideration in this EIS. This response is far from satisfactory. We have found that BLM has excluded vital issues. These are listed elsewhere in our comments. We reiterate the concern we raised in the scoping comments and our request for an answer. b. On each SSA, we raised specific issues during the public comment periods. We requested during scop- ing that those issues raised in our previous comments be placed in the record for scoping of the EIS. BLM's response in the EIS to this concern was that "No specific response to issues raised about individual SSAs was addressed by BLM in Appendix 2, General Scoping Comments and Responses of the Draft EIS." BLM is required to respond to these issues and describe their use in the Draft EIS. If they are not used, BLM must explain why, whether the issue is sig- nificant or not, and BLM's rationale for the decision regarding significance. We request that the agency provide this information in the Final EIS. 2.5 RESPONSE: Specific issues identified for the EIS are responded to in appropriate sections. An issue identification section has been included in the intro- duction to Volumes I through VI of the Final EIS and in the introduction to each individual WSA analysis. In de- termining the significance of issues, BLM considered the nature and magnitude of potential impacts, re- sources covered by law, the level of public interest or concern about the potential impacts, and the rele- vance of the issue to the individual WSA. It should be noted that significant issues do not equate to signifi- cant impacts. A specific rating system has not been applied to identify significant issues. Reasoning and experience of the EIS team or others may override public concerns, depending on the circumstances. For example, research may show that, even though the public believed a potential im- pact to be significant, the affected resource is not found in a WSA or the magnitude of the effect would be so small that the impact would be insignificant. The NEPA process requires that all potential impacts be assessed, but only the significant effects on the hu- man environment need be included in the EIS. Some otherwise "insignificant impacts" have been address- ed because of public views or controversy. Also, see the response to General Comment 9.2 for a discussion on issue identification. The commentor's narrative of BLM's response to scoping records is inaccurate. In the Draft EIS, Appendix 2, Comment Response 487, BLM explained that specific responses to issues raised about the individual SSAs were included in the individual anal- yses for WSAs, Volumes II through VI. 2.6 COMMENT: Many WSAs do not qualify as wil- derness. [Kane County, Wayne County, et al.] Wilderness should be those areas that are without the imprint of man's works there. By this definition, most of the WSAs should not be included in the wilderness evaluation. One WSA has cabins, fences, stock water ponds, and roads. One WSA has 40 miles of roads or vehicular ways. Will that road be closed to all travel? Another WSA has 30 miles of road that would be closed. One WSA has a city culinary water system through a portion of the area. One WSA bor- ders U.S. Highway 89, the route between Kanab and Lake Powell. All existing corridors should be left with a guarantee that, if minerals extraction becomes eco- nomically viable, they can be used. This should also include all roads that have existed in the past but which are not presently usable. Also, reconstruction assistance should be given when necessary. 2.6 RESPONSE: See the responses to General Com- ments 3.1, 4.1, 4.2, and 22.6. According to the wilderness inventory guidelines, WSAs need not be totally devoid of the imprints of man; the imprints need only be substantially unnotice- able. Corridors that met the official definition of a road and were surrounded by a WSA were cherry- stemmed and will remain open to vehicular use, even if the WSA is designated wilderness. 2.7 COMMENT: The EIS should provide the rationale for recommendations made on the Instant Study Areas (ISAs). [Utah Wilderness Coalition] a. Four ISAs (Book Cliffs, Devils Garden, Joshua Tree, and Link Flats) that were studied and recom- mended as unsuitable for wilderness designation are listed. It would be helpful to have more information on the rationale for the nonsuitability recommendation 4 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS or a reference document where such information is available. b. BLM has failed to explain why these areas do not meet the wilderness characteristics and why the new information should not be considered in the wilderness review process. This is a significant issue which is not addressed in the Draft EIS, even though we have raised it several times during the study. 2.7 RESPONSE: Refer to the Final EIS, Volume I, Introduction, The Wilderness System in Utah, for information on the BLM ISAs in Utah. Ten ISAs in Utah were identified and studied as required by FLPMA. Each ISA was studied and a rec- ommendation as to the suitability or nonsuitability for wilderness designation was to be forwarded to Con- gress within a specific Congressionally mandated time period. Utah BLM has reported on five ISAs (Book Cliffs, Devils Garden, Joshua Tree, Link Flats, and Escalante Canyon Tract 1). By special permis- sion, other ISAs are included in this EIS. The five reported were recommended by BLM as unsuitable for wilderness designation. To date, Congress has not acted on those recommendations. All 10 ISAs remain under Wilderness Interim Management and will remain so until Congress either designates them as wilder- ness or releases them from further wilderness consid- eration. Information on the ISAs and BLM recommen- dations and rationale is contained in reports submit- ted to Congress in 1984. The information provided in Chapter 1, Wilderness System in Utah section, ex- plains the study process for the ISAs in Utah. Also, rationale for the recommendations on the five report- ed ISAs are now included in Appendix 11, Summary of Rationale for the BLM Proposed Action, as a mat- ter of record, even though the study and reporting process for the five ISAs is complete. 2.8 COMMENT: BLM has not been consistent in mak- ing wilderness recommendations on ISAs. BLM failed to follow the Wilderness Inventory Handbook which requires consideration of contiguous roadless areas with ISAs. [Utah Wilderness Coalition] The Wilderness Inventory Handbook requires BLM to consider natural areas in conjunction with contigu- ous roadless land in its recommendation. Several ISAs are no longer shown under study by BLM. There were at least five tracts designated as outstanding natural areas surrounding Glen Canyon NRA. 2.8 RESPONSE: See General Comment Response 2.7. Each ISA was studied during the early stages of the wilderness review process. Those ISAs without contiguous land meeting wilderness standards were reported to Congress. Utah BLM received permission from the Secretary of the Interior to delay study on the remaining ISAs and include them in the inventory and evaluation of all other potential wilderness areas. 2.9 COMMENT: BLM did not do an environmental analysis or provide for public review of the ISAs. [Utah Wilderness Coalition] a. BLM is requested to correct the clearly obvi- ous violations of the inventory policy. We request that BLM consider these comments and recommend that all of the Joshua Tree ISA be designated wilder- ness. We ask that BLM produce the legal authority for recommending nonwilderness on the Joshua ISA without environmental analysis and public comment. This area is highly scenic and featured on local maps. This special area qualifies for wilderness designation. b. BLM failed to state that the designated Joshua Tree natural area is only 1,040 acres in an 11,600- acre roadless area largely covered by an equally im- portant Joshua tree forest. The larger area includes the benchlands with desert tortoise to the Beaver Dam Mountains 1,600 feet higher. 2.9 RESPONSE: Information on the ISAs and BLM recommendations and rationale is contained in reports submitted to Congress in 1984. Rationale for the un- suitable recommendations is included in Appendix 11 in Volume I. The ISA reports (environmental analyses) submit- ted to the Secretary of the Interior followed estab- lished procedures, and notice of their availabil-ity was published in the Federal Register at that time. The environmental analyses submitted to the Secre- tary of the Interior for forwarding to Congress are still available for public review. 2.10 COMMENT: The Big Hollow WSA was illegally dropped from wilderness study. [Utah Wilderness Coalition] 5 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS This WSA was dropped from wilderness study status by the U.S. Secretary of the Interior on Decem- ber 30, 1982, due to its small size. As a result of a decision of the Eastern District Court of California (Sierra Club vs. Watt, Civil No. 5-08-035 LKR, dated April 18, 1985), it was returned to WSA status. The legal decision covered all the areas that were dropped. BLM violated the court order to reinstate this area as a WSA. No mention is made of this in the Draft EIS. Communication with the wilderness coordi- nator confirmed that BLM was aware of the court decision and decided not to study this area. BLM stated that they were going to issue a notice in the Federal Register that would confirm dropping this area. The Utah Chapter of the Sierra Club formally requested written notice of this decision and has not received it yet. We request that BLM include this area in the wilderness study and evaluate its suitability for wilderness designation. We request what action BLM is taking, what opportunity for public comment has been provided, and what the justification for any decision is. 2.10 RESPONSE: Volume I, Chapter 1, Page 12 of the Draft EIS explains that the Big Hollow WSA failed to qualify for study because it is less than 5,000 acres and is no longer adjacent to designated lands or lands under consideration for wilderness designation. A formal announcement on Big Hollow appeared in the Federal Register on December 18, 1987. The date of the announcement has been added to the Final EIS in Volume I, Chapter 1, The Wilderness System in Utah. 2.11 COMMENT: WSA boundaries are too choppy. [Charles Stromberg and Utah Wilderness Coalition] a. The lines designated for wilderness are chop- ped up so bad I don’t think anybody could ever tell whether you were on wilderness or whether you weren't. Just take a block of land, and it is all chop- ped up so they squirmished around a lot of things so I think it would be very difficult for anybody to tell where the designated area is if they were in there backpacking or walking or whatever they were doing; they could never tell which area they were in. b. These areas clearly qualify for wilderness designation as defined by the Wilderness Act of 1964. It is the rugged beauty and natural character of the land that causes us to return to these areas. If this land is carved up into small, sporadic parcels, it will lose its attraction to backpackers that seek wilder- ness areas that offer outstanding opportunities for primitive and unconfined recreation, solitude, and land that is unscarred by humankind. We feel that the BLM Draft EIS does carve up the land in this way and is, thus, faulty. 2.11 RESPONSE: See the responses to General Com- ments 3.1 and 3.43. Also, refer to Appendix 11 in Vol- ume I, which summarizes the rationale for the BLM Proposed Action, and to the Environmental Conse- quences and Wilderness Values sections, which dis- cuss manageability of WSAs. 2.12 COMMENT: The criteria for wilderness have been misinterpreted by BLM. [Dennis Slifer, Wash- ington County Water Conservancy District, et al.] a. The criteria used for evaluating areas in the inventory and study phases have been questioned by many critics. The problem is not so much the criteria but the manner in which they were interpreted and applied by BLM. The inventory criteria were taken from the Wilderness Act and, for the most part, these are straight-forward guidelines. The problem arises from the perverse use of the criteria which states that: "... these areas must have outstanding opportunities for solitude or a primitive and uncon- fined type of recreation." This criteria is also used as one of the study policy and planning criteria (identi- fied as mandatory wilderness characteristics). BLM has taken their interpretation of this criteria to ridiculous extremes in order to eliminate vast areas of roadless land from both the inventory and study phases. It is hard to fathom how such arbitrary deci- sions have been made to delineate lands on the basis of solitude and primitive recreation when practically the entire southern half of the State has these charac- teristics--a vast, extremely rugged, undeveloped, inaccessible, and largely unpopulated place. Huge areas of wild land have been split apart and judged unsuitable for wilderness designation because they do not have outstanding opportunities for solitude or a primitive and unconfined type of recreation. BLM has insisted that their decisions are defensible, that the opportunities are either "outstanding" or they are not. Who is judging here, and what does "outstanding" mean to those who are passing judgment? In judging an area for solitude, huge areas have been eliminated because of such absurdities as "no topographic screen- ing." Never mind that you are many miles from the nearest road-if the place is flat, there is apparently 6 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS no outstanding opportunity for solitude here. The type of vegetation has been similarly used (abused) for similar ends. Areas without trees or bushes big enough to hide behind or thick enough to provide cover are seen as lacking outstanding opportunities, etc. This is a flagrant disregard for the concept of protec- ting the integrity of ecosystems. In judging the mer- its of an area's opportunities for primitive recrea- tion, BLM uses an arcane formula which compares miles of access routes (trails) to acres of areas accessible/ inaccessible. This seems to ignore the basic premise that primitive and unconfined recrea- tion is dispersed, which can mean traveling and camp- ing off trail. Much of this country in southern Utah is open enough to encourage off highway travel or cross- country travel. Huge areas of it are accessible to anyone who is willing to walk there, and it is primi- tive and unconfined recreation at its best. You have more solitude than you can imagine as soon as you lose sight of your car. Unsuitable recommendations should be based on real conflicts and not on tainted determinations of outstanding opportunities. For example, a WSA's proximity to or distance away from major population centers has nothing to do with its qualifications as wilderness. Diversity criteria are incredibly important. The law says that diversity and uniqueness are important which, if followed, would correctly designate the entire 3.2 million acres as wilderness, rather than cutting that acreage in half. It is not clear how those areas with the "most outstanding wilderness characteristics" were identi- fied in the first place. It appears that an area had to have BOTH solitude and primitive recreation. Why is the difficulty of managing certain areas a criteria? b. In Volume I of the EIS, Criterion No. 1 for the Evaluation of Wilderness Values (page 12) identified a diversity requirement of balancing the geographic dis- tribution of wilderness areas. The southwest region, primarily comprised of Washington County, provides sites for 30 of the 82 proposed WSAs, or approxi- mately 37 percent of the total proposed WSAs. When a WSA like Parunuweap has similar features to those contained in a national park, then the need to restrict use only to the wilderness area is diminished. c. Several WSAs and their preferred alternative of all wilderness designation violate the wilderness inventory criteria. According to Volume I, Overview, page 12: "... (3) have at least 5,000 acres of land or is of sufficient size as to make practicable its preservation and use in an unimproved condition . . ." The inventory criteria are prefaced by the explana- tion that: "Each area must meet all of the criteria as specified." Whereas, a specific minimum of 5,000 acres is expressed, only a vague allusion for excep- tion is made on condition of unimpaired practicable preservation. No definition of parameter in associa- tion with this is made either by explicit detail or by reference. Therefore, whereas these wilderness des- ignation decisions are going to be made, "... in per- petuity" (Vol. I, page III), nonspecific criteria excep- tions become invalid in the "forever more" scope of these wilderness designations. It seems the inventory criteria are being made extremely flexible and biased toward giving an area wilderness designation with nonspecific criterion as justification. Therefore, logic mandates that the explicit 5,000-acre minimum cri- terion be used and the rest of the associated state- ment be dismissed. The less than 5,000-acre areas should not be WSAs. 2.12 RESPONSE: Questions regarding the inventory and the application of the wilderness criteria are responded to in General Comment Response Sections 3 and 22, respectively. The BLM Wilderness Study Policy (USDI, BLM, 1982a) mandates the consideration of wilderness val- ues, diversity, manageability, and an overall balance of consideration of wilderness and competing re- source values in BLM's suitability recommendations. BLM's rationale for the Proposed Action are summa- rized in Appendix 11. FLPMA and the BLM Wilderness Inventory Hand- book both provide for study of areas less than 5,000 acres in size. 2.13 COMMENT: Mapping acreages of wilderness characteristics is illegal. [Rex and Judy Wells, Utah Wilderness Coalition, et al.] Volume I, Table 53, page 91, describes the acre- age of outstanding opportunities for primitive recrea- tion and solitude present in each WSA. We do not know how these WSA acreage figures could have been de- rived unless these opportunities had been mapped. Mapping of these opportunities is in violation of the Wilderness Study Policy (USDI, BLM, 1982a) which states: (page 5105 of the Federal Register Notice) ". . . criteria for determining the presence or absence of outstanding opportunities for solitude and unconfin- ed recreation were issued in the BLM Wilder-ness Inventory Handbook." Organic Act Directive 78-61, Change 3, which provides policy clarification and sup- 7 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS plemental guidance for the Wilderness Inventory Hand- book, prohibits the mapping of . discrete zones within units where outstanding opportunity is consid- ered to exist." As far as we know, this policy has not changed. This mapping also presents the ludicrous notion that each WSA or ISA contains "magical zones", outside of these zones, one is not getting any kind of experience or a less than outstanding exper- ience. The moment one steps inside the zone, the ex- perience is suddenly transformed into an outstanding experience. This mapping and the descriptions in the analyses for solitude also fail to recognize all of the factors to be evaluated in determining outstanding opportunities for solitude: namely, size and configura- tion of the unit. In addition, the mapping and descrip- tions are sometimes inconsistent with the intensive inventory information. For example, the description of the Scorpion WSA describes the area as lacking outstanding opportunities for solitude. However, the Utah proposed WSAs (April 1980) state the Scorpion area possesses solitude because of its size and topog- raphy. 2.13 RESPONSE: See General Comment Responses 22.5 and 22.10. The BLM Wilderness Study Policy (page 5104) notes that ". . . outstanding opportunities for solitude or a primitive and unconfined type of rec- reation were the factors used in the BLM wilderness inventory to determine which roadless areas qualified to become wilderness study areas . . . but these char- acteristics may be present in areas to varying de- grees." The wilderness study process calls for com- parison of opportunities and notes that opportunities in one WSA may be superior to those in another. BLM has used descriptive methods to facilitate compara- tive analyses of qualitative characteristics both within and between WSAs, as mandated in the Wilder- ness Study Policy. Any inconsistencies between the ratings of oppor- tunities for solitude or primitive recreation are addressed in the individual analyses for the WSAs involved. 2.14 COMMENT: The ratings of wilderness values are inconsistent among the BLM Districts in the State. [Riki Darling, Utah Wilderness Coalition, Owen Sever- ance, et al.] Many inconsistencies between the various BLM Districts are quite noticeable. Some of the areas for which clear criteria should be stated and used throughout the Draft EIS are: (1) determination of acres of solitude and primitive recreation (e.g., Wah- weap presumably has some 100,000 acres without outstanding solitude); (2) determination of special features (e.g., Cougar Canyon and Fifty Mile Mountain show poor rationale); (3) analysis of recreational activities present and/or outstanding (e.g., good in Volume II, confusing in other volumes); and (4) signifi- cance of conflicts with wilderness designation (e.g., Parunuweap, firewood). 2.14 RESPONSE: See the responses to General Com- ments 2.13, 3.17, and 22.3. The descriptive assess- ment of wilderness qualities reflect the judgment of the various BLM Districts relative to the standards outlined in the Wilderness Study Policy (USDI, BLM, 1982a). Rationale for BLM's balancing of wilderness and nonwilderness resources and development of the BLM Proposed Action are summarized in Appendix 11. 2.15 COMMENT: WSAs should not be dropped from study with no explanation. These include roadless areas, areas with outstanding wilderness values, and areas with mineral conflicts. [Dennis Slifer, George Wuethner, Wendell Anderson, et al.] a. BLM has eliminated vast roadless areas with no explanation of why they have chosen to do so. They have taken their interpretation of this criteria to ridiculous extremes in order to eliminate vast areas of roadless lands from both the inventory and study phases. b. In dealing with the theory of multiple usage of public lands, if a WSA was in conflict with some alter- native use such as proposed oil leasing or recrea- tional use, then the WSA was dropped or its bounda- ries were modified. Mineral potential was also used to disqualify wilderness every time it was proposed to exist in a WSA. Whenever the issue was raised of adverse effect on the local economy, social econom- ics, existing land uses such as grazing, energy devel- opment, or whatever, the more abstract values of solitude, wildlife, and wilderness experience were run aground. The concept of multiple use has merit but it also has limitations. Campsites and cow pies do not mix well. The lands BLM has chosen to study lack information on resource conflicts. Avoiding proposing an area as wilderness whenever any type of conflict exists is wrong. 2.15 RESPONSE: See the responses to General Com- ments 3.1, 3.2, 3.14, 3.18, 8.3, 8.5, and 8.6. 8 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS Appendix 1 1 in Volume I of the Final EIS summarizes the rationale for the BLM Proposed Action. The rationale used for recommending an area as suitable or unsuitable for wilderness are based on the Wilderness Study Policy (USDI, BLM, 1982a). This policy requires BLM to determine where wilderness is or is not the most appropriate use of the public lands. 2.16 COMMENT: The schedule and locations of pub- lic hearings were unfair. [Dennis Slifer, Earth First!, Utah Wilderness Coalition, et al.] a. I am suspicious about the design of the schedule for the public hearings. The 16 hearings occurred in widely scattered locations, but only on a tight cluster of 4 days (Wednesday/Thursday, May 7 and 8, and Tuesday/Wednesday, May 13 and 14). Could this have been done in order to prevent the attendance of BLM adversaries at more than just a few meetings? Most of these people would have to travel from Salt Lake City or from outside the area, and this schedule ensures that they are limited in their choice of meetings. Flaving the meetings on weekdays also makes attendance more difficult for anyone not local. Scheduling meetings in the evening ensures that any- one local can attend, but I wonder if all of this does not conspire to create a likelihood of potential anti- wilderness bias. It appears to me that BLM wanted the entire series of hearings to be over with as soon as possible and with a minimum of publicity. There should have been one meeting each week for 16 weeks instead of 16 meetings all crammed into one week (from May 7 to May 14). BLM also could have held some meetings outside of Utah. Why wasn't this alter- native opted for? b. The following recommendations should be con- sidered for all future wilderness hearings. Hearings should be held in States neighboring to Utah to allow testimony from others who regularly use Utah's BLM lands. At a minimum, hearings should be conducted in Grand Junction, Colorado; Aspen/ Vail, Colorado; Boulder/Denver, Colorado; Flagstaff, Arizona; or Phoenix, Arizona. Other possible sites would include Pocatello, Idaho; Boise, Idaho; or Albuquerque, New Mexico. Though not originally planned to allow for 90 days of time to write comments after the hearings were completed, the final schedule has worked well to allow more complete public participation. We recom- mend that, when future hearings are held, at least 90 days separate the deadline for written comments and the last hearing. We also offer the following suggestions: 1. The selection of dates should be spread out to allow better media coverage, better discussion, and more cross-State participation. 2. No more than two hearings should be held in one day. This would allow all citizens to absorb vari- ous comments from throughout the State. 3. Several hearings should be held on Friday, Saturday, or Monday to allow people who must travel to better arrange their time. Public hearings are an important American activity, and schedules must be arranged to maximize public participation from a broad area. 4. Two and maybe three different days should be scheduled for testimony in Salt Lake City. The extra day which was scheduled during the last hearing show- ed why this should be done in advance. 2.16 RESPONSE: The purpose of public hearings is to obtain the views of the interested public on wil- derness recommendations for consideration by BLM, the Secretary of the Interior, the President, and Con- gress in accordance with requirements of the Wilder- ness Act; also, to obtain the views of the public on the Draft EIS, in accordance with require-ments of the NEPA. Each hearing was open to comments on the Proposed Action, alternatives, and the adequacy and accuracy of the Draft EIS, including Volume I and the analyses of all 83 BLM WSAs. It was not necessary for everyone to attend every meeting. All comments made at the hearings became part of the official comment record and have been considered equally with written comments submitted within the extended 180-day comment period. There was no attempt on BLM's part to subdue publicity of the meetings. BLM announced and conduct- ed a publicity meeting shortly after release of the Draft EIS and notified the public of the hearing sched- ule. A schedule was also included in each copy of the EIS. Hearings were held at 16 locations throughout the State to provide an opportunity for concerned citi- 9 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS zens to present their views. Many of these locations (e.g., St. George, Vernal, Monticello, Moab, Delta, and Logan) are within driving distance of surrounding States. Given the length of the comment period for submission of written comments, it is BLM's belief that out-of-State hearings were not necessary in order to give the public an opportunity to comment on the Draft EIS. BLM has been flexible and modified the length of the comment period, according to the interest shown by the public. 2.17 COMMENT: Public hearings were dominated by special interest groups. [County Commissions and Utah Wilderness Coalition] a. The public hearings were unfair because they were filled with the environmentalist groups who dom- inated the meetings. b. We have several recommendations on proceures for future BLM wilderness hearings: 1. Limit speaking to 5 minutes maximum for all speakers, including public and elected officials. 2. Require public officials to sign up and accept a random position like everyone else. Most citizens who spoke have daily schedules which keep them just as busy as elected and public officials. In a public hear- ing, all participants should be treated equally. 3. People who are being paid to speak on behalf of a particular industry should be required to identify themselves as "paid representatives." 2.17 RESPONSE: The hearings were announced to the public at large. All individuals or groups were given the opportunity to speak. The order of speakers was selected at random, except for elected officials and government agencies who were allowed to speak first, as directed in BLM Washington Office Instruc- tion Memorandum 85-265. This is appropriate be- cause the Wilderness Act, FLPMA, CEQ, and NEPA guidelines all require specific notification and coordi- nation with elected officials of State and local governments. BLM had no control over the affiliation of atten- dees at the public hearings. All participants were asked to identify their affiliation. It can be assumed that industry representatives are all paid. No special statement is required. 2.18 COMMENT: The wilderness study process and BLM favor special interest groups or are biased against wilderness. [Mr. Johnson, et al.] a. This whole wilderness study process is, in my opinion, slanted against the present owners and users of the land in favor of the special interest groups who want it for themselves and to share it with absolutely no one else. b. The BLM Draft EIS is not objective. BLM's philosophy is evident all too clearly as biased against wilderness whenever any other economic use can be imagined for the land. BLM's current study and its analysis are fraught with anti-wilderness bias. At a BLM staff meeting in Moab, the wilderness staff was told, "If in doubt, throw it out." This bias is attribut- able to the background of those who prepared the EIS. 2.18 RESPONSE: The BLM wilderness study pro- cess is mandated by Congress through the Wilderness Act of 1964, FLPMA of 1976, and subsequent regulations. These regulations (e.g., Wilderness Study Policy) require that BLM balance wilderness and nonwilder- ness values, including economic values, in making wilderness recommendations. Appendix 11 summa- rizes the BLM rationale for the Proposed Action. Also, see the response to General Comment 8.15. 2.19 COMMENT: Special interest groups seek to designate all lands as wilderness. There is enough des- ignated wilderness already. [Dean Taylor, Utah Coun- ties, Utah Mining Association, Rocky Mountain Oil and Gas Association, et al.] Between reservation lands, BLM lands, FS lands, national park lands, national recreation lands, nation- al monument lands, and now proposed wilderness lands, we are gradually losing our potential for earning a living in this great country. Don't you be- lieve the environmental community for one second. Their goal is to lock up every single acre in the western United States for single use and they won't quit until this is accomplished. If you think that envi- ronmentalists are satisfied with the lands they have locked up already, then why do I hear proposals to have buffer zones around the existing national parks, national monuments, and national recreation areas? I GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS maintain that one of our western states is missing, locked up as wilderness. Ninety-eight percent of all wilderness-designated land is in the western United States. The latest count is over 90 million acres. This equates to 141,015 square miles. Montana, one of the largest states, has 147,000 square miles. The only states larger are Alaska, Texas, and California. 2.19 RESPONSE: BLM is aware of the extent of the NWPS. Congress has mandated the wilderness study and will ultimately decide how large the NWPS will be. Also, see the responses to General Comments 8.9 and 22.9. 2.20 COMMENT: The EIS should consider wilder- ness from local, regional, and national perspectives. [Wilderness Society, Rodney Greene, et al.] a. Obviously there are different perspectives being expressed here. You've heard the local perspec- tive. There are also regional and national perspec- tives to consider: that is, the public lands were set aside for the use of all the citizens of the United States. There are many people from all parts of the country who use this land and who care very deeply about it. It's obvious to me that we have a long way to go to resolve the conflicts between this regional and national perspective and the local issues that have been expressed. We need to do all that we can to protect natural values at the same time that we seek to balance that with the economic health of our local communities. b. BLM's tradition of decentralization and re- sponsiveness to local interests has made it difficult for the State and District Offices in Utah to take into account overall national goals expressed in the statutes and regulations of the last decade that are not reflected in local policies. That difficulty has led to the violations of the wilderness inventory regula- tions and it continues to be reflected in the Utah BLM Statewide Wilderness EIS, which treats wilderness as an afterthought in multiple-use decision-making and not as a vital component of proper land management. 2.20 RESPONSE: According to the Wilderness Stu- dy Policy (USDI, BLM, 1982a): "... the BLM will rec- ommend for wilderness designation only those areas for which it has been determined, through the Bur- eau's multiple resource planning process and public involvement, that wilderness is the most appropriate use of the land and its resources." Wilderness values are to be balanced against the benefits of other re- source values and uses which would be foregone due to wilderness designation. The Wilderness Management Policy also estab- lishes quality standards for analysis and documenta- tion. These standards require BLM to consider, among others, local social and economic effects of wilder- ness designation and the consistency of wilderness with officially approved and adopted resource-related plans of other Federal agencies, State and local gov- ernments, and Indian tribes, and the policies contained in the plans. Consideration of local concerns also is mandated by FLPMA and BLM's planning regula- tions. The environmental consequences section of Vol- ume I analyzes the effects of wilderness designation from national and State perspectives. 2.21 COMMENT: BLM is not listening to local elect- ed officials. [Thom Hatch and Utah Counties] a. One of the other areas that I would like to address that does not directly deal with the EIS is to ask BLM to very strongly listen to the words of the local elected officials and those of the State and national leaders on this. They were elected by the people and are representing the people at large; and they’re representing the views of those people who elected them. If they were elected by the small majority that the wilderness areas would serve, they would be saying different things than they are this evening and at other times. As you all read through the EIS, one of the things that you will notice is that the proposed wilderness, or partial wilderness of the proposed alternatives, conflicts with the management of most all the counties in which there is wilderness. This sets the proposed wilderness against what the local leaders have planned for in their counties and, likewise, would be against the wishes of local citi- zens. BLM has ignored input from local governments. County commissioners in the past have sat down with local BLM officials in our area and thought we had worked out a compromise pertaining to wilderness. It seems that the thoughts and ideas which were dis- cussed at those meetings were completely ignored by the BLM wilderness team, and the present preferred alternative does not in any form resemble the conclu- sion that was agreed upon in those meetings. As a legal entity of the sovereign State of Utah and duly elected by the citizens of our district, we are disap- pointed that the BLM management did not abide with its signed Memorandum of Understanding in working GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS with our district during the scoping process or any other process for that matter. We feel we are entitl- ed to more specific treatment than is provided for in public meetings such as this. The No Action/No Wilderness Alternative is pre- ferable because the All Wilderness Alternative would conflict with the county's multiple-use concept be- cause "... restrictive conditions would be placed on mineral development and oil and gas leases would not be renewed. At least one potential dam site on the North Fork of the Virgin River would be eliminated from consideration under this alternative." How can such a blatant effort to subvert the wishes of the sovereign citizens of this county be allowed? Are the machinations of the Executive Branch of Govern- ment, as embodied in the NPS and BLM, more impor- tant than the citizens of the State that is supposedly sovereign and equal to others? Too little emphasis in the light of a decision in perpetuity is given to analyzing clear and present plans developed by Kane County. For this reason and those stated above, we feel the Draft EIS is inadequate and pro-wilderness biased. 2.21 RESPONSE: The Wilderness Study Policy (USDI, BLM, 1982a) states the following: "In deter- mining whether an area is suitable or unsuitable for wilderness designation, the BLM wilderness study process will consider comments received from inter- ested and affected publics at all levels-local, State, regional, and national. Wilderness recommendations will not be based exclusively on a vote-counting ma- jority rule system." While BLM recognizes that local views are important, they are only one element that must be considered in the study process. BLM does endeavor to make the land use plans for Federal lands consistent with officially approved and adopted resource-related plans of other Federal agen- cies, State and local governments, and Indian tribes, so long as those plans are consistent with the pur- poses, policies, and programs of Federal law and regu- lation applicable to public land. In the case of the wil- derness review and since the county plans reflect desires of only a portion of the "interested and affect- ed publics," it is required that BLM utilize a broader perspective and, consequently, may not fully agree with the local views and county plans. BLM disagrees with the comment that the EIS is inadequate and pro-wilderness biased. As noted in the comment, the EIS analyzes the con- flict of wilderness designation with most county plans and policies. BLM has not ignored the input of local govern- ment, but has developed the Proposed Action based on guidance in the Wilderness Study Policy and the man- dates of Congress relative to wilderness designation. The BLM records do not indicate that a Memo- randum of Understanding between BLM and any county outlining the BLM proposals was ever signed by local BLM officials. Such an action would not be consistent with the outlined wilderness review process. BLM District-proposed actions are subject to the approval of the Utah State Director, the Director of BLM, and the Secretary of the Interior before being finalized as the recommendations forwarded to the President and Congress. 2.22 COMMENT: There should be a Statewide vote on wilderness designation. [Dean Taylor, et al.] a. Now, for the BLM and the FS to conjure up, that is go in collusion to put these lands in wilderness areas, I think it is unconscionable. I think the State of Utah should have a referendum and vote on these lands. Then we would find the true picture. Wilder- ness to me is hide and steal and conceal. It hides any of our mineral values, steals our revenues, and con- ceals the area to all but a limited number of people. State land is being consumed without a Statewide public vote. The present public hearings are unfair as they are filled with the environmentalist groups who dominate these meetings. A Statewide public vote is the only fair and just way. I think that we need to include the voice of a large majority of the people of the population and not just have specific groups or interests represented. b. All wilderness in the State of Utah and pro- posed wilderness is illegal. These lands cannot be des- ignated wilderness unless it is through a public vote, which has not occurred. These lands were given to the people, not to BLM. 2.22 RESPONSE: The BLM and FS wilderness studies on Federal lands are mandated by the Con- gress of the United States. Regulations duly imple- mented to guide the wilderness review process do not call for a public vote. GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS BLM has considered testimony received at the public hearings, along with written comments receiv- ed during the 180-day comment period. The comment period was open to the public at large, and everyone had an opportunity to express their opinion. 2.23 COMMENT: BLM does not have the authority to declare public land wilderness, drop areas from consideration, or regulate citizen recreation. [Jean Soko, George Wuerthner, et al.] It is my understanding that Congress, and Con- gress alone, has the authority to deny wilderness for reasons of mineral exploration. BLM is supposed to report solely on presence of wilderness values. Only Congress can drop areas in favor of ORV use. BLM has taken it upon themselves to tell us how we will play in future decades. BLM has no right to make this type of decision for us. The BLM Draft EIS is illegal. This multi-volume document often raises and answers questions which BLM as an agency has no right to raise. The Wilderness Act of 1964 and FLPMA of 1976 make clear that the agency is responsible for identifying all wilderness, not for deciding which wilderness shall be chosen for protection. I feel it is ridiculous to have to tell BLM what the law says, but it does seem to be necessary. Congress directed BLM to determine the wilderness suitability of the public lands. It did not have any clause in there saying study only those lands without conflicts. BLM has gone beyond the original intent of the Wilderness Act. BLM in Utah resists and flouts Congress' decree concern- ing wilderness. This is due to local pressures, poli- tics, and internal agency sentiment. BLM demon- strates a great abuse of discretion and violations of national regulations. 2.23 RESPONSE: Section 603 of FLPMA requires the Secretary of the Interior to review roadless areas or islands of the public lands and report to the President his recommendation as to the suitability or unsuitability of each such area or island for preserva- tion as wilderness. According to the wilderness review process sub- sequently developed by the Department of the Interior, BLM will make recommendations subject to approval of the Secretary of the Interior. The recom- mendations adopted by the Secretary will be passed on to the President of the United States and the Presi- dent will make recommendations to Congress. The regulations require that BLM not only report on the presence of wilderness values, but make judgments and recommendations on the suitability of areas for designation to the NWPS. Only Congress can actually designate areas to the NWPS. BLM has followed the regulations of the Department of the Interior during the wilderness review. 2.24 COMMENT: Updated and expedited resource management plans (RMPs) are needed before wilder- ness recommendations are made. [Environmental Protection Agency, Utah Wilderness Coalition, et al.] a. The BLM wilderness review process, as out- lined in the Wilderness Inventory Handbook and the Wilderness Study Policy, envisions that BLM's multi- ple resource programs will be addressed in RMPs prior to multiple resource decisions and land use allocations, including wilderness recommendations. The BLM Wilderness Study Policy states that: "The BLM will recommend for wilderness designation only those areas for which it has been determined, through the Bureau's multiple resource planning process and public involvement, that wilderness is the most appro- priate use of the land and its resource," and, "BLM wilderness studies will be carried out within the scope of BLM planning areas." By studying the WSAs and scoping the EIS on a planning area basis, BLM will readily be able to blend wilderness resource consider- ation into the multiple resource perspective of RMPs, management framework plans (MFPs), and MFP amendments, and at the same time provide adequate site-specific information on each WSA. More recent draft interim program guidance on this matter reiterates this sequence of planning by stating: ". . . through the resource management planning process, areas identified as having wilder- ness characteristics are evaluated to determine if they are suitable or unsuitable for preservation as wilderness." According to BLM's schedule for the Utah RMP/ MFP process, some of these land use plans will either be completed or updated concurrently with the State- wide wilderness review. However, the schedule for RMP completion in Utah would mean that all RMPs would not be updated until 1996 or 1998. Under FLPMA, the statutory date under FLPMA for comple- tion of the wilderness recommendation process is 1991. This means that some of the RMPs will not be completed by 1991. GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS b. To improve integrated multiple resource plan- ning and provide a document of sufficient brevity to aid in public understanding, BLM should submit the Wilderness Study Reports (WSRs) in the context of current RMP/MFPs, on a Statewide basis, to Con- gress as planned. c. Planned RMPs should be expedited in areas where significant resource development conflicts with wilderness recommendations, such as current and potential mineral development, grazing, and ORV uses, so that these conflicting uses are compared to the environmental benefits of potential wilderness management. Such RMP revisions could also be group- ed to consider WSAs adjacent to national parks. d. While wilderness management of areas included in the Proposed Action will undoubtedly result in positive environmental benefits, we are still concern- ed that the process followed by BLM does not allow for full consideration of the opportunities BLM has to include wilderness management with other nonconflict- ing multiple resource uses. For example, utilization of more current RMPs would allow refinement of where to establish wilderness management vs. other conflict- ing multiple uses. Minor revisions of inventory units, where appropriate, could be considered. If current information on the feasibility of potential mineral developments indicates little likelihood for progress, then less land may be considered conflicting with wilderness designation. e. To strengthen the utility of the EIS in aiding informed decisions on the full range of options for multiple resource management, including wilderness designation, wilderness designation should be consid- ered concurrent with the development of RMPs in Utah. f. As an example of where an updated RMP could possibly affect the Proposed Action regarding wilder- ness conflicts with ORVs, consider the analysis in the Moquith Mountain WSA. About 75 percent of the WSA is open to ORV use. Even though it appears this WSA has adequate size, naturalness, solitude, and lack of mineral resource conflicts similar to WSAs included in the Proposed Action, the conflict with ORV use appears to be a factor in recommending that Moquith Mountain not be used as wilderness. BLM conducts limited management of ORVs in Utah. We recommend that additional consideration be given to ORV controls as deemed appropriate by BLM and that this be conducted in the context of an updated RMP/MFP process and subsequent concurrent wilderness study. 2.24 RESPONSE: See the responses to General Comments 2.26 and 3.4 for additional information on the relationship of the wilderness study to the BLM planning system. In summary, the BLM wilderness study conforms to the Category 3 planning amend- ment option outlined in the Wilderness Study Policy (USDI, BLM, 1982a). As noted in the comment, BLM could not follow the procedure suggested and meet the 1991 deadline. The rationale for BLM's Proposed Action for the Moquith Mountain and other WSAs is summarized in Appendix 1 1 . 2.25 COMMENT: The Draft EIS contains too much to comprehend and is larger than allowed under CEQ guidelines for preparation of EISs. [Environmental Pro- tection Agency and Allex Morris] a. The CEQ regulations for preparation of EISs suggest that, for proposals of unusual scope or com- plexity, there should be a page limit of less than 300 pages (40 CFR 1502.7). These regulations indicate that, when there is potentially a very large number of alternatives possible, a full spectrum of alterna- tives needs to be analyzed and compared in the EIS. Therefore, a shorter RMP/EIS document, perhaps tiered to this EIS, could aid in comprehension and allow BLM to consider current information, perhaps resulting in site-specific refinements to the Proposed Action. b. I have completed the complete six volume study proposal, and it is just too much at once. Scrap the whole thing and come back at us with one parcel at a time so we can intelligently assess each location one at a time, and we can better work with you on the question. 2.25 RESPONSE: The Utah BLM Statewide Wilder- ness EIS is organized into volumes that contain individ- ual analyses of each of the 83 WSAs. Each WSA analysis is designed to be an independent EIS that can be reviewed individually. The CEQ guidelines state that, for proposals of unusual scope or complexity, an EIS shall "normally" be less than 300 pages. Size is not a hard-and-fast rule for EISs. Taken individ- ually, Volume I and the individual analyses each con- tain fewer than 300 pages. GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS Because the designation of WSAs as wilderness would have a cumulative effect, it is important to analyze the Statewide impacts of designating various combinations of WSAs. Volume I provides the State- wide overview of wilderness designation for BLM's WSAs. The individual WSA analyses are as site specific to the conditions within each WSA as possible without firm project or activity proposals. The No Action/No Wilderness Alternative is based on management pre- scribed in existing land use plans. Shorter RMP/EIS documents would not add to the specificity of the anal- ysis. A full spectrum of reasonable alternatives, rang- ing from No Action/No Wilderness to All Wilderness, has been analyzed. 2.26 COMMENT: The Statewide EIS violates BLM's wilderness study guidelines. [Utah Wilderness Coali- tion] a. During scoping, we pointed out that BLM has violated the agency's study policy by not integrating the wilderness study into land-use planning efforts. We asked, "How will BLM meet the planning require- ments stated in the current study policy and planning regulations?" BLM's Draft EIS Response (No. 450) is that, "Wilderness generally would be consistent with some features of the multiple-use concept reflected in most county plans since many resource uses (such as livestock grazing) would continue; however, wilder- ness designation also would conflict with these plans because restrictive conditions would be placed on all new development activities (minerals, rights-of- way, vehicle access, etc.) not covered by prior existing rights. If State land were exchanged as requested by the State, designation would not conflict with the policy of the State of Utah." The agency response is insufficient. The Wilder- ness Study Policy requires that wilderness recom- mendations evolve from the planning process. The BLM response does not describe how the agency is meeting or intends to meet the requirements of the study regulations. We believe that BLM is not meeting the regulations; that is clear from the example of the San Juan RMP. BLM has issued the Draft RMP for the San Juan Resource Area, one of the most critical in the State of Utah for its wilderness, archaeological, and other resources. The deadline for comments on the Draft RMP is virtually the same as for the Draft EIS. Obviously, this raises serious questions as to the ability of the public to comment on two such large and important documents at the same time. But, beyond that, it suggests that the two documents were pre- pared on separate tracks with no coordination. How can wilderness recommendations flow from the agen- cy's land use planning processes when the land use plan and the wilderness study are underway simultan- eously-and in apparent isolation from one another? We request that a more rigorous analysis be made of potential land use planning conflicts for areas near WSAs targeted for potential population growth or industrial development. b. During scoping, we expressed concern that the Utah BLM has lumped Utah wilderness study into a Statewide EIS. BLM's study policy allows such an aggregation, but only in one of four specific situa- tions. None of the four exists in Utah. BLM's deviation from the study policy is thus not justified. What au- thority does BLM have to deviate from established agency policy? BLM's EIS response to the concern No. 517 is that, "BLM’s Wilderness Study Policy (Federal Regis- ter Notice, page 5112, February 3, 1982) states that an EIS could cover a group of WSAs being studied together. There was no limit placed on the number of WSAs that may be studied together. BLM in Oregon and New Mexico is also conducting a Statewide wilder- ness review. The Utah BLM Statewide approach was authorized by the BLM Director at the request of Utah Governor Matheson and several members of the Utah Congressional delegation." The Wilderness Study Policy (Federal Register Vol. 47, No. 23, page 5111) sets out the require- ments that apply: "Use of such broad scope studies may be appropriate in the following situations: (a) when a WSA overlaps the boundaries of a State, dis- trict resource area, or planning area; (b) when oppor- tunities exist for joint studies with other Federal agencies; (c) when the study schedules for WSAs in neighboring planning areas coincide; and (d) when Category 3 amendments are utilized. "Category 3 amendments could provide more utility when combining amendments for WSAs with similar characteristics, or small numbers or acre- age." While the situations listed allow some grouping of WSAs for study, none allows a Statewide EIS. We GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS request that a complete explanation of the above con- cern be presented in the Final EIS, including amend- ments of regulations and legal authority. The wilderness study process is to be performed as part of the existing BLM land use planning system. The BLM multiple resource management planning system is described in the Federal regulations, 43 CFR 1601. The Wilderness Study Policy describes the use of the planning regulations: "The Wilderness Study Policy and planning cri- teria specify factors and quality standards to be addressed through the planning process in determining whether an area is suitable for preservation as wil- derness or more suitable for other uses. The wilder- ness planning criteria and quality standards will be applied in the planning process, along with guidance already issued for other resource programs, to deter- mine the most appropriate alternative for use of the land under study. Wilderness studies undertaken by the BLM will be conducted in accordance with BLM planning regula- tions (43 CFR 1601)." While BLM has used these policies correctly to support the wilderness suitability of lands under study, the agency has also misused these same policies to exclude other lands from potential desig- nation. BLM in Utah has chosen to separate the wilder- ness study from the land use planning process. The Draft EIS states: "All WSAs are included in approved BLM MFPs or RMPs; however, some plans are old. BLM is currently working on several RMPs that will be completed in the near future. BLM plans normally do not specific- ally address wilderness designations. Rather, they define how WSAs would be managed if not designated wilderness by Congress." This directly violates the requirements of the Wil- derness Study Policy. During the wilderness study process, numerous RMPs have been produced and more are in process now. Each of these plans deferr- ed the recommendation of wilderness suitability to the Utah BLM Statewide Utah Wilderness Draft EIS. The result is a kind of land management shell game. BLM chose a Statewide analysis for political reasons to accelerate the review process. It did so in violation of the Wilderness Study Policy. Besides ad- herence to Departmental policy, there are other im- portant reasons for wilderness study to be part of land use planning. The planning process is meant to be comprehensive. It develops issues, criteria, alterna- tives, and decisions on a resource area. A BLM re- source area occupies between 1 and 3 million acres. Equal planning consideration is given to lands under wilderness study and other BLM lands within the resource area. The current wilderness study focuses on lands under wilderness study and ignores balanced multiple-use with the remainder of the public lands. With BLM resources scarce, BLM has diverted resources from the land use planning system to per- form a Statewide wilderness study. As a result, the plans now in progress have suffered. Inventories are foregone, comprehensive analysis set aside, and wil- derness recommendations made without reference to their appropriate context, the public lands as a whole. The planning process requires BLM to give priority to the designation of areas of critical environmental concern. That has been lost in the present system. The process of inventory and recommendation highlights many values that also are important in mak- ing wilderness recommendations. Those benefits, too, are lost in the present system. Planning also designates areas unsuitable for sur- face mining. Thus, comprehensive land use planning might well find some coal lands-which BLM has used to recommend against wilderness-unsuitable for surface mining and so never to be developed. That in- formation, if available during the wilderness study process, would remove conflicts. As it stands, though, it is entirely possible (and maybe even like- ly) that coal that can never be developed stands as a barrier to the designation of pristine lands as wilder- ness. Land use planning analyzes the ability of all lands within an area, not just wilderness lands, to meet commodity production needs. The wilderness Draft EIS limits consideration to lands under wilderness study. The plan develops decision criteria for other resources, as well as criteria for making wilderness recommendations. The Statewide Draft EIS does not have criteria for identifying and asserting the exis- tence of conflicts with wilderness designation. With- out these criteria, it is impossible to form an objec- GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS tive judgment regarding development vs. wilderness protection. The planning system lists requirements for the inventory of resource values. The agency must pre- pare a situation analysis report during the planning process that responds to all the significant issues identified in the planning process. This analysis looks at opportunities to meet goals and objectives, consid- ers resource demand forecasts, and estimates the sustainable level of various commodities and services available in the resource area. The Statewide Draft EIS fails to perform this kind of analysis. As a result, the wilderness study lands alone are unfairly evalu- ated by this Draft EIS for their ability to support com- modity production. Notwithstanding whether the Utah BLM Director can alter the Wilderness Study Policy, we have no indication that the change in policy was done in a manner that adequately notified the public and gave the public the opportunity to comment on the change from the BLM Wilderness Study Policy to a Statewide Draft EIS. We are unaware of whether the change in policy has been done in a manner that is procedur- al^ adequate for purposes of giving the public an opportunity to be aware of, and comment on, such a proposed change. We assert that the Utah BLM Statewide Wilder- ness Draft EIS has been improperly prepared and needs to be rewritten in accordance with the BLM Wilderness Study Policy and its planning require- ments. 2.26 RESPONSE: The BLM Draft EIS Response 450 cited in this comment was not intended to answer the question posed. Comment 450 in the Draft EIS asked if wilderness designation would be consistent with local and State land use planning, not if the BLM wilderness EIS was prepared in concert with the preparation of other BLM land use plans. Draft EIS Response 517 does respond to this comment. "An amendment shall be initiated by ... a proposed action that might result in a change in the scope of resource uses, or a change in the terms, conditions, and decisions of the approved plan (43 CFR 1610.5). Considerable public involvement was solicited and analyzed in the wilderness study pro- cess and preparation of the EIS" (Volume I, Chapters 1 and 5). Existing BLM plans may be amended by a Statewide EIS, as Category 3 amendments (Wilder- ness Study Policy, Chapter III. A. 3, page 5110, Federal Register. February 3, 1982). In Category 3 amendments, the proposal considered through the amendment, if implemented, would have significant environmental impact: "An EIS is required as part of the additional analysis . . . (and) one or more plans may be involved" (Bureau Manual 1617.42C). Cate- gory 3 plan amendments have been made through recent EISs concerning tar sand, oil shale, and coal leasing in Utah. Even though the Category 3 process is used, it is important to note that site-specific anal- yses of WSAs have been included in the Statewide EIS to ensure that the analysis of each area is at least as specific and detailed as information included in RMPs. The Statewide Wilderness EIS serves to amend plans in areas containing WSAs. The BLM RMPs address WSAs in the event they are not designated wilderness (e.g., the No Action/No Wilderness Alternative of the wilderness EIS) and are comprehensive, multiple-use plans. The RMPs are not prepared in isolation of the wilderness EIS. The description of the No Action/No Wilderness Alternative is based on the MFPs and RMPs. In addition, the EIS addresses the planning criteria and quality standards. For RMPs to reiterate the Utah BLM Statewide Wilderness Draft EIS would be redundant and unnecessary. In addition, the BLM land use plans are regularly updated. The full spec- trum of future planning revisions could never be con- sidered at one point in time. The Statewide EIS also meets requirements of 40 CFR 1500, such as reducing paperwork (1 500.4[i]), addressing broad Federal actions ( 1 502.4[b]), and tiering (1508.20). BLM's budget, workload, and per- sonnel resources do not permit completion of land use plans for all public lands in Utah by 1991, at which time the BLM wilderness process is to be completed. The public was notified of BLM's intention to pre- pare a Statewide EIS in a series of Federal Register notices beginning in 1981. Federal Register Volume 48, No. 239, Monday, December 12, 1983, announc- ed the public comment period for site-specific WSA analyses and described the Statewide approach. Federal Register Volume 49, No. 10, Monday, Janu- ary 16, 1984, contained a public notice of intent to prepare the Statewide EIS. Also, see General Comment Responses 2.24 and 3.4 for additional information on the relationship of the wilderness study and BLM's RMP process. GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS 2.27 COMMENT: BLM should consider a program- matic wilderness EIS. [Environmental Protection Agen- cy] In order to improve upon integrated multiple resource planning and provide a document of suffi- cient brevity to aid in public understanding, BLM should consider a programmatic wilderness EIS. 2.27 RESPONSE: It is not clear how a program- matic EIS would differ from the Statewide EIS, of which part of the purpose is to aid in planning and providing information (Volume I, Chapter 1). Land use planning is addressed as it pertains to WSAs through Category 3 amendments, as specified in the Wilder- ness Study Policy (Chapter III, Section A3, page 5110, Federal Register. February 3, 1982). The Statewide analysis (Volume I) is a programmatic EIS based on specific alternatives and analysis included in the site-specific analyses (Volumes II through VI). 2.28 COMMENT: BLM did not consult with the rec- reational rockhounds. [Rocky Mountain Federation of Mineralogical Societies] Although 110 different organizations were listed as providers of coordination and consultation in your studies, none of these seems to be representative of the recreational earth science hobbyist. 2.28 RESPONSE: The agencies, officials, and organizations listed in Chapter 5 of the Draft EIS are those that participated in scoping or that BLM is required to consult. The Utah Gem and Mineral Soci- ety was and is listed. In response to this comment, the Final EIS notes that the Rocky Mountain Federation of Minerals should have been added to this list. 2.29 COMMENT: The Draft EIS demonstrates a lack of effort on BLM’s part and the EIS should be post- poned. [Michael Robinson] It has become obvious to me in reviewing BLM's wilderness proposal, as put forward in the Draft EIS, that it is, at best, a half-hearted and inadequate effort. Admittedly, when dealing with a challenge of this magnitude, BLM might well have found itself hard pressed, especially when faced with the pressures for development that exist locally in Utah. BLM has chosen to make a dispirited minimal attempt to com- ply with the letter, rather than the spirit, of their legal mandate. The Draft EIS is inadequately research- ed and documented. Congress will lack an adequate basis upon which to make sound policy recommenda- tions and decisions. Postpone the EIS until BLM can build an adequate data base. 2.29 RESPONSE: The Utah BLM Statewide Wilder- ness EIS represents a good faith effort on the part of BLM to use the scoping process outlined in the CEQ regulations for implementation of NEPA to identify issues and use the best available information in ana- lyzing the effects of designation or nondesignation of WSAs. Where information is lacking, the EIS points out the assumptions made and their relevance to the analysis. Because of the magnitude of the wilderness review in Utah, the mandated time frames for report- ing wilderness recommendations, and the fact that many of the effects of wilderness management will be realized so far into the future, postponement of the EIS is not a reasonable course of action. 2.30 COMMENT: Why wasn't the Navajo Nation re- quested to review the EIS? [Permits West] 2.30 RESPONSE: The Navajo tribe did receive the Draft EIS but was inadvertently left off the list of tribal governments. Their comments are responded to and the omission has been identified in the Final EIS. 2.31 COMMENT: BLM's time frame for investi- gating public comments is too short. [Utah Wilderness Coalition, et al.] Page 16 - If the "Statewide Preliminary Final EIS" is "scheduled for completion in early 1987," then it is obvious that BLM does not intend to investi- gate the issues and problems brought out in public comments. In order for BLM to do an honest job of re- viewing the comments, at least a year would be neces- sary. 2.31 RESPONSE: The schedule for completion of the Preliminary Final EIS was altered. The Final EIS reflects this change. A public comment analysis was completed on the Draft EIS, and BLM has studied the issues and problems identified by the public. 2.32 COMMENT: The Draft EIS is totally inadequate and should be reissued as a draft. [Brad Weaver, Utah Wilderness Coalition, Owen Severance, Emery Coun- ty, et al.] GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS a. Unfortunately, the Draft EIS is an inadequate tool for determining the suitability of public lands for protection from human disturbance. Public comments have indicated that it lacks sufficient credibility on either side of the issue. Environmentalists and devel- opers both claim that it is biased against them. The descriptions of alternatives are pitifully redundant. I'm afraid the Draft EIS will never be a best seller! The number of alternatives described does not approach the number of more viable alternatives that exist. Much of the information contained in the Draft EIS is subjective, unreliable, unrealistically general, or reflective of current conditions that are in a con- stant state of change. Visual resource classifications can be expected to have extremely low consistency because of the subjectivity and variability of people's perceptions of scenic beauty. These ratings are, in fact, opinions disguised as data. A native of Kansas visiting Utah for the first time, for example, might very well rate the entire State Class A. Recreational use estimates are likely to be very conservative. Visitors who use obscure trailheads or who neglect to sign registers or obtain permits are not counted. Descriptions of recreational opportunities for WSAs are also under-rated. Recreational and other uses for WSAs are limited primarily by the creativity and fortitude of users. Estimated amounts of recoverable mineral and energy resources and associated surface disturbances are based on data compiled by SAI that is likely to be outmoded and, therefore, overly con- servative. Estimates of recoverability and associated disturbances based on existing technology are also likely to become rapidly outmoded. The economic value of mineral and energy resources that may be found in WSAs is subject to rapid and dramatic change depending on supply and demand. Because of the fail- ings, shortcomings, biases, and inadequacies of the Draft EIS demonstrated by the public comments, we believe that the Utah BLM Statewide Wilderness Draft EIS fails to fulfill requirements of NEPA. We bejjeve that, pursuant to 40 CFR 1402.9, BLM is required to issue a revised Draft EIS for public comment. b. The existing document is so riddled with error that it defies meaningful analysis and otherwise fails to meet the agency’s obligations under NEPA. We realize that the preparation of a revised Draft EIS would entail some costs and some delays, but we believe it is preferable to letting the present Draft EIS stand as the principal analysis of the value of Utah’s wildlands. If NEPA is merely a bothersome technicality to be met before a Federal agency does what it has already decided to do, then even the most perfunctory and superficial analyses is probably suf- ficient. But if NEPA is to be what the Congress meant it to be, a sound analytical tool by which Federal de- cisionmakers, the Congress, and the public may know the alternatives to proposed Federal actions and the consequences of each, a different standard is called for. The Utah Draft EIS falls pitifully short of such a standard. We have scrutinized the Draft EIS as ex- haustively as possible but are not confident that we have uncovered all, or even most, of the document's faulty premises, erroneous assumptions, shoddy analysis, or outright anti-wilderness biases. c. The Draft EIS is a critical document. It pro- vides the public’s only chance to examine BLM's logic for wilderness designation for the most spectacular wildland in the country. For BLM to proceed on the basis of this document would be to severely prejudice the eventual decisions as to which areas will be recommended to Congress for wilderness designation. BLM should no more be the advocate for wilderness preservation than for unbridled development. It should be unbiased, thorough, and rigorous in its anal- ysis. It has not been. d. Considering the cost to taxpayers and assuming a professional and well-researched treatment, this document is a grave and embarrassing disappointment and an insult to any intelligent, thinking reader. It includes numerous and glaring inconsistencies and con- tradictions, plus a very obviously subjective approach overall, much of which seems influenced by small but politically or economically powerful fac- tions. The text is unnecessarily lengthy, largely due to repetition, poor composition, and poor organiza- tion. The meager 6 months given for citizens to digest, research, and analyze such an enormous vol- ume of material is totally inadequate. A full year would be more appropriate and, with the number of mistakes and omissions, the whole thing should be rewritten (again as a DRAFT) and again submitted for public comment with ample time allowed. e. I am very happy that the public won't be allowed to review the Preliminary Final EIS to see if BLM has investigated the improprieties in their earlier work and made revisions in the data and recommendations presented in the Draft EIS. Since the public will be excluded after the Draft EIS stage, the only proper course of action for BLM to take is to reissue the Draft EIS in a revised form that is consistent throughout with accurate data and unbiased wilderness proposals. The only BLM employees that GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS can be proud of the Draft EIS are those who managed to speak in accurate descriptions of wilderness values in a few of the WSAs, in spite of the opposition of their supervisors. When the wilderness study process started I was hoping for an honest debate on wilderness but, unfortunately, the dishonest work done so far by BLM precludes any possibility of an honest discussion of the issues. f. Time and time again, WSA analyses describe a given area as outstanding wilderness, yet the WSAs are either cut apart or dropped entirely. Such intern- al inconsistencies call into question the entire Draft EIS. In every WSA I have visited, I find the corre- sponding Draft EIS chapter full of lies. Many, indeed, do not sound as if they were written by a person who had visited the spot, much less carefully studied it. The entire Draft EIS needs to be rewritten by experts from outside the agency such as the Utah Wilderness Coalition. Those who have some knowledge of the San Rafael area feel it merits national park status as well as the Sids Mountain WSA, Mexican Mountain WSA, The Wedge, Buckhorn Draw, and along the San Rafael River. 2.32 RESPONSE: As stated in the comments, the problems encountered in analyzing the effects of wil- derness designation or nondesignation stem from sub- jectivity in rating various aspects of wilderness, the uncertainties of future demand for resources, etc. Nevertheless, delay of the wilderness review pro- cess to produce a supplemental Draft EIS would not solve any of these inherent problems. According to the CEQ guidelines for implemen- tation of NEPA, it is proper for BLM to prepare a Final EIS after responding to public comment by modifying or adding alternatives, improving the anal- yses, making factual corrections, or explaining why comments do not warrant further agency response. These steps have been taken and, in BLM's judgment, an additional Draft EIS is not necessary. 2.33 COMMENT: Exclusion of a WSA from further consideration before the U.S. Geological Survey (USGS) and Bureau of Mines (USBM) mineral reports are complete is a violation of BLM wilderness regula- tions. [Roy Young, et al.J 2.33 RESPONSE: The following response summarizes the Wilderness Study Policy (Federal Register. Volume 47, No. 23, Wednesday, February 3, 1982a). At the conclusion of the planning and envi- ronmental work, Wilderness Study Reports (WSRs) will be prepared. Among other things, these reports will contain BLM's wilderness recommen-dations. The study reports will draw from several elements of the wilderness review process, including the planning documents, the Final EIS, and the results of public participation. When required, the USGS and USBM mineral survey reports will be attached to the WSRs prior to review by the Assistant Secretary of the Interior. In those cases where both suitable and unsuit- able recommendations are made, the WSRs will con- tain final recommendations and rationale for the un- suitable areas only. All other areas will be labeled as preliminarily suitable, awaiting the results of the USGS and USBM mineral surveys. Final recommenda- tions and rationale for the preliminary suitable areas will be inserted in the WSRs only after consideration of the mineral survey reports. The results of the mineral survey reports will also be summarized and inserted in the original WSRs. If the mineral reports provide substantial amounts of new information, addi- tional NEPA review may be required. Also see the response to General Comment 8.3. 2.34 COMMENT: A decision on wilderness should not be made in the tar sand areas until a decision has been made on the lease conversion applications. [National Park Service] 2.34 RESPONSE: The decisions on wilderness desig- nation and combined hydrocarbon lease applications in STSAs are two separate actions based on two sepa- rate laws. One action is not dependent on the other. Assumptions made for analysis purposes in the wilder- ness EIS are not decisions for tar sand conversions. It should also be noted that any combined hydrocarbon lease located in a WSA would contain a wilderness protection stipulation. In summary, this stipulation notes that, in accepting a combined hydrocarbon lease in a WSA, the lessee acknowledges that the lands are being studied for their wilderness potential and that exploration or production activities not in conformity with Section 603 of FLPMA may never be permitted. Further, activities will be permitted under the lease only as long as BLM determines that they will not impair wilderness suitability, unless Congress has decided not to designate the WSA involved in the lease as wilderness. The stipulation defines the nonimpair- ment criteria. If the WSA were to be designated wilderness, the nonimpairment stipulation would re- main in force. If the WSA were not designated as wil- derness, the stipulation would not be necessary. Therefore, BLM believes that it is not necessary to 20 GENERAL COMMENTS AND RESPONSES SECTION 2: WILDERNESS REVIEW PROCESS delay wilderness designation in STSAs until a decision is made on the hydrocarbon lease conversion applica- tions. 21 ' GENERAL COMMENTS AND RESPONSES - SECTION 3 INVENTORY AND ALTERNATIVES INDEX 3.1 The EIS is inadequate because it doesn't analyze designation of all lands that qualify for wilderness study or it analyzes areas that don't qualify, (p. 2) 3.2 The EIS should provide a chronology of each WSA. (p. 7) 3.3 A cost benefit study is needed for each alter- native. (p. 7) 3.4 The wilderness analysis should be based on ex- pedited Resource Management Plans (RMPs). (p. 7) 3.5 BLM failed to provide rationale for alternatives or the alternatives are not consistent with the stated criteria, (p. 8) 3.6 The range of alternatives is incomplete, (p. 9) 3.7 The EIS should analyze citizen alternatives, (p. 11) 3.8 Chapters 3 and 4 should present information on the alternatives in comparative form. (p. 13) 3.9 The descriptions of the alternatives should be more specific, (p. 13) 3.10 The standard management practices should be better explained for each alternative, (p. 13) 3.11 Errors in the Manageability Alternative should be corrected, (p. 14) 3.12 BLM's alternatives are not large enough to pre- serve ecological diversity, (p. 15) 3.13 BLM has not considered geographic distribution in formulation of the alternatives, (p. 16) 3.14 The BLM Proposed Action Alternative is based on BLM's arbitrary and preconceived notion of what should be recommended, (p. 18) 3.15 BLM should analyze a multiple-use alternative. (p. 19) 3.16 A protection, but not wilderness, alternative should be analyzed, (p. 19) 3.17 Statewide consistency is needed, (p. 20) 3.18 Not all BLM WSAs are included in the alterna- tives. (p. 21) 3.19 The Large and Small Cluster Concept Alterna- tives should be redefined, (p. 22) 3.20 The Highest Quality Alternative has significant problems, (p. 25) 3.21 The All Wilderness Alternative is misnamed, (p. 26) 3.22 Why have all of the areas admitted by BLM to be of the highest quality wilderness not been included in the Proposed Action? (p. 26) 3.23 The BLM alternatives should complement inter- agency management, (p. 27) 3.24 The EIS should include and analyze a land trans- fer alternative, (p. 27) 3.25 The size benefits of designating adjacent areas should be considered in development of alternatives. (p. 28) 3.26 The water project exception policy should be omitted in the description of the alternatives, (p. 28) 3.27 The description of predator control in the alter- natives is in error, (p. 29) 3.28 The House Range Complex should be included in the alternatives, (p. 29) 3.29 BLM should analyze and propose the Book Cliffs WSAs as a roadless region, (p. 29) 3.30 The San Rafael Swell should be held under wilder- ness study protection until national park status can be carefully analyzed, (p. 30) 3.31 The Lost Spring Canyon WSA should be included in an Arches/Westwater/Dolores Triangle Ecosys- tem. (p. 30) 1 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES 3.32 The Burr Trail setback is unnecessary, (p. 30) 3.33 The acreage in the WSAs should be recalculated to delete boundary set-backs for adjacent roads and cherry-stems, (p. 31) 3.34 The EIS discussion of State lands is in error, (p. 31) 3.35 The relationship of wilderness alternatives to private land should be clarified, (p. 31) 3.36 Outstanding wilderness characteristics should not be criteria for partial alternatives, (p. 32) 3.37 The description of the alternatives and analysis should recognize the potential of future technology and alternatives, (p. 32) 3.38 A description of mitigation is needed for nondes- ignated parts of alternatives, (p. 33) 3.39 The BLM Proposed Action Alternative is de- signed around a strong commodity production bias. (p. 33) 3.40 The Zion National Park areas should be excluded from the wilderness alternatives, (p. 35) 3.41 The White River area should be included, (p. 35) 3.42 The U.S. Air Force recommendations should be included in the Final EIS. (p. 36) 3.43 The EIS should explain how WSA and alternative boundaries were established, (p. 36) COMMENTS AND RESPONSES 3.1 COMMENT: The EIS is inadequate because it doesn't analyze designation of all lands that qualify for wilderness study or it analyzes areas that don't qualify. [U.S. Environmental Protection Agency, Utah Counties, Sierra Club, Utah Wilderness Association, Utah Wilderness Coalition, Valerie Cohen, Tim Graham, Kim Jennyson, D.C. Kennell, Kevin O'Brien, et al.] a. Given the massiveness of the document, spe- cific comments are almost impossible to make. The disturbing aspect of BLM's wilderness recommenda- tions are their incomplete nature, which leaves many fine roadless areas out of consideration. As a citizen, I should have the opportunity to comment on any and all roadless public lands, not just the ones BLM has selected. In general, the recommendations made are worthy of wilderness; the areas left out are often worthy also. It should be possible to comment on them all, and it's a shame that the public has been left out of this process. b. BLM should establish WSAs, conduct studies, and recommend wilderness designation for the follow- ing areas. Specific comments for each are provided. Arch Canyon Beaver Creek/Tower Dolores River Beaver Dam Wash Black Ridge Box Canyon Bull Frog Creek Cove Point Cedar Mountain (San Rafael) Colt Mesa Coyote Creek Comb Ridge Dance Hall Rock Docs Pass Dog Water Creek Diamond Breaks Dugway Mountains Duma Point East of Bryce Fifty Mile Bench Fort Knocker Canyon Forty Mile Gulch Goldbar Canyon Goose Necks (North and South) Fisher Towers Granite Creek Gravel and Long Canyon Harmony Flats Harts Point Hatch Wash Hell Canyon Hondu Country Horse Spring Canyon Hunter Canyon Jones Bench Kanab Creek (Upper Part) Labyrinth Canyon Lamp Stand Limestone Cliffs Little Egypt Little Goose Creek Moonshine Draw Moroni Slopes Mussentuchit Badlands Newfoundland Mountains Nipple Bench Nokai Dome Notom Bench Nutter's Hole Ragged Mountain Red Desert Roaring Canyon Shaffer Canyon Sheep Canyon Shunesburg Silver Island Mountains Smokey Hollow Spring Canyon Point Squaw and Papoose Canyon Squaw and Willis Creek Upper Muddy Creek Wah Wah Mountains (Central) White Canyon White Rock Range White River Wild Horse Mesa c. The inventory process in Utah was improperly done and has biased the entire wilderness study pro- cess in Utah. BLM has the authority to reinventory areas that were improperly inventoried. d. Outstanding opportunities for solitude have been too narrowly defined for BLM landscapes. The elements contributing to solitude are unique in each WSA. Basing the lack of solitude on outside sights and sounds and on topography and vegetative screening is wrong. BLM apparently borrowed its screening cri- teria from the FS, which manages quite different land- scapes. 2 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES e. Volume I, Page 94: I question your application of solitude in your analysis. Solitude, "the state of being alone or remote," can be a state of mind as well as place. It is possible to experience solitude without complete topographic or vegetative screening. By using such a narrow definition, you are denying the existence of solitude in many WSAs which have ex- cellent capability for solitude. f. One of the major shortcomings of the entire BLM review process is in the application of solitude criteria. It does not take 200-foot cliffs and canyon walls to screen one 6-foot person from another. An area that is remote and large, even if relatively flat, offers incredible opportunities for solitude because there are few people there. A type of terrain that you seem to continually reject on this basis is slickrock domes and rolling fossil dunes such as are found in Fiddler Butte, Scorpion, Escalante Canyon, and other WSAs. This country is very unique and extremely beautiful and wild and should be preserved. The lack of vegetation and deep canyons do not preclude soli- tude. How many people did your field workers see dur- ing their inventory of these slickrock areas? g. Topographic or vegetative screening is an inap- propriate concept in this landscape. BLM must con- sider that space alone provides solitude. Great hard- wood forests are a thing of the eastern United States; pine forests are a thing of high mountains. BLM apparently borrowed its screening criterion from the FS, which manages quite different landscapes. h. Recognition of diverse elements and their cumu- lative contribution to solitude is utterly lacking in the agency approach to analysis. Each area is made up of unique wilderness qualities and not equatible to a stereotypic norm. To assume that the same elements are at work, in the same measure, contributing to solitude in each area, ignores uniqueness and suggests that only a single area in all the world need be viewed as possessing the ultimate wilderness. Be thankful the world we live in offers more diversity than that. i. We suggest that BLM reevaluate administrative decisions affecting the wilderness inventory since the inventory was completed in 1980. BLM could clarify in the EIS how areas were omitted from the WSA and the procedural options BLM has to revise the inven- tory process regarding the issues of solitude and road- less areas. IBLA has clarified the application of the criterion of solitude by indicating that this be addressed by the "interrelationship of size, screening, configuration, and other factors that influence solitude and roadless areas." In some instances, IBLA determined that BLM has relied heavily on the influence of vegetative screening and had not developed a thorough rationale regarding the declared lack of solitude. If IBLA's clari- fication on this particular criterion were to be applied to all areas under roadless review, additional lands might qualify as WSAs and be able to be considered in the EIS. In this case, the application of the IBLA deci- sion, which was subsequent to the completion of the inventory, may identify additional roadless lands suit- able for wilderness management or multiple uses that do not conflict with wilderness management. j. BLM made several mistakes and violated the wilderness inventory guidelines during both the initial and intensive inventory phases. Administrative appeals have revealed these errors in the Utah BLM inventory. However, IBLA has held that BLM's subjec- tive judgment is entitled to "considerable deference." Therefore, administrative appeals require extensive fieldwork, documentation, and legal assistance. For these reasons, appeals were filed on only 30 of the 195 units in the intensive inventory. Forty-three more inventory units should have been appealed. BLM used several methods to reduce the chance of appeal. For example, BLM did not provide key agency regulations or Organic Act Directive No. 78-61, Change 2, until the opportunity for protest had al- ready passed. A second method was to suppress the rationale for recommendations. The initial inventory covered more than 950 units in just 115 pages, and the maps were on so small of a scale that they were not useable. In order to comment on or protest deci- sions, the public was required to travel to each BLM District to read the District files. The following is an abbreviated list of BLM viola- tions during the initial and intensive inventories: INITIAL INVENTORY VIOLATIONS 1. BLM incorrectly dropped units where valid doubts questioned the BLM recommendation. 2. False assessments were made of solitude and recreation. 3 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES 3. Boundaries didn't follow "roads" and nonpublic lands. 4. BLM used an "overly pure" assessment of natu- ralness. 5. BLM failed to consider boundary adjustments to exclude significant impacts. 6. Boundaries were not adjusted to be immedi- ately next to human impacts. 7. Study units were improperly divided in ways that affected the BLM decision regarding the units. 8. No evidence supports BLM's determination on solitude or opportunity for wilderness activities. INTENSIVE INVENTORY VIOLATIONS 1. Incorrect cherry-stemming of vehicle ways. 2. BLM exaggerated the extent of human impacts and abused boundary adjustments. 3. Development of adjoining agency wilderness studies was incorrectly used by BLM. 4. BLM erroneously alleged that outside sights and sounds impact solitude. 5. BLM confused outstanding solitude with screen- ing. 6. Wilderness values were limited to the values of the "lowest common denominator." 7. Portions of the units were dropped because they lacked solitude. 8. BLM exaggerated the effeci of each WSA's configuration on solitude and recreation. 9. BLM incorrectly found that lack of access made wilderness activities not outstanding. 10. Wilderness activities were rated not out- standing because of lack of water and small unit size. 11. BLM failed to assess the diversity of wilder- ness activities. 12. BLM failed to consider supplemental values in assessing wilderness activities. 13. BLM failed to consider scenic vistas in assess- ment of wilderness activities. 14. BLM deleted areas with wilderness values by using the "Director's Exception" regulations. 15. BLM made an inconsistent assessment of wil- derness activities and solitude. 16. Evidence provided by conservationists was not considered by BLM during the inventory. k. The Draft EIS studiously avoids mentioning that over 900,000 acres omitted from wilderness study by BLM were appealed to the IBLA by environmental groups and, as a result, over 600,000 acres were added to the WSAs. In Volume IV, over 140,000 acres were added to the WSAs after the 1 ,400-page appeal, but only about 30,000 acres of that total are rec- ommended for wilderness designation. This negative bias toward the appealed acreage is not noted or ex- plained in the Draft EIS. A substantial number of inventory units were eli- minated from the wilderness study during the inven- tory phase by incorrectly claiming that these areas had lost their naturalness. No attempt has been made by BLM to correct the information in the files and an honest review of the roadless areas in San Juan County. We are willing to show anyone in BLM those areas that have been improperly dropped from the wilderness review. BLM should do its own investiga- tion of these areas and not leave the job to Congress. l. Does BLM plan to include additional areas other than WSAs discussed in the Draft EIS? Does BLM plan to consider public comment and consider additional areas that should be included in WSAs and addressed in the Final EIS? Does BLM plan to be responsive to the public and address the public desires in the Final EIS? m. We are concerned that BLM did not complete a very thorough on-the-ground review of all the exist- ing and former WSAs mentioned in our comments. We hereby request that BLM publish a complete listing of the particulars for each on-site review in the Final EIS. This list should include: 4 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES 1. Number of BLM employees who participated. 2. Time spent on the site per BLM employee. 3. Date(s) and time(s) of visit. 4. Method of travel at the site (including helicop- ters and airplanes). This will be an important item for determining if BLM did conduct a complete review of the land. We could use the data to evaluate our own experience with a unit against BLM's experience. n. BLM included only 3.2 million acres under the All Wilderness Alternative. We request BLM to iden- tify the criteria and the authority it used to exclude the remainder of the 6.1 million acres from consid- eration in the All Wilderness Alternative. o. Over and over again you see WSA boundaries defined not by physical features, such as ridge lines, drainages, or even roads, but by political boundaries and special lines and such. When researching the reason why, a curious thing is revealed. The bound- aries of WSAs are those of mineral leases. BLM has drawn its WSA boundaries around mineral leases. This is clearly a violation of the spirit and the law of the Wilderness Act. p. BLM keeps claiming that the wilderness pro- cess is not an election and that the number of "votes" will not determine the wilderness recommendation, yet throughout the inventory stage, the number of people in favor or opposed to any invenory unit was used to justify BLM's position. Usually, "no" votes carried much more weight than "yes" votes. The whole wilderness study process has been geared to- ward eliminating as much roadless acreage as possi- ble from wilderness consideration without regard for wilderness values. q. Many inventory units were dropped without adequate examination of their wilderness values. The statements in the "Wilderness Inventory Situation Evaluation" documents will not hold up under any kind of objective review. Apparently, the reason that BLM won’t review these documents is the realization that the work done in the early stages of the wilderness review was badly flawed and biased against wilder- ness designation. Any admission of improper evalua- tions at this time is politically unacceptable. BLM hasn’t even accepted the much less visionary option stated in the "Wilderness Inventory Handbook" (page 14). "d. Possibility of the Area Returning to a Natural Condition. - An inventory unit or portion of an in- ventory unit in which the imprint of man's work is substantially noticeable, but which otherwise contains wilderness characteristics, may be fur- ther considered for designation as a Wilderness Study Area when it is reasonable to expect the im- print of man’s work to return or be returned to a substantially unnoticeable level either by natural processes or by hand labor." This option was not used by BLM anywhere in the wilderness study process. In many inventory units, areas that could be rehabilitated and included in the WSAs were not-one of the many examples of BLM's negative bias toward wilderness designation. r. There was no public participation during the inventory phase. s. To designate de facto wilderness, a wilderness area serves no purpose. To legally designate a tiger a TIGER does nothing to enhance the nature of the beast. These areas are dry, rugged, and inhospitable. In the areas passable to vehicles, roads already exist. All areas are criss-crossed by seismic lines dating back to the 1930s. There are capped wells, flowing wells, reservoirs, and corrals within their boundaries. t. As earlier stated, much of these lands are rugged and impassable, but it is important to note that in those areas where development has been fea- sible, significant human impact has taken place. Dur- ing the last 100 years, these areas have been used for mining, logging, and cattle raising until human intrusions are in evidence in every WSA. Many miles of roads passable by both two- and four-wheel drive vehicles exist. Airstrips necessary for cattle opera- tions, corrals and cabins, reservoirs and fences, drill sites, mines, placers, and capped wells will all be eradicated or rendered unprofitable and useless by wilderness status. Less than half of these structures have been catalogued by the Draft EIS, the tactics of which seem to be to minimize any severe human impact (e.g., calling a road passable by passenger car a "way"). These features will be photographed and included in the committee report to the Congressional Lands Committee. 5 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES u. By definition, wilderness areas should be with- out the imprint of man's works there. By this defini- tion, most of the WSAs in Kane County should not be included in the wilderness evaluation. One WSA has cabins, fences, stock water ponds, and roads. One WSA has 40 miles of roads or vehicular ways, to use the EIS terms, that will be closed to all vehicle tra- vel. Another WSA has 30 miles of road that would be closed. One WSA has a city culinary water system through a portion of the area. One WSA borders High- way U.S. 89, the route between Kanab and Lake Powell. 3.1 RESPONSE: Because of the definition of several terms in the Wilderness Act, the inventory process conducted by BLM has been controversial, and it has been impossible to complete without considerable sub- jectivity. Disagreements over what constitutes outstand- ing, roadless, substantially unnoticeable, definitions of roads, ways, etc., have been the primary issues involved. The wilderness inventory (initial and inten- sive) was conducted by BLM in Utah following the guidelines contained in the Wilderness Inventory Hand- book - Policy, Direction. Procedures, and Guidance for Conducting Wilderness Inventory (September 27, 1978) and subsequent Organic Act Directives per- taining to the inventory. The inventory followed the prescribed procedures, involved the public throughout the process, and has been concluded. Numerous public meetings, public comment periods, and appeal periods were held throughout the inventory process so that citizens could become involved, participate in the in- ventory decisions, raise issues or concerns, and have those issues considered before proceeding to the study phase. The appropriate time to raise questions, issues, or concerns about the inventory was during that phase of the review process. Because the inven- tory phase has been completed according to prescrib- ed policy and guidance, BLM will not revisit inventory issues during this stage (study phase) of the review. This is supported by policy of the Assistant Secre- tary of the Interior issued February 5, 1987. Addi- tional lands may be studied in future BLM land use planning under provisions of Section 202 of FLPMA. As stated in the Wilderness Inventory Handbook (page 12): "Specifically, the size criteria will be satisfied for inventory units in the following situa- tions and circumstances: a. Roadless areas with over 5,000 acres of con- tiguous public lands. State or private lands are not included in making this acreage determination. b. Any roadless island of the public lands of less than 5,000 acres. c. Roadless areas of less than 5,000 acres of con- tiguous public lands where any one of the following apply: 1. They are contiguous with lands managed by another agency which have been formally determined to have wilderness or potential wilderness values; or 2. The public has indicated strong support for study of a particular area of less than 5,000 acres and it is demonstrated that it is clearly and obviously of sufficient size as to make practicable its preser- vation and use in an unimpaired condition, and of a size suitable for wilderness management; or 3. They are contiguous with an area of less than 5,000 acres of other Federal lands administered by an agency with authority to study and preserve wil- derness lands, and the combined total is 5,000 acres or more." Public Law 88-577, September 3, 1964 (Wilder- ness Act) and 94-579, October 21, 1976 (FLPMA) specify that wilderness be undeveloped Federal land. BLM has no authority to study or recommend State or private lands as wilderness. When extensive State or private lands occur which create a very congested and narrow boundary area affecting the wilderness characteristics on surrounding BLM land under inven- tory, the boundary of the unit was adjusted according- ly. Boundaries of WSAs were drawn so as to be inclusive of the required wilderness characteristics and, at the same time, be sensitive to other condi- tions that existed in particular circumstances (e.g., narrow and congested boundaries that would affect wilderness values). In addition to being roadless, an area is to have the following characteristics to be considered for wil- derness: 1. Size. At least 5,000 contiguous roadless acres of public land. 2. Naturalness. The imprint of man’s work must be substantially unnoticeable. 6 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES 3. Either: a. An outstanding opportunity for solitude; or b. An outstanding opportunity for a primitive and unconfined type of recreation. "To qualify for wilderness study identification, an area of public land must be shown to meet BOTH Factors 2 and 3" (Wilderness Inventory Handbook, Page 6). If an area did not contain the required char- acteristics (or factors), it was not identified as a WSA. To include such areas would have violated the intent of Congress and inventory procedures. 3.2 COMMENT: The EIS should provide a chronology of each WSA. [Michael Salamacha, Kim Jennyson, Utah Wilderness Coalition, et al.] a. There is a need to show a chronology and evolu- tion of each WSA from the initial wilderness inven- tory proposals of 1979 to the presently determined WSAs in the Draft EIS. It should be necessary to show the starting acreage and boundary of each WSA and clear reasons why acreage remained or was deleted along the way, so a citizen can then determine if they agree or disagree with BLM. So often hundreds of thousands of acres were deleted for no apparent rea- son. This should be required because of the admitted subjectivity of the process. BLM needs to be more accountable for their actions. 3.2 RESPONSE: See the responses to General Com- ments 2.4 and 3.1. 3.3 COMMENT: A cost benefit study is needed for each alternative. [Utah Mining Association] a. Areas designated as wilderness already burden the citizens of Utah. The burden is evident in higher costs to consumers and lost jobs in industries that can no longer be provided with the raw resources lying within the confines of these limited single-use areas. Careful review should begin again so as to correctly and adequately identify the mineral re- sources and their value lying within the WSAs. Such a review will facilitate the necessary cost benefit analysis as regards further wilderness designations within the State of Utah. 3.3 RESPONSE: BLM does not use cost/benefit anal- ysis as the basis for decision on wilderness pro- grams. BLM does not believe that a cost/benefit anal- ysis or any other comparison based solely on econom- ic considerations can properly portray trade-offs involved. This is because: (1) many of the values re- lated to wilderness are intangible; (2) market condi- tions that affect consumptive resources are highly variable over time; (3) the wilderness study criteria do not lend themselves to cost/benefit interpretation; and (4) the numerous and divergent factors that con- tribute to wilderness considerations would make a cost/benefit analysis unmeaningful. 3.4 COMMENT: The wilderness analysis should be based on expedited RMPs. [Environmental Protection Agency] a. Expedited RMPs should be prepared to provide for more detailed consideration of wilderness alterna- tives on a BLM resource area basis. These then could be grouped to consider WSAs adjacent to the national park land under similar management or grouped toge- ther to form a larger geographical unit. A potential group could be those WSAs near Canyonlands National Park to include the Horseshoe Canyon (North), Horse- shoe Canyon (South), Fiddler Butte, French Spring- Happy Canyon, Little Rockies, Mancos Mesa, Dark Can- yon Complex, Butler Wash, Bridger Jack Mesa, and Indian Creek WSAs. Also, consider the potential group near Desolation Canyon that could include Jack Can- yon, Desolation Canyon, Turtle Canyon, Floy Canyon, Coal Canyon, Spruce Canyon, and Flume Canyon WSAs. 3.4 RESPONSE: The suggestion to include wilder- ness studies in expedited RMPs for the 16 BLM re- source areas in Utah would not provide any advan- tage over the current Statewide effort. The State- wide EIS volumes present five regional groups of WSAs based on geographical considerations. Various Statewide alternatives also reflect groups. Even if expedited RMPs were to be prepared, a new inventory would not be conducted and new lands would not be added to the study; therefore, new alternatives would be limited to the same areas as covered in the Statewide EIS. The preparation of expedited RMPs would not result in significantly more detailed information than is contained in the Statewide EIS. The Statewide study is a land use plan amendment action, as noted in Volume I, Chapter 4. 7 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES Also, see the responses to General Comments 2.24 and 2.26 for a discussion on the relationship of the wilderness review and BLM's planning process. 3.5 COMMENT: BLM failed to provide rationale for alternatives or the alternatives are not consistent with the stated criteria. [Utah Wilderness Associa- tion, Utah Wilderness Coalition, Rodney Greeno, Kim Jennyson, Randolph Jorgen, et al.] a. BLM did not follow the rationale on page 30 in choosing the areas to include in the Proposed Action Alternative. The rationale says: "This alternative includes those areas judged by BLM to be suitable for wilderness designation based on physical character- istics of the WSAs and concern for both wilderness and nonwilderness values, utilizing the wilderness suitability parameters (refer to Chapter I, Wilder- ness Criteria and Standards section). WSAs with no significant conflict with other resources were gener- ally determined suitable even if they had low wilder- ness values." This does seem to be a logically needed alternative for analysis, but BLM did not "generally" include areas it thought had "low wilderness values" even if there was "no significant conflict." In fact, 583,000 acres of such lands were excluded, or 24 percent of all lands that met the rationale for the alternative. Thus, BLM did not consider an alternative which included all lands where wilderness values override conflicts or where there are no conflicts. This is an alternative that should have been analyzed in order to meet NEPA's requirement that the EIS allow comparison of the merits of the other alterna- tives and allow assessment of the agency's Proposed Action. b. BLM's Proposed Action is described in Volume I, Page 19, of the Draft EIS as follows: "(1) utilizes wilderness suitability parameters from BLM's "Wil- derness Study Policy" (USDI, BLM, 1982a); and (2) includes all areas and acres currently judged by BLM to meet the test of suitability; and (3) units may have low wilderness quality but no identified conflicts with other resources." The Draft EIS gives no further explanation. The Draft EIS does not explain how this alternative uses the suitability parameters as compared to any of the other alternatives. BLM sets out no criteria that con- stitute "the test of suitability." BLM must present these criteria and explain their use. Without this ex- planation, BLM's recommendations can only be consid- ered arbitrary. The description of the Proposed Action then says that, "units may have low wilderness quality but no identified conflicts with other resources." This is the only part of the description that gives any hint of the criteria to be used for recommendations. The Proposed Action is not adequately explained. The Draft EIS fails to offer a clear explanation of how BLM determines the wilderness recommendation for a specific area. Without a clear description, BLM's pro- posal appears arbitrary and without rationale. Looking at the areas BLM chose to exclude from the Proposed Action, several inconsistencies appear. BLM does recommend many areas which have no con- flicts as suitable. But without explanation, other areas are deleted--even those that BLM says lack con- flicts. Among these areas are Cheesebox Canyon, Fremont Gorge, Daniels Canyon, most of the Cedar Mountains, Rockwell, and Conger Mountain. If the criteria were applied to these areas, they should appear in the Proposed Action. In each case, BLM failed to state any reason for not recommending wil- derness designation for these areas. c. Very rarely are the reasons given for BLM proposing a Partial or No Action Alternative for a WSA. These reasons should be outlined very clearly. d. The following chart shows some of the WSAs which were dropped by BLM, in whole or in part. The apparent rationale in the individual SSAs for dropping portions or all of these WSAs is largely based upon "not outstanding enough" wilderness characteristics (or in some cases, no apparent reason at all), instead of clearly defined conflicts with minerals or other resources. Volume I of the Draft EIS states the high- est wilderness quality alternative "is not significant- ly different than BLM's Proposed Action (59 percent of the WSA acreage in 58 WSAs) that is studied in detail." This alternative includes several areas not found in BLM's proposal that meet the Proposed Action criteria. If these two alternatives are similar, as BLM states, then the high quality wilderness ex- cluded in BLM's Proposed Action can be included with- out significant impact. In fact, these high quality areas should have few, if any, resource conflicts if the alternatives are indeed similar. The SSAs prove this point by showing resource conflicts are of no sig- nificance in many WSAs which were apparently ex- cluded, in whole or in part, because of those re- sources. 8 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES 0. Mt. Pennell, Mt. Ellen-Blue Hills, Swasey Moun- tain, Howell Peak, Notch Peak, Wah Wah Mountains, Canaan Mountain, Phipps-Death Hollow, Steep Creek, and Scorpion: portions of all of these areas have been deleted from the Proposed Action with only the state- ment given that the intent of the action is to preserve " as wilderness that portion of the WSA with the most outstanding wilderness characteristics." This is a clear example of the "divide-and-conquer" approach BLM has taken throughout this review process, why should we not continue to identify the most out- standing portions of the most outstanding portions until we are left with one quintessential acre, or 1.9 million of 22 million, almost as absurd? Clearly, this is not the intent of Congress nor the desire of the American people, who, I believe, generally prefer to maximize wilderness designation for qualified lands. The lands deleted in these partial alternatives do qualify, are important parts of the entire WSAs, and should be recommended. BLM's arbitrary but pseudo- statistical means for disqualifying these acres should not be making value judgments for us. Some Areas Excluded From The Proposed Action (Whole Or In Part) With Little Or No Conflict WSA Name Acreage Cedar Mountains 50,500 Swasey Mountains* 15,000 Conger Mountain 20,400 King Top 53,044 Wah Wah Mountains* 5,758 Cougar Canyon 15,968 Parunuweap Canyon* 16,700 Canaan Mountain*.* 13,170 Moquith Mountain 14,830 Phipps-Death Hollow* 3,475 Scorpion* 26,264 Mt. Ellen-Blue Hills*.* 16,700 South Horseshoe Canyon* 2,800 Mt. Pennell 74,300 Mt. Hillers* 3,000 Fremont Gorge 2,540 Road Canyon* 6,700 Cheesebox Canyon 15,410 Coal Canyonc 47,670 Spruce Canyon 20,350 Flume Canyon 50,800 Floy Canyon*.* 24,000 Westwater Canyon* 5,160 Daniels Canyon 2.49S Total 507,035 • Partial exclusions. <> Conflicts total 1,200 acres. * Excludes coal acreage on Wildcat Mesa. o Excludes coal acreage In KRCRA. f. In Volume I, page 250, BLM clearly states that it is making value judgments regarding resource tradeoffs, which obviously must be made on the basis of some rationale. Yet, in the same breath, we are ad- vised of their refusal to divulge that rationale, which we are left to "deduce." Why the big secret? It is be- cause BLM knows that their rationale is too vulner- able to withstand honest criticism. 3.5 RESPONSE: The descriptions for all of the Statewide alternatives in Volume I have been revised in response to public comment. The explanation of the Statewide Proposed Action has been expanded, and the rationale for the Proposed Action for each of the individual WSAs is summarized in Appendix 11. Also, see the responses to General Comments 8.1 and 8.2. 3.6 COMMENT: The range of alternatives is incom- plete. [Utah Wilderness Coalition, Tim Graham, Allex Morris, Raymond Wheeler, et al.] a. The Draft EIS offers a range of 1 1 alterna- tives and a comparison of some of the issues and val- ues found in the alternatives. These alternatives include No Wilderness, All Wilderness, Proposed Action, Manageability, Highest Quality, Modified Plan- ning, Commodity Production, Large Cluster Concept, Paramount Wilderness Quality, Regional Represen- tative Areas, and Small Cluster Concept Alterna- tives. Superficially, this appears to be a wide range of options. But examination of the descriptions of the alterna- tives shows that many are similar. The Commodity Production Alternative, Modified Planning Alterna- tive, and the Proposed Action Alternative are all three described in virtually the same manner. There is no clear difference in the written description of what the alternative is and how areas qualify for designation in that alternative. BLM's recommenda- tions in these areas differ marginally but, as we will demonstrate, BLM has not consistently applied the descriptions of the alternatives in making recom- mendations. Two of the alternatives may violate the Wilder- ness Study Policy. The Large and Small Cluster Con- cept Alternatives may make for an interesting discus- sion, but fall far short of constituting reasonable alternatives. The Wilderness Study Policy requires the consideration of several criteria. These alterna- tives require that an area be less than 0.5 mile from an area of 100,000 acres or more of wilderness 9 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES lands. BLM offers no explanation of the reasons for choosing this standard. The choice of the size and distance are arbitrary, and, therefore, not valid tools in making a wilderness recommendation. BLM uses the distance and size criteria to exclude lands from wilderness recommendations. It can be argued that a candidate wilderness area would be a good component for a cluster of wilderness areas be- cause it added an important value or shared common wilderness values. Size and distance are relative to the wilderness values. For example, migrating wild- life could rely upon nearby areas or upon more dis- tant areas, depending upon the species. The fact that the Deep Creek Mountains are not within 0.5 mile of a 100,000-acre wilderness unit should not disqualify them from designation. Outside the cluster concept there are other reasons to desig- nate lands that deserve consideration. BLM can only argue that this area has added importance for desig- nation because it is part of a cluster that would bene- fit from shared wilderness values. b. There are seven alternatives in the wilderness plan. I submit that there are at least three more alter- natives. They may sound radical and ridiculous to you, but they certainly are alternatives that we have options for. One, give back the land that was uncon- stitutionally denied Utah and her citizens. Number two, sell back the land to Utah and her citizens. Let's pay off the national debt. The national parks could be State parks and could be operated by the State just as well as Federal agencies. Or number three, we can support multiple use of land that already should be- long to the people for all of the people. Stop the gerry- mandering and the cherry-stemming and the renaming of roads to ways to further deny access. Go back to Congress and tell them that they made a mistake. The mandate that they came up with in 1976 is not written in stone on Mt. Sinai. The things Congress has done, they can undo. Tell them that we want our land back. c. BLM has identified a No Wilderness Alternative which explicitly promotes the agenda of wilderness opponents. I see no reason why BLM cannot also define an alternative which accurately represents the views of the vast majority of wilderness supporters. During the past 5 years, opinion polls have repeatedly demonstrated that those people who want more des- ignated wilderness in Utah outnumber those who do not want more by a factor of two to one. Such over- whelming public support for wilderness preservation merits equal representation in BLM’s analysis to that given the tiny minority of Utahns and Americans who oppose wilderness designation. d. I recommend the following spectrum of alterna- tives. 1. "All Wilderness" (16-million acre Earth First! proposal). 2. "Paramount Wilderness" (5.1 -million-acre Utah Wilderness Coalition proposal). 3. "Maximum Commercial Development" (3.2 million acres). 4. "No Wilderness." e. The process that should be followed for decid- ing which land should be wilderness and which should not is: 1. The area is roadless .2 1. There are no bona tide roads in the area recommend for non- wilderness uses 2. The area has no resource conflicts .... recommend for wilderness 2. The area has possible resource conflicts 3 3. Resource potential low recommend for wilderness 3. Resource potential high 4 4. Resource development not recommend for wilderness economically profitable 4. Resource development economically . . . 5 profitable 5. Wilderness qualities outstanding recommend for wilderness 5. Wilderness qualities not outstanding recommend for non- wilderness uses Each area should be examined using this key to determine its suitability for wilderness, with the maximum acreage preserved without serious re- source conflicts. I think it is important to emphasize that, just because a resource is present, does not mean that its exploitation will be the best use of the land. This alternative emphasizes wilderness qualities of the land and de-emphasizes the importance of re- sources in these areas. This is a valid and logical approach because of the uniqueness of the lands being GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES considered. This kind of country is found no where else in the world and should be protected as any other rare and beautiful thing. 3.6 RESPONSE: The range of alternatives has been reviewed. Table 4 in Volume I of the Final EIS lists 18 Statewide alternatives suggested and/or considered. The Final EIS contains a detailed analysis of six Statewide alternatives, which cover a suitable range of acreage identified for designation. See Figure 2 in Volume I. The identification and selection of alterna- tives were based on the scoping process, where suggestions were requested from the public. Sugges- tions for various combinations of WSAs were consid- ered and synthesized into the BLM alternatives de- scribed in the Final EIS. This required that BLM add certain assumptions and criteria in order to define the alternatives sufficiently for analysis purposes. It is not intended that all combinations of WSAs be de- scribed; rather, the alternatives analyzed are repre- sentative of the various concepts and differing amounts of wilderness and their resultant impacts. It was clearly stated during scoping that the EIS would address the WSAs as identified in the inventory process, and that the inventory phase had been com- pleted; therefore, comments on the EIS which suggest that the range of alternatives be increased over the 3.2 million acres in WSAs are inconsistent with the study process. The Cluster Concept Alternatives do not violate the Wilderness Study Policy. Further, they are con- sidered reasonable alternatives within the context of NEPA. The concept has been illustrated with a revised alternative, entitled Cluster and Interagency Areas, in the Final EIS. The suggested alternatives to give the Federal land to the State of Utah are not consistent with FLPMA, the Wilderness Act, or the purpose of this EIS. Also, see the responses to General Comments 3.1, 3.7, 3.16, and 3.23. 3.7 COMMENT: The EIS should analyze citizen alter- natives. [Earth First!, Utah Wilderness Coalition, D.C. Kennell, Jay Lepreau, Tom Sewell, et al.] a. The Draft EIS addresses 11 alternatives rang- ing from proposing no additional wilderness to pro- posing 3.2 million acres of wilderness. Several of these alternatives are extremely similar in content. Individuals, public officials, and organizations have proposals ranging from no wilderness, 3.8 million acres, 5.1 million acres, and 16 million acres of wil- derness. How can the EIS meet NEPA requirements if some of the major proposed alternatives are not even covered within the array of alternatives? Why does BLM not include and address the 3.8- million-acre and 5.1 -million-acre alternatives in the Draft EIS? Does BLM plan to seriously consider public com- ment on the Draft EIS? If so, does BLM plan to reeval- uate their alternatives and at least address and dis- cuss proposed viable alternatives? b. The Utah Wilderness Coalition has put together a proposal of 5.1 million acres. We proposed that acre- age be recommended as an alternative in the EIS. BLM said that they are required to consider all reason- able alternatives. This is one of them. It is not an All Wilderness Alternative. We've identified more than 7 million acres of land that qualify in the wilderness study in the State. c. Why did your alternatives fail to give a con- servationists' alternative? Many people support a 5- million-acre wilderness proposal as put forth by the Sierra Club and Southern Utah Wilderness Alliance. Your EIS should include our 5-million-acre alterna- tive. The so-called All Wilderness Alternative in your Draft EIS leaves out many deserving areas. If you have a No Wilderness Alternative on one end, then you must have an All Wilderness Alternative on the other. d. In the middle of last year, the Utah Wilderness Coalition provided BLM its citizens' proposal for Utah BLM wilderness for consideration in the Draft EIS. The Draft EIS fails even to mention that this was received. The Utah Wilderness Coalition's proposal of 5.1 million acres is a reasonable alternative that has al- ready received broad public support. During the public hearings on the Draft EIS, pro-wilderness witnesses greatly outnumbered anti-wilderness witnesses. And among pro-wilderness witnesses, the overwhelming majority spoke in favor of the Utah Wilderness Coali- tion's 5.1 -million-acre proposal. GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES This alternative was developed after years of effort by our many volunteers in the 17 conservation groups that form the coalition. We have literally tra- veled every road and track to investigate human im- pacts. We have flown dozens of hours collecting infor- mation on wilderness values. After the field-work was nearing completion, we spent 6 months in a series of nine Statewide meetings to pool all our infor- mation and develop boundaries. BLM has a set of our working maps. We have pro- vided a list of the estimated acreage we are recom- mending for designation as wilderness. BLM has not disclosed how or whether it has used this informa- tion or if it intends to. The coalition proposal repre- sents lands that qualify for wilderness study and des- ignation under BLM's wilderness inventory and study policy. We have deleted lands with significant human impacts from our proposal. In each of the individual area descriptions, we have presented the wilderness values of the area, the errors BLM made in the inven- tory, the legal requirements for BLM to review new information and revise recommendations, and a rec- ommended alternative that meets the agency's own regulations. For these reasons, our alternative is a reasonable one that merits full and equal considera- tion in the Draft EIS. BLM has not cited any reasons for ignoring our proposal and has never identified the legal authority under which it does so. BLM did not include an analysis of the Utah Wil- derness Coalition's proposal because, it said, it had already evaluated the additional lands involved and found that they lacked wilderness character-istics. Our detailed descriptions of the excluded areas show that every area in the proposal has high wilderness values and should be considered in the Draft EIS. Because the Draft EIS fails to do so, the document's utility for decisionmaking is severely limited. The Draft EIS should be rewritten to include all reasonable alternatives. e. I support the Utah Wilderness Coalition's carefully thoughtout proposal for 5.1 million acres in 142 areas. It deserves analysis and consideration in your Final EIS as one of the alternatives as it has widespread support, is backed up by extensive on-the- ground study, and more accurately represents the so- called All Wilderness Alternative than your 3.2- million-acre All Wilderness Alternative. Note that your No Wilderness Alternative precisely coincides with the position of interest groups on the opposite side of the issue. The conservationists' side deserves equal analysis-they certainly have as good or better record of involvement and study of the issues, documents, and land. As grossly manifest in some of the areas in the intensive inventory (e.g., the Moroni Slopes), the inventory was seriously flawed and many of these areas would qualify for wilderness study if studied more carefully. f. The BLM wilderness issue, especially here in Utah, has already been cut to pieces by this agency. BLM in Utah and in most of the western States is simply giving us for consideration mere pieces of the true potential wilderness that is under their domain. Earth First is proposing that 16 million acres become wilderness, as shown in the following list and on the attached map. Name Acres North Salt Lake Desert 600,000 South Salt Lake Desert 440,000 Deep Creek Range 200,000 House Range 1,000,000 Sevier Lake-King Top 1,000,000 Wah Wah Mountains South 370,000 Beaver Dam Wash 230,000 Moquith Mountains 160,000 Escalante 3,000,000 Death Hollow-Aquarius Plateau 750,000 Clay Hills 180,000 Mt. Ellsworth 180,000 Moki Canyon 250,000 Grand Gulch 200,000 Fish Creek 250,000 Canyonlands 2.500,000 South San Rafael Swell 1,000,000 North San Rafael Swell 700,000 Negro Bill 40,000 Westwater Canyon 230,000 Arches 200,000 Desolation Canyon 2,200,000 Dinosaur 160,000 Little Sahara 130,000 San Juan River 25.000 Total 15,995,000 Rounded 16,000,000 3.7 RESPONSE: The alternatives suggested by the Utah Wilderness Association (3.8 million acres), the Utah Wilderness Coalition (5.1 million acres), and Earth First! (16 million acres) are identified in the Final EIS. See Volume I, Chapter 1, and Appendix 12. These alternatives were considered carefully. How- ever, they are not analyzed in further detail since they are not consistent with the Wilderness Act Cri- teria, or BLM's inventory and wilderness review guidelines. Further, the 16-million-acre alternative GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES was completely impractical. The inventory has been completed and is not being revisited by the EIS, as explained in General Comment Responses 3.1 and 3.6. 3.8 COMMENT: Chapters 3 and 4 should present information on the alternatives in comparative form. [Utah Wilderness Coalition] a. The alternatives section is the heart of the EIS. The information and analysis presented in the Affect- ed Environment and Environmental Consequences sections should present the environmental impacts of the Proposed Action Alternative in comparative form, thus sharply defining the issues and providing the decisionmaker a clear basis for choice among op- tions and the public a clear basis for understanding the choice (40 CFR 1502.14). 3.8 RESPONSE: The Statewide impact summary table in Volume I, Chapter 2, and Table 1 in each of the individual WSA analyses provides information and analysis in comparative form as required by the CEQ guidelines for preparation of EISs. This information focuses on the significant Statewide issues in Volume I and the WSA specific issues in Volumes II through VI. 3.9 COMMENT: The descriptions of the alterna- tives should be more specific. [Composite comment from several sources.] The descriptions of the Proposed Action and other alternatives often do not identify specific actions on which to base the impact analysis. The primary pro- blem is with the lack of descriptions of mineral development activity. 3.9 RESPONSE: Refer to the responses to General Comments 9.12 and 15.20. 3.10 COMMENT: The standard management prac- tices should be better explained for each alternative. [State of Utah, Utah Mining Association, Hardy Redd, et al.] a. Page 199, Appendices: It would be helpful to the general public to include an appendix which explains standard management practices and wilder- ness management policy (similar to the summary found in the Oregon WSA EIS, Volume I, page 17). b. The EIS tacitly admits that there will be an increase in vandalism and suggests that these vandals will be monitored and controlled by helicopters. Will helicopters flying over wilderness areas to monitor vandals increase or decrease the solitude? The EIS does not adequately consider the impacts of the in- creased law enforcement and methods used therein on wilderness values. c. BLM insinuates that pre-FLPMA leases and pre- existing valid mining claims could be developed after wilderness designation. Historically, the application of the IMP prevented operators from exercising any rights under pre- or post-FLPMA leases or upon valid pre-existing mining claims. Pre-FLPMA leases and pre-existing valid mining claims may provide all manner of rights; exercising those rights in or near a wilderness area is often impossible, and BLM should not seriously suggest otherwise by including these rights as part of those resources that can be devel- oped under the various alternatives. 3.10 RESPONSE: Information as requested by the comment was included in Volume I, Appendix 1, Part C in the Draft EIS. It also is included in the Final EIS. Also, see the response to General Comment 1.13 for a discussion on mining claims and leases. 3.11 COMMENT: Errors in the Manageability Alter- native should be corrected. [Sierra Club, Cache Group; Utah Wilderness Association; Charles Bagley; and Randolph Jorgen] a. On page 27 under the discussion of alternative No. 4 it states: "In addressing the concept of manage- ability, it is important to note that the parameters of this alternative relate to legal and physical charac- teristics, not the funding capabilities of BLM to imple- ment wilderness management." What is meant by this sentence? Certainly, it is not the objective of Con- gress to limit its options for choosing wilderness areas according to the current budgets of the various Federal administrative agencies. It should be presum- ed that Congress will wish to look at all wilderness areas first, and then, if necessary, adjust budgets to manage the wilderness areas that it has designated. The Draft EIS should expand considerably on exactly what it is trying to say about the question of "funding capabilities." b. An error in the Statewide Manageability Alter- native needs to be corrected. The Floy Canyon WSA coal is not leased and there are no valid, existing rights that would prevent the area from being man- aged as wilderness. The Manageability Alternative GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES should include the All Wilderness Alternative for Floy Canyon. c. There are a number of areas mentioned in the Draft EIS that BLM denies for wilderness status be- cause of manageability problems. BLM simply says that, if one of these areas is designated as wilder- ness, then they could probably not manage the unit as wilderness. This conclusion is poorly drawn and does not represent the intent of Congress when BLM was directed to study and recommend wilderness candi- dates. If an area has wilderness qualities, then it should be recommended for wilderness designation, regardless of whether or not BLM thinks it can man- age it as such. d. Manageability should not be used as a reason to avoid designating an area as wilderness, as has been done in some instances in the Proposed Action, and especially in defining alternative No. 4, Manageabil- ity. To forego wilderness protection for wildlands be- cause of an expectation that there may be difficulties in maintaining portions of these in pristine quality, is giving up the battle before it has begun and is inexcus- able. It just doesn't make sense. Even if wilderness values are ultimately lost to some extent on portions of these lands due to pre-existing rights, we are still better off to have wilderness designation for these and surrounding lands for the constraints it imposes than to simply throw up our hands and lump them in with the great majority of lands consigned to develop- ment. 3.11 RESPONSE: The comment is correct in observ- ing that wilderness designation should not depend on the current budgets of the land management agencies. The sentence in question explains this by stating that the parameter of the alternative is "not" related to funding capabilities. Manageability is defined as the legal ability of BLM to effectively manage wilderness values in a particular area. For example, BLM may not be able to prevent some uses (such as vehicle access for mining) in a wilderness area because of pre-wilderness rights held by others. Although not unmanageable, it may be administratively difficult and expensive to prevent some uses (such as motor- bikes) because the access and terrain would require constant, numerous patrols or extensive barrier fenc- ing. Administrative and manageability problems are identified in the Final EIS. Since publication of the Draft EIS, many pre-FLPMA leases have been relin- quished and are no longer a manageability problem. Because there are few manageability problems in the WSAs, the Statewide Manageability Alternative has not been included in the Final EIS. Manageability pro- blems are addressed where appropriate in the Wilder- ness Values sections of the individual WSA analyses in Volumes II through VI. The opinions stating that manageability should not be considered are noted. It is national BLM policy that only those areas that can be managed as wilderness in the long term will be recommended as suitable for designation (USDI, BLM, 1981b). The approach used for the WSAs in Utah is consistent with that policy. Also, see the response to General Comment 9.14. 3.12 COMMENT: BLM's alternatives are not large enough to preserve ecological diversity. [Richard Christie] a. The Earth First! proposal reflects the applica- tion of deep ecological and philosophical values to the question of natural preservation in Utah. It is not a BLM public lands wilderness proposal as such. The wilderness designation recommended in the Earth First! proposal includes BLM-administered lands; FS- administered lands which have already been desig- nated wilderness and those which have not; land recommended for wilderness by the NPS but not designated; State lands; and some private in-holdings in public land areas. The Earth First! proposal does not observe the strictures of the Wilderness Act of 1964 (P.L. 88- 577) in that it specifically calls for the rehabilitation of certain roads or otherwise impacted areas into wilderness, and would eliminate grazing of domestic livestock in the wilderness areas proposed. The Earth First! proposal thus broadens the dialogue about what we are and should be thinking about when we contem- plate the designation of wilderness areas as a preser- vation effort by our species and nation. The Earth First! proposal for Utah wilderness arises from the field of thinking and writing by Earth First! about "biological preserves"-large areas rep- resenting each major biome which would be restored as much as possible to their original biological diver- sity and then left to evolve as nature dictates. These areas would, of necessity, have to be large enough to provide for multiple habitats for all the various spe- cies in the "genetic preserve" so that natural cycles of decline and renewal of various plants (e.g., due to forest or range fire) would not eliminate the habitat 1 4 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES as can happen when only one representation of a par- ticular habitat is set apart for preservation. In Utah, Earth First! has alerted us to the fact that we have an opportunity to apply this concept of biological or genetic preserves to the process of wil- derness designation. It is from this perspective that the Earth First! wilderness proposal proceeds. This is why the proposal proposes huge contiguous areas for wilderness preservation, heedless of land ownership or administrative assignments and calls for the extir- pation of human intrusions such as "roads," old air- strips, mining sites, and grazing paraphernalia when these compromise the integrity of a biologically defin- ed area. The Earth First! proposal deliberately ig- nores political and economic factors in order to focus on ecological values to present a proposal that the plants and animals of Utah would have written. You will note that they generously leave the vast major- ity of the State (36.5 million acres, 69.5 percent) for our one species to alter as we see fit, asking only 30.5 percent be left alone for all of them. By ignoring the limitations of the Wilderness Act in defining what may be considered for wilderness, the Earth First! proposal does us the favor of making us re-think the values which designating wilderness serves. At the very least, an examination of the ecological values at issue, in more than homocentric terms, should be done by BLM in revising the Draft EIS for Utah public lands into the Final EIS. The Statewide Wilderness Draft EIS prepared by the Utah BLM is greatly flawed, as a whole, by the use of a very rigid, myopic interpretation of the in- tent of Congress in considering wilderness designa- tion and directing Federal agencies to do inventories and "staff reports" (the EISs and agency recommen- dations with reasoning) on the subject in order to in- form the Congress. 3.12 RESPONSE: The Utah BLM Statewide Wilder- ness EIS and the wilderness review process are con- sistent with the parameters established by the Con- gress in NEPA and the Wilderness Act. Further, BLM is authorized only to propose wilderness designation on lands that it administers, except as agreements may be made for special joint studies. Such joint studies are not planned in Utah since the FS review has already been completed and NPS recommendations have been made. Congress has already acted on the FS recommendations, but has not yet acted on the NPS recommendations. Only Federal lands are proposed for designation; therefore, State and private lands could become part of the NWPS only if they are later exchanged or otherwise change to Federal ownership. In view of the existing roads, communities, ranches, and other human uses of the lands in central and southern Utah, BLM considers it unrealistic to disregard the Wilderness Act in order to propose wil- derness preservation for "large, entire ecosystems." The existing WSAs and the BLM Proposed Action contain a wide range of ecological diversity and geo- graphic distribution on a substantial acreage. Also, see the response to General Comment 3.7 concerning citizen alternatives. 3.13 COMMENT: BLM has not considered geogra- phic distribution in formulation of alternatives. [Con- solidated Counties, Emery County, Washington County Water District, Consolidated Coal Company, Tim Graham, Harvey Merrell, Kevin O'Brien, et al.j a. One of the criteria is the balance in geographic distribution of wilderness areas. A map of the State of Utah with the WSAs on it fails to show me a very good balance of wilderness areas. In fact, the balan- cing act has failed miserably. For example, Volume I (Draft EIS Table 69) shows Carbon County, WSA acreage, and then the WSA acreage as a percent of the county acreage. Carbon County had 85,860 acres, a total of 9.0 percent. BLM's recommendation only takes 7.1 percent of the county. Emery County had 446,000 acres, which took 15.6 percent of county. Grand County is similar, 337,000 acres was 14.3 percent. San Juan County had 397,000 acres, which was 7.9 percent; and the BLM recommendation was reduced down to 6.9 percent. I have a recommended solution that would make everybody happy, though. What if we divided Utah up into 29 parts, and we already have that in the counties. Reserve 100,000 acres of wilderness for each of the 29 counties. That way there would be a fair geographic distribution of wilderness throughout the State, as well as give close access to a wilderness area to all the people in the State. This would give local people access to a wilderness area of their choice. The environmentalists would receive their 2.9 million acres of wilderness in which to meditate and whatever else they do. The local government wouldn't be asked to give up as much as 15 percent of their counties; and all the other good or bad economic loss or gain would be shared on a more even basis through- GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES out the State of Utah, not just the southern half of the State. b. The Regional Representative and Small Cluster Concept 6 and 7 Alternatives must be rejected simply due to their arbitrary geographical limitations. Elimi- nating areas from consideration solely due to location will not serve the purpose of wilderness designation. I also do not believe that FLPMA or the Wilderness Act intend for areas to be released from wilderness based on a narrow-sighted geographical grouping. c. Balancing wilderness area distribution within the State: This is a ridiculous and useless concept. Wilderness is where man has not yet made an impact. We cannot hope to establish a national system of wil- derness areas that are neatly arranged in a regular dispersion pattern throughout the country. We must take them where they are, and consider them on their merits. Basically, that means the characteristics within the boundaries. For additions to existing wilder- ness, the fact that the WSAs would be added to ex- isting areas should greatly influence recommenda- tions. Analyses should be conducted on the combined area as a single unit, regardless of the agencies involved in managing the different parcels. A number of WSAs qualify for these considerations, and BLM should look at this aspect more closely. d. The Draft EIS is remiss in its recommendations for wilderness because designation would create a geographic imbalance and redundancies in designated wilderness acreage. Many of southeastern Utah's national parks and State parks already contain and protect the same kind of formations, cultural sites, and ecological values for which recommendation was made on the WSAs within Emery County. There is no need to designate as wilderness the areas in the county. There is nothing unique within the areas that is not either already protected by the Federal govern- ment and its agencies, the county planning and zoning ordinances, or the natural make-up of the area itself. Of the 82 WSAs considered in the Draft EIS, 68 or 83 percent of the total are located in two specific State and Federally recognized labor market areas. Of the 58 areas recommended by BLM in the Proposed Action Alternative, 51 or 88 percent of 1,683,896 acres are located in these two labor market regions. In addition to the 1,683,896 acres included in the 51 proposed wilderness areas, the two labor market regions contain 166,102 acres of designated wilder- ness, 1,224,747 acres of NPS-administratively endorsed wilderness, 90,100 acres of additional con- sidered NPS wilderness, 56,800 State-designated acres, and 413,000 acres of Indian tribe wilderness, for a total of 3,634,645 acres. For comparison, the balance of the State, consist- ing of five labor market regions, contains 208,506 acres in the BLM Proposed Action, 659,088 acres of designated wilderness, 39,684 acres of NPS- administratively endorsed wilderness, and 1,853 acres of additional considered NPS wilderness, for a total of 909,131 acres. Considering the wilderness acres in the BLM Proposed Action, plus other Federal and State designated or proposed wilderness, Utah contains a total of 4,543,776 existing or proposed acres of wilderness. Of this total, 3,634,645 acres, or 80 percent of the total acreage, is situated in the southern and southeastern labor market areas. Wil- derness will have an impact on man's activities out- side of designated areas. The density of BLM and other agency wilderness or proposed wilderness areas in southern and southeastern Utah will result in the area's peripheral zones of influence overlapping one another and compounding their net influence across essentially the whole of the two labor market areas. Taken as individual units, the two labor market areas of southern and southeastern Utah are homo- genous economic and labor market regions. Within each region, the labor pool, the resource base (includ- ing water and air), and the communities themselves are largely self-contained, free-standing, and dis- tinct from the balance of the State. A significant change in this geo-economic composition in one part of one region will affect the entire region. If the change is land-based, then the effect is further com- pounded since the economies of both regions are land- based. Wilderness designation of 3,634,645 acres of land in the two regions, with all of its attendant limitations, restrictions, and extraterritorial influ- ences, would be a significant change. While a small number of scattered wilderness areas in a given re- gion will exert a measure of influence on surrounding lands, numerous areas concentrated in specific, de- fined geoeconomic regions, such as southern and southeastern Utah, will have a profound effect on the activities and management of surrounding lands and land-dependent economies. The concentration of 88 percent of BLM’s proposed wilderness areas in the two labor market areas of southern and southeastern Utah is clearly contrary to the notion of geographic balance. The Wilderness Study Policy states that geographic balance "will not be used as the sole basis for determining whether an area is recommended as 1 6 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES suitable or unsuitable for wilderness designation." However, the Wilderness Study Policy goes on to state that "depending on the amount of designated or administratively endorsed wilderness present in a State or surrounding region, such circumstances, considered in conjunction with other factors in an overall context, could contribute to a unsuitable rec- ommendation for a WSA in the same region." From this, it is clear that the amount of wilderness in a given area was intended to be a factor in determining whether additional wilderness will be designated. De- spite the language of the Wilderness Study Policy, BLM has not considered the factors of redundancy and geographic balance as justification for ruling out WSAs as candidates for designation in areas where substantial wilderness already exists. The BLM Draft EIS has not adequately or correctly considered the factor of geographic balance and redundancy of wilder- ness areas, as demonstrated by the fact that 88 percent of the areas studied or, stated differently, 89 percent of the wilderness acres of the Proposed Action, are located in two out of seven labor market areas of the State of Utah. It makes little sense to apply the concept of wil- derness management to arbitrarily defined tracts amidst the vast public domain of the western public land States. Because the Federal government owns most of the land in many of the western States, ample opportunity and statutory and regulatory au- thority exist to protect wilderness values without wilderness designation. For this reason, affected local governments in Utah support the Utah legislative concurrent resolution arising out of the Second Spe- cial Session of the 1986 Legislature wherein Con- gress is urged to modify FLPMA to exclude any State with greater than 30 percent Federal ownership from provisions of the 1964 Wilderness Act. This, in our view, would be a more appropriate application of the concept of geographic balance. e. The BLM Proposed Action proposes 82 indi- vidual wilderness areas involving 1,892,402 acres dominantly in the southeast quadrant of the State of Utah. In Emery County alone, five wilderness areas involving 265,645 acres are proposed by BLM. We contend that the Proposed Action Alternative does not represent a national perspective on the need to bal- ance the geographic distribution of wilderness areas. f. In Volume I of the EIS, Criterion No. 1 for the Evaluation of Wilderness Values (page 12) identified a diversity requirement of balancing the geographic dis- tribution of wilderness areas. The South-West Re- gion, primarily comprised of Washington County, pro- vides sites for 30 of the 82 proposed WSAs, or approximately 37 percent of the total proposed WSAs. When a WSA like Parunuweap has similar fea- tures to those contained in a national park, then the need to restrict use only to the wilderness area is diminished. 3.13 RESPONSE: The concept of geographic distri- bution must be viewed in concert with several other factors, including: a. The BLM-administered lands are not uniformly distributed throughout the State; b. the lands that remain natural and potentially eligible for wilderness consideration are not uniform- ly distributed within the State; and c. the main utility of the concept is to highlight opportunities for proposing new wilderness areas, if qualified, in regions where potential or designated wilderness is limited or lacking. Applications of the concept of geographic distri- bution must be done primarily on the basis of philo- sophical or intangible judgment rather than literal interpretation. It is not the intent that every county have a designated wilderness area. Also, it is not the intent that "quotas" of wilderness be assigned to re- gions or percentages of market areas or populations. The intent is to portray how any particular wilder- ness proposal fits with similar lands within a region or State as a whole (i.e., it puts the proposal in context with the overall perspective of wilderness opportunity). The EIS chart that provides WSA acres by region and county merely provides locational information for lands included in the wilderness study. It was, and is not, intended to be a commentary on (or the appli- cation of) geographic distribution as applied to pro- posing areas as suitable for wilderness designation. The Small and Large Cluster Concept Alterna- tives, the Regional Representative Alternative, and the Cluster and Interagency Areas Alternative are proper variations of geographical distribution on a Statewide basis within the framework of BLM- administered lands. These alternatives are not intend- ed to represent all of the areas that may be suitable for wilderness designation. All BLM WSAs and GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES wilderness areas of other agencies are illustrated in Volume I, Pocket Map 7, to give an overall perspec- tive of designated and proposed wilderness areas throughout Utah. The concept of balancing geographic distribution of wilderness areas will not be used as the sole basis for determining whether an area is recommended as suitable or unsuitable for wilderness designation (USDI, BLM, 1982a). States with large areas of Federal lands are not exempt from provisions of FLPMA. The resolution referred to in the comment does not alter the legal mandate for the BLM wilderness review process. The suggestion to exclude any State with greater than 30- percent Federal land from the provisions of the Wil- derness Act is an incorrect interpretation of the con- cept of geographic balance. 3.14 COMMENT: The BLM Proposed Action Alterna- tive is based on BLM's arbitrary and preconceived notion of what should be recommended. [Tim Graham and Glen Lathrop] a. How did the figure of 55 percent of the total WSA arise? The scoping document states it is the sum of the District Managers' recommendations. I am suspicious-was it the sum of their decision, or did it surface as an attempt to placate the pro-wilderness groups and avoid litigation similar to the RARE II debacle in California? In the scoping meeting I attended, a BLM employee said that to avoid a RARE II- type court case, they wanted their alternative to include more than 30 percent of the total. Fifty-five percent is a very convenient number-just over half, to satisfy the wilderness advocates, yet small enough to placate industrial interests. Some areas were dropped just to reduce the acreages recommended. Justify your decisions! b. BLM manages 22 million acres in Utah, and you can only offer 1 .9 million acres. It's simply not a fair distribution of the land. Several surveys in Utah have showed that at least 17 percent want wilderness; then 17 percent of the BLM land should be wilderness. 3.14 RESPONSE: The Draft EIS correctly stated that the figure of 55 percent was the sum of the District recommendations. There was, and continues to be, no pre-conceived percentages for alternatives. In fact, percentages for alternatives have changed from the Draft to the Final EIS as WSAs have been reconsidered. The experience of the FS in RARE II does indicate that a wide range of alternatives must be considered. BLM believes that the alternatives considered in this EIS provide a suitable range from No Action/No Wilderness to All Wilderness, with intermediate alternatives of widely varied acreages. BLM does not manage land to correspond to per- centages expressed in opinion polls. Rather, manage- ment depends on the capacity of the land for various resource uses, the legal mandate for multiple use, and many other factors. Public views are just one of the many factors influencing management. In the case of wilderness, the BLM Proposed Action for wilder- ness reflects input from local, State, and national interests, to the extent that this input is constructive and consistent with the study mandate. Since this input consists of widely divergent viewpoints, it has been necessary for BLM to synthesize the input, based on professional judgment. 3.15 COMMENT: BLM should analyze a multiple-use alternative. [Utah Wool Growers, Mr. Johnson, Hardy Redd, Utah Counties, et al.] a. Instead of the total wilderness concept, I suggest instead a modified approach for this ground being discussed for wilderness. I propose that all of the land in this study be set aside for multiple use for all of the people and not just one or two special interest groups. I also propose that the grounds now under control by BLM could be controlled by an advisory board made up of every class of people who use the land and that others be allowed in these areas. b. We maintain BLM should stay to a total multiple- use concept on all their land. If a special area needs attention, they already have authority to so desig- nate. c. The Draft EIS did not consider whether scenic and aesthetic resources can be managed under exist- ing designations with multiple-use principles and prac- tices modified to protect these resources. The Draft EIS should evaluate other management alternatives and their costs, as well as the impact on surrounding lands and the socioeconomic impacts for State and local governments. 3.15 RESPONSE: While FLPMA requires BLM to apply multiple-use planning and management, it also requires BLM to conduct a wilderness review. As not- ed in Chapter 1 of the EIS, BLM is required to report GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES wilderness recommendations by 1991. Wilderness use is one of the multiple uses of BLM land. The fact that most BLM lands are subjected to the traditional multiple-use mandate does not relieve BLM of its responsibility under FLPMA to identify areas suitable for wilderness designation. Even with wilder- ness designation, selective use of other resources would occur. These selective uses could include recre- ation, livestock grazing at existing levels, wildlife, hunting, mining on valid claims, watershed protec- tion, and nature study/research. Also, see the response to General Comment 1.2 for an explanation on the relationship of wilderness and the multiple-use concept. 3.16 COMMENT: A protection, but not wilderness, alternative should be analyzed. [Allex Morris] a. I want to know why there is not an alternative a little bit below wilderness status, one that does not close existing wilderness and trails (and I use the word "trails" loosely). They call them ways. Some of the roads that I drive on you would have a hard time walking on perhaps, and that is part of the fun of four- wheel driving. When these seven alternatives are the only alter- natives offered, I have little choice but to oppose in general any areas that have trails, roads, or passable ways, whatever you want to call them. In all other respects, I find myself very much for the preserva- tion of these areas in the pristine, beautiful State which they now are. I don't want to see them devel- oped any more than I am sure many of you do. 3.16 RESPONSE: The standards and objectives for wilderness management do not provide for differing levels of protection and use. Uniform definitions exist for roads and ways, as related to wilderness. If an area is designated by Congress as a unit of the NWPS, it must be subjected to the management principles expressed in the Wilderness Act, unless specific exemptions are authorized by Congress. The Final EIS describes a Statewide alternative (Volume I - Chapter 2 and Pocket Map 2) to illustrate a combination of wilderness and other special desig- nations. These other designations could provide for activities different or less restrictive than the specif- ic requirements of wilderness. Administrative actions available to BLM which would be "a little bit below wilderness status" would come under the purview of the No Action/No Wilder- ness Alternative. Such lands would be managed through BLM land use plans, which have been used to describe the No Action/No Wilderness Alternative. This would be in line with normal administrative actions rather than special Congressional designation. The BLM land use plans contain protective require- ments in certain areas, and future updates or amend- ments to these plans could be considered additional protection "a little bit below wilderness status." However, this may not provide the recognition or permanency which otherwise would result from desig- nation to the NWPS. 3.17 COMMENT: Statewide consistency is needed. [Utah Wilderness Association, Wilderness Society, Owen Severance, et al.] a. There is a major benefit to having a Statewide EIS: the discrepancies and inconsistencies in BLM's wilderness proposals can be seen by comparing the work done in five Districts. What cannot be deter- mined is the amount of qualified BLM land that was dropped from the wilderness review process due to the faulty and inconsistent application of wilderness criteria. It should not be up to individuals and groups outside BLM to make sure that the rules were followed and qualified areas were not intentionally (illegally) left out at the District level. The All Wilderness Alternative should be used as the starting point for a revised Draft EIS. Many WSAs should be enlarged for the reasons stated above and other qual- ified areas that were dropped earlier in the review process should be reinstated. It is apparent that the extremely negative attitude toward wilderness shown by the Cedar City and Richfield Districts is slowly being changed; however, their unsatisfactory initial inventory unnecessarily eliminated a large amount of acreage from study for wilderness designa- tion. BLM should re-evaluate all roadless areas in the State using the same criteria for all instead of letting each District use its own variation of the criteria, as was done initially. b. The analyses of wilderness values in the Kai- parowits Plateau region is atrocious. Consistently, the criteria in assessing opportunities for solitude have been misapplied and misinterpreted. The only cri- teria considered have been topographic and vegeta- tive screening. Even then, the fact the Kaiparowits has numerous, dense stands of pinyon-juniper and is GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES cut by innumerable canyons is ignored. No considera- tion has been given to the relationship of size (700,000 acres of roadless country) to opportuni- ties for solitude. No consideration has been given to the lack of outside sights and sounds affecting the solitude of users. No consideration has been given to the remoteness of the area, where you can travel for days without encountering another person. Simply be- cause the land is not "standing straight up" and smo- thered in vegetation, BLM has determined much of the Kaiparowits lacks opportunities for solitude. How an area (Wahweap Canyon WSA) of 134,000 acres in size can possess solitude on only 13,000 acres is beyond comprehension. In many instances, the Draft EIS' exacting acre-by-acre inventory of wilderness characteristics views each portion of lands as if it were divorced from the surrounding land. The mesa tops are an integral part of the canyons they divide. The openness of the desert is the single-most impor- tant factor in the feeling of isolation one receives in southern Utah. You cannot experience the vastness of the redrock country from the bottom of a canyon the way you can from the top of the Kaiparowits Plateau. Wilderness values must be judged on reality-how the land is actually used rather than whether people could hide themselves if thousands invaded the area at once. Findings that much of the Kaiparowits lacked wil- derness values were consistently rejected by IBLA. Why BLM continues to cling to these unsupportable claims is very troubling. Is it because the area's coal resource blurs BLM's vision when looking for wilder- ness values? Or is it simply an unwillingness to admit past errors? No one can argue that a potential con- flict exists on some of the Kaiparowits units between wilderness designation and coal development, al- though we might argue on the level of conflict. But it is foolish for BLM to continue to argue the Kaiparo- wits lacks wilderness values. It is misleading and leaves BLM wide open to charges of perpetuating an anti-wilderness bias. Opportunities for solitude and primitive recrea- tion do not exist solely by topographic screening via deep canyons or dense vegetation. The sheer vastness and remoteness of many of the WSAs, as well as smaller topographic features (e.g., rounded sandstone domes and intricately dissected badlands), allow for outstanding solitude and primitive recreation, often more so than in deep canyons. c. Special features, visual quality ratings, and wilderness quality are some of the items that need attention. They are assessed in different ways by dif- ferent Districts. This is a serious error. d. The individual wilderness proposals are wildly erratic due to the Resource Area Offices applying an inconsistent set of wilderness criteria. Some exam- ples: the Henry Mountain Resource Area used the claim "similar to other WSAs" as the reason for not proposing WSAs for wilderness; the Cedar City Dis- trict used screening as the sole determinant for soli- tude; the Grand Resource Area used speculative min- eral values to eliminate whole WSAs from the propos- al. Unfortunately, the inconsistent application of what was supposed to be a standard set of criteria has existed from the beginning of the wilderness study process. There is no indication in the Draft EIS that any attempt will be made to standardize the Wilder- ness Study Reports. This incredible variation in the quality of work done in the various Districts that shows up in the Draft EIS makes me feel that BLM is just going through the motions of the wilderness study process and doesn't plan to address the issues and problems that are being brought up by the public. The BLM lands contain our last wilderness fron- tier. Of all the Federal agencies, BLM provides more habitat for wildlife, contains more diversity of eco- systems, and has more potential for archaeological discovery than any other systems. In Utah, we have an opportunity to preserve for ourselves and future generations a sample of these diverse wild lands. e. BLM's Cedar City District has consistently shown its anti-wilderness bias all through the wilder- ness study process. This negative bias is shown in Volume lll-A, in the form of a perverted definition of solitude. The Cedar City District uses topographic and vegetative screening as the sole determinant for the presence of solitude. The "Wilderness Inventory Hand- book" (1978) defines solitude as "the state of being alone or remote from others; isolation. A lonely or secluded place." It is not the sole determinant. For instance, it is absurd for BLM to state that only 66 percent of an area 23 miles by 19 miles has outstand- ing opportunities for solitude (the Paria-Hackberry WSA). How many miles am I supposed to hike before I find outstanding isolation? All of the WSAs in the Cedar City District should be re-evaluated using the proper definition of solitude. 3.17 RESPONSE: It has been and continues to be BLM's intent to apply in a consistent manner the Wilderness Study Policy criteria and guidelines for 20 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES conducting wilderness studies. A BLM consistency team was formed in Utah during the early phases of the process. Specific and consistent criteria have been used throughout the inventory and in the formula- tion of the Proposed Action. BLM has endeavored to apply that criteria uniformly, although it is recog- nized that numerous people and individual interpreta- tions have been involved over lengthy inventory and study periods. Further, each WSA recommendation must be determined based on its own merits and on a case-by-case basis. Also, see the responses to Gen- eral Comments 2.12 and 3.1. 3.18 COMMENT: Not all BLM WSAs are included in the alternatives. [Marathon Oil] This EIS is misleading because all WSAs in Utah that could be studied for wilderness are not included in the study. 3.18 RESPONSE: All WSAs in Utah are analyzed or referenced in the EIS. The only WSAs not included in the Description of Alternatives and the Statewide analysis are: 1. Seven areas in Utah totalling 23,030 acres which overlap from adjacent States, as listed in Volume I (Table 52) of the Draft EIS. These areas are under study and will be reported by Colorado or Nevada. 2. Five small ISAs, as noted in Volume I, Chapter 1 (Book Cliffs, Devils Garden, Joshua Tree, Link Flats, and Escalante Canyons Tract 1), that pre- viously were studied and recommended as nonwilder- ness. These areas total 3,352 acres. Rationale for these areas is shown in Appendix 11, Table 1, in Volume I. Volume I of the EIS provides information on the NWPS in the U.S. and Utah. Since these areas are men- tioned in the EIS and they are or have been studied, BLM disagrees with the comment that the EIS is mis- leading. Also, see General Comment Responses 2.8, 2.9, and 2.10 for information on the wilderness review process for ISAs and the Big Hollow WSA. a. BLM fails to consistently apply the alternative description to each WSA. For example, the criteria for the Large Cluster Concept Alternative, found on page 20 in the Draft EIS, states that clusters: (1) include areas selected from the All Wilderness Alternative: (2) consider geographic distribution; (3) includes adjacent WSAs separated by dirt or gravel roads, minor intrusions, and less than a 0.50-mile distance: (4) totals 100,000 acres or more, including adjacent non-BLM wilderness lands or proposals; and (5) provide at least 25 percent of BLM WSA lands in a cluster. In the West Desert, BLM has not identified any cluster, thus violating its own geographic distribution criteria. Here are the areas that meet the criteria in each of the clusters: West Desert Cluster WSA Acreage Recommendation Notch Peak 51.130 Unsuitable Howell Peak 24,800 Unsuitable Swasey Peak 49.500 Unsuitable Total Acreage 125,430 Each of these areas abuts the House Mountain Range in the West Desert. The total acreage is more than 100,000. King Top would be a logical addition to this since it is only separated by a paved road 50 feet wide. (The road surface seems to matter little and is just another arbitrary factor in the criteria for this alternative.) All the areas listed below directly abut the larger Zion National Park wilderness proposal. They are a logical part of this cluster and meet the BLM criteria. Zion Cluster WSA Acreage Recommendation Beartrap Canyon 40 Unsuitable Goose Creek Canyon 89 Unsuitable Taylor Creek Canyon 35 Unsuitable The Watchman 600 Unsuitable Spring Canyon 4.433 Unsuitable Red Butte 804 Unsuitable LaVerkin Creek Canyon 567 Unsuitable Deep Creek 3.320 Unsuitable North Fork Virgin River 1.040 Unsuitable Orderville Canyon 1,750 Unsuitable Parunuweap Canyon 30.800 Unsuitable Canaan Mountain 47,170 Unsuitable Zion National Park 126.5.1& NPS-recommended Total Acreage 217,183 3.19 COMMENT: The Large and Small Cluster Concept Alternatives should be redefined. [Utah Wilderness Coalition and Dennis Willigan] 21 BLM gives no reason why The Cockscomb is not part of the Kaiparowits Cluster. BLM should include GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES The Blues, separated from Mud Spring Canyon by a paved highway. Mud Spring Canyon is part of the cluster. In the Escalante Canyon Cluster, BLM neglected to include Escalante Tract 5, which is a logical part of Coyote Creek and the Glen Canyon NRA wilderness area. BLM also failed to include Steep Creek, which is separated from North Escalante Canyon/The Gulch by a narrow road (the Burr Trail). Phipps-Death Hollow is separated from North Escalante Canyon/The Gulch by a narrow paved road and is a logical part of the Escalante Canyon Cluster; BLM excluded it as well. Kaiparowils WSA Acreage Recommendat ion Paria-Hackberry 135,822 Suitable Wahweap 134,400 Suitable Burning Hills 61,550 Suitable Death Ridge 62,870 Suitable Mud Spring Canyon 38,075 Suitable Fifty Mile Mountain 146,143 Suitable The Cockscomb 10,080 Unsuitable The Blues 19.Q3Q Unsuitable Total Acreage 607,970 In the San Rafael Swell, BLM included none of the areas that form a cluster. Excluded were Crack Canyon, Muddy Creek, Devils Canyon, and the San Rafael Reef. These units are logical parts of the region and were ignored in the recommendation with this alternative. BLM ignored the logical wilderness cluster which links Glen Canyon NRA and Canyonlands National Park. The Glen Canyon NRA/Canyonlands National Park Cluster should include the following: Glen CanyorV (Canyonlands) Cluster WSA Acreage Recommendation Little Rockies 38,700 Unsuitable Fiddler Butte 73,100 Unsuitable Dirty Devil 61,000 Unsuitable French Spring-Happy Canyon 25,000 Unsuitable Mancos Mesa 51,440 Suitable Dark Canyon 68,030 Suitable Butler Wash 24,190 Unsuitable Bridger Jack Mesa 5,290 Unsuitable Indian Creek 6,870 Unsuitable Horseshoe Canyon 20,500 Unsuitable Canyonlands National Park 260,150 NPS Glen Canyon NF1A 62Q.436 NPS pre-proposal Total Acreage 1,254,706 As you can see, some of the BLM WSAs that abut NPS recommendations are listed and some are not. This list shows those that abut the larger cluster and meet the BLM criteria. On Cedar Mesa, BLM neglected to include Fish and Owl Canyon, Road Canyon, and Mule Canyon in a cluster. These areas abut each other and are sepa- rated only by narrow roads. They are really a part of the larger Cedar Mesa Cluster which includes Grand Gulch Complex. Fish, Owl, and Road Canyons come within 0.5 mile of Grand Gulch Complex. Again, only a narrow paved road separates them. b. To enhance conservation efforts consistent with the intent of the Wilderness Act and to maximize socioeconomic benefits to the State and local commu- nities arising from the tourism potential of wilder- ness areas, BLM should take the WSAs identified in its All Wilderness Alternative, in combination with those recommended additions proposed by the Utah Wilderness Coalition, and then identify large clusters of adjacent wilderness areas or those relatively close to each that could support extended hiking, river, or pack trips from centralized staging areas or commercial outfitting locations. These large wilderness clusters should be design- ed to draw the public's attention to important ecosys- tem characteristics. For example, an Escalante Clus- ter could include proposed wilderness areas in that region generally made up of canyon systems that all drain into the Escalante River. The Escalante River and its outstanding side canyons form a unified eco- system that could be presented in a very attractive manner to facilitate tourism. Wilderness permits issued by BLM could be structured so that hikers and campers are evenly dispersed throughout the cluster to help ensure quality wilderness experiences with few human contacts. Identification of all aspects of large clusters could help prevent overuse of areas that are better known but not necessarily superior to other parts of the cluster. For example, not everyone needs to hike and camp in Coyote Gulch in the Esca- lante to experience the outstanding wilderness quali- ties found throughout that area. Careful design of the coordinated large cluster wilderness concept proposed above could yield less than 20 separate clusters rather than the fragmented picture created by the 82 WSAs considered in BLM's All Wilderness Alternative. Stress needs to be placed on the preservation of entire ecosystems rather than bits and pieces of ecosystems. 22 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES Existing small communities located near these large cluster wilderness areas should be clearly designated in available promotional literature and on highway signs as staging areas for tourists and com- mercial outfitter operations. Local economies should be developed around what may already be or eventu- ally become their principal socioeconomic resource, wilderness. 3.19 RESPONSE: The cluster concept was included in response to several general suggestions made dur- ing the scoping process. In order to define the concept more specifically, BLM formulated the criteria rela- tive to allowable separation, intrusions, and dis- tances between WSAs; cluster size; and percentage of BLM iands. The criteria were first formulated and then applied in an objective way to the array of 82 WSAs; they were not devised to match pre-conceived clusters or to minimize/maximize acreage in the cluster alternatives. While some people consider these criteria to be arbitrary, BLM believes that they represent the intent that clusters be formed with WSAs that are adjacent and of sufficient size to afford extended wilderness experiences. To meet the criteria, a visitor must be able to hike (or horseback ride) from one WSA to another without encountering substantive human intrusions. The presence of a dirt or gravel road between WSAs was considered acceptable because of low likelihood for vehicle traffic, whereas a paved road was not considered acceptable because of a higher chance of vehicle traffic encounters (thereby substantially interrupting the wilderness experience). The separa- tion distance of 0.5 mile between WSAs is considered a maximum area for wilderness visitors to cross where they may be subjected to existing or future human intrusions (such as vegetative manipulations, utility corridors, gravel sources, etc.) and other land uses that may detract from the wilderness experi- ence. The minimum cluster size of 100,000 acres was selected to represent a need for relatively large wil- derness areas. BLM recognizes that any other simi- larly large number could be used for this criteria. This figure has been changed to approximately 60,000 acres for the Cluster and Interagency Areas Alternative analyzed in detail in the Final EIS. The criteria that BLM land comprise at least 25 percent of a cluster is reflective of the need for the BLM land to make a substantial contribution to the concept, inasmuch as this is a wilderness study pro- cess for BLM-administered lands and that the wilder- ness should be manageable. The suggested cluster in the West Desert does not meet the criteria because the Notch Peak WSA is more than 0.5 mile from the Howell Peak WSA. The suggested cluster in the vicinity of Zion National Park does not meet the criteria because the acreages listed in the comment are, in fact, com- prised of three separate groups. One group is sepa- rated by more than 0.5-mile distance and one is sepa- rated by a paved State highway. None of the three groups individually meets the 100,000-acre size criteria. The suggested cluster for the Kaiparowits region already is included, except for The Cockscomb and The Blues. The Cockscomb WSA should have been included in the Large Cluster Concept Alternative and the Small Cluster Concept Alternative. The Blues WSA does not meet the criteria because it is separat- ed by a paved State highway. In the Kaiparowits Cluster, Escalante Canyons Tract 5 already is included in the Small Cluster Concept Alternative, but was inadvertently omitted from the Large Cluster Concept Alternative. Steep Creek WSA was not included in the Small Cluster Concept Alternative because of the 0.5-mile corridor (0.25-mile setback on each side of the Burr Trail). It has been added to the Large Cluster Concept Alterna- tive. The Phipps-Death Hollow WSA does not meet the criteria because it is separated by a paved State highway. While Crack Canyon WSA, Muddy Creek WSA, Devils Canyon WSA, and San Rafael Reef WSA are part of the San Rafael region, they do not meet the cluster criteria due to separation by either paved roads or more than a 0.5-mile distance. Individually, none of these areas meets the 100,000-acre size criteria. Glen Canyon NRA and Canyonlands National Park are linked with NPS-endorsed wilderness which is included in the EIS as part of the BLM Dark Canyon Cluster. The BLM Mancos Mesa Cluster includes lands in Glen Canyon NRA. The other WSAs suggested in the comment do not meet the criteria. 23 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES On the Cedar Mesa, Mule Canyon WSA does not meet the criteria because it is separated by a paved State highway. Road Canyon and Fish Creek Canyon WSAs together do not contain at least 100,000 acres. A paved State highway and more than 0.5 mile separates these areas from the Grand Gulch Complex of WSAs. The Grand Gulch Complex is included in the EIS as a cluster, along with adjacent NPS-endorsed wilderness in Glen Canyon NRA. BLM lands outside WSAs are not included in the cluster alternatives because they did not meet the BLM wilderness inventory requirements. See General Comment Response 3.1. The Draft EIS included a detailed analysis of the Small Cluster Alternative. For the Final EIS, that de- tailed analysis has been replaced by a new Statewide alternative: Cluster and Interagency Areas. Criteria used to formulate this new alternative differ some- what from that used previously for the two cluster concept alternatives. See the description of the new alternative in Volume I. It is intended to more fully in- vestigate and explain the extent to which the cluster concept may increase attention, tourism, and promo- tional opportunities. 3.20 COMMENT: The Highest Quality Alternative has significant problems. [State of Utah, Utah Wilder- ness Coalition, and Kevin O'Brien] a. BLM requires that an area have outstanding opportunity for solitude and primitive and unconfined recreation on at least 75 percent of the WSA. The key shortcomings to this are the arbitrary choice of 75 percent of an area and the absence of any objective- or, as BLM has applied it, even predictable-method of evaluating wilderness solitude and potential for wil- derness activities. BLM gives no rationale for choos- ing the 75-percent figure. This becomes an arbitrary tool and the alternative crafted with it does not con- stitute a reasonable alternative. The Congress does not demand that both wilderness-grade solitude and potential for wilderness-based activities be present to qualify an area for wilderness protection; why does BLM? Beyond that, the agency's own Wilderness Study Policy directly forbids this practice: "However, arbi- trary assignments of numerical weights and/or sub- jective ratings or rankings should not be used in BLM wilderness studies." BLM uses an undocumented and unauthorized method in the Draft EIS to conclude that a certain percentage of each area has high, medium, or low wilderness values. The method differs with dif- ferent areas and appears to be inconsistently applied. The Fiddler Butte WSA offers an example of the problems with BLM's ranking of wilderness values. The Dirty Devil River flows through the middle of this area. The west side of the Dirty has cliffs and can- yons over 1,000 feet high. The eastern side of the river has deeply eroded badland benches surrounded by large mesas and buttes. BLM found solitude on the west outstanding and on the east not outstanding. The Red Benches are proposed as unsuitable solely be- cause of BLM's finding on the issue of solitude. These benches are undulating and a hiker would be screened from-physically out of sight of-another person few- er than 100 yards away. In one candidate area after another, BLM has found low-grade solitude, often in huge, rugged, and natural areas. And this, without benefit of any publish- ed standards for such determinations, as we have pointed out. BLM's methods are clearly arbitrary and without merit. The BLM wilderness study states plainly and unmistakably that "arbitrary assignments or numerical weights and/or subjective ratings or rankings should not be used in BLM wilderness stu- dies." But BLM's studies are riddled with such forbidden features. BLM uses numerical quantities, a percentage of the area which must possess outstand- ing recreation or solitude opportunities or fall short of wilderness recommendation. This clearly violates the Wilderness Study Policy. All such arbitrary rank- ings should be dropped from the EIS and lands exclud- ed on the basis of such ranking should be re-evaluated and restored to the process. b. Page 20, column 2, Highest Quality Wilderness Alternative: This paragraph discusses the Highest Quality Wilderness Alternative as an alternative con- sidered and eliminated from detailed study. This alter- native was eliminated because it was not "signifi- cantly different than the BLM Proposed Action." This alternative proposes 2,050,922 acres of wilderness as opposed to the 1,892,402 acres of BLM's Pro- posed Action. This seems like a significant difference. c. I have to wonder if BLM has not recommended certain areas simply to appease various political development groups. I also wonder why, if 2.6 million acres of WSAs are suitable under the Manageability Alternative, why are only 1.9 million acres included in the Proposed Action? Why were 0.7 million acres 24 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES declared unsuitable when they both qualify for wilder- ness and are manageable as such? Many of these are identified as "highest-quality wilderness" by your own analysis. All of Howell Peak, Wah Wah Mountains, North Escalante Canyons/The Gulch, Mt. Ellen-Blue Hills, Mancos Mesa, and Mexican Mountain are designated suitable in both the Highest Quality and Manageability Alternatives, but only partially recommended as suitable by BLM. If these are high quality, manageable wilderness areas, they should be managed entirely as wilderness. The wilderness resource in these areas outweighs any other uses. Also, French Spring-Happy Canyon, Mt. Pennell, Jack Canyon, Coal Canyon, Spruce Canyon, Flume Canyon, and Daniels Canyon are not recommended as both manageable and high quality areas. These areas should also be all recommended for wilderness sta- tus; this is the best possible use for these areas. 3.20 RESPONSE: The Highest Quality Alternative was formulated to consider the impacts from wilder- ness designation of those areas, which in BLM’s judg- ment, have the most outstanding wilderness qualities. BLM believes that wilderness values are of a higher quality in areas where outstanding opportunities for solitude and/or primitive recreation exist, prefer- ably in combination with wilderness special features. This objective is a reasonable basis for an alterna- tive. Although "Congress does not demand" only the highest values, BLM believes that the alternative does provide useful information and included it in the EIS for this purpose. It is noi the BLM Proposed Action. The alternative is not based on the arbitrary assignment of numerical weights or rankings, nor is it based on undocumented and unauthorized methods. See General Comment Responses 8.6 and 8.11. Some WSAs or parts of WSAs have higher wilder- ness characteristics (more ecological variety, more terrain variety, more visual interest, etc.) than others. In the analysis and when providing informa- tion to the public and to the Congress, it is necessary to describe these various characteristics. The criter- ia used by BLM to identify wilderness quality is, of necessity, subjective because the characteristics themselves are subjective. The terms high, medium, and low (and the approximate percentages of each) are used to describe the differences in the wilderness attributes; this is not an "arbitrary assignment" or an "unauthorized method." Rather, it is the narration of BLM's judgment concerning these values. The Highest Quality Wilderness Alternative is a summation of all areas that BLM believes have the highest wilderness values, regardless of any poten- tial conflicts with other resources. This alternative was not analyzed in detail in the EIS since the State- wide total acreage is not substantially different from an alternative which is analyzed; therefore, it does not constitute a significant difference in the range of alternatives for a Statewide perspective. Each of the WSAs mentioned in the comment have been reviewed for appropriate inclusion or exclusion from the various alternatives. 3.21 COMMENT: The All Wilderness Alternative is misnamed. [Raymond Wheeler, et al.] The agency should relabel the All Wilderness Alternative the "Maximum Profitable Development Alternative" because that is precisely what it is. A vast amount of information has already been supplied to Congress (specifically, to the House Interior Public Lands Subcommittee in the course of five BLM over- sight hearings) which convincingly demonstrates that the Utah BLM systematically excluded deserving lands from its wilderness inventory for the express purpose of omitting from the inventory any and all roadless lands with potential for commercial develop- ment of any kind. 3.21 RESPONSE: See the response to General Com- ment 3.1. 3.22 COMMENT: Why have all of the areas admit- ted by BLM to be of the highest quality wilderness not been included in the Proposed Action? [Randolph Jorgen, et al.] These include the following WSAs: Deep Creek Mountains, Howell Peak, Wah Wah Mountains, North Escalante Canyons/The Gulch, Mt. Ellen-Blue Hills, French Spring-Happy Canyon, Mt. Pennell, Mancos Mesa, Fish Spring Canyon, Sids Mountain, Mexican Mountain, Jack Canyon, Desolation Canyon, Floy Canyon, Coal Canyon, Spruce Canyon, Flume Canyon, and Daniels Canyon. To consign these areas to degradation from short-term resource consumptive gains, as nondesignation would eventually do, is inexcusable. 25 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES 3.22 RESPONSE: After consideration of all comments and any new information available, BLM has carefully reviewed and revised the Proposed Action. All of the WSAs listed in the comments were reconsidered. The rationale for including or excluding these areas is summarized in the Final EIS, Appendix 11. Also, refer to General Comment Responses 8.6 and 8.9. 3.23 COMMENT: The BLM alternatives should com- plement interagency management. [Sierra Club, Cache Group, and Miki and John Magyar, et al. J a. The Draft EIS states: "There would not be direct conflicts with Federal and Indian land manage- ment plans . . ." with wilderness designation on all WSA lands (page 1-134). This is a good statement, but it does not go far enough. Wilderness, in most cases, would complement and enhance Federal land manage- ment plans. The NPS has made major invest-ments in Utah's various Federal parks for all Americans to enjoy. There are a number of BLM tracts that would enhance these lands if wilderness designation were afforded to them. BLM should complete a thorough analysis on the relationship between units adjacent to NPS lands and the respective NPS lands. The EIS should include a plan to work in conjunction with NPS and FS on developing integral management or direct transfers of wilderness designated lands that abut different agency units. b. In the case where BLM wilderness areas are contiguous to other agency wilderness lands, by all means, facilitate one another by redrawing admini- strative lines on the map. State in-holdings do not seem to me an excuse for why BLM cannot manage for wilderness where there has been livestock, min- eral, and recreational use in the past. All of the BLM's contiguous wildlands, given their small acre- ages in comparison to neighboring NPS or FS wilder- ness, would be most efficiently managed as other agency additions. c. We are pleased to see the proposed alternatives for the other WSAs adjoining Zion National Park. It is critical to keep these headwaters as safe as possible from development and abuse. Zion is very much a "river" park and, as such, needs a natural water re- gime. 3.23 RESPONSE: The EIS identifies those WSAs that would complement the management of adjacent Federal land managed by the NPS or FS. This is done in the applicable individual WSA analyses and in the Statewide alternatives, including the Cluster and Interagency Areas Alternatives that are analyzed in detail in the Final EIS. The EIS is not the proper docu- ment for coordination plans or agreements for joint management or transfers of jurisdiction. The EIS addresses environmental impacts of wilderness desig- nation or nondesignation. Interagency management arrangements, if any, would be separate actions that may be considered in the future, regardless of wilder- ness designation. Certain lands in small WSAs adjacent to NPS units already have been identified for possible transfer of jurisdiction (House Resolution 1214, Ninety-eighth Congress). Out of 31 areas that would be affected by HR 1214, the NPS concluded that 18 are unsuitable for transfer and 13 are suitable for inclusion in adja- cent park units, regardless of wilderness considera- tions (USDI, NPS, 1984a). Action on this proposed legislation was deferred, but it may be reintroduced at a future date. Also, see the responses to General Comments 6.4 and 8.7 for information on in-holdings and the influ- ence of BLM wilderness on adjacent units. Further discussion is found in the responses to General Comments 23.10, 23.14, 23.15, and 23.18. 3.24 COMMENT: The EIS should include and analyze a land-transfer alternative. [Utah Counties] a. Twenty-nine BLM wilderness areas, consisting of 871,500 acres, are adjacent to wilderness or wilderness review units administered by other agen- cies. In the Draft EIS, BLM made no recommendations for transferra! of BLM wilderness to other agencies. Accordingly, BLM has deferred any discussion of possible interagency transfers for inclusion in the Wilderness Study Report, which is the decision- making document following the Final EIS. Because of the number of BLM wilderness areas contiguous to wilderness or proposed wilderness of other Federal agencies, it is reasonable to expect that exchanges will occur between Federal agencies. If exchanges occur, it must be assumed that the exchanged lands will be subject to management policies of the recip- ient agency. Of the 871,541 acres of BLM WSAs con- tiguous to other Federal agency wilderness or wilder- ness review areas, 135,800 acres are adjacent to units of the NPS. If any or all of these areas are trans- ferred, it is not known whether they will become 26 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES subject to Class I air quality designation. The cumula- tive impacts of wilderness designation, including possible expanded Class I air quality areas in south- ern Utah, is a matter of deep concern. b. The socioeconomic impacts of any proposed agency transfers should be analyzed in the Draft EIS. If no proposals for exchange are ultimately set forth in the Wilderness Study Report, then the Draft EIS, in its present form, may be adequate in its treatment of the issue of interagency exchanges. However, if the Wilderness Study Report contains recommendations for transfers of wilderness areas between Federal agencies, then the Draft EIS will have been inadequate and incomplete with regard to its analysis of socio- economic impacts. Since it cannot be known until the Wilderness Study Report is written whether recom- mendations for exchanges will be made and since it is likely that recommendations for exchange will be made, the Draft EIS has erred in not having addressed agency exchanges of WSAs. 3.24 RESPONSE: Any transfer of jurisdiction be- tween Federal agencies is a matter separate and independent from the question of wilderness designa- tion. The BLM, FS, and NPS have equal authorities and responsibilities for wilderness management; there- fore, a Congressional decision to designate wilder- ness is not dependent on which agency has administra- tive jurisdiction. BLM does not propose to recommend agency transfers as part of the wilderness reporting process. Also, see the responses to General Com- ments 3.23 and 10.2. 3.25 COMMENT: The size benefits of designating adjacent areas should be considered in development of alternatives. [Wayne Ranney, John Veranth, et al.] a. One wilderness area of 20,000 acres is more desirable than four areas of 5,000 acres each (the whole is greater than the sum of the parts). Wilder- ness is as much a state of mind as it is real acreage, and this state of mind is enhanced in a larger area. I would favor a few less wilderness areas if they were of a larger size and did not contain intrusive cherry- stems or highly irregular boundaries. Small wilder- ness areas are fine and we need them close to urban areas, but the crown jewels of the wilderness preser- vation system are those which are large and include many square miles without the visual intrusions of the smaller areas. Please emphasize the larger areas in their entirety as priority. b. In the individual WSA sections, the Size section states areas are of sufficient size to enhance wilder- ness values. Why was the additional benefit of the ad- jacent areas not discussed? 3.25 RESPONSE: The wilderness review must be based on the 5,000-acre criteria established by the Wilderness Act and the existing network of roads, disturbances, and existing rights. Consequently, the study criteria often result in the identification of individual WSAs of limited size. Still, these areas may have natural values deserving of wilderness designation. Each WSA must be studied on the basis of its own merits and must be reported as an individual unit. Consequently, Volumes II through VI do not ana- lyze the cumulative effects of adjacent WSAs. Where applicable, adjacent WSAs are mentioned in the Intro- duction of each individual WSA narrative. It is the purpose of the Statewide analysis in Volume I to identify and discuss the various combina- tions or groups of WSAs on a cumulative basis. The size benefits of adjacent WSAs are addressed in the Statewide cluster concept and interagency areas alternatives. The information on this subject has been revised and expanded in the Final EIS. 3.26 COMMENT: The water project exception poli- cy should be omitted in the description of the alterna- tives. [Charles Bagley] On page 31, it is not clear what is meant in right hand paragraph No. 2. "New water resource facilities or watershed activities not related to ranch land or wildlife management would be allowed only if enhanc- ing to wilderness, if necessary to correct conditions imminently hazardous to life or property, etc." Inas- much as the wilderness areas will contain no private property and will not be sites where humans routine- ly remain, it is hard to see what conditions could therefore exist that would be hazardous to life or pro- perty. This designation could be expanded by live- stock grazers to allow them to put dams in wilder- ness areas on the mere supposition that runoff from the area might cause flooding to private property outside the wilderness area. This management alterna- tive should be omitted. 3.26 RESPONSE: The text in question is not consid- ered a management alternative. Rather, it is a man- agement provision based on the national Wilderness Management Policy (BLM Manual 8560) that would apply to all areas designated wilderness in any of the 27 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES Statewide alternatives (see Appendix 1). The same text, except for differences in acreage, applies to the description of each of the Statewide alternatives. 3.27 COMMENT: The description of predator cotrol in the alternatives is in error. [George Hinde, et al.] a. Page 37, All Wilderness Alternative, states that "Use of aircraft generally would not be allowed for predator control." The other alternatives do not include this statement. They should. If predator control has to be allowed in wilderness areas, the restraints need to be increased. The prac- tice of predator control as written in Chapter 2 allows too many loopholes. b. The description of predator control for each alternative with nonwilderness needs revision. Prac- tices in those areas would be in accordance with programs of the Animal and Plant Health Inspection Service (APHIS) of the Department of Agriculture and State law regarding wildlife. 3.27 RESPONSE: The description of predator con- trol in alternatives has been revised as suggested. Restraints described therein are in accordance with legal and Federal policy requirements. Also, see the response to General Comment 1.5. 3.28 COMMENT: The House Range Complex should be included in the alternatives. [Sierra Club, Cache Group] By designating the large area as wilderness, Swasey Mountain will complement potential wilder- ness designation with Howell Peak and Notch Peak. These three areas could easily be considered the House Range Wilderness Complex for a better and larger management plan. 3.28 RESPONSE: The Swasey Mountains, Howell Peak, and Notch Peak are individual WSAs separated by roads. They would not be managed as one wilder- ness area, although similar management objectives would apply. These areas were considered for inclu- sion in the cluster concept alternatives, but they did not meet the criteria. See the response to General Comment 3.19. 3.29 COMMENT: BLM should analyze and propose the Book Cliffs WSAs as a roadless region. [John Veranth, Utah Wilderness Association, Utah Wilder- ness Coalition, et al.] BLM should propose wilderness designation for the Book Cliffs area, with the following WSAs: Deso- lation Canyon, Turtle Canyon, Floy Canyon, Coal Can- yon, Spruce Canyon, and Flume Canyon. These areas provide a high quality wilderness experience and would receive much more visitor use if more hikers and backpackers were aware of the difference be- tween the high plateaus and the cliffs facing the highway. This is a large, contiguous roadless area consist- ing of 600,000 acres of BLM land. When adjacent State and Indian roadless lands are included, the poten- tial roadless/wilderness area totals about 1 million acres. The synergistic benefits of the adjacent areas are not fully addressed in the Draft EIS. This large area would allow human-impacted sensitive wildlife species to spend the entire year in a roadless area since the elevation range encompasses both summer and winter ranges. 3.29 RESPONSE: Part of Desolation Canyon WSA, all of Turtle Canyon WSA, and part of Floy Canyon WSA (totalling 298,830 acres) were included in BLM’s Proposed Action in the Draft EIS and in the Large and Small Cluster Concept Alternatives. On the basis of public comment and new information, the Pro- posed Action has been changed. The Proposed Action for Desolation Canyon was reduced by 46,560 acres and Turtle Canyon was reduced by 5,730 acres. However, additions to the Proposed Action were made in three WSAs as fol- lows: Flume Canyon, 16,495 acres; Coal Canyon, 20,774 acres; and Spruce Canyon, 14,736 acres. The net change is a reduction of 285 acres for the Book Cliffs region; however, 52,005 acres east of the Green River and adjacent to the State of Utah roadless area have been added to the BLM Proposed Action. The discussion of regional benefits for recreation and wildlife has been expanded in the WSA analyses. 3.30 COMMENT: The San Rafael Swell should be held under wilderness study protection until national park status can be carefully analyzed. [Wendall Ander- son, et al.] 28 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES The San Rafael area merits national park status. The area should include all of the Sids Mountain and Mexican Mountain WSAs and additional wildlands and the more developed land around The Wedge, Buckhorn Draw, and along the San Rafael River. This could either be a new park or an addition to the Canyonlands and Capital Reef National Parks. 3.30 RESPONSE: The BLM wilderness study pro- cess is not an interim measure to foster or accommo- date national park designation. IMP is intended to preserve decision options until Congress can act to release the lands or designate them as units of the NWPS. Any consideration of the San Rafael area for national park status would be a separate action, com- pletely independent from the BLM wilderness mandate and the BLM responsibility to manage the public lands. Also, see the responses to General Comments 3.23 and 3.24. 3.31 COMMENT: The Lost Spring Canyon WSA should be included in an Arches/Westwater/Dolores Triangle Ecosystem. [Linelle Wagner] Lost Spring Canyon is another pristine area included after court appeals in the Utah wilderness roster because of its size. It is contiguous to vast tracts of NPS backcountry and provides "outstanding primitive recreational values" (Volume V, Lost Spring Canyon WSA). From its lack of mineral potential to its ease of management, it is an obvious candidate for inclusion in the NWPS and should not be deleted under any future proposals. Rather, adjacent and nearby BLM roadless areas and other previously explored/recovered areas should be added to form a greater Arches/Westwa- ter/Delores Triangle Ecosystem, with roads and de- velopments cherry-stemmed and drawn out as neces- sary. This would aid in endangered species recovery, enhance recreation and wildlife opportunities, and greatly benefit economically depressed Grand County. 3.31 RESPONSE: BLM's Proposed Action includes all of Lost Spring Canyon WSA and part of Westwater Canyon WSA. The other lands in the Dolores Triangle vicinity were reviewed to ascertain their wilderness values during the BLM inventory process in 1979 and 1980. Due to roads and other intrusions, they did not qualify for WSA status and are, therefore, no longer under consideration. Also, see the response to Gener- al Comment 3.1. 3.32 COMMENT: The Burr Trail setback is unneces- sary. [John Issacs, Thea Nordling, Utah Wilderness Coalition, et al.] a. The proposed boundary setback alternative for the Burr Trail is both unnecessary and undesirable. BLM proposes deeply penetrating cherry-stemmed nonwilderness corridors in three locations: Horse Canyon, the V between Harris Wash and the Esca- lante, and Big Spencer Flats. A short cherry-stem should be used instead. b. The proposed boundary setback along the Burr Trail is unnecessary and undesirable. The road should retain its natural and scenic character, as stated by NPS Director Mott. 3.32 RESPONSE: The views expressed are noted. The alternatives, which include a wilderness bound- ary setback for the Steep Creek and North Escalante/ The Gulch WSAs, are retained in the EIS. Scenic val- ues of the Burr Trail can be retained, even if the set- back was selected, because wilderness designation is not the only way to maintain scenic values. In most cases, the setback would physically extend only to the base of the cliffs in Long Canyon; this would be sufficient to allow for road modification. Various de- sign, construction, and highway landscape techniques are available to limit disturbance and protect scenic values. Also, see the responses to General Comments 4.3 and 4.4 for information regarding wilderness boundary setbacks along roads. 3.33 COMMENT: The acreage in the WSAs should be recalculated to delete boundary setbacks for adjacent roads and cherry-stems. [Utah Wilderness Coalition] 3.33 RESPONSE: In many places, the boundary of the WSA is located on the shoulder of the road or along the right-of-way line. In actual practice for designated wilderness areas, the boundaries would be refined with a setback of 30 to 300 feet, depending on the type of road, as noted in Volume I, Chapter 2, of the EIS. This practice is reflective of the concerns for highway maintenance and adjustments to serve traffic needs. The acreages given for the alternatives do not consider the setbacks that may be applied; however, the amounts would be small and usually within the 29 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES margin of tolerance for standard techniques in calcu- lating acreages of mapped units. Also, see the responses to General Comments 4.3 and 4.4 for information on wilderness boundary setbacks along roads. 3.34 COMMENT: The EIS discussion of State lands is in error. [State of Utah; Sierra Club, Cache Group; Utah Farm Bureau Federation, et al.] a. It is interesting to note that, even though the Draft EIS does not include the additional 330,250 acres of State lands up front and build it into its appropriate acreages under each alternative, it assumes that the exchange of lands between the State and Federal governments will proceed. On the other hand, Project BOLD has lost a tremendous amount of momentum in recent years. Indeed, it is a less palat- able option among various user groups, as well as agencies, the more closely it is examined. It is our opinion, along with many others, that such an exchange could seriously jeopardize our fra- gile tax base, which is significantly generated by energy and mineral developments and livestock per- mittee leases. The energy and mineral development potential from these strategically located areas, along with BLM acreage, has not been adequately assessed and only the future can tell what these areas are truly capable of producing. b. Page 119, Item 2: Delete "except those con- taining coal or other minerals." Mineral rights are re- served in land sales. Section 65-1-4 is not an appro- priate reference. Section 565 does not exist. c. Page 119, Paragraph 1: Item 6 should be 65-1 - 45(3). d. The major problem involves school sections in various BLM lands. It is in the best interest of both the State and BLM to facilitate a land transfer as soon as possible. BLM must develop a series of alterna- tives that could be used to accomplish land exchanges or purchases. These alternatives should be outlined in the Final EIS. 3.34 RESPONSE: As a result of the changed position of the State of Utah, as explained in Volume I, Chapter 1, of the Final EIS, the assumptions and analysis related to State lands have been revised completely. The current State position is that in-held and adjacent State lands will not be exchanged, ex- cept on a case-by-case basis to be determined some- time in the future. Since the State has declined to identify in advance those cases where exchange would be requested, BLM has assumed, for the pur- poses of EIS analysis, that no State exchanges would occur for wilderness purposes for any particular WSA, and that reasonable access would be allowed, if needed. This assumption is the same for each of the alternatives. In reference to the various sections of the Utah Code pertaining to State lands, the discussions have been corrected. There is no need to develop alternatives to accom- plish land exchanges or purchases. Laws, regulations, and procedures already exist that would allow ex- changes and purchases (although it is expected that Federal funds for such purchases would be limited or unavailable). Also, see the responses to General Com- ments 6.3, 6.4, 6.5, and 23.10. 3.35 COMMENT: The relationship of wilderness alternatives to private lands should be clarified. [Sierra Club, Cache Group, et al.] Most of the BLM lands in question during this wil- derness review process do not affect private lands. Any private lands that remain in wilderness areas should either be traded or purchased at the earliest possible moment. It appears that BLM is recom- mending this action. 3.35 RESPONSE: BLM does not propose acquisition of any private in-holdings unless requested on a case- by-case basis by the landowner or unless conditions as described in Parts 5 and 7 of the BLM Wilderness Management Policy should occur in the future. Also, see General Comment Responses 6.1 and 6.2 for a discussion on private and State in-holdings. 3.36 COMMENT: Outstanding wilderness character- istics should not be criteria for partial alternatives. [Rex and Judy Wells, Utah Wilderness Coalition, et al.] We oppose the concept of identifying Partial Wil- derness Alternatives on the basis that only those portions of the WSA "with the most outstanding wil- derness characteristics" would be recommended as suitable. This approach is based upon the identifica- tion of distinct zones, which is in violation of the 30 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES Wilderness Study Policy. The Wilderness Study Policy (page 5118) states: "There appears to be two general cases when it may be appropriate to consider recommending less than entire WSAs for wilderness: (1) Resolution of conflicts and (2) Manageability of wilderness." Furthermore, it is not clear how those areas with the "most outstanding wilderness charac- teristics" were identified. It appears that areas with the "most outstanding wilderness characteristics" are only those that possess naturalness and outstand- ing opportunities for both solitude and primitive recreation. This implies that an area possessing only solitude or primitive recreation opportunities, but not both, is of lesser quality than an area possessing both characteristics. 3.36 RESPONSE: See the responses to General Com- ments 2.13, 3.19, and 3.20. The BLM Wilderness Study Policy states: "In each wilderness study objec- tive, information will be gathered to enable judg- ment on the extent to which the quality of the area's mandatory wilderness characteristics contributes to its suitability for wilderness designation." For some WSAs where BLM believes that significant differ- ences in quality exist, Partial Wilderness Alterna- tives have been formulated to portray this required information. This does not violate the Wilderness Study Policy. The areas included and excluded in the partial alternatives were identified based on the judgment of BLM personnel in the various Districts; consequently, the interpretation of wilderness quality may vary somewhat (much the same as public views regarding quality may vary). BLM does not consider this to be an objectionable condition, since those per- sonnel most familiar with on-the-ground conditions are best able to determine areas with differing qualities. 3.37 COMMENT: The description of the alterna- tives and analysis should recognize the potential of future technology and alternatives. [Sierra Club, Cache Group; Bruce Chesler; et al.] a. Concerning energy-related resources, the Draft EIS highlights several unproven technologies such as oil shale and tar sand. Certainly the wind blows in Loa and the sun shines enough in Hanksville to consider these alternative energy sources on an equal basis on BLM lands in Utah. Although we each have our own preconceptions of how energy may be produced, who would have questioned anything but wood or coal could have powered an engine 100 years ago? Because this document is a plan for the future, wind and solar technologies are a reasonable consider- ation. b. BLM also should review other technologies that can remove minerals and fossil fuels from wilderness areas without surface occupancy of the land. This could involve slant drilling and boring and subsurface mining with entrances outside of a wilderness bound- ary. Additional concerns involve alternative sources for the conflicting minerals and fossil fuels. BLM should identify possible mineral sources outside of potential wilderness areas that would meet local, State, and national needs. An attempt should be made to recommend alternative minerals that would suit the needs of the nation in place of the conflicting min- erals found on the lands in question. 3.37 RESPONSE: The potential advantages of fu- ture technology are acknowledged; however, it is un- certain that specific and currently unknown future technologies will fully replace the need or potential need to utilize mineral and energy resources present in some of the WSAs. Because of this uncertainty, it is not possible to recommend specific extractive tech- niques, new processing technologies, or alterna-tive minerals that may be viable in the future. The EIS analysis, of necessity, must deal with available data, known technologies, and current market trends and conditions. It is based on "reasonably foreseeable" (CEQ, 1986) conditions and assumptions. Also, see the responses to General Comments 2.20, 8.8, and 9.12. 3.38 COMMENT: A description of mitigation is needed for nondesignated parts of alternatives. [Utah Wilderness Coalition] The Draft EIS fails to provide "appropriate mitiga- tion measures" to impacts that the Draft EIS proposes for lands found unsuitable for wilderness designation. While many of the alternatives list the wilderness values that would be lost with nondesignation, BLM consistently fails to describe what actions it would take to mitigate the cumulative impacts of develop- ment upon natural values on lands not designated wilderness. For example, BLM says the numerous archaeological sites and opportunities for solitude and recreation, as well as wildlife habitat, will be lost if tar sand development occurs. No description of the mitigation needed to protect these resources is given 31 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES in the Draft EIS. This same situation is found with most of the WSA descriptions of recommendations for either partial or no wilderness. BLM describes in great detail the commodities that may be lost or fore- gone through wilderness designation, but never de- scribes the loss of wilderness values if the land is not statutorily protected as wilderness-strange, to say the least, in a document that purports to be an analy- sis of Utah's BLM wilderness. 3.38 RESPONSE: Management actions (including mitigation) are part of the description of the No Action/No Wilderness Alternative. Also, mitigation for nondesignated areas is included in the description of the partial alternatives. One of the analysis assumptions states that future users in areas included in the study would meet requirements for all applicable Federal, State, and local permits. This indicates that standard and spe- cialized mitigation would be applied to projects to pro- tect wildlife, threatened and endangered plants, cul- tural resources, air quality, etc. Also, see the response to General Comment 9.7 for a discussion on environmental standards. 3.39 COMMENT: The BLM Proposed Action Alterna- tive is designed around a strong commodity produc- tion bias. [Sierra Club, Cache Group; Utah Wilderness Coalition; Randolph Jorgen; Dennis Slifer; Ann Wechsler, et al.] a. All of the areas identified in the Commodity Production Alternative should be included in the Pro- posed Action since, by definition, there is little or no resource conflict. Since these have already been de- termined to have necessary wilderness characteris- tics, why should they not be designated? These areas include Cougar Canyon, Mt. Ellen-Blue Hills, Fremont Gorge, and Daniels Canyon. b. Throughout the Draft EIS it appears that min- eral values have taken a precedence over all other noncommodity values, such as wilderness. Whenever a potential mineral conflict occurs, no matter how insignificant when compared against other values, the area (or part of it) has been removed from further consideration. This is wrong. The intent of Congress was for BLM to find lands that meet wilderness qualities, such as solitude and opportunities for primitive recreation, and then rec- ommend them for wilderness designation. Congress did not direct BLM to only select wilderness quality lands that were free from any possible commodity use. This is where the process appears to be flawed, as executed by the Utah BLM office. We believe that the entire Draft EIS process in Utah has been flawed by this mineral development bias since the early Statewide inventories. Wilder- ness is truly a finite resource just as any fossil fuel or mineral. If a land has valuable minerals, it can remain there for future emergency needs. The 1964 Wilderness Act provides a mechanism for releasing such lands. In the Draft EIS, it appears that the following WSAs received reduced wilderness recommendations because of this analysis: The Blues, Mud Spring Canyon, Burning Hills, Death Ridge, Carcass Canyon, French Spring-Happy Canyon, Mt. Pennell, Cheese- box, Negro Bill Canyon, Jack Canyon, Coal Canyon, Spruce Canyon, Flume Canyon, and Winter Ridge. As potential evidence for this anti-wilderness bias with an emphasis on mineral extraction and devel- opment, the following Draft EIS quote shows how BLM developed alternatives to work around any potential mineral conflicts: "The objective of this alternative is to . . . reduce (potential) tar sand conflict." (French Spring-Happy Canyon WSA Analysis, page 9). Examples of this approach can be found through- out the Draft EIS. We are also concerned about BLM using existing claims and other similar conflicts. We remind BLM about the following procedure from the Wilderness Study Policy: "Disqualifying a WSA from consideration as suitable for wilderness preservation based solely on assumptions about values resulting from mining and grazing activities, which the (1964) Wilderness Act allows, would be inconsistent with the Act." We do not believe that this policy has always been adhered to by BLM when considering wilderness quali- fications for Utah public lands. c. The BLM Proposed Action is not only a reflec- tion of anti-wilderness bias in the agency, but is also indicative of their bias for commodity production. The most damning piece of evidence to support this claim is tucked away in Volume I, page 25, Alternatives Considered and Eliminated from Detailed Study sec- tion. In this discussion of the Commodity Production 32 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES Alternative is this statement: "... it was not given detailed study in this EIS because the overall effect of this alternative on commodity production would be similar to that of the BLM Proposed Action." d. During recent years, much of this rugged Escalante Country wilderness, which encompasses the headwaters of the Escalante River, has been open- ed to development. The integrity of this magnificent unit of pristine plateau and canyon country has al- ready been seriously eroded, and now you propose to release another 45,000 acres to further degradation! Conflicts with development of tar sand in the Circle Cliffs and the potential mining of uranium appear to be the primary reasons for the fragmentation of the entire unit in your wilderness recommendations. It appears that the extractive industries are winning the battle for the Colorado Plateau. e. BLM needs to discuss the Commodity Production Alternative and how it applies to the Fiddler Butte area. It would appear that, with the unlikely develop- ment of minerals, an all wilderness recommendation would also be part of the Commodity Production Alternative. For the scenario most likely to occur, the commodity production differences between the alternatives for minerals is zero. 3.39 RESPONSE: The Wilderness Act requires that mineral resources information be obtained and that certain mineral developments be allowed in wilder- ness areas. FLPMA specifically requires that mineral resources be considered as part of the BLM wilder- ness review process. Both of these acts reflect a strong Congressional concern for mineral resources in areas considered for or designated as wilderness. The Wilderness Study Policy (USDI, BLM, 1982a) states: "Recommendations as to an area's suitability or unsuitability for wilderness designation will re- flect a thorough consideration of any identified or potential energy and mineral resource values present in the area." Resolution of conflicts is necessary where mineral extraction would conflict with wilder- ness designation or vice versa. The Utah BLM Statewide EIS is consistent with the concern expressed by Congress and with the Wilder- ness Study Policy. Mineral resources have been con- sidered to the extent that information is available (General Comment Response 15.1). The BLM Proposed Action does reflect preference to mineral resources in certain WSAs where BLM believes those resources outweigh wilderness values; however, it also gives preference to wilderness values in certain WSAs where BLM believes that wilderness values outweigh mineral values. In some WSAs where both values are high, BLM has proposed partial alternatives to mini- mize conflicts and/or to allow substantial opportuni- ties for beneficial use of both wilderness and nonwil- derness resources. The BLM Proposed Action in the Draft EIS has been reviewed and refined considering new mineral data and other information. It represents, in the judg- ment of BLM, an objective and unbiased proposal that can serve both wilderness and commodity develop- ment interests and is reflective of the broad mandate for multiple use (including wilderness in some loca- tions) as established by Congress for the public lands. Mineral resources information for the Escalante country, Fiddler Butte, and other WSAs has been reviewed. The influence of mineral resources in the BLM Proposed Action in the Final EIS is explained in the summary of rationale added to this Final EIS in Volume I, Appendix 11. 3.40 COMMENT: The Zion National Park areas should be excluded from the wilderness alternatives. [Utah Counties] A concern with the numerous small WSAs around Zion National Park is the fact that they do not meet a number of wilderness characteristics outlined in the Wilderness Study Policy. Such areas should be ex- cluded from the BLM wilderness study process and be considered independently as a possible park expan- sion under the provisions of an independent park expansion bill. 3.40 RESPONSE: On April 18, 1985, the United States District Court of the Eastern District of Cali- fornia (Sierra Club et al. vs. Watt et al., Civil S-83- 035 LKR) determined that the small areas adjacent to Zion National Park do meet the wilderness inventory criteria and must be included as WSAs. Since adja- cent NPS lands have potential for wilderness designa- tion, BLM has no discretion to exclude them from the wilderness study process. Also, the areas have been and may, in the future, be considered in a separate park expansion bill, as explained in the response to General Comment 3.23. Also, see the response to Gen- eral Comment 2.12. 33 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES 3.41 COMMENT: The White River area should be included. [Uintah Mountain Club, Clay Johnson, D.C. Kennell, et al.] a. We propose that an area of approximately 8,500 acres in the canyon of the White River south of Vernal be included in the NWPS. An outline of our proposed boundaries are on the map (submitted to the BLM Vernal District). It is a lovely area of gentle meanders, cotton- wood groves, grassy benches, and changing banks. It usually is the perfect river for the inexperienced boatman, the novice outdoorsman, and the weekend wanderer. This area was rejected for further study by BLM in 1979 for suspect reasons. The boundaries for a potential WSA were much too generous, the prospec- tive area much too large, so that conflicts with roads, well sites, pipelines, and leases were bound to disqualify the proposal. What we did was simply to contract the boundaries and trim the size of the area, while maintaining the qualities for a wilderness area. In a meeting in March 1986 with the Vernal District BLM personnel, we discussed the proposal, and we were told at that time that no obvious conflicts could be identified that would be really significant. They promised to continue to look into the situation for us. Judge Kane's recent decision concerning water rights in Colorado wilderness appears to have many different interpretations, and it's true that no final interpretation has been given to it. But it appears to indicate to me that water rights adjudicated to a new wilderness would still be junior to existing water rights on the White River. Thus, there appears to be no significant threat to water use upstream or down- stream from our proposed wilderness. If there were conflicts and the conflicts were significant, I guess one alternative would be to let the White River go dry completely. I don't think that's a very good alterna- tive, either. Why not then preserve this lovely river canyon for the enjoyment of future generations? If the Ver- nal BLM Office can release thousands of acres of land annually for commercial development, it can certain- ly afford to propose and manage as wilderness a modest area like the White River Canyon. b. Our 110-member club supports the inclusion in your Final EIS of a proposal to designate as wilder- ness an area of approximately 8,600 acres in the canyon of the White River in southern Uintah County. The proposal enjoys widespread local support among conservationists and recreationists and is certainly deserving of legislative protection. We suggest that, although the White River was not a WSA during the BLM Statewide wilderness review, the area repre- sented in our proposal should be reconsidered and included in your final recommendations to Congress. The area proposed for wilderness designation consists of the canyon of the White River, beginning approximately 15 river miles west of the new Bonanza bridge in Section 21 of grid R. 23 E. in the USGS Transverse Mercator Projection. This is just downstream from the mouth of Asphalt Wash at 109 17 east 30 36 30" north. The area proposed flanks the White River for approximately 12 river miles downstream and ends on the western boundary of Section 18 in grid R. 23 E. c. There are two ways to manage our multiple- use lands. One way is to try and use all the acres for any and all purposes. That doesn't work. You can't graze on a road. There are a lot of conflicting uses that just won't work out. The other way is to recog- nize certain uses are preempting and others conflict and to manage certain areas for the purposes to which they are especially suited. In the first 5 years in Uintah County alone, according to the Vernal Express. Wednesday, March 5, BLM deeded or long-term leased over 148,000 acres to various entities for such purposes as gar- bage dumps or road building and so on. These acres are effectively lost forever for use in a natural state, for recreation or for grazing. If BLM were to recommend the White River for wilderness designation, that would equal less than one- eighth of the BLM land leased or deeded for private and preemptive uses in Uintah County for just one year, 1984. d. The White River wilderness is no longer listed as a WSA, but should be reinstated as one. There is wide public support for this area to be maintained as wilderness. The area provides unique family recrea- tion opportunities with regards to easy canoeing and rafting. BLM has currently recognized the area as important for primitive recreational opportunity and is managing the area as such. It is a beautiful canyon 34 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES providing a scarce water-type recreational opportu- nity. e. The current list of BLM WSAs is inadequate and does not cover all the areas that have wilderness qual- ities and characteristics. One example is the proposed White River wilderness area located in Uintah County. The original White River WSA was totally inadequate, having pipeline corridors, exploratory wells, and roads within the area. Instead of re-evaluating the WSA to develop boundaries that would meet wilder- ness characteristics, the entire area was dropped and is not considered in the Draft EIS. At the public hearing held in Vernal, the large majority of the pub- lic expressed interest in a White River wilderness. A proposal was made with new boundaries that meet wilderness characteristics. Does BLM plan to consid- er public comments and include the White River wil- derness in an alternative in the Final EIS? 3.41 RESPONSE: The area along the White River suggested by the comments is being given special management attention by BLM, including restrictions on ORV use as cited by BLM land use plans. It has not, however, been added to the wilderness study. As explained in the response to General Comment 3.1, the inventory phase has been completed and the wilderness study currently is limited to the WSAs identified in the Draft EIS. 3.42 COMMENT: The United States Air Force (USAF) recommendations should be included in the Final EIS. [Brian O’Hara, LTC, USAF] The Air Force takes no position as to whether areas identified in the Draft EIS should be designated wilderness areas. There are, however, certain re- quirements that must be satisfied for the wilder-ness areas and the Utah Test and Training Range to co- exist. As stated throughout Volume II (West-Central Region) of the Draft EIS, high-speed low-altitude (100 feet above ground level) flights will continue with or without designated wilderness areas. The impact (sight and sound) is adequately identified with the Draft EIS. Per United States Air Force policy, we will not negotiate nor sign any agreement to avoid the proposed wilderness areas. The Utah Test and Training Range is a one-of-a- kind complex; it cannot be duplicated anywhere at any price. Missions conducted on the Utah Test and Train- ing Range include defense programs presidentially directed as top national priority. The ability to pro- vide such a unique complex for military testing must not be compromised. It is possible to protect the inter- est of BLM and preserve the training range as a national asset. The Air Force advocates the recom- mendations set forth in this response be included and made a matter of policy in the Final EIS. 3.42 RESPONSE: As noted in the comment, the de- scriptions of the alternatives indicate that USAF flights will continue with or without wilderness desig- nation. The USAF position of not negotiating or signing any agreement to avoid proposed wilderness areas is noted. 3.43 COMMENT: The EIS should explain how WSA and alternative boundaries were established. [Nation- al Park Service, Michael Salamacha, Kim Jennyson, John Veranth, Ginny Taylor, Owen Severance, et al.] Many boundaries of WSAs followed section lines instead of natural ground features. Boundaries of WSAs should follow topographic features rather than section lines. Boundaries of WSAs should be drawn which would ignore the presence of State land when adjacent to the WSA. Large areas were excluded in the inventory be- cause of the presence of State land. 3.43 RESPONSE: On occasion WSA boundaries were established along legal subdivision (section lines) where adjacent non-BLM lands occurred, or when identifiable on-the-ground topographic features were difficult or impractical to distinguish (e.g., bounda- ries that traversed across open ground where no top of slope, toe of slope, creek bed, ridge, etc., was identifiable). In these cases, following section lines makes it possible to establish a boundary that could be identified on the ground through legal survey. There is justification for use of either the natural feature or the section line techniques to establish boundaries. Those who favor the use of natural features point out that: 1. these are easy to distinguish on-the-ground by most wilderness users and by land managers; 35 GENERAL COMMENTS AND RESPONSES SECTION 3: INVENTORY AND ALTERNATIVES 2. they readily encompass or exclude selected landscape attributes; and 3. they are more reflective of "natural" values rather than artificial or arbitrary concerns. Those who favor the use of section lines believe that: 1. natural features are subject to adjustment over time, due to erosion, flooding, and other natural events; 2. legal subdivision lines are unchanging over time and maintain a high degree of precision, which can be made visible at key locations to aid users and field managers. Use of both techniques is allowed in BLM's procedures. Also, see the response to General Com- ment 6.4. 36 GENERAL COMMENTS AND RESPONSES SECTION 4 ROADS, WAYS, AND CHERRY-STEMS INDEX 4.1 The Draft EIS inadequately discusses the defini- tion of roads in WSAs. (p. 1) 4.2 BLM hasn't recognized the State and local govern- ment definitions of a road. (p. 2) 4.3 The discussion of the setback on wilderness bound- aries adjacent to roads is inadequate, (p. 3) 4.4 UDOT recommends a 100-yard setback for wilder- ness areas along all State or Federal-aid highways. (P- 4) 4.5 Cherry-stemming of roads biases the wilderness decisions and creates manageability problems. BLM is not properly managing cherry-stemmed roads, (p. 4) 4.6 BLM incorrectly classified the Green River as a road. (p. 4) COMMENTS AND RESPONSES 4.1 COMMENT: The Draft EIS inadequately dis- cusses the definition of roads in WSAs. [Utah Coun- ties, Cache County Corporation, Richard Christie, Utah Woolgrowers, Kim Jennyson, et al.] a. Certain roads on BLM lands meet the State defi- nition of a county road, but this was not pointed out in the EIS discussions of wilderness criteria. WSAs that contain roads do not meet the roadless criterion for wilderness and should be dropped from further wilder- ness study. b. BLM's definition of roads, which categorizes some as ways, requires rethinking. For example, in southeastern Utah, numerous roads run through sever- al WSAs. These are not maintained by mechanical means, nor do they need to be in Utah's climate. These ways which, as in at least one case, can sus- tain speeds of 35 miles per hour, should qualify as roads. c. A road by any other name is called a way. Who- ever determined that a road could be called a way and get by in wilderness is really like that character in Alice in Wonderland who said "I choose whatever I want to mean by words." We could say that Interstate 70 is a road and everything else is a way, if we want- ed to designate an area as wilderness. I would suggest the concept of ways and roads in the EIS is flawed. d. After reviewing the Utah BLM Statewide Draft EIS, I conclude that BLM used very conservative judg- ment in deciding what was a road and what was not in defining WSAs. The rule of thumb used appears to be: (1) if it is used with any frequency by anybody to go to a destination for commercial or recreational pur- poses, it is a road, regardless of the manner of con- struction or maintenance; and (2) even if it is not used, if the road cuts or other characteristics make it substantially noticeable and not subject to natural rehabilitation, it is at least a human intrusion and should be left out of a WSA. Thus, the complaint by certain public officials that roads were included by the Utah BLM in its wilderness study processes is specious. e. A definition of road versus ways is needed. What determines a road? What is a way that has only been maintained once? Is it a road? 4.1 RESPONSE: The Glossary to Volume I defines roads and ways. Also, see General Comment Response 4.2 which discusses the definition of a road. For the purposes of the BLM wilderness inven- tory, the following definition of a road was adopted: The word "roadless" refers to the absence of roads which have been improved and maintained by mechanical means to ensure relatively regular and continuous use. A way maintained solely by the pas- sage of vehicles does not constitute a road. This language is quoted exactly from the legisla- tive history of FLPMA, the House of Representatives Report 94-1163, page 17, May 15, 1976. It is the only statement regarding the definition of a road in the law or legislative history. From the language in FLPMA's legislative history, it appears that Congress specifically intended BLM to follow the definition in the House Report. 1 GENERAL COMMENTS AND RESPONSES SECTION 4: ROADS, WAYS, AND CHERRY-STEMS Therefore, BLM has adopted and will use the fol- lowing sub-definitions of certain words and phrases in the BLM road definition stated above, as taken from the Wilderness Inventory Handbook: Policy. Direction. Procedures, and Guidance for Conducting Wilderness Inventory on the Public Lands (USD!. BLM. 1978), Improved and maintained: Actions taken physical- ly by man to keep the road open to vehicular traffic. Improved does not necessarily mean formal construc- tion. Maintained does not necessarily mean annual maintenance. Mechanical means: Use of hand or power machin- ery or tools. Relatively regular and continuous use: Vehicular use which has occurred and will continue to occur on a relatively regular basis. Examples are: access roads for equipment to maintain a stock water tank or other established water sources; access roads to maintain recreational sites or facilities; or access roads to mining claims. Roadless: Refers to the absence of roads which have been improved and maintained by mechanical means to ensure relatively regular and continuous use. A way maintained solely by the passage of ve- hicles does not constitute a road. 4.2 COMMENT: BLM hasn’t recognized the State and local government definitions of a road. [Utah Coun- ties, San Juan County, et al.] a. The wilderness study fails to recognize the Class D road system established by the State Legis- lature. The Wilderness Act of 1964, as amended, does not define a road. FLPMA of 1976 does not define a road. Agencies that have traditionally operated under authority of the Wilderness Act of 1964 have evolved their own definitions. CFR, Title 43, Part 19, Subpart A, which pertains to the NPS and the FWS, contains a definition of roadlessness. Part 19, Subpart E, per- tains to the BLM, and it does not contain a road defini- tion (USDI, BLM 1978). The USDI has taken the posi- tion that, whether or not a road is a public highway is determined by the law of the State where the land is located, and the State courts are proper forums to determine whether a public highway under 43 U.S.C. 932 has been created (Homer Meeds, 26 IBLA 281, 1976). Section 27-15-1 UCA (Office of the Solicitor, 1978) defines a road as: Road means any road, way, or other land surface route that has been or is established by use or con- structed and is maintained to provide for usage by the public for vehicles with four or more wheels that is neither a Class A, Class B, or Class C road under Article 9, Chapter 12, Title 27 (Office of the Solici- tor, 1978). In this definition "maintained" means to keep the road reasonably passable for vehicles with four or more wheels. If a road is dedicated and abandoned to public use by uninterrupted use by the general public for a peri- od in excess of 10 years, then that road, unless other- wise designated, is under the control of the county commission in the county where it is located (Office of the Solicitor, 1978). Rainfall in the Utah BLM WSAs is slight (5 inches in the low areas to 25 inches in the Henry Mountains and mountains of the West Desert, BLM Draft EIS, Vol- ume I, page 59). Erosion and degradation of roads on Utah BLM lands is correspondingly slight. Extensive or frequent maintenance, either by hand or mechani- cal means, is usually not necessary to maintain "rea- sonably passable" conditions for the type of vehicles customarily found on Utah BLM lands. For these rea- sons, the frequency of maintenance on Utah BLM roads does not necessarily serve as a measure of whether a given passage is or is not a road for wilder- ness purposes. Certain roads on BLM lands meet the State defini- tion of a county road: they do receive recurrent use for preplanned, predetermined, and intended purposes and yet they were included in WSAs without recogni- tion of their legitimate status as roads. These roads will be identified individually in the discussion of spe- cific WSAs. The rationale and legal precedents dis- cussed above serve as a basis for our claim that the passages in question are, in fact, roads under Utah law and also for our claim that they should be recog- nized as such by BLM. We believe that the Draft EIS was inadequate in its evaluation and designation of certain roads on lands administered by BLM. b. Regular use of a road should be considered maintenance. 2 GENERAL COMMENTS AND RESPONSES SECTION 4: ROADS, WAYS, AND CHERRY-STEMS 4.2 RESPONSE: The Glossary in Volume I defines a road and a way as used in the wilderness study by BLM. Also, see General Comment Responses 4.1, 4.3, 4.4, and 4.5 for discussions on roads, ways, and cherry-stems. Congress, in using the language contained in House Report No. 94-1163, defined a road for purposes of the wilderness inventory. By using this definition, Congress did not make any distinction between county Class D roads, highways, or other forms of vehicular routes, except to define a road for purposes of the wilderness inventory. Following the definition given by Congress, BLM applied the criteria in assessing roads in the wilderness inventory. Vehicular routes in question either met that criteria or did not. Whether or not the county had classified the road as a Class D road for their purposes had no bearing on the deter- mination of a road for purposes of the wilderness re- view process. The county or State government classi- fication of a vehicle route as a Class D road was not adopted by Congress, and the definition established by Congress governs the Federal wilderness review process. The State of Utah legislature has defined a Class D road as: "Road" means any road, way or other land sur- face route that has been or is established by use or constructed and is maintained to provide for usage by the public for vehicles with four or more wheels that is neither a Class A, Class B, or Class C road under Article 3, Chapter 12, Title 27(2). This definition differs considerably from that giv- en by the Congress of the United States in their legis- lative history of FLPMA. The definition of a road giv- en by Congress must be used throughout the Federally mandated wilderness review. 4.3 COMMENT: The discussion of the setback on wil- derness boundaries adjacent to roads is inadequate. [Utah Wilderness Coalition] a. In Volume I of the Draft EIS, BLM makes an assumption which sets back a potential wilderness boundary from 30 to 300 feet from the current bound- ary. BLM assumes that a maintenance-and-use border would be allowed along roads adjacent to or cherry- stemmed into the wilderness area for purposes of road maintenance, temporary vehicle pull-offs, and trailhead parking. The problem with this assumption is that it automatically deletes thousands of acres of land from wilderness protection with no comparison of the wilderness values lost to the convenience gain- ed. Often, this kind of boundary change would exclude scenic cliffs and streams. b. BLM plans to determine the amount of setback "during preparation of official wilderness maps and boundary descriptions required subsequent to wilder- ness designation." This process would occur without public review or environmental analysis. 4.3 RESPONSE: See the Draft EIS, Volume I, Chap- ter 2, Description of the Alternatives section. The complete statement referred to above reads as fol- lows: "This border would extend up to 100 feet from the edge of the road surface. It is noted that this 100- foot setback has been used throughout the EIS for all roads that border or are cherry-stemmed in WSAs. The intent is to illustrate the concept of operation and maintenance corridors along existing roadways. In ac- tual practice, the setback may vary from 30 to 300 feet from the road centerline, depending on the type of road. This would be determined during preparation of the official wilderness maps and boundary descrip- tions required subsequent to wilderness designation (USDI, BLM, 1985b)." Acts of Congress designating wilderness general- ly state that "As soon as possible after enactment of this Act, a map and a legal description of each wilder- ness area designated by this Act shall be filed by the Secretary of the Interior with the Committee on Energy and Natural Resources of the United States Senate . . ." There is no authority under existing law for BLM to adjust or change boundaries provided by Congress. BLM included statements on the setbacks under guid-ance of USDI Instruction Memorandum 85- 381 (USDI, BLM, 1985b), which notes that "Congress traditionally has used the following setback standards for wilderness boundaries along existing roads: Distance from Centerline Type of Road 300 feet 100 feet 30 feet High standard roads such as paved highways High standard logging road6 Jeep roads, low standard logging roads, dirt roads used for right-of-way maintenance, etc.' 3 GENERAL COMMENTS AND RESPONSES SECTION 4: ROADS, WAYS, AND CHERRY-STEMS The setback from existing roads was analyzed and included in the Draft EIS for public review. Even though the setbacks could include a large number of acres, the configuration of these setbacks as extreme- ly narrow areas along the fringes of wilderness would not pose a significant threat to the management or wilderness values of the affected areas. 4.4 COMMENT: UDOT recommends a 100-yard setback for wilderness areas along all State- or Fed- eral-aid highways. [Utah Department of Transporta- tion] a. The need to widen or make safety improve- ments is necessary and likely in the future. Since the presence of a highway is not in concert with wilder- ness intent, we do not feel that this setback and the resulting minimal reduction in acreage would have an effect on the proposed wilderness areas. b. Since highway right-of-way lines are a definite and usually visible line, they make a good reference. However, it is often necessary to change right-of- way lines slightly to accommodate a realignment for safety or access purposes. I would request that high- way right-of-ways receive a 100-yard setback for special areas like WSAs and ACECs. This would avoid the red tape we have recently experienced when a line adjacent to a WSA was requested to be moved 30 feet to accommodate an access to a BLM road. 4.4 RESPONSE: See the response to General Com- ment 4.3. Also, see Volume I, Chapter 2, Description of the Alternatives section. As stated in the Draft EIS, a setback is assumed; however, it will vary in width depending on the type of road, individual circumstances, and the boundaries established by Congress. 4.5 COMMENT: Cherry-stemming of roads biases the wilderness decisions and creates manageability problems. BLM is not properly managing cherry- stemmed roads. [Advocates for Multiple Use, Ginny Taylor, Miki and John Magyar, Tom Sewell, et al.] a. Cherry-stemming should not be allowed be- cause it simply ignores the presence of roads and erroneously allows BLM to include areas in the study that obviously lack wilderness characteristics. Fol- lowing the definition of cherry-stemming will create manageability problems by allowing access. Cherry- stemming roads makes a mockery of wilderness. b. BLM needs to close all cherry-stemmed roads in WSAs. c. BLM should restrict ORVs on cherry-stemmed roads. 4.5 RESPONSE: See the response to General Com- ment 4.1. Inventory criteria specified that an area must be roadless to qualify as a WSA. The boundary of a WSA was to be placed at the physical edge of a road, right-of-way boundary, or other similar fea- ture. Cherry-stemming a road that intruded into the roadless area followed wilderness inventory guide- lines, because the boundary was drawn along the edge of the road to the end and back down the other side of the road. Cherry-stemming is required to follow the definition of a road while also following the definition of roadless. The presence of cherry-stemmed roads may create manageability problems from vehicles en- tering a wilderness area, but may also provide better access for visitors. When applicable, the effect of cherry-stemmed roads on manageability is analyzed in Volume I and WSA specific analyses (Volumes II through VI). 4.6 COMMENT: BLM incorrectly classified the Green River as a road. [Utah Wilderness Coalition, et al.] a. In Labyrinth Canyon, BLM fragmented the WSA by saying that the river divided it and that a river is a road. This justification is pure insanity. The Colo- rado River through the Grand Canyon carries motor- ized boats, yet is not legally a road. Neither is Yellow- stone Lake in Yellowstone National Park or Jenny Lake in Grand Teton. 4.6 RESPONSE: As decreed by the U.S. District Court (Civil Suit Number C-201-62, January 8, 1965), and the U.S. Supreme Court (283 U.S. 64) May 18, 1931, the section of the Green River below 12-mile rapid (approximately 8 miles north of Green River, Utah) is navigable. The navigable portion of the river is not public land and does not qualify for wilder- ness study. Considering intrusions east of the river, the river was used as the boundary for the Horseshoe Canyon (North) WSA west of the river. 4 GENERAL COMMENTS AND RESPONSES - SECTION 5 INTERIM MANAGEMENT INDEX 5.1 BLM has allowed intrusions in direct violation of the IMP nonimpairment standards and, in certain in- stances, has used these intrusions as rationale for not recommending areas or parts of areas for wilder- ness. (p. 1) 5.2 Utah BLM is not consistent with other BLM offices in handling IMP violations, (p. 1) 5.3 BLM management of mining claims has been lack- ing. What is BLM doing to improve management and control of existing developments? (p. 2) 5.4 BLM is not protecting a number of WSAs from ORV use. (p. 2) COMMENTS AND RESPONSES 5.1 COMMENT: BLM has allowed intrusions in direct violation of the IMP nonimpairment standard(s) and, in certain instances, has used these intrusions as rationale for not recommending areas or parts of areas for wilderness. [Utah Wilderness Coalition, et al.] 5.1 RESPONSE: See Volume I, Glossary definitions for "grandfathered use" and "nonimpairment cri- teria." Public Law 94-579 (FLPMA) states: "(C) During the period of review of such areas and until Congress has determined otherwise, the Secretary shall continue to manage such lands according to his authority under this Act and other applicable law in a manner so as not to im- pair the suitability of such areas for preservation as wilderness, subject, however, to the continua- tion of existing mining and grazing uses and miner- al leasing in the manner and degree in which the same was being conducted on the date of approval of this Act: Provided, that, in managing the public lands the Secretary shall by regulation or other- wise take any action required to prevent unneces- sary or undue degradation of the lands and their resources to afford environmental protection." Following the intent of law and regulations, BLM's IMP allows certain activities to take place within WSAs that will not "impair the suitability of such areas for preservation as wilderness." Other activi- ties are not necessarily a discretionary action with BLM except to prevent "unnecessary or undue degra- dation." These activities generally involve "valid ex- isting rights" and "grandfathered" uses as provided in the statement: "subject, however, to the continuation of existing mining and grazing uses and mineral leas- ing in the manner and degree in which the same was being conducted on the date of approval of this Act." If these permitted activities impair wilderness val- ues, then BLM will so note that activity and will make a recommendation to Congress accordingly. Activities proposed within WSAs are reviewed through NEPA process to determine if the proposed activity is grand- fathered, is a valid existing right, or if the activity will impair the suitability of the area for preserva- tion as wilderness. These activities are also review- ed to determine if the lands can be rehabilitated to a substantially unnoticeable condition by the time the Secretary reports to the President on the suitability or unsuitability of the area for wilderness preserva- tion. If the proposed activity meets the criteria as stated, it will generally be permitted within WSAs. WSAs are also monitored for unauthorized activities; appropriate actions are taken for these activities. A summary of IMP activities and the actions taken by BLM has been added to the applicable WSA analyses, in the Affected Environment, Wilderness Values, Natu- ralness section. 5.2 COMMENT: Utah BLM is not consistent with other BLM offices in handling IMP violations. [Utah Wilderness Coalition, et al.] We think the BLM in Utah is different from the BLM in other States. If somebody is caught damaging WSAs in New Mexico, the person responsible is fined and charged necessary administrative responsibilities to cover that and the necessary expenses to reclaim. In Utah, that's not the case. These kinds of violations are overlooked generally. 1 GENERAL COMMENTS AND RESPONSES SECTION 5: INTERIM MANAGEMENT 5.2 RESPONSE: Utah BLM has enforced require- ments for reclamation or restitution in cases of IMP violations. A list of violations and the measures taken by BLM has been included in the applicable WSA anal- yses, Affected Environment, Wilderness Values, Naturalness section. 5.3 COMMENT: BLM management of mining claims has been lacking. What is BLM doing to improve man- agement and control of existing mining develop- ments? [Rosemary White, et al.] 5.3 RESPONSE: BLM's management and control of existing mining claims has been consistent with ex- isting laws and regulations. Management of valid min- ing claims in WSAs is governed by the IMP (USDI, BLM, 1979). Management of valid mining claims in designated wilderness areas will be governed by the Wilderness Act of 1964 and FLPMA. Both laws recog- nize the rights of the mining claimant under the min- ing laws (see Appendix 1). The 43 CFR 3809 regula- tions govern mining activities on claims not located in WSAs, while the 43 CFR 3802 regulations govern min- ing activities on mining claims located within WSAs. 5.4 COMMENT: BLM is not protecting a number of WSAs from ORV use. [Utah Wilderness Coalition, et al.] a. BLM should manage WSAs to protect their wil- derness qualities until Congress can decide their fu- ture. During the last 6 months, personal observations have identified serious ORV damage in the following areas: Devils Canyon, San Rafael Swell, Crack Can- yon, Muddy Creek, and Mexican Mountain. BLM should investigate these areas immediately. If there is abuse, as reported, then all available ac- tion should be taken to prevent ORVs from entering these areas. BLM will lose credibility with members of Congress and the public if it cannot properly pro- tect the land as Congress requires. This is a serious problem and requires immediate attention. Overall, BLM's management of ORVs is very poor. BLM should have extensive travel plans readily avail- able for ORV users that clearly identify which lands are open, closed, or limited to ORV traffic. Along with maps, BLM should promote ORV control and, subsequently, public lands protection with the following: Media information, including advertisements. Signs and other markers on BLM boundaries. Physical barriers at critical WSA entrances. Intensive field enforcement in critical and highly abused areas. Legal action and enforcement as often as required. The FS is doing a much better job (although not complete) of controlling ORVs in critical locations. BLM should approach the FS for help on this matter. Perhaps an interagency task force should be estab- lished to coordinate this public lands problem. 5.4 RESPONSE: The policy of BLM with regard to ORV use in WSAs, as stated in the IMP, is: "Recreational use of ORVs may be permitted on existing ways and trails and within "open" areas designated prior to approval of FLPMA (October 21, 1976). The BLM will cooperate with ORV organiza- tions to achieve the least amount of new impact on lands under wilderness review. If impacts of ORVs, either on or off existing trails, threaten to impair the area's wilderness suitability, the BLM may close the affected lands to the type of ORVs causing the pro- blem . . . No lands will be designated as "closed" solely be- cause they are under wilderness review. But if in- creasing impacts threaten to impair wilderness suita- bility, the BLM will move to control these impacts and may designate the area as "closed" to the type of vehicles causing the problem, in order to control the impacts . . ." Although funds and manpower are limited, BLM is monitoring and controlling ORV uses to avoid impair- ment of the suitability of WSAs for wilderness desig- nation. Your concerns have been referred to the Moab District Manager for investigation and necessary action. The EIS analyzes the naturalness of the WSAs and, in Appendix 11, summarizes the rationale for the BLM Proposed Action. 2 GENERAL COMMENT RESPONSE SECTION 6 IN-HOLDINGS INDEX 6.1 In-held and adjacent lands are directly subject to the influence of wilderness management on BLM lands. State or private lands located within WSAs become locked-in by wilderness restrictions, (p. 1) 6.2 The EIS should point out that activities on State or private lands in-held or adjacent to wilderness areas could have an impact on wilderness values in- side the wilderness and, conversely, wilderness man- agement could affect State or private lands, (p. 3) 6.3 The State of Utah's position on exchange of lands and the impacts of the exchange should be clarified. (P- 4) 6.4 Although State sections adjacent to proposed BLM WSAs are beyond the direct authority of BLM, we rec- ommend the Final EIS consider these sections as poten- tial additions, (p. 5) 6.5 It is the position of local government that ex- changes (State in-holdings) should be to the net bene- fit of the State and not on an acre-for-acre or value- for-value basis, (p. 5) 6.6 Appendix 3 inaccurately reports the State sec- tions in six of the WSAs. (p. 5) 6.7 The title for Table 1, pages 282 and 283, should specify surface ownership, (p. 6) 6.8 Page 281, paragraph 1, lists the wrong number of WSAs with State in-holdings. Fifty-seven WSAs have State in-holdings, (p. 6) COMMENTS AND RESPONSES 6.1 COMMENT: In-held and adjacent lands are di- rectly subject to the influence of wilderness manage- ment on BLM lands. State or private lands located within WSAs become locked-in by wilderness restric- tions. [Utah Board of Water Resources, Utah Coun- ties, Utah Woolgrowers, et al.] a. The Draft EIS does not address the effect of wil- derness designation on the use and value of in-held and adjacent private and State lands. We want assur- ance that we will be able to have access by vehicle or whatever means we desire to the State lands inside of wilderness areas. b. The EIS says up to 330,114 acres of State trust lands are either in-held or adjacent to WSAs. This number is composed of 300 in-held sections and 234 sections that are so closely involved with wilder- ness boundaries that they could become isolated by either BLM or NPS wilderness proposals. An additional 311 sections are considered adja- cent, but not at the risk of becoming isolated. This means that a total of 845 sections, or approximately 540,800 acres (or 12.6 percent) of the State's trust land estate, is directly subject to the influence of wil- derness management on BLM lands. c. It says there will be a peripheral zone of influ- ence on lands adjacent to wilderness areas and, be- cause this factor was not considered in the Draft EIS, it can be fully expected that many more State sec- tions will be affected by wilderness management. This is particularly true in southern and southeastern Utah, where peripheral zones of influence are likely to overlap in many areas. d. The trust to which the State of Utah is bound and which is evidenced by these State-owned lands is a bilateral compact entered into at statehood by and between the Territory of Utah and the United States Government. The requirement of this bilateral com- pact is that the lands be used only to the benefit of the designated beneficiary. The designated benefici- ary is primarily the public schools of the State. The binding bilateral compact contained in the Utah En- abling Act cannot be changed by State statute or by State constitution amendment. The State, then, is bound to the obligation in its Enabling Act to manage the lands granted to it under terms of the bilateral compact in the best interest of the designated beneficiaries. However, because the Utah Enabling Act is valid United States law, and be- cause the compact contained within it is bilateral, and because there has been no change in the Enabling Act 1 GENERAL COMMENTS AND RESPONSES SECTION 6: IN-HOLDINGS since its passage, then it must be concluded that the Federal government is equally and currently bound to the terms of the agreement. To the extent that wilder- ness management has in the past and will in the future restrict the value of revenue-generating capacity of State lands, then the Federal government has violated its compact within the State. It is the position of rural local government in Utah that the Federal government is in error and in viola- tion of its compact with the State of Utah by virtue of proposing to subject State trust lands to the detri- mental effects of peripheral zones of influence by virtue of mandating that the State consider integral vistas with national parks and by virtue of having isolated certain school trust lands from full access and use by the State through either NPS or BLM wil- derness area designation. Such actions are tantamount to land use planning and zoning imposed from the Federal level upon the local level. They constitute a serious challenge to State's rights and are violative of historical prece- dent and the customary exercise of law. Affected local officials can support no further designation of wilderness in Utah until such time as the conflict between the terms of the bilateral compact and the designation of wilderness, with all of its attendant extraterritorial implications, is legally resolved. e. In-held and adjacent lands: State school trust lands are significantly involved in the wilderness proposal. In fact, 193,000 acres or one-tenth of the proposed wilderness areas are State-owned. To pre- vent conflicts between the State and Federal govern- ment, trade-out provisions for in-held lands would have to be incorporated into any wilderness bill. At the same time, water rights would have to be address- ed. Many water rights are filed in the name of the State on State lands in some of the WSAs. f. The Federal government rarely compensates owners for land taken in the wilderness process. Its priorities for dealing with in-holdings are (1) through donation by the non-Federal owners; (2) through coop- erative management agreement with the non-Federal owners; (3) through exchange; and (4) through pur- chase. Private in-holdings exist on some WSAs. Under a wilderness designation, it is unclear whether the private owner would receive adequate compensation. Given the amount of wilderness in Utah, there is little information on the effects that a wilderness designa- tion would have on limiting the use of nearby lands. Restrictions on motorized access and other manage- ment conflicts could impact adjacent lands. g. In a decision dated September 29, 1979, the United States District Judge Aldon J. Anderson ren- dered a decision that the State of Utah and its lessee, Cotter Corporation, had the right of access to State school sections. We believe that we have that same right to State school sections that we lease. We do not want to wait for lengthy amounts of time while BLM takes their time in writing an EIS or other docu- ments that would allow us to use our leased lands. We feel that there should be more addressed to State school sections in the EIS. h. There are approximately 6,000 acres of pri- vate in-holdings, besides thousands of acres of State land that will be impacted by wilderness designation. Possessive rights of individuals who have made im- provements on State and Federal lands will be, for practical purposes, lost. Private in-holdings will be adversely affected because of access, and operation of private property will be severely restricted. 6.1 RESPONSE: See Volume I, Introduction, State and Private Land In-holdings section. Also, see the responses to General Comments 7.1 and 7.2 for infor- mation on buffer zones and the responses to General Comments 6.2 through 6.8 for information on in- holdings. General Comment Response 23.10 addresses the State’s position on exchange of State trust lands. State or private in-held lands may be affected to some degree by wilderness management because there would be restrictions or operations on the adja- cent Federal lands. For example, the feasibility of ex- tracting minerals from isolated State sections may be reduced. Access will be granted to in-holdings within wilderness areas, as provided in the BLM Wilderness Management Policy (BLM Manual 8560) and as demon- strated in the Cotter Corporation decision. The EIS analysis assumes that access would be provided to State lands where there is a potential for future activ- ities and developments. The value of in-held or adjacent State or private land could be decreased due to restrictions possibly placed on activities occurring on adjacent Federal lands. These lands may also become more valuable, depending on the type of resources present. The trust land lease revenue produced from State land in-holdings is only a small percent of the trust 2 GENERAL COMMENTS AND RESPONSES SECTION 6: IN-HOLDINGS land income. For example, in 1987 the Utah Division of State Lands and Forestry contributed $11,226,792 to the public school fund and an addition- al $966,911 to other trust institutions (Utah Division of Natural Resources [UDNR], 1986). Because only about 5 percent of State trust lands are in WSAs (see Volume I, Chapter 3, Land Use Plans) and because the trust land income makes up only about 2 percent of the funding for public schools (UDNR, 1986), the un- likely loss of all State revenues from in-held and isolated State sections would not noticeably affect public school revenues on a local or State basis. No assurance can be given that "access by vehicle or whatever means" desired, can or will be granted. However, access will be a "combination of routes and modes of travel which will, as determined by BLM, cause the least impact on the wilderness resource and, at the same time, serve the reasonable purposes for which the State or private land is held or used." Provisions are also made in the law for the purchase or exchange of State or private lands within a wilder- ness area. Therefore, the State of Utah or any pri- vate land holder who has land that meets the criteria and will be affected by wilderness designation has the option to exchange those lands for other lands outside the wilderness area. BLM will abide by the laws enact- ed by Congress as they pertain to in-holdings within wilderness areas. Therefore, reasonable access will be provided to in-held lands or they will be exchanged and will not be "locked in" by wilderness designation. 6.2 COMMENT: The EIS should point out that activ- ities on State or private lands in-held or adjacent to wilderness areas could have an impact on wilderness values inside the wilderness and, conversely, wilder- ness management could affect State or private lands. [Utah Counties and State of Utah] a. If the exchange of in-held or otherwise substan- tially affected trust land does not occur for some rea- son, then the discussion of impacts on page 119 of Volume I of the Draft EIS is too passive in nature. The adverse effects on the manageability of the proposed wilderness may be so significant that some WSAs would not be suitable for wilderness designation. Por- tions of some WSAs would have to be dropped from further consideration because the WSAs dissected by State land would have to be studied as two WSAs rather than one. b. Vegetative manipulation, other range improve- ments, and water developments could occur on State lands, possibly without regard for visual impacts or other impacts on the wilderness values of surround- ing lands. Serious legal questions arise from fire spreading to State lands due to lack of suppression efforts on adjacent Federal lands. 6.2 RESPONSE: See Volume I, Introduction, State and Private Land In-holdings section. Also, see the responses to General Comments 6.1, 6.3, and 6.5 for information regarding in-holdings. The responses to General Comments 7.1 and 7.2 discuss buffer zones, the response to General Comment 1.14 discusses fire control, and the response to General Comment 23.10 discusses the State's policy on exchange of in-held lands. It is recognized that activities on adjacent or in- held land will affect wilderness values on public land. Activities on State or private land could detract from wilderness values. However, as stated in the Wilder- ness Management Policy (BLM Manual 8560): No buffer zones will be created around wilderness areas to protect them from the influence of activities on adjacent land. The fact that nonwilderness activi- ties or uses can be seen or heard from areas within the wilderness shall not, of itself, preclude such activities or uses up to the boundary of the wilder- ness area. When activities on adjacent lands are proposed, the specific impacts on those activities upon the wil- derness resource and upon public use of the wilder- ness area will be addressed in environmental assess- ments or environmental impact statements, as appro- priate. Mitigation of impacts from outside wilderness will not be so restrictive as to preclude or seriously impede such activities. These statements apply only to public lands and do not infer that activities or uses on State lands can be regulated by BLM. It is clear from these statements that, while there are to be no buffer zones around wil- derness areas that would preclude activities or uses, there will be a zone of influence around them that could restrict the manner in which some activities or uses on public lands could be conducted because of the wilderness area. No such restrictions could be exer- cised by BLM on State or private lands. What is done on surrounding State or private lands is up to those landowners, not BLM. GENERAL COMMENTS AND RESPONSES SECTION 6: IN-HOLDINGS As with most resource management issues, legal questions will continue to arise concerning Federal, State, and private land management practices. In re- gards to wilderness areas, it is the policy that "All fires will be controlled to prevent loss of human life or property within wilderness areas or to prevent the spread of fire to areas outside of the wilderness where life, resources, or property may be threat- ened" (Wilderness Management Policy, BLM Manual 8560). Currently, the various land management agencies (Federal, State, and county) cooperate to control and suppress wildfires. These cooperative efforts are ex- pected to continue, regardless of whose land the fire starts on. The legal questions associated with fire management practices are not generally fire suppres- sion, but the cause of the fire and whom is responsi- ble for paying for suppression efforts. These ques- tions have to be determined when and if a fire occurs and when the particular circumstances can be assess- ed. Instances where access to in-held lands would affect wilderness values have been analyzed in the Wilderness Values sections of the EIS. 6.3 COMMENT: The State of Utah's position on ex- change of lands and the impacts of the exchange should be clarified. [State of Utah, Utah Counties, and Utah Nature Study Society] a. In the interest of compiling an inventory of sub- stantially affected trust lands, the Division of State Lands and Forestry has commented on BLM's account- ing for lands in Volume I, Appendix 3, and has identi- fied changes. This should not be construed as meaning that the exchange of these lands will ultimately be re- quested nor that these are the only lands the division will want exchanged. b. During the briefing conducted by BLM when the Draft EIS was distributed to State agencies, BLM per- sonnel expressed concern over the Office of Manage- ment and Budget's opposition on an exchange program solely for the purpose of accommodating wilderness designation. BLM reported further that the office's position is that State lands surrounded by wilderness are worth less than lands with comparable resources not surrounded by wilderness. In other words, wilder- ness designation diminishes the value of in-held State trust lands. The Division of State Lands and Forestry rejects that position on the grounds that it is tanta- mount to a breach of the land grant trust by the Fed- eral government, a clear violation of the bilateral compact established in the Utah Enabling Act. As offi- cers of the trust, that division would be compelled to take whatever action is necessary, including litiga- tion, to challenge the diminishment of trust asset values. c. I would indicate also that the Association of Counties has taken a position expressing very real concern about the trading out of those trust lands. There are nearly 180,000 acres of State trust lands that are going to be affected by this designation. The legislature, in their next session, is going to ask to deal with the issue specifically and to urge the Land Board not to trade those sections out of the WSAs. The EISs which we're dealing with anticipate that those trust lands will be traded out. And I think that's something also that calls into question the complete- ness of the EIS. I don't mean to suggest that that's your problem. There was, as I understand it, and as I know full well, there was communication for the Governor’s office before the election last year that those trust sections probably would be traded out. But the position of the State and the policy of the State has changed since that occurred. d. What lands will be exchanged for the enclosed State lands within the wilderness areas? These ex- change lands should be identified and be evaluated within the EIS. Some of the exchanged lands under the State's direction may have more effect on wilderness areas than the present multiple-use management. 6.3 RESPONSE: See the response to General Com- ment 6.1. Also, see the response to General Comment 23.10 for a discussion on the relationship of wilder- ness to State of Utah land use plans and policies. Appendix 3 and Volume I, Chapter 2, have been revis- ed to reflect the current position of the State of Utah. Also, a discussion of the State's position has been added to the Land Use Plans in the Affected Environ- ment sections of the EIS. Since the State has not identified the sections that would be exchanged, public lands that would be ex- changed cannot be identified at this time. However, BLM's regulations for exchanges require that offered and selected lands be determined suitable through the public land use planning process, including compliance with NEPA. In general, Federal lands are not consider- ed available for exchange if threatened or endangered plant or animal species are present, if cultural 4 GENERAL COMMENTS AND RESPONSES SECTION 6: IN-HOLDINGS resources are unique enough to be appropriate for the National Register, or if exchange would create severe management problems for BLM. The effects of land ex- change on site-specific values is a consideration that will be addressed following designation. 6.4 COMMENT: Although State sections adjacent to proposed BLM WSAs are beyond the direct authority of BLM, we recommend the Final EIS consider these sections as potential additions. [National Park Ser- vice, Utah Wilderness Coalition, et al.] 6.4 RESPONSE: See the responses to General Com- ments 6.1, 6.2, 6.3, and 6.5 for information regard- ing in-holdings. Also, see Volume I, Introduction, State and Private Land In-Holdings section. The Wilderness Act (1964) and FLPMA (1976) au- thorize and mandate wilderness review; both indicate that only Federal lands qualify for the review. "An area of wilderness is further defined to mean in this Act an area of undeveloped Federal land retain- ing its primeval character and influence . . ." (Public Law 88-577, Wilderness Act, Eighty-Eighth Congress of the U.S., 1964). Sec. 603(a) of FLPMA states: "within fifteen years after the date of approval of this Act, the Sec- retary shall review those roadless areas of five thou- sand acres or more and roadless islands of the public lands, identified during the inventory . . ." (Public Law 94-579, FLPMA, Ninety-Fourth Congress of the U.S., 1976). State lands adjacent to WSAs are not public land administered by BLM and will not, therefore, be con- sidered as potential additions to wilderness. The Utah State Board of Lands and Forestry (1987) has indicat- ed that State lands will be exchanged only when the exchange is in the best interest of the citizens of Utah. BLM interprets this to mean that the State is not willing to exchange to further the purposes of wilderness. 6.5 COMMENT: It is the position of local govern- ment that exchanges (State in-holdings) should be to the net benefit of the State and not on an acre-for- acre or value-for-value basis. [Utah Counties] 6.5 RESPONSE: See the responses to General Com- ments 6.1, 6.2, 6.3, and 6.4 for a discussion on in- holdings and Volume I, Introduction, State and Private Land In-Holdings section. Volume I, Appendix 3, is a list of State lands in WSAs. The State of Utah has indicated that, if it is in the best interest of the citizens of Utah, some State lands would be exchanged if the surrounding or adja- cent BLM lands are designated as wilderness. As stat- ed in Appendix 3 of the Draft EIS: "BLM would endea- vor to use the exchange concept with roughly equiva- lent values, but it could also consider purchase under special circumstances." It is reasonable to assume that "value-for-value" for exchange would be the only fair and equitable way to balance the needs of both the American public and the citizens of Utah. In addition, Section 5(a) of the Wilderness Act (1964) and Section 603(c) of FLPMA (1976) provide for ex- change of in-held State or privately owned land for "Federally owned land in the same State of approxi- mately equal value . . ." (emphasis added). 6.6 COMMENT: Appendix 3 inaccurately reports State sections in six WSAs. [State of Utah] a. In the interest of maintaining an inventory of substantially affected trust lands, the following changes should be made. Mt. Ellen-Blue Hills: Delete T. 30 S., R. 9 E., SW1/4 SW1/4, sec. 32. Add T. 80 S., R. 11 E„ sec. 32-All, 640.00, 640.00. Mt. Hillers: Add T. 33 S., R. 11 E., sec. 32-All, 640.00, 640.00, T. 34 S., R. 11 E., sec. 16-All, 640.00, 640.00. Wah Wah Mountains: Delete T. 23 S., R. 16 W., sec. 2-All, 638.52, 638.52. Add T. 25 S., R. 16 W., sec. 2-All, 638.52. North Escalante Canyons/The Gulch: Add T. 35 S., R. 5 E., sec. 36-All, 640.00. Road Canyon: For T. 40 S., R. 19 E., sec. 16, insert comma after N1/2 NW1/4. Butler Wash: Add T. 32 S., R. 20 E., sec. 32-All, 640, 640.00. 6.6 RESPONSE: The list of sections has been updat- ed and revised. 5 GENERAL COMMENTS AND RESPONSES SECTION 6: IN-HOLDINGS 6.7 COMMENT: The title for Table 1, pages 282 and 283, should specify surface ownership. The Dirty Devil WSA includes about 2,555 acres of State land. The table lists zero acres of State ownership. [State of Utah] 6.7 RESPONSE: BLM concurs; the title of the table has been changed to indicate surface and mineral own- ership as well as percentage of BLM ownership. Also, the headings for private and State lands were revers- ed in the Draft EIS. These headings have been correct- ed in the Final EIS. 6.8 COMMENT: Page 281, paragraph 1, lists the wrong number of WSAs with State in-holdings. Fifty- seven WSAs have State in-holdings. [State of Utah] 6.8 RESPONSE: Recounting indicates that 53 WSAs have State in-holdings amounting to 177,790 surface acres and an additional 9,138 acres of mineral estate. The text of Appendix 3 has been changed accordingly. 6 GENERAL COMMENTS AND RESPONSES - SECTION 7 BUFFER ZONES INDEX 7.1 Wilderness designation automatically creates a buffer zone around the designated area. To what de- gree will wilderness be a factor in governing activ- ities on adjacent lands? (p. 1) 7.2 Environmentalists intend to push for buffer zones around wilderness, (p. 2) 7.3 BLM is illegally trying to establish buffer zones around some WSAs. (p. 3) COMMENTS AND RESPONSES 7.1 COMMENT: Wilderness designation automatical- ly creates a buffer zone around the designated area. To what degree will wilderness be a factor in govern- ing activities on adjacent lands? [Utah Counties, Utah Power and Light, Utah Mining Association, Utah Wool- growers, Utah Nature Study Society, Roy Morley, Michael Robison, et al.] a. It says (in the Draft EIS) that there will be a peripheral zone of influence on lands adjacent to wil- derness areas, so it can be fully expected that many more State sections will be affected by wilderness management. b. Although BLM wilderness will not "of itself" preclude or "seriously impede" activities on adjacent lands, it is clear that the existence of BLM wilder- ness will be a factor in the regulation of activities on adjacent lands. The question remaining is "to what de- gree will wilderness areas be a factor in governing activities on adjacent lands?" With a strict mandate to preserve wilderness character, it is arguable that wilderness proximal to a proposed activity could be a substantial factor negatively affecting that activity. The debate over logging at Gilbert Creek adjacent to the High Uintas wilderness is a current case in point. c. Boundaries around wilderness areas are con- stantly growing through the creation of buffer zones. These buffer zones are designed to ensure that a wil- derness area is cushioned by a protection zone. While this buffer or protection zone is not officially desig- nated as a wilderness area, history teaches that it will be managed in such a manner so as to prevent many of the multiple uses allowed in nonwilderness areas. Thus, the limited single use constantly en- croaches, becoming the only use. d. Regulation vagueness, combined with a clear overriding policy mandate (i.e., to preserve and en- hance the wilderness character), creates limitless opportunities for litigation to restrict certain uses that had been allowed through prior rights and impose certain limitations that were not anticipated by the general public during the review period. e. Contrary to what certain environmental groups say and would lead us to believe, it is undeniable that the buffer-zone concept is a current and relevant issue. Two bills now before Congress, 9B-2092 and 3B-1869, seek to establish environmental zones and tax benefit limitation zones, respectively, around Fed- erally protected areas. In view of this, I think BLM has erred in its fail- ure to analyze the possible negative economic impacts of restrictive peripheral zones of influence or quasi- buffer zone management on lands adjacent to wilder- ness areas. f. Once the land is designated as wilderness, vari- ous groups or agencies could exercise or otherwise exert control over the areas, thus changing the plans or attitudes of BLM. One such example is a Sierra Club decision. While the Secretary of Agriculture thought his management of an area complied with Fed- eral mandates, the Sierra Club thought otherwise and forced a change by judicial procedure. Similar tactics could also be employed by like groups, invalidating any promises or intentions of BLM. Historical pat- terns and precedents from national parks and estab- lished wilderness areas (i.e., logging in the Gilbert Creek area of the Uintas, restrictions on development near Canyonlands, Kaiparowits coal fields, etc.) is testament of the existence of buffer zones. Other government agencies could be delegated control over the areas by Congress, thus changing completely the managing body's attitude towards the use of the land. 1 GENERAL COMMENTS AND RESPONSES SECTION 7: BUFFER ZONES Any of these other groups, in addition to changes in policy of BLM itself, could affect changes in inte- gral vista policy, air quality standards, or buffer zone policy. The possibility exists that buffer zones could be created or that adjacent lands would be im- pacted in some manner by wilderness designation. g. The maps should also include the visual im- pacts. What happens if we designate a wilderness area? What happens outside that wilderness area? Is there a buffer zone? Would anything that could be seen from that wilderness area be precluded from taking place? We've had some experience with Canyon- lands Park, which was enlarged to provide a buffer zone. In all these areas, the EIS is inaccurate, vague, and incomplete, both in the treatment of the issues it treats and the ones it leaves out. h. Creation of buffer zones around wilderness areas has the same impact on existing uses and future developments as integral vistas do on areas surround- ing national parks. i. Future developments should be allowed up to the wilderness boundary. j. There seems some concern about buffer areas adjacent to wilderness areas. We examine many aspects of nature. Our members utilize hand lenses as their main tool. Thus, our outings do not go far from the automobile. These outings are often disrupted by ORV use, even to the extent that the motorcycles have traveled through our groups while observing na- ture. We recommend that wilderness boundaries exist right to the road to allow uninterrupted outdoor exper- ience. This would include the Buckhorn Wash area. k. BLM should make a priority of establishing wil- derness areas that will protect the integrity of the na- tional parks and monuments in Utah. Your proposals, as outlined in the Draft EIS, will not accomplish that worthy goal. 7.1 RESPONSE: See the responses to General Com- ments 6.1 through 6.5 for information regarding in- holdings and General Comments and Responses Section 10, for discussion of air quality. See the responses to General Comments 4.3 and 4.4 for information regard- ing wilderness boundary setbacks for roads. As stated in BLM's Wilderness Management Policy (BLM Manual 8560): No buffer zones will be created around wilderness areas to protect them from the influence of activities on adjacent land. The fact that nonwilderness activi- ties or uses can be seen or heard from areas within the wilderness shall not, of itself, preclude such activities or uses up to the boundary of the wilder- ness area. When activities on adjacent lands are proposed, the specific impacts on those activities upon the wil- derness resource and upon public use of the wilder- ness area will be addressed in environmental assess- ments or environmental impact statements, as appro- priate. Mitigation of impacts from outside wilderness will not be so restrictive as to preclude or seriously impede such activities. It is clear from these statements that, while there are to be no buffer zones around wilderness areas that would preclude activities or uses, there will be a zone of influence around them that could affect the manner in which some activities or uses could be conducted because of the wilderness area. Activities and uses will be allowed in areas adjacent to wilderness; however, some restrictions could be imposed that would restrict the manner in which those activities or uses could be carried out, accord- ing to the policy stated above. The extent of these restrictions will have to be determined on a case-by- case basis, depending on the type of activity propos- ed, its location, and its size. Land use plans would, at the time of their preparation, deal with these issues and establish any restrictions that would be foreseen at the time. The EIS does analyze the restrictions that would be placed on projected development or activi- ties on Federal lands within wilderness areas in each of the alternatives. State lands are not owned or controlled by BLM. The State of Utah independently owns and manages their lands; therefore, no zone of influence around wilderness areas on Federal lands would apply on lands controlled by State or private ownership. 7.2 COMMENT: Environmentalists intend to push for buffer zones around wilderness. [Utah Woolgrow- ers, Utah Power and Light, et al.] a. Environmentalists will have you believe that, even in wilderness, you can have grazing and wildlife. Is there grazing in Canyonlands National Park or Natural Bridges National Monument as there is on BLM? The answer is "No." They were all promised 2 GENERAL COMMENTS AND RESPONSES SECTION 7: BUFFER ZONES originally. If you think that environmentalists are satisfied with the lands they've locked up already, then why do I hear proposals to have buffer zones around the existing national parks, national monu- ments, and national recreation areas? b. The potential for claim of buffer zones is espe- cially critical in the WSAs in Emery County and near the Kaiparowits KRCRAs. c. So long as conservationists intend to push for buffer zones around wilderness areas, future wilder- ness designations must be made only in areas that do not conflict with current or future economic uses, or the wilderness-authorizing legislation specifically must grant permission for future development up to the boundary of each wilderness area. 7.2 RESPONSE: See the response to General Com- ment 7.1. For purposes of the EIS, it must be assumed that present regulations will be followed and buffer zones will not be established around designated wil- derness. BLM has no basis to assume that the wilder- ness management guidelines relative to buffer zones will be changed in the future. 7.3 COMMENT: BLM is illegally trying to establish buffer zones around some WSAs. [Utah Board of Water Resources] At a buffalo habitat inventory on April 23 and 24, 1987, the Richfield Associate District Manager stat- ed that BLM is going to create a 0.5-mile buffer zone around all WSAs to prevent actions that might harm the WSAs. We maintain that this is an arbitrary and capricious action that is not backed by law, common sense, or anything else. Is this another way to create more wilderness? We want the buffer zone idea dropped now. Just for your information, in the Mt. Ellen-Blue Hills 58,480 acres is proposed now; if they increase that to a buffer zone of 0.5 mile, it would increase to 82,060 acres, or a gain of 40.3 percent. The Blue Mountain would be a gain of 45.2 percent; the Dirty Devil a gain of 47.8 percent, Horseshoe Canyon a gain of 35 percent, Fiddler Butte a gain of 66.7 percent, Mt. Hillers a gain of 47 percent, and Little Rockies a gain of 39.7 percent. 7.3 RESPONSE: BLM does not have a policy of cre- ating buffer zones around WSAs. BLM managers have been advised to check the relationship of proposed activities to WSA boundaries when an activity appears to be within 0.5 mile of a WSA boundary. This is done to ensure that improper activities are not carried out inside a WSA. However, there is no specific restriction on land use up to the boundary of a WSA. 3 I ' GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE GENERAL COMMENTS AND RESPONSES - SECTION 8 RATIONALE INDEX 8.1 BLM deliberately failed to include rationale for its Proposed Action, which is illegal and makes effective public comment impossible, (p. 2) 8.2 A rationale section should be included in the Final EIS. (p. 3) 8.3 Many speculative resource values are used as rationale to not recommend WSAs for designation. More specific analysis and the USBM/USGS mineral reports are needed in the Final EIS to support the Proposed Action, (p. 4) 8.4 In many instances, the rationale used for recom- mendations is inconsistent with the analysis, (p. 6) 8.5 BLM should provide rationale for all WSAs not recommended for wilderness, (p. 7) 8.6 BLM overstepped its mandate and has confused suitability and desirability. This approach will pre- judice Congress in their deliberation on wilderness. (P- 8) 8.7 In the Final EIS, BLM should use a more holistic approach and give more consideration to the joint use of BLM wilderness and contiguous areas, (p. 10) 8.8 The analysis time frame used in the EIS Proposed Action is too short. BLM should consider long-term consequences in the analysis and the proposal, (p. 10) 8.9 BLM should answer the question of "How much wilderness is enough?" (p. 11) 8.10 BLM should remember that de facto wilderness will exist even if lands are not designated, (p. 12) 8.11 Ranking of wilderness values is inappropriate for rationale, (p. 13) 8.12 BLM should not use potential range projects or agricultural production as rationale for recommend- ing against wilderness, (p. 14) 1 8.13 The Draft EIS analysis of the No Action Alterna- tive is too optimistic and downplays impacts, (p. 14) 8.14 BLM’s recommendations are based on a pro- mineral bias. (p. 14) 8.15 BLM's wilderness recommendations have been influenced by the eastern mineral industries to dam- age western mineral interests, (p. 15) 8.16 In making wilderness recommendations, the BLM should remember that lands should be open to develop- ment. (p. 15) 8.17 In making recommendations, the BLM should rec- ognize industry's need to explore for and develop oil and gas. (p. 15) 8.18 BLM's use of potential transportation corridors in the Kaiparowits region as a wilderness issue is not valid, (p. 16) 8.19 BLM should not exclude any WSAs from the Pro- posed Action because of ORV use or manageability of ORVs. (p. 17) 8.20 By advancing a Proposed Action which recom- mends wilderness designation for WSAs of lower wilderness quality to avoid conflicts that may exist in WSAs of higher wilderness values, BLM fails to meet its responsibility as established by NEPA. (p. 18) 8.21 How will public comments be evaluated, utilized, weighted, and counted? (p. 18) 8.22 The role of the diversity criterion should be sole- ly to increase the diversity of ecosystems in the NWPS. (p. 19) 8.23 The Draft EIS should not include manageability as a selection factor, (p. 19) GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE 8.24 Outside sights and sounds should not be consider- ed as a solitude factor in making recommendations, (p. 19) 8.25 Proprietary information should not be allowed in the decisionmaking process because the information is not public and not subject to review, (p. 19) 8.26 Hazards to hikers is not a valid reason to elimi- nate areas from consideration as wilderness, (p. 20) COMMENTS AND RESPONSES 8.1 COMMENT: BLM deliberately failed to include rationale for its Proposed Action, which is illegal and makes effective public comment impossible. [Utah Wilderness Coalition] a. BLM has deliberately failed to include in the Draft EIS any specific rationale for its choices of Proposed Action under each WSA. This procedure is inconsistent with NEPA and CEQ regulations promul- gated under the Act. Furthermore, the failure to in- clude the reasons for each Proposed Action prevents effective public comment and thus makes an adequate record impossible. BLM argues that sections "1502.2 (g) of NEPA [sic]" and sections 1502.14(b) and (e), taken together, mean that BLM "should not provide" any justification for the Proposed Action until the decision document (Federal Register Notice). Rather, BLM states the agency should analyze each alterna- tive in detail and merely state the Proposed Action, if one exists. The result of this construction of the NEPA regulations is evidenced by the Utah BLM State- wide Draft EIS. Reviewers are confronted with a mass of descriptions of each studied alternative and a bare conclusionary identification of the agency’s Pro- posed Action. Readers are left to deduce the reasons for the agency's choice by reading between the lines of the different descriptions of the alternatives. By BLM's own admission, this is not possible in all cases. The section which BLM bases its position on reads, in entirety: "Environmental impact statements shall serve as a means of assessing the environmental im- pact of proposed agency actions rather than justify- ing decisions already made." BLM significantly omits the last two words of the quoted section. Thus, the agency reads the passage as forbidding the inclusion of rationales in a Draft EIS. When taken completely and in context, however, the section requires that NEPA's EIS process serves as a way of shaping decisions rather than a post-hoc method of rationaliz- ing off-the-record decisions. See 40 CFR 1502.5. In this way, public comment and other aspects of NEPA procedure contribute to the ultimate decision. BLM's construction of this section would accomplish just the opposite of the actual intent of the section. By with- holding the rationale for each Proposed Action from public scrutiny, BLM prevents public comment from helping to shape the decision as to which alternative will be selected in each WSA. The impression this procedure creates is that BLM wishes to make these decisions without public participation, using the Draft EIS as a means of legitimizing a decision not based on the record. NEPA and its regulations clearly do not allow such a strategy. Sheltering the rationale for BLM's decisions from public participation is inconsis- tent with other sec-tions of NEPA and its regulations as well. For example, Section 1500.1(b) of the CEQ regulations declares that "public scrutiny [is] essen- tial to implementing NEPA." No public scrutiny of the reasons for BLM's Proposed Action is possible. Section 1500.1(b) also requires that NEPA docu- ments "concentrate on the issues that are truly signif- icant to the action in question, rather than amassing needless detail." As mentioned above, the Utah BLM Statewide Draft EIS recites factual details for each alternative without identifying those issues that the choice of the Proposed Action was based on. Supply- ing rationale is necessary in order to identify those issues which are "truly significant" to the agency decision. Section 1502.9 of the CEQ regulations re- quires that a Draft EIS be adequate enough to allow "meaningful analysis." This cannot be said of the Utah BLM Statewide Draft EIS, as reviewers are left to guess at the reasons for each Proposed Action. Sec- tion 1502.14 requires that the EIS "sharply [define] the issues and [provide] a clear basis for choice among the options by the decisionmaker and the pub- lic." Implicit in this section is an opportunity for meaningful public participation in choosing among alternatives, and critical in this case is an explana- tion of the basis for the agency choice. No basis is provided in BLM's Draft EIS, and the fact that it may be "deduced" in some cases (see Federal Register Notice) can hardly be considered the "clear basis" that NEPA requires. The text of NEPA itself recog- nizes that "each person has a responsibility to contri- bute to the preservation and enhancement of the envi- ronment" (42 U.S.C. Section 4331 [c]). CEQ recog- nizes this and the "policy that the public is entitled to the fullest information regarding the decisionmaking processes of the Federal Government" (40 CFR 2 GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE Section 1517.1). BLM, on the other hand, has deli- berately chosen to withhold from the public its bases for its choices among alternatives in each WSA, claiming NEPA requires such a course of action. This practice is not only not required by NEPA and its regulations, it is totally inconsistent with the text and purpose of those provisions. Even more impor- tant, BLM's decision not to include the rationale for its choices of Proposed Action has made it impossible for the public to criticize those choices. Without a stated rationale, reviewers are left to guess at the reasons for a particular area being excluded or includ- ed as wilderness. Reviewers are unable to address themselves to the issues that BLM views as critical, because BLM has decided not to reveal what those issues are. Public comment on the issues that the agency views as important is critical in order to build the record in those areas. And public participation in decisions regarding each WSA is most enhanced if commentors can direct themselves to those factors which BLM thinks are controlling. Moreover, because in many cases a reason for BLM's decision cannot be deduced from the Draft EIS, many decisions appear to be wholly arbitrary. BLM must certainly have reasons for its decisions or those decisions are, in fact, arbitrary. Given that NEPA does not require that these decisions remain secret, what is the justification for refusing to state them? If public participation and the NEPA process are to be at all meaningful in determining which areas BLM will ultimately recommend to the Secretary of the Interior for wilderness designation, BLM must provide the public with the rationale for selecting a particular alternative as a Proposed Action, and the public should have an opportunity to comment on that reasoning at the Draft EIS stage. 8.1 RESPONSE: When commenting on the Draft EIS, the public has presented its views on what should not be considered as rationale for BLM wilderness recom- mendations. This information has been utilized by BLM in refining the Proposed Action. The EIS is not the decision document, but the EIS provides information and environmental analysis. The EIS is only one of many considerations which contri- bute to the decision document. Nevertheless, in re- sponse to the several public requests for further ex- planation, a summary of rationale for the BLM Pro- posed Action for each WSA has been added to the Final EIS (Appendix 11). A further discussion of the ration- ale also will be included in the Wilderness Study Re- port for each WSA. The Wilderness Study Report is the appropriate location for the rationale. 8.2 COMMENT: A rationale section should be includ- ed in the Final EIS. [Earth First!, Rodney Greeno, Mark Peterson, Sierra Club, D.C. Kennel, et al.] a. The Final EIS should have one section for each WSA which would list the reason(s) for the final selec- tion. An additional section should explain the rationale for the final selection. Of course, the EIS is not a deci- sion document and BLM is not legally required to dis- cuss rationale, but they could have done so. For ex- ample, the Oregon BLM carried paragraphs of ration- ale for each area in their Statewide EIS. There is no reason why the Utah BLM didn't do likewise except for an anti-wilderness bias. In reviewing BLM's very lengthy Draft EIS, the reader is repeatedly left with the impression that numerous tracts were found un- suitable for dubious reasons. The implication is that a decision was made to not recommend these areas for wilderness designation, and then various reasons were contrived to support the decision already made. Allow me to offer some examples. Time and again areas have been excluded by BLM's blithe claim that an area "lacks wilderness characteristics." In almost all cases, this statement proves to be indefensible. Consider the Indian Creek region, just east of Canyon- lands National Park. This rugged area is an outstand- ing maze of twisted canyons--there can be little doubt that it should be included in the adjoining park. Yet, BLM recommends only several thousand acres, immediately adjacent to the park boundaries, for wil- derness. This area, the Indian Creek WSA, omits the most spectacular portion of the unit at large, includ- ing all lands between the Needles Overlook and the park boundary. Horsethief and Rustler Canyons and Indian Creek itself should all be included in an area recommended for wilderness designation. Yet, BLM has not so recommended them and, further, no con- vincing reason is offered. It is clear that political forces have motivated the decision to leave these lands undesignated. But these are public lands of national importance. The natural resources involved belong to every citizen of the United States, and they deserve a more fair accounting in the wilderness designation process. Moreover, there are numerous other areas through-out the State which have suffer- ed a similar fate. Most of these should be included in the NWPS. b. Will BLM develop some way to display its rationale on what areas are selected in the Proposed 3 GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE Action for wilderness designation? Why are certain WSAs not included in the Proposed Action when, according to BLM's own statements, the area is best suited for wilderness designation? How did BLM de- cide on the Proposed Action Alternative? What were the criteria used to select areas listed in the Propos- ed Action? Why are WSAs that meet the same criter- ia for being recommended wilderness not recommend- ed in the Proposed Action? Why does BLM exclude areas from their Proposed Action based on the poten- tial for future mineral development which might or might not occur? Why doesn't the BLM recommend areas for wilderness based on those areas that ex- hibit exceptional wilderness characteristics? c. BLM in the errata statement (dated March 25, 1985) claims that it does not need to give a rationale for choosing the Proposed Action as the preferred alternative. This may be true, but BLM also notes that NEPA requires that an EIS "shall serve as a means of assessing the environmental impact of proposed agency actions" and that alternatives should be "considered in detail including the Proposed Action so that reviewers may evaluate their comparative merits." These NEPA statements seem to require that there be some justification for the array of alterna- tives considered. This requirement was forcefully upheld by the Ninth Circuit's 1982 decision, Califor- nia vs. Bergland, on the FS National Wilderness Study EIS. Thus, while BLM may not need to give a rationale for choosing its preferred alternative, it should have a rationale for choosing the alternatives to be ana- lyzed. 8.2 RESPONSE: It is important to note the Proposed Action identified in the EIS is not BLM's final recom- mendation. The final recommendation will be made in Wilderness Study Reports that will follow the Final EIS. A summary of the rationale for the BLM's Pro- posed Action has been added to the Final EIS as Appen- dix 11. It is appropriate to include rationale in the Final EIS because the public has commented and BLM will be using the Final EIS to develop its final recom- mendation. BLM believes that wilderness characteristics are a legitimate consideration in formulation of recom- mendations. Other criteria and standards, as describ- ed in BLM's Wilderness Study Policy (summarized in Volume I, Chapter 1), also are considered. Criteria for each of the Statewide alternatives were given in the Draft EIS. BLM's Proposed Action has been reviewed, revised, and further explained as presented in Volume I, Chapter 2, of the Final EIS. The BLM Proposed Action for the WSA cited in the comment was and continues to be the All Wilderness Alternative. Lands outside the WSA were evaluated during the inventory phase and are not addressed in the wilderness study. See General Comment Response 3.1. 8.3 COMMENT: Many speculative resource values are used as rationale to not recommend WSAs for des- ignation. More specific analysis and USBM/USGS min- eral reports are needed in the Final EIS to support the Proposed Action. [Uintah Mountain Club, Utah Wilder- ness Coalition, Utah Wilderness Association, Roger Jenkins, Dean Petaja, John Wahl, Rosemary White, Roy Young, Tod Young, et al.] a. It appears that, although BLM has examined all of these areas under one Draft EIS, there is no explic- it or consistent rationale for designating a particular area for wilderness. Instead, areas are compromised, despite very high wilderness ratings, if they conflict with big business (mining, coal, gas, oil) interests. The EIS does not recognize the vast areas of BLM land not included in the WSAs which are available for pros- pecting. It seems that BLM has too often allowed min- ing, oil, gas, and coal interests to override wilder- ness values. Many of BLM's biases continue to color the decisions in the Draft EIS. Time and time again, a clearly valuable wilderness resource is ignored in the face of an insignificant extractable resource: insignifi- cant due either to its low potential or economic viabil- ity. This is particu-larly frustrating given the fact that throughout the Draft EIS the economic impact of wilderness designa-tion is considered insignificant. Less biased and more resource-based decisions would certainly reflect a more accurate portrayal of the wil- derness potential in Utah. Continued efforts are need- ed on behalf of Utah’s world-class natural heritage. b. Refer to page 25, the two paragraphs under the heading Commodity Production Alternative, emphasis on the second paragraph. BLM has indeed reconciled wilderness quality and other resource uses, with wil- derness at great disadvantage. Areas such as the Book Cliffs, where high wilderness values coexist with mineral potential (oil/gas), are dropped or shrink in acreage (WSA Nos. 68-73). c. Refer to Volume I, Scoping Comments 242 and 258, pages 248-249 of the Draft EIS. Instead of 4 GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE recommending wilderness for deserving areas and then advising Congress that mineral conflicts exist, BLM has not recommended these areas but noted that they are excellent wilderness. d. There is a flaw in the process whereby untouch- ed natural areas of haunting beauty and unequivocal naturalness are disqualified at this stage because of mineral, oil, and gas potential. e. BLM has evidently given unsuitable recommen- dations for several WSAs on the basis of speculative uranium resources. For example, 19,000 acres in the North Escalante Canyons/The Gulch ISA were left out, presumably because of uranium deposits. SAI rat- ed this area 2+ because of uranium prospects and de- posits along the east edge of the area near Circle Cliffs. SAI notes that inferred and known deposits could be as much as a few hundred tons, but most of this material is currently not economic to extract. The 1981 USGS mineral resources report on the area (Open-File Report 81-559) concludes that the mineral and energy resource potential of the area is low. This is at variance with the high rating used in the Draft EIS (Volume lll-B, page 25 of the Draft EIS), which is based on a single "personal communication" from DOE. The Draft EIS gives no explanation why two published analyses of the entire area are passed over in favor of an unpublished analysis that lumps the 19,000 acres into the 1,126-square-mile Circle Cliffs Prob- able Resource Area. The Draft EIS analysis should be based on the published area-specific analysis instead of an unsupported generalization. On the basis of this example, the uranium resource evaluation is suspect and should be redone; areas dropped for reasons of supposed uranium conflicts should be reinstated to the wilderness recommendation. f. After nearly a decade of work on the BLM wil- derness review, we still find wilderness values down- played and mineral values and other conflicts exagger- ated. BLM continues to look at 3.2 million acres of WSAs as though they are the first storehouse of min- erals, the last opportunity for range improvements, the only areas for ORV use, and of little importance to wildlife. We're still told "flat" land cannot have wilderness values even though there is "flat" land in the NWPS. We're still told land with "sparse" vegeta- tion cannot provide wilderness values, even though land with sparse vegetation is in the NWPS. We're still told that potential for development, potential for minerals, potential for range manipulations, and potential for ORV use are all more important than protecting lands as wilderness. g. BLM is proposing action on the 3,231,327 acres in the WSAs based upon what it acknowledges as highly speculative data regarding the nature and extent of the mineral resources (Draft EIS, Volume I, pages 114, 129, and 130). From the 52 areas listed in Table 30 as WSAs with medium to high energy and/ or mineral potential, nearly 1.2 million acres are dropped from WSA status in the Proposed Action, fully 36 percent of the acreage in the WSA inventory. BLM has forgotten that the SAI ratings contain the admonition that they ". . . are not meant to take the place of detailed field studies" and ". . . that the avail- able data are too limited and oftentimes too unreliable to" (provide a step-by-step cookbook approach to rat- ings). BLM clearly lacks the data and the expertise to make a candid and unbiased appraisal of the resource potential for uranium as well as other mineral and en- ergy resources in the WSAs. This should apply to all 14 WSAs summarily dropped from evaluation in the Proposed Action for "mineral potential," but is espe- cially appropriate in the case of the 22 WSAs listed in Table 30 with uranium "resource." Based on current markets for uranium and the updated 1983 National Uranium Resource Evaluation definition of "potential uranium resources" which BLM accepted in Appendix 5, no acreage can be dropped from WSA status. At the very least, BLM is overstepping its authority to make decisions based on scientific appraisal and should defer these "mineral potential" questions to the Congress which can then act, based on profession- al field surveys to be completed by the USBM/USGS in 1987-88. h. The argument that wilderness designation "locks up valuable natural resources" is totally inval- id because it fails to consider that wilderness itself is a valuable natural resource. Those resources which wilderness protection overrides are those that are generally nonrenewable and extractable for the profit of local or other special interests and not of signifi- cant national importance. In addition, the exploitation of unique scenic and recreational resources for extraction of commonly found energy and mineral resources makes a mockery of common sense. The wild lands of the Colorado Pla- teau are like no other in this country. The same can not be said for the mineral and energy resources found there. Does one destroy the wilderness quali- ties of, for example, the area in and around Little 5 GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE Death Hollow in the eastern section of the North Esca- lante Canyons/The Gulch WSA to get more of the same kind of ore that could be extracted near Moab? This is, in effect, what action BLM is encouraging in many of its recommendations for partial wilderness designation. This is a bewildering course of action, indeed. BLM's stated emphasis on commodity produc- tion in their Proposed Action (page 25, Volume I of the Draft EIS) is simply out of step with the times and needs of our technological society. It fails to recog- nize the shift toward consumption of less beef, oil, and uranium, and greater use of leisure time for tra- vel and the need for solitude and opportunities for primitive recreation. When wilderness values for a particular area were in conflict with mineral potential and other de- velopment interests, it appears that wilderness val- ues were shortchanged, dismissed, and sometimes just ignored, many times for no apparent reason. It must be the other way around. Give the land the bene- fit of the doubt. It is not going anywhere. Put mineral potential, ORV demands, and other development inter- ests into the proper perspective. The quantifier "mil- lions" must be put into the proper perspective also. Millions of anything appears to be a large quantity. However, when minerals and wilderness potential is considered it is truly a small number. 8.3 RESPONSE: See the responses to General Com- ments 8.1 and 8.2. BLM has a legal mandate to pro- vide the Secretary of the Interior, the President, and the Congress with recommendations. These recommen- dations must take into account the several factors listed in the Wilderness Study Policy and include con- sideration of tradeoffs with nonwilderness resources. Mineral resources are an important consideration, as evidenced by the Congressional requirement for the independent USBM/USGS mineral investigation. All mineral information used in the Draft EIS has been re- viewed and updated (see the response to General Com- ment 15.1). The USBM/USGS work done to date is re- flected in the Final EIS. Because of timing, workload, and funding factors, it was not possible for all of the USBM/USGS studies to be completed in time for the Final EIS. According to the Wilderness Study Policy (USDI, BLM, 1982a), the Secretary of the Interior will review the mineral reports before making rec- ommendations to the President. If significant new information is found that would change the recom- mendations, the new information will be reflected in a supplemental environmental document. BLM must pro- ceed with the Final EIS and with Draft Wilderness Study Reports to meet the 1991 legal due date. In addition, Congress will have both the BLM recommen- dations and the USBM/USGS mineral reports when it acts on the question of wilderness designation. Also see the responses to General Comments 15.11, 15.14, 15.16, 15.18, 15.20, 15.28, 15.43, and 15.57 that address questions on the relative value and evaluation of minerals in WSAs. 8.4 COMMENT: In many instances, the rationale used for recommendations is inconsistent with the analysis. [Neal Berg, David Jorgensen, Owen Severance, Nora Worthen, et al.] a. For example, in Mexican Mountain EIS, BLM has recommended 46,750 acres of wilderness, yet under the No Wilderness Alternative, beginning on page 30 under Geology it states: "Impact to geological condi- tions would be small." Under Air Quality it states: "The WSA would continue to be managed by the State of Utah as a PSD Class II area." Under Vegetation it states: "It could be reasonably concluded that the via- bility of these endangered or threatened plants would be preserved." Under Water Resources it states: "No substantial impact to surface water resources are expected." Under Wildlife it states: "Most impacts would be short term." Under Forest Resources it states: "Any impact to forest resources would be min- imal." Under Visual Resources it states: "Significant magnitude of the disturbance is unlikely." b. We are certainly confused about exactly what the Draft EIS proposes for the Parunuweap WSA since it identifies both the Partial Wilderness (L) (Volume I, Table 4, page 21) and the All Wilderness Alternatives (Volume 1 1 1- A, Table I, page 12) as the Proposed Action. We also fail to understand the criteria used to arbitrarily exclude the upper parts of Mineral Gulch and Meadow Creek Canyon and all of Joseph Canyon from consideration. Although it is difficult to ascer- tain exactly why Elephant Cove Bench is excluded in the Partial Wilderness (L) Alternative, we can only assume that the lack of vegetative screening and past wood-cutting practices may have some bearing on this decision. The first point conveniently discounts the remoteness of the area as a factor contributing to opportunities for solitude. The second advocates the deletion of the area based on admittedly incomplete (and some would say inconsistent) data (Volume lll-A, page 19). Opposition to the Parunuweap dam and selec- tion of the All Wilderness Alternative are augmented 6 GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE by the inclusion of the upper drainages of Mineral Gulch and Meadow Creek and all of Joseph Canyon. c. It is interesting to note that the Draft EIS, while coming to the same conclusions as presented in the SSAs (in most cases), leaves out a lot of the damning information that was in the SSAs. As a result, the Draft EIS is misleading because it doesn't state a lot of the reasons that could be used against adopting BLM's Proposed Action. For example, in the Red Mountain WSA, the Draft EIS doesn't include the information from the SSA that BLM’s Proposed Action leaves out the "spectacular Red Cliffs paralleling old Highway 91" (SSA, page 8). Another instance is the Moquith Mountain WSA where the Proposed Action is the No Action Alternative. The Draft EIS doesn’t say that "the Bureau's planning efforts have identified portions of the WSA as suitable for intensive recrea- tion development" (SSA, page 4). These are typical omissions that prejudice the Draft EIS in favor of BLM's Proposed Action. The Final EIS should be more objective, but I am not optimistic that it will be. d. The preliminary recommendation is not philo- sophically consistent. Critical parts of large quality wildernesses are left out. Sometimes the reasons for not recommending such areas are arbitrary. In other cases, the preliminary recommendation might not be arbitrary. Nevertheless, in some of these areas, the extraordinary wilderness values obviously outweigh the other resources which created the conflict. A few relatively small additions would dramati- cally improve the preliminary recommendation. Land not recommended in Parunuweap and Canaan Mountain for what amount to arbitrary reasons should be rec- ommended as wilderness. Essentially the same thing happened in Paria-Hackberry, a unit which has more Class A rated scenery than any WSA other than Deso- lation Canyon. The positive recommendation on Sids Mountain should not be emasculated by ORV corridors. The preceding changes would not cause economic hardship. No significant resource conflicts exist in the nonrecommended parts of Sids Mountain, Paria- Hackberry, Canaan Mountain, or Parunuweap. In addition to these changes, all of North Esca- lante and all the land outside the KCRA in Floy Canyon should be recommended as wilderness. There appears to be some conflict with some minerals in these areas, but the wilderness values are known to be ex- ceptional. Further, the basic philosophy outlined on page 30, Volume I of the Draft EIS, requires weigh- ing wilderness and commodity values. Exceptional areas such as these can be recommended even though conflicts exist. 8.4 RESPONSE: The analysis and the rationale have been reviewed and compared. Accordingly, adjust- ments in the recommendation have been made. A sum- mary of rationale for the Proposed Action is provided in Appendix 11 of this Final EIS. Inconsistencies between Volume I and the indivi- dual WSA analyses (Volumes II through VI) were creat- ed by labeling mistakes during preparation of the EIS. These inconsistencies were corrected in an errata sheet mailed to EIS recipients (see General Comment Response 25.18). ORV management has been further considered. Although the comment provides a clear listing of de- sirable steps for ORV management, in actual practice the problem is not easily resolved. BLM is participat- ing with the FS and the State of Utah in an increased level of ORV management; nevertheless, this will con- tinue to remain an administrative problem. Also, see the response to General Comment 9.14, which discusses manageability. Comments concerning the WSAs cited as exam- ples are responded to in Volumes Vll-C, Specific Com- ments and Responses Sections 13 (Red Mountain), 19 (Parunuweap), 20 (Canaan Mountain), 24 (Paria- Hackberry), 64 (Mexican Mountain), and 68 (Floy Canyon). 8.5 COMMENT: BLM should provide rationale for all WSAs not recommended for wilderness. [Kim Clegg] BLM has severely cut and nibbled away at all of the roadless areas. Consequently, anything that has made it this far is qualified for wilderness designa- tion. At this time, I think the focus must be on justify- ing any recommendations to not designate every unit remaining as wilderness. If it is not to be recommend- ed, that exclusion demands that reasons be given. 8.5 RESPONSE: The reasons for recommending and not recommending each area or partial area are sum- marized in the Final EIS, Appendix 11. Also see the response to General Comment 3.1 that addresses questions on BLM's Wilderness Inventory. 7 GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE 8.6 COMMENT: BLM has overstepped its mandate and has confused suitability and desirability. This approach will prejudice Congress in their deliberation on wilderness. [Uintah Mountain Club, Randolph Jorgen, Dennis Slifer, et al.] a. In making its draft recommendations and study, BLM has overstepped and subverted its mandate from Congress, which has been to identify those areas which are suitable for recommendation as wilderness (i.e., which contain the necessary wilderness charac- teristics) and to gather and present data to be used in the consideration in the public and political arenas where the choices will be made as to which areas should finally be designated. Volume I, page III states that the purpose of the EIS is to provide information for use in planning and in wilderness suitability recom- mendations and to provide information for Congres- sional decisionmaking. BLM has gone beyond providing information in recommending against designation of some areas not on the basis of any demonstrated unsuitability, but rather on the basis of themselves making choices involved in resource tradeoffs. It is those choices which belong strictly in the political sphere, not in the bureaucratic sphere, for these lands belong to all the public, not just to the managers or their cronies in the resource consumptive indus- tries. b. BLM split the Colorado Plateau physiographic province into three or four different WSAs, which ignores the similarities and unifying characteristics and cannot be justified merely on the basis of admini- strative expedience. The approach taken to these areas does not differ substantially from your approach to suitability for all other areas in the Draft EIS. Suitability for wilderness designation is not rec- ognized as an inherent quality of the land which stands alone and which is in itself a justification for the next step: legislative determination of desirabil- ity. Your analysis identifies all the criteria that wil- derness should possess as being qualities of these WSAs (with the exception of manageability, which is not discussed), yet you reject these areas as candi- dates for wilderness designation. This is presumably on the basis of Standards No. 1 through 6 in Volume I, Chapter 1. In other words, criteria for wilderness conflict with standards of analysis. With this distinction, BLM separates suitability from desirability. This biased approach plagues the entire Draft EIS. An area may satisfy all the criteria for wilderness, yet BLM determines, seemingly arbi- trarily, whether it is desirable that the area be wil- derness. In this respect, BLM acts as a gratuitous agent for a variety of interests who oppose further preservation of wilderness values on public lands. Often, as is the case, we are not told why BLM makes its recommendation. If we read some parts of the Draft EIS, we are led to believe that BLM sees its role as primarily narrative (i.e., as identifying favor- able characteristics and possible conflicts). We read that "impacts to each are analyzed under each alterna- tive," but "the final judgment as to which resource outweighs other resources will be made by Con- gress." But your recommendation of No Action unal- terably prejudices the Congress in their deliberation on wilderness lands. We know that, without your en- dorsement as suitable, these lands will never get ano- ther look by Congress. The suitability of these areas for wilderness-which is an inherent quality of the land itself (either an area is or is not wilderness qual- ity) has been ignored on the basis of potential con- flicts. BLM, not Congress, has made a value judg- ment. There is a thumb on the scales, and it belongs to BLM. This is not a subtle point. For these WSAs, the arbitrary assignment of undesirability has been made by BLM, and we are not told why the area was not recommended or how the No Action Alternative was chosen. This flaw can be seen throughout the Draft EIS, and no disclaimers can justify the process. Since "BLM does not believe that a cost-benefit anal- ysis, or any other comparison, based solely on eco- nomic grounds, can properly portray tradeoffs involv- ed" (Volume VI, Coal Canyon, page 1), why does BLM give the nod to development? If "BLM believes that it can serve best by narrating the situation," why does not it just identify those areas that meet wilderness criteria and let the people, through their Congress, decide which areas are and which are not deserving of further statutory protection under the Wilderness Act? BLM may say that FLPMA is to blame, yet it should not blithely cull areas solely on the basis of perceived conflicts. The magnitude and significance of conflicts may take on quite different dimensions in the Congressional review. Let Congress decide what commercial values should be foregone and which ex- ploited. Do not prejudice the legislative review pro- cess before it begins. c. BLM's Proposed Action includes all areas (or portions of areas) which BLM judges to meet the test of suitability-that is, they have "outstanding" oppor- tunities for solitude, etc. The Draft EIS states that " . . . these areas may have low wilderness quality, but no identified conflicts with other resources." How 8 GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE can they be of low quality, yet still possess "outstand- ing" attributes? And where is "conflict with other resources" identified as a criteria for judging suitabil- ity? d. The Proposed Action should be, in effect, the All Wilderness Alternative (i.e., that all these lands are suitable); BLM should not be involved in making our choices for us. All lands meeting the inventory criteria test should be presented as suitable--they are suitable-since recommendations based on the Wilderness Study Policy and planning criteria (page 12) are based on subjective values which belong in the public, not bureaucratic, sphere. e. Section 603 of FLPMA specifically states that the Secretary shall review roadless lands "identified during inventory ... as having the wilderness charac- teristics." Throughout the review documents, BLM has downplayed what should have been the primary goal of the Draft EIS. Assessments of wilderness qual- ity were colored by knowledge of possible conflicts. While that information may be useful to Congress and the President in the decision to desig-nate these areas, I believe BLM should have been more impartial in their review. BLM gathered the information. It is the job of Congress to make the evaluations. f. All of the WSAs that survived the inventory and study process to remain among the final 82 are suitable by the agency's own stringent standards and, therefore, should not be eliminated from any alterna- tive. BLM’s Proposed Action does not include many WSAs or portions of WSAs included in several other alternatives, including the Manageability Alternative. Because those areas are considered free from con- flicts of existing rights, uses, land ownership, and other management considerations and because no rea- son is given for their removal from BLM’s Proposed Action, at a minimum those areas should be returned to that alternative. Areas included in their entirety in the Manageability Alternative and not in BLM's Pro- posed Action include: Fish Springs (Partial only), Swasey Mountain (Partial), Howell Peak, Conger Mountain, Wah Wah Mountains, Cougar Canyon, Cotton- wood Canyon, Parunuweap Canyon, Canaan Mountain, Mud Spring Canyon, Paria-Hackberry, Phipps-Death Hollow, Steep Creek, North Escalante Canyons/The Gulch, Carcass Canyon, Scorpion, Fifty Mile Moun- tain, Mt. Ellen-Blue Hills, Horseshoe Canyon (South), French Spring-Happy Canyon, Fiddler Butte, Mt. Pen- nell, Mt. Hillers, Mancos Mesa, Mexican Mountain, Jack Canyon, Coal Canyon, Spruce Canyon, Flume Canyon, Fremont Gorge, and Daniels Canyon. These areas are considered highly suitable and free from conflict in at least two or more of BLM's own alternatives. There are no reasons given to jus- tify their lack of inclusion in BLM's Proposed Action; if some justification is noted, it contradicts other parts of the document (i.e., "low mineral potential" becomes "moderate" in other parts of the document, based on the same BLM and contractor studies). The discrepancies show that the Draft EIS and alterna- tives are faulty and need to be reworked for consis- tency and facts, if not for content. 8.6 RESPONSE: As explained in Volume I, Chapter 1, the wilderness review process has three basic phases: inventory, study, and reporting. All of the WSAs met the requirements of the inventory phase (roadless, natural, and other wilderness characteris- tics). This does not mean that the WSAs are automati- cally suitable for designation. Application of the Wil- derness Study Policy requires resource information, use of professional judgment for subjective aspects, consideration of public views, and management con- cerns. Also, it requires that all of these factors come together in a balancing process (i.e., the BLM planning system). Formulating a recom-mendation in light of the various study factors does require consideration of resource tradeoffs. In this effort, BLM has not overstepped its mandate. BLM recognizes that "suitability" and "desirabili- ty" are not the same. However, the process of wilder- ness review involves a series of screens as outlined in the BLM wilderness review guides (USDI, BLM, 1978, 1980b, and 1982a). The first two of these (ini- tial inventory and intensive inventory) concentrated on roadless and primary wilderness characteristics. The third screen includes two criteria and six stand- ards, the EIS process, and Wilderness Study Reports which ultimately provide information and recommen- dations for further consideration by Congress. BLM's responsibility is to address suitability in the context of all three of the screens noted above; this consti- tutes more than just a report on wilderness values. BLM's responsibility is to provide a realistic and com- plete recommendation, balancing all of the pertinent considerations. Congress will consider and adjust that recommendation, based on all of the review informa- tion, and will determine desirability (i.e., respond to public and political views on the need for and desired amount of wilderness). This statement is supported 9 GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE by the experience of the FS in Utah, where 492,998 acres were proposed for wilderness by the agency and Congress designated 802,639 acres. Also, see the responses to General Comments 2.23 for a discussion on the wilderness review pro- cess and 3.11 for a response to questions on the manageability alternative. 8.7 COMMENT: In the Final EIS, BLM should use a more holistic approach and give more consideration to joint use of BLM wilderness and contiguous areas. [National Park Service, et al.] In general, the NPS would recommend wilderness designation for those WSAs adjoining units of the na- tional park system. We would like to see the Final EIS place more emphasis on the opportunity such desig- nation would offer for a more holistic approach to land use planning. That is, there should be greater dis- cussion in the EIS that BLM wilderness adjoining park- lands would provide compatible management of contig- uous watersheds, airsheds, wildlife species, cultural resources, viewsheds, and recreation uses (i.e., hik- ing, river running, horse packing). That discussion should also establish how such a complementary approach would enhance the wilderness experience for visitors to those public lands as well as in the parks. 8.7 RESPONSE: In the Final EIS, the relationship be- tween national park system units and the wilderness aspects of the adjoining BLM-administered lands has been given additional emphasis in the Recreation and Wilderness Values sections. The discussions of Land Use Plans in the Affected Environment sections also describe the relationship of BLM WSAs to adja-cent lands. The Draft EIS did discuss opportunities for com- plementary management and analyzed the effects of each alternative on such items as the opportunity to complement PSD Class I airshed, recreational access to national parks, etc. These relationships were con- sidered during formulation of the BLM Proposed Action and will be further addressed in the Wilder- ness Study Reports. 8.8 COMMENT: The analysis time frame used in the EIS Proposed Action is too short. BLM should consider long-term consequences in the analysis and the pro- posal. [Jean Soko, Linelle Wagner, et al.] a. Does BLM consider in this Draft EIS the billion years of geologic evolution known as the Grand Stair- case, or does the world revolve around energy corri- dors, strip mines, hydroelectric dams, carbon diox- ide well fields, tar sand synfuel projects, and urani- um mining? Unfortunately, I must conclude from the BLM Draft EIS that this is what the world revolves around, potential energy development for petro- chemicals for years to come, at least half a century any way. b. The thrust of BLM's Proposed Action is to mini- mize conflicts with mining, grazing, ORV, or local gov- ernments. While resource conflicts are a factor in wil- derness recommendation, the agency has taken the road of least resistance. In the short term, this may be perceived as the correct course. Flowever, in the long term, the irreversible impact of such short- sightedness will be tragic. Although this document con- tinually states the current trend of a depressed coal, oil and gas, and uranium market, BLM is willing to sac- rifice irreplaceable national treasures to transporta- tion corridors and mineral exploration in hopes of a future market boom. c. One glaring truth that strikes the casual obser- ver is the concentration of WSAs removed without justification from a handful of southern Utah counties. We are aware of the number of qualified areas elimi- nated from the initial inventory and other phases due to local parochial interests, greedy development inter- ests, and energy company plans for uneconomic pro- jects which have as yet failed to materialize, much less benefit, those who hoped for those benefits, short-lived as they might have been. The very wrong- ness of eliminating qualified areas for consideration as WSAs has been proven over and over again in courts, by the IBLA, etc., at every phase of the wil- derness process, by the reinclusion of eliminated areas. This will undoubtedly continue. The process has been flawed in the past and continues to be flawed at this stage. WSAs can be added, areas not included can be reconsidered. Many areas which, under IMP status, were allowed to be degraded, roaded, drilled, or otherwise illegally marred, can be recovered and reincluded. A WSA is still a WSA, and it is not the fault of the land, only the land managers, that it has been injured. That is not sufficient reason for elimina- tion from BLM's Proposed Action. They must be includ- ed. 8.8 RESPONSE: The analysis time frame is influ- enced by several factors, including limitations on the ability to forecast the future, practical consideration of past and current events, availability of data, and GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE nature of decisions involved. In most matters, both short- and long-term aspects are considered, al- though these do not usually extend to years of geolog- ic evolution. BLM does not believe that analysis in terms of geologic time would be particularly accurate or useful. Analysis of the resources listed in the com- ment is necessary to provide information on the poten- tial conflicts with wilderness designation. BLM has considered both the short- and long-term aspects of wilderness and wilderness trade-offs with other public land resources. BLM has other resource mandates, as well as a mandate to study potential wil- derness areas. Conflicts among competing uses are an important consideration in management of the public lands for the public as a whole. The inventory phase of the study has been com- pleted. Opportunities for public input were provided and adjustments made. See the response to General Comment 3.1 that addresses inventory questions. BLM is following the IMP and future Congressional options for wilderness designation are being pre- served. See the responses to General Comments 5.1 and 5.2 concerning the IMP. Also, see the responses to General Comments 2.21, 5.4, and 8.1. 8.9 COMMENT: BLM should answer the question of "How much wilderness is enough?" [Emery County, Utah Mining Association, Normal Gubler, Randolph Jorgen, Marvin Morris, Robert and Deanna Tubs, John Veranth, et al.] a. Utah contains six national parks and numerous designated wilderness areas. These current wilder- ness areas contain hundreds of thousands of acres, acres that guarantee the limited use for the limited few. The national parks are designed to provide many of the same values and protections of the single-use wilderness designation. What is being created through wilderness designations is a series of "super national parks" that are generally enjoyed only by the super hearty. The few benefit, while the many and their opportunities for multiple-use enjoyment are hinder- ed. b. In the southern Utah and Nevada area we al- ready have State parks, national parks, and parking areas which are beautiful and are well supervised. "Enough is enough." No wilderness is needed in our southern desert area. We must have room to maintain the human race. c. In Volume I, page 4, BLM states: "The purpose of the EIS is to provide an objective analysis of envi- ronmental impacts. It is not intended to resolve public controversy on need for wilderness, answer the ques- tion, "How much wilderness is enough?," provide a cost/benefit analysis, or be a final decision docu- ment. But clearly the document goes far beyond being an objective analysis and into the realm of subjective choice, since it has made recommendations on what should be designated based on value judgments of re- source values and tradeoffs. Furthermore, in making those judgments, BLM must have given consideration to those very questions of the need for wilderness, of "How much is enough?" Any Proposed Action which is not based on such considerations, along with relevant concerns such as the social, philosophical, spiritual, and aesthetic value of wilderness to society at large, is not valid, since it ignores a large portion of the rationale for establish-ing those areas. Since it is neither within the capabil-ity nor appropriate func- tion of a bureaucracy to make this sort of judgment based on intangible values, it is inappropriate for BLM to be doing anything other than to provide information on what clearly is objective and recommending all of those areas that are suitable, in contrast to what has been done, which has to go beyond identifying those areas that are suitable to only recommending those areas it deems desirable, by its own covert rationale. Examples of WSAs recom-mended against on the basis of BLM's subjective judgments and covert rationale include, among others, those areas which even by BLM's own admission are of the highest quality wilder- ness (meet the test of suitability as wilderness areas), but which were not included in BLM's Propos- ed Action. These include French Spring-Happy Can- yon, Mt. Pennell, Jack Canyon, Coal Canyon, Spruce Canyon, Flume Canyon, and Daniels Canyon. d. Five million acres of wilderness may sound to some like a large sum, but it is not. Already the States of Idaho, Wyoming, Montana, Colorado, and California each have 3 to 5 million acres of designat- ed FS lands, and recently Senator Alan Cranston of California introduced his bill into the U.S. Senate for 8 million additional acres of BLM wilderness in his State. Surely Utah can afford to be reasonable in the preservation of lands which many believe are the finest public lands in North America; the best of the best of our last frontier. GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE e. In the Draft EIS, it was stated that BLM was not to answer the question, "How much wilder-ness is enough?" The All Wilderness Alternative is asking for over 3 million acres. BLM is proposing that we not set aside that much. BLM suggests only about two- thirds of the maximum. f. Let's talk about the idea of wilderness and BLM’s multiple-use mandate. Primitive recreation has been recognized as a viable use. Preservation of wild- life habitat and the protection of the remote, wild character of some public lands has been encouraged by Congress with the 1964 passing of the Wilderness Act. Why has the Utah BLM historically been so reluc- tant to acknowledge these facts? Utah is unquestion- ably the jewel of BLM wilderness. BLM should be proud and quick to protect as much of the lands as pos- sible. Less than 2 percent of all the land in the contigu- ous United States is designated as wilderness. More than this is covered with concrete. If every one of the WSAs discussed in the Draft EIS were given full wilderness status, it amounts to only 16.15 percent of all the lands in Utah (Draft EIS, Volume I, page 12). Nationwide, BLM only finds 9.6 million of its 174 million acres suitable for wilderness protection. That is less than 5 percent! Where is BLM's sense of mod- eration? What is a fair percentage of wild lands to protect and preserve for generations? Five, ten, twenty? Certainly America can afford to preserve 5 percent of the lower 48 States as wilderness, and Utah is the place to start. All the lands studied in the Draft EIS, plus other designated wilderness lands in Utah, amount to 11.02 percent of the State’s land area (Volume I, page 12). Thirty percent of Utah's lands could qualify as wilderness, and at least 20 percent should be designated as such. After all, this is a national wilder-ness system. Why should develop- mental interests cry when 80 percent of the State is wide open for full-scale development and over 95 per- cent of the whole lower 48 States is wide open? g. The total acreage devoted to wilderness should be judged in the context of future needs. Utah is one of the fastest-growing States in the union, and the demands on the roadless areas will change in coming decades. Developers talk about forest harvest, min- erals, and grazing. In the meantime, tourism is grow- ing and many migrants to Utah are coming because of the ready access to recreational opportunities. It is not possible to determine today how much wilderness ultimately will be appropriate for Utah. 1 2 h. Many of southeastern Utah's national parks and State parks already contain and protect the same kinds of formations, cultural sites, and ecological val- ues for which recommendation was made on the WSAs within Emery County. There is no need to designate as wilderness the areas in the county. There is nothing unique within the areas that is not either already pro- tected by the Federal government and its agencies, the county planning and zoning ordinances, or the natu- ral make-up of the area itself. 8.9 RESPONSE: See the responses to General Com- ments 1.1, 2.18, 8.6, 8.10, 21.5, and 21.7. Con- gress will review the BLM recommendation, which is required by FLPMA. In addition, Congress will review the opin-ions, comments, suggestions, and recom- mendations of others. Through the political and legis- lative processes, Congress will determine how much wilderness should be designated on the BLM-admini- stered lands in Utah. The future recreational demand for wilderness is addressed in the recreation sections of the EIS. 8.10 COMMENT: BLM should remember that de facto wilderness will exist even if lands are not designated. [Millard County, Rocky Mountain Federa- tion of Mineralogical Societies, et al.] a. The basic question which really hasn't been ask- ed or answered is if this wilderness is left alone as de facto wilderness what will happen within the fore- seeable future. This means the rest of the country doesn't move to Utah, there may be development of some type, whether it's ORV usage, mineral usage, or agricultural usage on probably less than 4 percent of the acres, possibly 10 percent maximum. So, not mak- ing this wilderness area designated under the law will, contrary to what most of the people seem to feel, not ruin the wilderness values. In the vast ma- jority of areas, there will be no change whatsoever. b. The proposed lands are already essentially in wilderness status, with the exception of a few roads providing minimal access. It is unnecessary to create a new management jurisdiction to preserve their pris- tine beauty and solitude since, by their very charac- ter, they are not threatened now. There are 272,740 acres of WSAs in Millard County. Virtually every mountain range west of Delta is included in these WSAs. These WSAs are not at risk of man's imprint. Why do we need to go to the ex- treme of wilderness designation? According to the GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE Draft EIS, these 272,740 acres have only 1,418 visi- tor days per year. That means that, on any given day, only 3.8 people are visiting any of these six mountain ranges. The projected growth in visitor days over the next 20 years only amounts to an addi- tional two people per day wandering around in this vast 270,000-acre area. The majority of our visi- tors are amateur geologists, deer hunters, and pine nut harvesters that have been the only repeat visi- tors for years and years to these areas now under study; and the vast majority of these visitors are on Easter weekend and on the deer hunt. Another reason that the West Desert areas are not being threatened comes out in the numbers that state that the total acres of wilderness that may be lost under the differ- ent alternatives. According to BLM, if all the WSAs were ultimately designated as wilderness, only 990 acres would retain its wilderness value over and above the alternative in which none of the area was designated wilderness. Nine-hundred and ninety-nine acres out of 270,000 acres is less than 0.33 of 1 percent. Do we want to restrict activity in 270,000 acres in the West Desert because it may preserve wilderness value on less than 0.33 of 1 percent of the total? 8.10 RESPONSE: The No Action/No Wilderness Alternative describes the predicted future conditions if areas are not designated as wilderness. It is true that many of the remote and rugged lands likely will remain undisturbed for the foreseeable future. Also, see the response to General Comment 1.1, Purpose of Wilderness; and the response to General Comment 9.12, which discusses development scenarios for the No Action/No Wilderness Alternative. The lack of projected activity or threat to WSAs can be interpreted to mean that wilderness designa- tion is not needed; however, it could also be an argu- ment in favor of wilderness designation because there would be little or no conflict with existing or poten- tial nonwilderness activities. 8.11 COMMENT: Ranking of wilderness values is inappropriate for rationale. [Utah Wilderness Coali- tion, Neal Berg, Rodney Greeno, Rex and Judy Wells, et al.] a. The Utah BLM apparently developed a suitabil- ity matrix for rating wilderness characteristics in WSAs. Under this rating system, such characteristics as outstanding opportunities for solitude and wilder- ness activities were scored as high, medium, and low. BLM should document the use of the matrix and make the information available for public review. EIS response to this comment was that use of a matrix was considered in order to define values as high, medium, or low. It was not used because narra- tive explanation best serves in the evaluation. We sup- port BLM's decision not to use the suitability matrix, but find it was replaced with a two-tiered matrix. BLM still uses an unpublished method to determine outstanding opportunities for wilderness activities and solitude. The use of this method still violates the wilderness study process. b. BLM offices in other States have not found it necessary to undertake a counting of WSA acres that do or do not have outstanding opportunities. BLM's surgical identification of outstanding opportunities in the Utah wilderness study seems to be in violation of the national regulations in the same way that the wil- derness inventory decisions were through over- emphasis on screening. The criteria given on page 94 for evaluation of opportunities for solitude include size and configuration, topographic and vegetative screening, outside sights and sounds, and the ability of a user to find a secluded spot. Logically and legal- ly, these factors are to be considered together in evaluating opportunities for solitude (and they are in other States) but in Utah, BLM offices have subdi- vided WSAs and determined opportunities simply on the basis of the screening criterion. This is the only way to explain BLM's findings of solitude in Utah since the other criteria require consideration of en- tire WSAs and not subdivisions of WSAs. c. The Draft EIS concentrates on analyzing each WSA as if it were a series of isolated geological or geographical features, while deemphasizing the val- ues of the WSA (or often, several interrelated WSAs) that require the area to be viewed as a complete and complex ecosystem. For example, sections of the Draft EIS often mention in passing that the large size of a WSA offers substantial opportunity for solitude. The analysis then considers a subregion of the WSA in isolation and concludes that it fails to provide out- standing opportunities for solitude due to lack of topo- graphic relief or adequate vegetative screening. It is incorrect to judge an area in isolation; it exists as part of an environmental system, and the systemic implications should clearly supercede any purely local conditions. 1 3 GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE 8.11 RESPONSE: The EIS does not reflect the use of either a three- or a two-tiered matrix, and there is no unpublished method to determine outstanding opportunities. The narrative does reflect the subjec- tive views and professional judgments of BLM spe- cialists. The use of BLM personnel and professional expertise (i.e., judgment) to investigate, interpret, analyze, and explain the wilderness attributes identi- fied in the BLM inventory and wilderness study guide- lines does not violate the wilderness study process. Also, see the responses to General Comments 2.11, 2.12 and 2.13 for information on the study process and identification of outstanding opportunities. Fur- ther discussion on the rating of wilderness values is found in the response to General Comment 22.5. 8.12 COMMENT: BLM should not use potential range projects or agricultural production as rationale for recommending against wilderness. [John Veranth, et al.] a. Chaining projects lie behind BLM's recommenda- tions of No Wilderness for several areas, including the Henry Mountains and Paria-Hackberry. Certainly the Wilderness Act intends that grazing continue, but not that massive range improvements be implement- ed. Inasmuch as only about 3 percent of this nation's beef is raised on public lands, grazing is not, after all, terribly important to our economy. Thus, there is no justification to drop WSAs because local ranchers wish to chain the pinyon-juniper forest. b. America's agricultural problem is surplus, not shortages. Although a few ranchers who operate in or adjacent to proposed wilderness areas might be ad- versely affected by wilderness designation, the over- all impact on America's food supply will be totally insignificant. Arguments about the need to produce food and fiber are no justification to allow agricul- tural interests to operate wilderness areas in ways that are not compatible with the true meaning of wil- derness. 8.12 RESPONSE: The proposed chaining projects shown in the EIS are those reflected in the existing BLM land use plans. It is not known at this time the exact location and extent of the chaining that would be implemented in the future; therefore, the over- view estimates from the existing land use plans are considered the best information available. Before any chaining project was actually implemented, it would be subjected to a economic analysis to assure that it was justified. Chaining for livestock is a valid trade- off consideration in wilderness recommendations be- cause livestock grazing and production is a valid pub- lic land use, as recognized by Congress in the Taylor Grazing Act and FLPMA and must be considered in BLM land use planning. See the response to General Comment 8.6 which explains that BLM's Wilderness Study Policy requires BLM to balance wilderness against other resource uses. The responses to General Comments 18.4 and 24.5 address questions on range projects for live- stock forage. 8.13 COMMENT: The Draft EIS analysis of the No Action Alternative is too optimistic and downplays impacts. [Utah Wilderness Association, et al.] We are told in the EIS not to worry, nothing will happen to wilderness values even without designation. Don't worry about Sclerocactus wriahtiae (endanger- ed) even though its only habitat in Mexican Mountain will be open to ORVs. Don’t worry about black bear, cougar, and elk even though their most important habitat in the Book Cliffs will be left open to full- scale oil and gas exploration and road building. Don't worry about the cultural resource treasures of the Kaiparowits even though the region is left open for coal mining, oil and gas exploration, ORV, chaining, and whatever else. 8.13 RESPONSE: It is intended that the No Action/ No Wilderness Alternative depict a realistic situation, reflective of BLM management activities without wil- derness designation. That situation does recognize the presence of various multiple uses and protective man- dates, such as FLPMA, the Endangered Species Act, the Archaeological Resources Protection Act, the Sur- face Mine Reclamation Act, etc. It also recognizes that some of the remote and rugged lands likely will remain undisturbed without wilderness designation. It is necessary to recognize that wilderness designation is not the only way to protect, conserve, and enhance wild land values. The alternative has been reviewed to revise any language that may have been overstat- ed. Also, see the responses to General Comments 8.10 and 9.13. 8.14 COMMENT: BLM's recommendations are based on pro-mineral bias. [Michael Goddard, et al.] BLM has overstepped its bounds. Throughout the document, BLM slants its recommendations to the energy industry. It seems that BLM has eliminated GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE any areas that possibly have energy resources. Is this true? 8.14 RESPONSE: BLM has formulated recommenda- tions after consideration of all pertinent study fac- tors. In some cases it was found that mineral values should take precedence and, in other areas, it was recommended that wilderness values should prevail. Also, see General Comment Responses 2.16, 8.3 and 8.6 for discussions on anti-wilderness or pro-mineral bias and the wilderness review process. 8.15 COMMENT: BLM's wilderness recommenda- tions have been influenced by the eastern mineral in- dustries to damage western mineral interests. [Utah Mining Association] We suggest that some of these areas are included as preferred BLM designations at the insistence, not of wilderness groups, but of senators and representa- tives representing eastern and midwestern mining in- terests. We suggest that this Eastern and mid-west- ern "mining relief act" appears to be yet another attempt to support these areas' mining industries at the expense of Utah's industry and population. 8.15 RESPONSE: Utah BLM does not have any rec- ord or knowledge of eastern mining interests attempt- ing to influence the Utah wilderness study process. Large energy and mineral companies who have provid- ed input to the study may have eastern mining inter- ests, but their concerns have all been related to keep- ing the energy and mineral resources in Utah open for development. BLM does not believe that the commen- tor's allegations are correct, and the opinion is not reflected in the Environmental Consequences section or in the rationale described in Appendix 11. 8.16 COMMENT: In making wilderness recommenda- tions, BLM should remember that lands should be open to development. [Chevron Resources Company, et al.] No public lands should be closed or restricted from resource development and nonwilderness multi- ple uses in the absence of compelling national inter- est, which override the need for domestic oil and natural gas, coal, water, agricultural products, min- erals, timber, and other valuable resources. 8.16 RESPONSE: The Wilderness Act of 1964, FLPMA, and appropriate rules and regulations guiding the wilderness review do not provide for energy and mineral resource development in wilderness areas, except as subject to prior rights. All of the items listed in the comment have been considered in BLM’s analysis and formulation of rec- ommendations. Also, it is expected that the national interest will be reflected in whatever decisions are made by the Congress in their actions regarding des- ignation or nondesignation of wilderness. Rationale for BLM's Proposed Action are summarized in Appen- dix 11. Also, see the General Comment and Response Section 1, which discusses the purpose of wilderness and the multiple-use concept. 8.17 COMMENT: In making recommendations, BLM should recognize industry's need to explore for and develop oil and gas. [Chevron Resources Company, et al.] Our concern regarding the inadequacy of the Draft EIS is that BLM is recommending 11 areas for total or partial wilderness that even the overly conservative SAI reports recognize as having moderate to high potential for oil and gas. BLM does not recognize that such designations would have a major impact on indus- try's ability to explore for and develop energy re- sources; and that, in an unstable world where the U.S. is already dependent upon energy imports for more than one-third of our energy consumption, desig- nating these moderate to high potential areas as wil- derness threatens our future national security. 8.17 RESPONSE: BLM recognizes that industry has a need to explore for oil and gas. This need, however, must not be provided uniformly in all geologic set- tings and in all cases. Other resource values must be considered as well. The EIS provides the best informa- tion available regarding oil and gas potential, includ- ing pertinent information provided by representatives of the oil and gas industry. The SAI data have been re- viewed and updated (see the response to General Com- ment 15.1.) BLM concurs with the comment regard- ing the difficulty in predicting oil and gas pools. Given the legal mandate to complete the wilderness review by 1991, however, BLM cannot wait until future drill- ing programs further define oil and gas reserves. Con- sequently, available data, professional judgments, and assumptions are necessary. The USBM/USGS mineral reports are limited by the same conditions. The Proposed Action, as discussed in the Draft and Final EISs, is designed to include those areas judged by BLM to meet the test of suitability for GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE wilderness designation (see pages 12 and 13, Volume I of the Draft EIS for a discussion of wilderness cri- teria and standards). BLM recognizes that designation of these WSAs with moderate or high mineral and en- ergy potential could result in a potential loss of miner- al and energy production and dollars earned by com- panies; Federal, State, and local governments; and local communities. Potential mineral and energy depos- its could go undiscovered and undeveloped. However, it is also noted that production could still occur on ex- isting leases or mining claims already located in WSAs. These possibilities are projected in the Final EIS. When final recommendations are made to the President, mineral and energy potential in the WSAs will be one of the considerations. 8.18 COMMENT: BLM's use of potential transporta- tion corridors in the Kaiparowits region as a wilder- ness issue is not valid. [Utah Wilderness Coalition, Neal Berg, Ray Wheeler, et al.] a. BLM claims that future transportation corri- dors pose conflicts with wilderness designation. In many cases, large areas are deleted to accommo-date such corridors. BLM provides no maps describing the location of the proposed corridors for any of the WSAs involved. In the case of Mud Spring, BLM claims that a "future rail or coal slurry pipeline" would cross the area. BLM stated that The Kaiparo- wits Coal Development and Transportation Study for Southern Utah describes the proposal. The consultant who prepared this document offers only general con- ceptual ideas which describe broad areas where corri- dors may be proposed. The conceptual corridors are up to 15 miles wide, and six alternate routes are de- scribed. BLM uses this as the sole justification for de- leting large parts or all of several WSAs from wilder- ness study. There are several problems with what BLM is proposing. The first is giving a consultant's re- port the status and weight of a land use plan. The re- port has not gone through the planning process nor had an EIS prepared on it. It has not complied with BLM's procedures for the designation and management of rights-of-way. The public has not had an opportuni- ty for participation. For these reasons, this document cannot be considered a land use planning document and should be subject to general comments from the pub- lic. A utility corridor 15 miles wide is an absurdity. It represents nothing more than the effort by interest- ed parties to keep every option open; that is under- standable. What is difficult to understand is BLM’s use of such a "wish list" as a serious proposal sufficient to disqualify an area for wilderness. BLM has demon- strated no need for these corridors. There has been no justification for any-much less all-of these pro- vided to the public. BLM’s decision to use the corri- dors as real conflicts is arbitrary. It is not supported by BLM's planning process. BLM falsely states the potential for corridor designation and the amount of land the corridor would occupy. BLM should apply each of the required criteria when considering trans- portation corridors (43 CFR 2806.1) in the wilder- ness study. We ask that BLM describe how the criter- ia have been used as well as which have not been used. A majority of the corridors proposed could be served with existing rights-of-way. BLM fails to de- scribe the current rights-of-way, their present use, their capacity, and the feasibility of using them for additional facilities. Common sense requires such an evaluation. We recommend that BLM drop transporta- tion corridors as a wilderness conflict in the EIS un- less the analysis described above is performed. To be fair, BLM must give equal weight to wilderness val- ues and to proposals for commercial uses. Apparent- ly, pre-existing development proposals were given precedence. b.The Paria-Hackberry WSA represents the middle level of the "ascending staircase" between the Vermilion Cliffs to the south and Bryce Canyon and the Aquarius Plateau to the north, and consequently, is a representative continuum of this unique geologi- cal feature that should be preserved as a whole. The exclusion of the Paria River bed from the proposed wilderness area seems particularly absurd and ignores the appeal of the WSA as an integrated ecosys- tem of riparian streams, vertical rock faces, deep canyons, pinion-juniper benchlands, and isolated mesas. It is interesting that the cited conflicts with mineral and energy development, transportation cor- ridors, and desalinization facilities are purely hypo- thetical. While it is properly within the scope of the Draft EIS to consider potential developments within the designated area, it seems excessively unbalanced to deemphasize current, tangible wilderness values while stressing a stack of "proposed" or "potential" developments that have been stagnant (if not dead) for several years and promise to remain so into the foreseeable future. The other two conflicts identified in rangeland developments seem of dubious value. In summary, the decision to exclude the Paria River from the Paria-Hackberry WSA seems the product of sheer, if inspired, whimsy. 8.18 RESPONSE: Maps showing the location of the potential transportation corridors were included in GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE the study which was referenced in the EIS and referr- ed to by the commentor. BLM did not see the need to reprint the maps and add to the already large size of the EIS. The information is included by reference. BLM did not infer that the transportation study was an official RMP. BLM's Wilderness Study Policy requires that the Statewide Wilderness EIS include an analysis and documentation of the extent to which wil- derness designation would conflict with other re- source values and uses, including energy, minerals, and rights-of-way. The degree to which use or devel- opment of an energy resource is compatible with or conflicts with wilderness management is a factor which must be considered. The Kaiparowits Coal De- velopment and Transportation Study identifies corri- dor areas where wilderness designation would re- strict possible development of rail and slurry lines. The study resulted from an agreement between the Secretary of the Interior and the Governor of Utah to review issues that would be created by coal transportation from the Kaiparowits Plateau. The study was a regional planning document, jointly fund- ed by the State of Utah, BLM, and NPS and developed under contract to a consultant. Public meetings were held in Utah and Arizona, and public input was encour- aged. A major objective of the study was to identify possible areas for construction and operation of fu- ture railroad or slurry pipeline systems within the restrictions of general environmental and engineering constraints. Constraints were defined as features that would preclude the location of a 10- to 15-mile- wide corridor. Corridors of 2 to 15 miles in width were then selected, allowing maximum flexibility for future location of more specific routes. Existing and potential rights-of-way and truck haul routes also were considered. Also, see the response to General Comment 23.2 which discusses land use plans and the need for Kaiparowits coal. BLM believes that future transportation aspects are a valid consideration, even though specific propos- als (except for the Alton coal slurry pipeline) do not currently exist. The coal transportation corridor is a major fac- tor in the rationale for the Proposed Action in only one WSA, The Cockscomb, where the WSA and the existing Paria-Box Wilderness Area would severely restrict the corridor. The wilderness values that would be affected by transportation corridors are described in the Wilderness Values sections of the EIS. 8.19 COMMENT: BLM should not exclude any WSAs from the Proposed Action because of ORV use or man- ageability of ORVS. [Utah Wilderness Coalition, Mark Peterson, et al.] a. For the most part, the recreation conflict in WSAs is between backpackers/hikers and ORVers. The 1980 SCORP indicates hiking/backpacking activi- ties were slightly more popular than ORV activities (Draft EIS, Volume I, page 87). It hardly seems unrea- sonable to set aside 15 percent of the land for the hik- ers and backpackers, since 85 percent would remain available to ORVers. Of course there are other consid- erations (i.e., minerals) when determining wilderness suitability, but excluding land strictly for ORV use is not justified. Only 2 percent of the vehicle ways in the State are in WSAs, and many of the ways in these areas are not used. b. Many areas have been omitted because of sup- posed conflicts with traditional ORV use. I am a mem- ber of the California Association of Four-Wheel-Drive Clubs, a member of the Desert Foxes Jeep Club, and a frequent visitor to the many backroads and jeep trails of the Colorado Plateau. Based on this experi- ence, I know that most such claims are based not on fact, but on increasing pressure brought to bear by ORV groups who care only about their own interests, and not in the greater national interests of resource protection. c. BLM considers ORV trespass a manageabil-ity problem in several WSAs. In Moquith Mountain, for example, BLM makes the assumption that ORVs can physically enter an area and that the area is, there- fore, unmanageable. BLM has misapplied this criterion to exclude several key wilderness areas. In each case, BLM deleted either part or all of an area, not be- cause ORVs cannot be managed, but because BLM pre- fers to promote ORV use in that area. BLM manages ORV use in Utah only minimally. Most lands (more than 90 percent of BLM lands, in fact) are left open to all ORV use. Some example areas show success with little actual effort. BLM has posted the Joshua Tree Natural Area, noting that vehicular use is limited to existing routes. Very little use of those routes has occurred, even without any additional management action. In this case, posting is all that was needed. Moquith Mountain is covered with sand dunes. It GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE would take regular major use to notice-ably alter the plant and animal communities of this naturally healing area. No deep erosion gullies, no scared hillsides ex- ist in this area; only sand dunes. Current use has not affected the area. BLM has done no posting and has taken no other management actions to discourage ORV use. There is a range of actions that BLM can take that has worked well in other locations on public lands. The first is to inform the public of the special values a given area contains. This works in a major- ity of cases. The second is to post the area and make monitoring checks for compli-ance. The third is to cite violators. This is especially effective when a few offenders are targeted, cited, and the incident widely publicized. The last method is to physically block ve- hicle access to the area. This involves closing key ve- hicular access points. BLM has no record of manage- ment problems in these areas. The agency only admits it has not monitored use. BLM has not attempted any of these manage-ment techniques to control ORV use in areas it wants to disqualify on the basis of threat- ened vehicular damage. BLM has no basis for determin- ing that ORVs cannot be managed in wilderness areas. BLM has no evidence or analysis to establish with reasonable certainty that these WSAs are unmanage- able. Other examples include the Rockwell and parts of Westwater WSAs. 8.19 RESPONSE: See the responses to General Com- ments 9.14, 21.4, and 21.20. Wilderness designation will enhance primitive recreation, but will not signifi- cantly reduce opportunities for ORV use. Neverthe- less, it is BLM's judgment that certain areas are more suitable for ORV use than wilderness, and vice versa. Appendix 11 summarizes the rationale for BLM's Proposed Action. 8.20 COMMENT: By advancing a Proposed Action which recommends wilderness designation for WSAs of lower wilderness quality in order to avoid con- flicts that may exist in WSAs of higher wilderness values, BLM fails to meet its responsibility as esta- blished by NEPA. [Brian Williams] 8.20 RESPONSE: BLM disagrees with the comment. WSAs have been considered on their own merits, not as compensation for dropping another. Also, NEPA does not establish any requirements or responsibili- ties concerning the amount or quality of wilderness that BLM may propose. NEPA sets forth a required process for environmental analysis and for public re- view. BLM is following that process. Any proposals or recommendations may be made at the discretion of BLM after consideration of many factors including, but not limited to, environmental concerns. The NEPA process is only one aspect of the decision process, and it does not mandate any particular decision rela- tive to wilderness quality. 8.21 COMMENT: How will public comments be eval- uated, utilized, weighted, and counted? [Utah Wilder- ness Coalition, et al.] First, how will these written comments be evalu- ated and how will the information within them be uti- lized? Will each letter be read, or will there simply be a signature count of the letters and all of the types of public input? And finally, will original letters be given appropriate weight when compared to the form letters for petitions? Now, I urge BLM to clarify the policy right now with regard to this issue and then I would also urge them to stick with what they decide to do. I hope that BLM does not incur the same pro- blems that the FS came across in the Rare II wilder- ness process. The FS also initially asked for written public comments but, when they became overwhelmed with the vast majority of mail that came in with re- gards to the WSAs, they switched to simply counting the signatures and didn't tell anybody until the end of the process. In fact, a study by a Utah State Univer- sity professor analyzed the Rare II process and found that signature counts became the most important in deciding the state of different WSAs more than even research values or wilderness values of those areas. This decision by the FS did not allow full utilization of the large amount of information submitted by the gen- eral public. Now, many people in this State are invest- ing considerable time and effort into visiting WSAs and then, in turn, writing comments on these areas. I would urge BLM to read and evaluate every comment submitted. 8.21 RESPONSE: BLM has designed a public analy- sis program that has effectively used the large num- ber of comments submitted on the Draft EIS. The pro- gram determined the number of comments in favor or against (1) wilderness in general; (2) each alterna- tive on a Statewide basis (including citizens' propos- als); and (3) each alternative for a particular WSA. The program then summed the reasons supporting commentors' choices, whether submitted on a gener- al, Statewide, or WSA specific basis. The program also determined the number of comments received regarding poor quality data or analysis, inventory, IMP, etc. GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE All comments received were totaled by number of inputs and signatures. Inputs are letters, postcards, oral testimony, form letters, etc. If a person sent one comment letter and also testified at one public hearing, he was coded as having two inputs with one signature. However, if his testimony read almost exactly as his comment letter, he was coded as hav- ing one input with one signature. A petition that was signed by 50 people was counted as one input with 50 signatures, even if the petition was submitted 50 times by 50 different individuals. In addition to the public comment analysis, each letter was read by at least two members of the EIS team to ensure that all substantial comment themes were included and answered in Volume VII of the Final EIS. Corrections were made in the Final EIS where necessary. The comment analysis, public concerns, and sub- stantive comments for each WSA (see Volume Vll-C) were presented to BLM decisionmakers who consi- dered the content and accuracy on a case-by-case basis when considering and developing the Proposed Action. A more complete review of the comment analysis will be part of Wilderness Study Reports that will be submitted to the Secretary of the Interior, the Presi- dent, and Congress for use in the decisionmaking pro- cess. 8.22 COMMENT: The role of the diversity criterion should be solely to increase the diversity of ecosys- tems in the NWPS. [Tim Graham, et al.] The role of diversity criteria to determine wilder- ness should be to increase the diversity of ecosys- tems in the NWPS. This is the only diversity criterion I feel is valid, and I would like to stress that it should play a very important role in deciding how much land in Utah is recommended for wilderness. The Colorado Plateau lands are globally unique. In the context of the world and the NWPS, if all of the entire 3.2 million acres were included in the system, there would be less then 3 percent of the NWPS represented by slick- rock canyons and redrock lands. 8.22 RESPONSE: In developing the Proposed Ac- tion, BLM's policy on the diversity criterion was to note opportunities for adding to the NWPS, rather than using diversity as a criterion for not recommend- 1 9 ing WSAs. Appendix 11 summarizes the rationale for the BLM Proposed Action. Also, see the responses to General Comments 22.9, 22.10, and 22.11 that discuss the NWPS and diversity as a wilderness value. 8.23 COMMENT: The Draft EIS should not include manageability as a selection factor. [James Hansen, et al.] Why is the difficulty of managing certain areas a criteria for selection? It seems to me that our legal system is not at all found upon that premise and that we have difficult situations; even the national parks direct traffic. All of those sorts of things are diffi- cult to monitor and to manage. And since there is really not a lot of experience in trying to manage those areas, I think it may be inappropriate to include that as a selection factor. 8.23 RESPONSE: See the response to General Com- ment 9.14. The rationale for the BLM Proposed Ac- tion, including manageability constraints, is summa- rized in Appendix 1 1 . 8.24 COMMENT: Outside sights and sounds should not be considered as a solitude factor in making rec- ommendations. [Utah Wilderness Coalition, et al.] BLM consistently underestimates wilderness val- ues and recommends against wilderness for many WSAs because of what it calls a "lack of opportunities for solitude." For example, the Draft EIS claims that much of Cheesebox Canyon WSA lacks solitude be- cause of outside sights and sounds on the boundary road. Such intrusions are minimal; moreover, the Con- gress has repeatedly declared that outside sights and sounds do not argue against wilderness designation. The 28,000 people who annually drive up Little Cot- tonwood Canyon from Salt Lake City do not substan- tially interfere with the wilderness experience of visitors to Utah's Lone Peak Wilderness. Neither did the impressive view from the top of the peak to the urban area in the valley below disqualify it for wilder- ness designation. 8.24 RESPONSE: Outside sights and sounds were considered to reduce opportunities for solitude only in cases where they would be overwhelming. Such cases are identified in Appendix 11, which summarizes the rationale for BLM's Proposed Action. GENERAL COMMENTS AND RESPONSES SECTION 8: RATIONALE Only two WSAs, Cheesebox and Devils Canyon, are subject to substantial influence of out-side sights and sounds. 8.25 COMMENT: Proprietary information should not be allowed in the decisionmaking process because the information is not public and not subject to re- view. [Emery County Attorney, et al.] 8.25 RESPONSE: Proprietary information is not subject to public review; however, it is a valuable source of information that cannot be ignored. No deci- sions were strictly based on proprietary data. This is an important source of information and was used, along with all of the other sources of information available to BLM, to determine mineral potential in the WSAs. In many cases, these data simply confirm- ed what was thought to occur in a given WSA. BLM's geologists and mineral specialists reviewed the pro- prietary information, and their assessment of the information is reflected in the favorability and cer- tainty ratings for minerals reported to the public in the EIS. Also see the response to General Comment 15.19 that addresses the accuracy of proprietary minerals information. 8.26 COMMENT: Hazards to hikers are not a valid reason to eliminate areas from consideration as wil- derness. [Unidentified] The comment has been made that certain WSAs are dangerous to visit and should not be designated. A better idea would be to set these areas aside as wil- derness and not allow anyone inside at all. How can hikers be in more danger than cattlemen or ORV users? 8.26 RESPONSE: BLM has not proposed that any WSAs or portions of WSAs be removed from consider- ation as wilderness because of hazards or dangers to visitors. Please refer to the discussion of health and safety considerations in Volume I, Chapter 5, page 182 of the Draft EIS, and to Appendix 11 of this Final EIS, which summarizes the rationale for BLM's Pro- posed Action. Also, see the response to General Com- ment 1.4. and the issue identification section in Vol- ume I, Chapter 1 of the Final EIS. 20 GENERAL COMMENTS AND RESPONSES - SECTION 9 ANALYSIS ASSUMPTIONS AND GUIDELINES INDEX 9.1 The analysis in the EIS is in error because it is based on asynchronous data ranging from 1974 to 1985. (p. 1) 9.2 BLM's scoping process failed to identify the key issues such as air quality, preservation of soils, plant communities, water resources, wildlife, and visual and cultural resources, (p. 2) 9.3 The EIS is repetitious and does not focus on the issues, (p. 2) 9.4 Development assumptions are inconsistent and vary from one alternative to another, (p. 3) 9.5 The cumulative impact analysis in Volume I should be expanded, (p. 3) 9.6 The EIS analysis is unbalanced because the analy- sis of resources such as minerals is much more com- plete than the analysis of wilderness values, (p. 4) 9.7 The EIS fails to evaluate whether proposed devel- opments and their cumulative impacts would violate national environmental standards or policies, (p. 5) 9.8 The EIS does not identify or explain key method- ologies used in the analysis (i.e., evaluation of oppor- tunities for solitude and wilderness recreation, etc.), or provide the source of definitions for the terms used in the analysis, (p. 6) 9.9 The EIS should discuss the value of WSAs for scientific study, (p. 7) 9.10 The EIS should analyze and identify the need for the commodities found in WSAs and alternative sources of those commodities. The EIS does not con- sider the need for commodities by quantity or time period, (p. 9) 9.11 The EIS uses faulty logic in assuming that future water developments would not be precluded just be- cause none are currently planned, (p. 9) 9.12 "Worst-case" analysis should not be used. The disturbance estimates used in the EIS are unrealistic and the methodology for the estimates is not explain- ed. (p. 10) 9.13 The EIS portrays wilderness designation as fraught with many dire environmental consequences when, in reality, it will only stop BLM's destructive management practices (e.g., chaining), (p. 12) 9.14 The EIS does not describe how BLM defines a management conflict or its authority under law for such decisions, (p. 13) 9.15 The discussions of impacts in the Environmental Consequences section of each document should include an identified conclusion for each analysis, (p. 14) 9.16 The Draft EIS lacks growth projections and a proper baseline against which to compare impacts, (p. 15) 9.17 If minerals are not already located and active claims made, then it should be assumed that there is no interest in developing new or existing claims, (p. 16) COMMENTS AND RESPONSES 9.1 COMMENT: The analysis in the EIS is in error because it is based on asynchronous data ranging from 1974 to 1985. [Permits West] The data are not synchronized. The most recent year cited for data ranges from 1974 through 1985. All tables, data, and figures should at least be summa- rized through 1984. Drawing a conclusion from 11 different years is more anecdotal than analytical. 9.1 RESPONSE: The analysis in the EIS is based on the best available information. Because the condition of some resources remains constant over long peri- ods of time, the information used in the EIS is valid, even though inventories were done several years ago. This would apply to such resources as air quality, soils, geology, topography, water resources, 1 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES vegetation types, forest resources, and wildlife habitat. Information on such resources as minerals, live- stock, recreation, and economics has been updated for the Final EIS when possible. 9.2 COMMENT: BLM's scoping process failed to iden- tify the key issues such as air quality, preservation of soils, plant communities, water resources, wild- life, and visual and cultural resources. [Randolph Jorgen, Utah Wilderness Coalition, et al.] The decisions made in scoping and the subsequent Statewide analysis are untenable and reflect BLM’s attempt to avoid discussion of key issues in the wil- derness debate. In the section entitled Resources Not Analyzed on a Statewide Basis (Volume I, Page 183 of the Draft EIS) we see a sad attempt to gloss over some of the most significant issues by claiming that ". . . cumulative effects are not expected to be sig- nificant on a Statewide basis." Much of this is, of course, based on a consistent policy throughout all volumes of understanding the magnitude of probable and possible development impacts in nondesignated areas. It is absurd to say that such issues as (1) impacts on grazing levels, which statutorily must be maintained at least at present levels; (2) operations of a few ranchers, which have been shown as quite minimal; or (3) government revenues, which are of insignificant magnitude throughout the discussion should be analyzed on a Statewide basis, but that issues which are central to the concerns and rationale for establishing wilderness areas (i.e., air quality, preservation of soils and plant communities, water resources, wildlife, visual resources and cultural resources) are not likely to be significant on a State- wide basis and do not merit Statewide analysis. 9.2 RESPONSE: BLM believes that the scoping and EIS processes have identified the proper issues for analysis in Volume I. None of the issues addressed in the comment were ignored. Data on all resources have been compiled in the individual WSA analyses to provide a cumulative data base for making judgments on the proper issues to address in the Statewide Over- view (Volume I). Many resources are analyzed as sig- nificant in the context of local or individual WSAs, but insignificant when placed in perspective of State- wide effects or cumulative totals. The section referred to in the comment has been changed and moved to Chapter I, Issue Identification, and retitled as "Issues Considered But Not Analyzed in Detail" for each alternative. Livestock grazing is not analyzed on a Statewide basis in the Final EIS. Government revenue is discussed in the State- wide analysis, not as an issue in and of itself, but as a component for analyzing the effects of wilderness designation on local economic conditions. Also, see the response to General Comment 2.5, which addresses identification of significant issues. 9.3 COMMENT: The EIS is repetitious and does not focus on the issues. [Dennis Slifer, et al.] a. It is difficult to determine whether issues are being analyzed in the document or dismissed from analysis. After reviewing the numerous site-specific analyses, it is difficult to understand how the scoping was applied because the impact topics are almost iden- tical from one WSA to the next. Descriptions of actions and analyses of effect do not vary significantly from WSA to WSA when there are reasons to conclude that WSAs are different. The differences are often only in names and acres. The repeated discussions have a "canned" appearance. b. A great litany of repetition occurs in Chapter 4, Environmental Consequences of Alternatives. Here the reader must run through discussions of the conse- quences of the 12 principal issues for the seven alter- natives. This produces 84 discussions, many of which have little or no substantial variation from one alter- native to another. BLM has gotten off track here, in that an EIS should focus on impacts. 9.3 RESPONSE: Scoping is a continuous process and several issues arose late in the preparation of the Draft EIS. In some cases, the time did not allow revi- sion of the lists of scoping issues before publication of the Draft EIS. BLM has reviewed the issues and in- cluded an issue identification section in the introduc- tion to each volume. The Environmental Consequences sections have been revised to address only those issues considered by BLM to be significant. Note that an issue can be significant even if the environmental consequences are not. The descriptions of actions taken with wilderness management are similar because wilderness manage- 2 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES merit would, in fact, consist of similar actions and re- strictions regardless of the area being considered. One factor that contributes to the apparent but neces- sary redundancy in the EIS is that each individual WSA analysis must be complete and separate, even though many of the WSAs are located adjacent to one another and, in fact, have comparable resources and issues. 9.4 COMMENT: Development assumptions are incon- sistent and vary from one alternative to another. [Washington County, Jolle Buffa, et al.] a. A primary concern is the inconsistency of assumptions among WSAs. In many cases, develop- ment and extraction of minerals are projected; yet under the All Wilderness Alternative the impacts are estimated to be low because there is little likelihood of development. The assumptions even vary to ex- tremes in some WSAs. In those WSAs it is assumed that development would be "worst-case," but the de- velopment projected is said to be reasonable develop- ment; however, no development is anticipated to be foregone under the All Wilderness Alternative. Assumptions should not change between alternatives. b. The assumptions on projections found in impact analysis often waffle between it is not likely to hap- pen and it will happen. The "waffle" should be elimi- nated by making basic actions expected (i.e., most likely) clear in the descriptions of alternatives. BLM should project the long-term potential for future actions. c. The "worst-case" is always presented for min- eral and energy resources in the tables summarizing significant environmental consequences, while the impacts to wilderness values are evaluated in a "best- case" scenario. It is always assumed that the loss of mineral and energy resources from the All Wilder- ness Alternative will be the maximum potential, re- gardless of how skeptical or unlikely the recovery possibilities are. 9.4 RESPONSE: In analyzing the short- and long- term effects of designation or nondesignation of WSAs, BLM realizes that there are many uncertain- ties. For example, detailed information on the pres- ence of minerals, a key issue, is not available for all locations due to lack of field exploration (drilling, etc.) which would be very costly and impractical to obtain for every location; consequently, professional interpretation of available general data has been nec- essary. Also, such relevant factors as future de- mand, future technology, sources, etc., cannot be accurately projected. The so-called "waffle" in the assumptions in the Draft EIS was an attempt to indicate the uncertainty involved in making projections into the future on the basis of limited knowledge. The assumptions used within each of the alternatives were not inconsistent. For example, where it was indicated that mineral de- velopment could (substitute for the word "can" but less certain) occur, it was also stated that wilder- ness values could be affected. BLM has changed the approach to analysis assump- tions in the Final EIS. The Description of the Alterna- tives in Volumes I through VI include an Action Sce- nario that states what activities are projected to occur under the No Action/No Wilderness and other alternatives, and the analysis has been rewritten in language that indicates what would or would not occur given the indicated set of assumptions. Projected activities are explained in Volume I, Appendix 6 and Appendix 10. The activities projected for each alter- native are not a worst-case scenario, but are reason- ably foreseeable considering resource conditions, terrain limitations, and economic conditions. 9.5 COMMENT: The cumulative impact analysis in Volume I should be expanded. [Utah Wilderness Coali- tion, National Park Service, et al.] a. The cumulative discussion on page 174, Volume I of the Draft EIS is shallow. It should be expanded to account for the total effect on each of the important Statewide issues identified as relevant cumulatively. At issue is the total effect on mineral production, grazing, and revenues. There may be others, but the discussion in the Draft EIS provides only an overview of total acreage and an examination of diversity. The benefit of the Statewide volume total is to show the public that BLM looked at the total consequences. This section needs more impact consideration. b. In Chapter 4, pages 109-178, the cumulative Statewide effects of the various wilderness alterna- tives were not addressed for much of the affected environment. This included most of the natural envi- ronment (i.e., threatened and endangered species, wildlife, vegetation, aquatic species, riparian habi- tat, raptor habitat, water resources, etc.). By detail- ing the effects of wilderness designation on only an individual WSA basis, the cumulative impact of the 3 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES wilderness alternatives on these resources cannot be assessed. In addition, the splitting will tend to de- crease the importance of the greater wilderness alter- natives to these resources. Since most of the miner- al, grazing, and economic impacts are assessed on a Statewide basis, we recommend the natural environ- ment be assessed in the same way. In a similar man- ner as above, recreation is not assessed on a State- wide basis. This appears to be a very significant part of the wilderness proposal. We recommend the EIS identify what will be the total change in recreational patterns in the State as a result of the various wilder- ness alternatives. Because of the above lack of evalua- tion, there is an appearance in the document that min- erals, grazing, and other economic factors are consid- ered more important than many of the natural, cultur- al, visual, and recreational resources within and sur- rounding the WSAs. 9.5 RESPONSE: Volume I is a cumulative analysis of the Statewide proposal. See the response to Gen- eral Comment 9.2. Information on the resources re- ferred to in the comment was accumulated in a data base and totals were considered in the context of Statewide significance. All resources are addressed in the Affected Environment (Chapter 2, Volume I). Chapter 1 of Volume I of the Final EIS identifies re- sources that would not be significantly affected on a Statewide basis. BLM does not consider minerals and economic factors as more important than natural, cul- tural, visual, and recreation resources; however, the analysis indicates that wilderness designation or non- designation would not have a significant affect on these latter values on a Statewide level, thus detailed Statewide analysis of them was not undertaken. 9.6 COMMENT: The EIS analysis is unbalanced be- cause the analysis of resources such as minerals is much more complete than the analysis of wilderness values. [Jay Lepreau, Utah Wilderness Coalition, et al.] a. In general, the BLM's analysis of resources such as minerals is much more complete than its an- alysis of wilderness values. This information gap will be exacerbated when the USBM/USGS mineral survey is done. This disparity inevitably contributes to a bias against wilderness and needs to be rectified, even if it means delaying the Final EIS. For example, essen- tially, no formal archaeological inventories were done, although that resource's importance in many areas is unquestioned. Note that this issue was raised in the scoping phase, but does not appear to be satis- factorily answered in the Draft EIS. b. The scoping concern was a request for informa- tion collected firsthand by BLM and used to evalu-ate the wilderness qualifications of individual WSAs. In addition, please explain what criteria BLM used to compare the relative values of minerals data, wilder- ness qualities, and other attributes used in the Draft EIS. c. BLM has contracted for studies of mineral val- ues within WSAs, but it has neither done nor hired anyone to study or to inventory and analyze the wide range of wilderness or noncommodity values within these same areas. Archaeological and endangered spe- cies surveys have been conducted only in areas slated for development. There are enormous gaps in BLM's data for recreation and wildlife. Information is not bal- anced and wilderness-either by chance or by design- is clearly the loser. There can be no analysis, no ra- tional selection among choices, absent a thorough knowledge of the competing values. What is BLM doing to correct this imbalance? Is BLM now conducting field inventories of wilderness use and values? BLM's Draft EIS response was that BLM personnel prepared site-specific data on various resources (including wil- derness values), but general-ly lacked sufficient min- eral data. The mineral data were needed to help bal- ance other data. BLM's response is disingenuous. BLM, to our knowledge, has done no thorough archaeo- logical inventory of the lands under study and no thor- ough analysis of many other resources that fall under the category of wilder-ness values-either on its own or by contract. If guess work was sufficient for, say, archaeological resources, why did mineral re- sources require an expensive study prepared by out- side consultants? We request a list of any inventories BLM conducted for its Utah wilderness studies, as well as agencies or specialists, contract or in-house, who prepared individual assessments of wilderness values. d. Another important point in the context of the testimony given by primarily the oil and gas indus- try, Rocky Mountain Oil and Gas Association and Sohio, is the idea that the Draft EIS is inadequate based on the failure to use updated mineral analysis. Well, I would say that the Draft EIS is inadequate based on the failure to analyze or inventory the full extent of the wilderness values in the State and, in addition to that, it's very clear that BLM does not have any idea how many archaeological sites are 4 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES found in the WSAs, much less in the other roadless acres in the State. How does BLM know what current wilderness uses are in existence and how many hik- ers and hunters and other values are being included? So, if the EIS is inadequate because there is an inade- quate amount or not enough information about oil and gas, then it is inadequate on all levels because none of the resources are clearly known at this time. e. BLM needs to clearly identify the multiple-use benefits that wilderness designation will bring. Care- ful control of mineral exploration and extraction is one example. Strong protective stipulations on oil and gas activity is another. Preservation of naturalness protects archaeological sites, wildlife habitat (includ- ing endangered species), and recreation values. Incom- plete inventories hamper the analysis of impacts to these values. A quantifiable estimate of benefits in protecting wilderness values in wilderness areas needs to be completed. To do this, the required wilder- ness inventories need to be completed. 9.6 RESPONSE: See the responses to General Com- ments 13.1, 16.2, 16.3, 20.2, and 22.1 for discus- sions on the need for inventories on vegetation, wild- life, cultural, and other wilderness resources. In gen- eral, the Wilderness Study Policy (USDI, BLM, 1982a) identifies the resources addressed in the com- ment as wilderness special features and states that BLM should consider these features "based on an assessment of the estimated abundance or importance of each of these values to the area." This indicates that full-scale and detailed inventories are not requir- ed for wilderness consideration. BLM has gathered ex- isting information and estimated the abundance or im- portance of these values in developing BLM's Propos- ed Action. Appendix 1 1 summarizes the rationale for the Proposed Action. The requirement for a detailed assessment of po- tential mineral values is included in Section 603 of FLPMA, which mandated the wilderness review for public lands. The Bibliography sections of the EIS identify spe- cific information sources used by BLM in preparation of the EIS. 9.7 COMMENT: The EIS fails to evaluate whether proposed developments and their cumulative impacts would violate national environmental standards or policies. [Chevron Resources Company, Utah Wilder- ness Coalition, and Environmental Protection Agency] a. Because lands are not designated wilderness does not mean that the Federal government lacks the authority to enforce environmental protection stan- dards. Environmental laws such as the Clean Water Act, Clean Air Act, Resource Conservation and Recov- ery Act, FLPMA, Endangered Species Act, and NEPA clearly provides superlative protection for all sur- face resources. b. The EIS fails to evaluate whether proposed de- velopment, including the cumulative impacts of devel- opments that may occur, violates national environ- mental standards or policies. In many cases, enor- mous coal development, tar sand production, range projects, and uranium mines are proposed with no description of the cumulative impacts related to any standards. BLM needs to determine whether and which environmental standards are violated by the worst-case development scenario for each alterna- tive. Without this kind of analysis, the public has little basis for weighing alternatives relative to en- vironmental standards or policies. 9.7 RESPONSE: BLM realizes that developments would not proceed in violation of law. The level of detail requested in the comment cannot be achieved without specific project proposals, including such in- formation as the exact location of facilities and de- tails on types of processes and control technology. This level of information is not available at this time and will only be provided as part of specific project proposals submitted to BLM in the future. It must be assumed that future users in areas included in the wil- derness study would meet requirements for all applic- able Federal, State, and local permits. Where applica- ble, the analysis notes that developments may be re- strained in size, location, and technology due to the requirements of law and regulation. The No Action/No Wilderness Alternative portrays the general applica- tion of environmental standards and policies without wilderness designation. The analysis assumptions have been revised for the Final EIS, and analysis is based on the Action Scenarios that address likely activities in the WSAs in the foreseeable future, ra- ther than worst-case. Also, see the response to General Comment 9.4. 9.8 COMMENT: The EIS does not identify or explain key methodologies used in the analysis (i.e., evalua- tion of opportunities for solitude and wilderness rec- reation, etc.) or provide the source of definitions for the terms used in the analysis. [Utah Wilderness Coalition, et al.] 5 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES The EIS does not identify or explain the key me- thodologies used in the analysis, and the methodolo- gies that appear to be used are not consistently applied. Here is a brief list of the methodologies mis- sing from the Draft EIS: (1) evaluation of outstand- ing opportunity for solitude; (2) evaluation of out- standing opportunity for wilderness recreation; (3) estimates of revenues received; (4) estimates of mineral quantities; (5) estimates of recreation use; (6) estimates of wildlife populations; (7) criteria to determine the significance of issues; (8) determina- tions of significance of a conflict with wilderness designation; and (9) estimates of grazing use in WSAs. A number of BLM's conclusions concerning various WSAs appear to be based on the facts and data not appended to the Draft EIS. Further, there is no indication that other available and applicable data such as studies, reports, and inventories have been considered. It is nearly impossible to legitimately and appropriately comment on the methodology of BLM and, more specifically, on the conclusions reached in the Draft EIS, without access to that data and informa- tion. Numerous terms and figures were used in the Draft EIS without reference to the source of the defi- nitions (although the definition itself was often in the Glossary). It would be helpful to further clarify the meaning and cite the sources of these terms and/or figures: crucial, critical, and high priority wildlife habitat, Class V visual management, $4.10/ visitor day average recreational expenditure, visitor day equals 12 hours, and a day's driving time equals 5 hours. I find it particularly difficult to understand the difference in length of a "day" used for driving and one used for recreating. 9.8 RESPONSE: The methodology used was one of relating the projected use (e.g., recreation) to the ex- isting conditions on the unit and interpreting what effect was likely over the short- or the long-term based on the level of the action involved. The data used in the EIS are found in the sources identified in the Bibliography. Please note that the Introduction to Chapter 3, Affected Environment, states that "Unless otherwise stated, information for this chapter was taken from the 83 individual analyses (Volumes II through VI) and/or inventory and planning documents (as referenced in the individual analyses, Volumes II through VI), other file records in each of BLM District or Area Offices, or personal knowledge of BLM re- source specialists." The CEQ guidelines (1502.21) allow incorporation of information by reference when the effect is to cut down on document bulk without impeding agency and public review of an action. The incorporated material is cited in the statement, and its content is briefly described. The sources cited are reasonably available for inspection by interested persons either at BLM State Office or at the District Offices. Page i of the Draft EIS listed a name and telephone number to con- tact for further information. For items (1) and (2) the sources cited in the EIS are BLM Inventory Files located at the District Offices. Determinations on "outstanding opportuni- ties" were made during the inventory phase of the wilderness review through use of the methodology outlined in the Wilderness Inventory Handbook (USDI, BLM, 1978) and subsequent Organic Act Directives. For item (3), estimates of revenues, the cited sources are BLM Utah Facts and Figures (USDI, BLM, 1985c), BLM Public Land Statistics (USDI, BLM, 1985d), and the unit rates provided in text multiplied by the units of resource in the WSAs (e.g., $2 per acre per year for oil and gas leases multiplied by the acreage of leases within the WSA). Appendix 9 de- scribes the methodologies used for estimates of rev- enues. For item (4), estimates of mineral quantities, the source cited throughout the EIS is SAI, 1982. Appen- dix 5 explains the criteria for the ratings and the esti- mated resource quantities used by SAI. The estimates of existing recreation use (item 5) are based on the best available information such as UDWR hunting and fishing records, BLM visitor regi- sters and estimates by BLM District and Area recrea- tion staffs. The information sources used have been more carefully noted in the Final EIS. Recreation use projections for the various alternatives are based on the studies of Cordell and Hendee (1982) and the Utah SCORP (Utah Outdoor Recreation Agency, 1980) and others. This methodology is described in Appendix 9 and referenced in text. Also, see the response to Gen- eral Comment 21.5. Where given, wildlife populations are estimated (item 6) by local BLM and UDWR wildlife specialists familiar with the WSAs. Also, populations are in- ferred from current UDWR Utah Big Game Investiga- tions and Management Recommendations. 6 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES For item (7), BLM compiled information for each resource from the Description of the Affected Envi- ronment in the individual WSA analyses. No resources were ignored in the individual analyses. Based on the cumulative totals of affected resources in all 83 WSAs and the level of interest or controversy con- cerning certain resources, BLM either addressed the subject in detail in the Statewide EIS or presented negative declarations for the resources that, in BLM's judgment did not warrant detailed discussion in Volume I, the Statewide Overview. These negative declarations and the rationale for the judgments were provided in the Draft EIS in Chapter 5, Resources Not Addressed in Detail On A Statewide Basis. They are provided in Volume I, Chapter 5, Issue Identification in the Final EIS. Also, see the responses to General Comments 9.2 and 9.3. Item (8), Significance of Conflicts, is also addressed in the Issue Identification sections and Appendix 11, which contains a summary of BLM's rationale for BLM’s Proposed Action. In keeping with the Wilderness Study Policy guidelines for satis-fying quality standards, BLM has discussed, in descriptive format, how energy and mineral resource and other resources would be affected by wilderness designa- tion and how wilderness values would be affected by other resource uses without designation. The Wilder- ness Study Policy does not require any special me- thodology for establishing the "significance of a con- flict with wilderness designation" in development of the Proposed Action or recommendations. See the response to General Comment 3.5. BLM has analyzed public input and the trade-offs involved to determine an appropriate use of the public lands. Accordingly, BLM has developed a Proposed Action based on its best judgment concerning wilderness suitability. This procedure is described in the Wilderness Study Policy (USDI, BLM, 1982a) (see the response to General Comment 8.6). Grazing use estimates (item 9) were made by pro- rating the number of AUMs of licensed use in each allotment by the percentage of the allotment within the WSA. An explanation of this approach is provided in the Final EIS. Also, see the response to General Comment 18.4. 9.9 COMMENT: The EIS should discuss the value of WSAs for scientific study. [Utah Wilderness Coali- tion, James Janney, and Alice Lindahl] a. During scoping we asked, "How will BLM address the value of WSAs for scientific study?" The Draft EIS states that "Wilderness would limit nonconforming activities and thereby help protect ex- isting ecological, geological, or other features of sci- entific, educational, scenic, or historic value in the area. Wilderness would foster a natural distribution of native species of wildlife, fish, and plants by ensur- ing that natural ecosystems and ecological processes continue to function naturally with minimum outside influences." We heartily concur in the above statements but they do not respond to our previous scoping com- ments. We asked how the agency intends to address the scientific values of WSAs. We still request a thorough inventory and a rigorous analysis of these values for each WSA. The scientific value of each WSA should be analyzed in the Final EIS. If the agency believes the statements it made in the above "re- sponse," it should also believe, as we do, that it is crucial to understand the scientific values that exist in areas not recommended for wilderness so that we may understand which values will be denied the pro- tections outlined above. BLM assumes the pre-sence of minerals where inventory information is minimal. BLM may be correct in making estimates for re- sources not yet inventoried, but should apply the same standard to wilderness values that it has not inventoried. BLM needs to estimate the special wilder- ness values that are present based on existing infor- mation. BLM uses the lack of an inventory to conclude that the value is absent. Without this consistency, the environmental effects of the different alternatives cannot be fairly compared. BLM appears not to have sought guidance from the scientific community about which lands should be pre- served for scientific study. BLM has not approached the scientific community for the kind of expert com- ment about the scientific activities that need and rely upon protected natural lands. Such activities may well include studies of geology, ground and surface water, weather, air quality, visibility, plants, ani- mals and insects, grazing use, recreational use, genet- ics, and many more. BLM should inventory the cur- rent and potential wilderness-dependent scientific re- search and identify which WSAs would support it. b. Not enough attention has been given to the scientific value of wilderness. This is a difficult subject to talk about in detail because it is, by its 7 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES very nature, unknown. We cannot say what there is to learn from wilderness before we have learned it. More importantly, we cannot say now what we will have to learn from wilderness 50 or 100 years from now. The history of science is full of surprises and rapid change. Current research in aerodynamics in- volves studying the way the wings of birds bend as they pass through the air. The way schools of fish or flocks of birds manage to coordinate their movements is of interest to engineers trying to design distributed systems. It would have taken exceptional foresight to predict these interests even 10 years ago. The entire science of the ecology of natural systems, which may eventually lead to an understanding of our own econo- my, is comparatively recent. We cannot definitely identify all of the scientific value of wilderness, but to fail to preserve what wilderness still remains is to assert that there is nothing of value that we can learn from it, and that is certainly untrue. Also, there are some unique and important geologic features in these areas that should be preserved. Ten thousand years ago, as you probably know, there was a giant lake that occupied most of Utah or a good portion of it. It left its mark at the bases of these ranges in the form of shore lines, delta deposits, and beach deposits. Along the bases of the Fish Springs Range, the House Range, and the Deep Creek Range are prominent, rela- tively young fault hearths which are a record of past large earthquakes. Although these features have been recognized by geologists, they have been largely un- studied. It is important that these features remain in pristine condition for future scientific study. c. In my work as a biologist/community ecolo- gist, I study the relationship between aquatic species in isolated habitats. The natural pools of the slickrock canyon country are ideal for these studies. They pro- vide natural experiments in the effects of pool size, temperature fluctuation, immigration potential, chemi- cal make-up, and many other factors on the dynamics of community membership. Studies like these tell us a lot about interrelations between organisms and also how evolutionary change is promoted in isolated eco- logical settings. That these pools need to be undisturb- ed by cattle watering, mining, road building, and other activities is obvious. Wilderness designation provides this protection. Such a small percentage of the total area of Utah is considered here, that the in- vestment for future generations in recreation as well as protection of natural areas of scientific interest seems small indeed. I think that BLM has overlooked some very important areas of high wilderness and sci- entific value. These are Nokai Dome (80,000 acres) and Mancos Mesa (109,000 acres). These areas are the remnants of the sandstone habitats under Lake Powell. They are particularly valuable for the natural studies I have described in community ecology and are surely deserving of protected status. 9.9 RESPONSE: The Draft EIS response referred to in this comment was written to answer the question "When and how would wilderness designation protect important scientific values?" The question asked by this comment is not the same, but asks "How will BLM address the value of WSAs for scientific study?" The EIS addresses the scientific values of the WSAs as part of the resource discussion and in the special features portions of the Wilderness Values sections. The scientific community was afforded the opportunity to participate in the wilderness review process from the initial inventory, through EIS, scop- ing, and the comment period for the Draft EIS. Many persons from universities and diverse interest groups (including specialists in ecology, cultural re- sources, threatened and endangered species, clima- tology, geology, etc.) have provided comments and suggested investigation of unique and special scienti- fic values. These values are identified in the EIS to the extent that the scientific community, including BLM personnel, have identified the issues in the public process. Examples of the scientific values identified in- clude the giant atriplex in the Rockwell WSA, the spe- cial cultural resources in the South-East Region, the need for climatological studies and special geological features in the Henry Mountains and West Central WSAs, the significance of cryptogamic soils in desert regions and the relationships mentioned in paragraphs b and c of this comment. See the response to General Comment 9.6, which explains that the Wilderness Study Policy (USDI, BLM, 1982b) requires an assessment be made on the basis of estimated abundance and importance of wil- derness special features. Additional statements on wilderness special features have been included in the Wilderness Values sections of the Final EIS. 9.10 COMMENT: The EIS should analyze and identi- fy the need for the commodities found in WSAs and alternative sources of those commodities. The EIS does not consider the need for commodities by quan- tity or time period. [Utah Wilderness Coalition, et al.] 8 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES It is inappropriate to consider individual WSAs as discrete economic units, unrelated to either State- wide or national economies. Nonwilderness and wilder- ness values should be compared-both quantitatively and qualitatively-against the available State and na- tional supplies. This is especially important and espe- cially appropriate inasmuch as BLM has pursued a Statewide EIS. Presumably, if there is any defensible rationale at all for a Statewide EIS (in violation of agency policy), it is the opportunity to take a compre- hensive look at all the resources involved in wilder- ness decisions. The Draft EIS does not consider the need for commodities by quantity or time period. While the Draft EIS lists alternative sources for com- modities, it fails to identify alternative methods for meeting the need. For example, there are materials now available as alternatives for potash. 9.10 RESPONSE: The availability of various com- modities in areas outside WSAs is indicated in the EIS by comparison of the amounts of various commodi- ties with estimated State and national supplies. For example, Table 28 (Volume I of the Draft EIS) indi- cates that the proven U.S. reserve of phosphate is 14 million metric tons, while the proven phosphate re- serve of Utah is 220 million metric tons. Table 29 shows that the estimated in-place phosphate in WSAs is 14 tons. A comparison of these figures indicates that there are alternative sources of phosphate out- side BLM WSAs. In response to the public comment on the Draft EIS, BLM has made more definite assumptions on the potential for commodity development in the foresee- able future. These assumptions are based on current projections for the various commodities within the WSAs as explained in Appendix 6 in Volume I. BLM assumes that, if there are economically feasible alter- native methods for meeting the need for commodities found in WSAs, their influence is reflected in the eco- nomic and demand projections used in making develop- ment assumptions. A multitude of scenarios address- ing the technical feasibility of substituting one com- modity for another in various industrial applications is not appropriate for the Utah BLM Statewide Wil- derness EIS. Also, see the responses to General Comments 2.24 and 2.26, which discuss the relationship of the Utah BLM Statewide Wilderness EIS and BLM's plan- ning system. See the responses to General Comments 3.37 and 15.20 for information on the future demand for commodities and development assumptions. 9.11 COMMENT: The EIS uses faulty logic in assum- ing that future water developments would not be pre- cluded just because none are currently planned. [Fre- mont River Soil Conservation District] All of the WSAs effectively prevent development of water improvements. Wilderness is a decision in perpetuity, and to preclude future water develop- ments just because none are currently planned is faulty logic and also shows a pro-wilderness bias. 9.11 RESPONSE: Even though BLM wilderness man- agement guidelines allow water development for live- stock and wildlife purposes if compatible with wilder- ness management, and development of major reser- voir projects if approved by the President of the US, the Water Resources sections of the EIS state that opportunities for additional improvements or expan- sion of existing water improvements would be reduc- ed. Also see the response to General Comment 3.26. The EIS analysis reflects the current situation and foreseeable future regarding water development. Also, it notes several water resource development potentials that have been identified in river basin in- ventories and general investigations. Although pro- jects are not presently planned, these could be fur- ther studied in the long term. The most likely and fea- sible water project sites for both short- and long- term consideration are included. BLM does not believe that it is faulty logic to base an objective analysis on the best information available regarding potential water resource development when considering trade- offs with wilderness values. You cannot preclude something that isn't going to happen, and until there is some reasonable evidence that a development is like- ly, it is pure speculation to claim an effect that may never occur. 9.12 COMMENT: The disturbance estimates used in the EIS are unrealistic, and the methodology for the estimates is not explained. [Utah Counties, Randolph Jorgen, Utah Wilderness Coalition, et al.] a. Faulty logic is used when a worst-case analy- sis for disturbance on 190 acres is determined for the No Action Alternative, but the analysis for soil disturbance under the All Wilderness Alternative only assumes 20 acres will be disturbed. How can this be? Aren't the claims and leases the same on the same land under either alternative? This is a patent case of pro-wilderness bias. If worst-case analysis results in 190 acres of disturbance, shouldn’t it also show 9 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES the same figure under the All Wilderness Alterna- tive? How can larger amounts of acreage disturbance be shown for nonwilderness than for wilderness areas? Aren't claims and leases the same under either alternative? Appendix 10 needs clarification. b. In referring to Appendix 10 (Volume I, page 370 section entitled "All Wilderness and Partial Wil- derness Alternatives, under Locatable Minerals) in trying to find out the methodology used for determin- ing the number of acres disturbed under the All Wil- derness Alternative, we read the following: "Where the location of minerals in the WSA was unknown, the disturbance estimated for the No Action/No Wilder- ness Alternative was assigned to designated and non- designated portions of the WSAs based on relative pro- portions of the WSA that would be designated and non- designated. Where the position of the locatable miner- als in the WSA was known, disturbance was specifical- ly assigned to the designated or nondesignated area." This does not clarify how only 20 acres will be dis- turbed in this WSA under the All Wilderness Alterna- tive. It doesn't clarify anything. Any reference to Appendix 10 in response to these comments will be as useless as trying to decipher some substantive mean- ing from the bureaucratic gobbley gook quoted above. c. The basic question which really hasn't been asked or answered is if this wilderness is left alone as defacto wilderness, what will happen within the foreseeable future. This means that, if the rest of the country doesn't move to Utah, there may be develop- ment of some type, whether it's ORV usage, mineral usage, or agricultural usage on probably less than 4 percent of the acres, 10 percent at a maximum. So, not making this wilderness area designated under the law will not, contrary to what most of the people seem to feel, ruin wilderness values. In the vast ma- jority of areas, there will be no change whatsoever. d. I question the EIS's basic assumption that WSAs left undesignated as wilderness (in either the No Action or Partial Wilderness Alternatives) will have only a small portion of the wilderness values impair- ed. Utah is one of the fastest-growing States. Based on my observations from living in areas that have already experienced high growth and development (California presently and the midwest previously), the wilderness values left unprotected will gradually be impaired through mineral development, ORV activ- ities, campgrounds, garbage dumps, range improve- ments, exotic plant introductions, timber harvest, etc. A more correct assumption would be that the majority of wilderness values will be lost on areas not designated as wilderness. e. Throughout the Draft EIS, BLM has done a re- markable job of understating the likely development impacts if these lands are left unprotected by wilder- ness designation. Perhaps they have succeeded in fool- ing themselves with statistical machinations, count- ing up an acre here and there, but when they get all done they should stop and take a look at how plausible the totals seem. Would they seriously have us believe that in a 100 or more year-span only 82,000 acres of over 3 million acres will be disturbed by energy and mineral development and exploration, especially considering the magnitude of the hue and cry of the mineral industry over wilderness consideration, and the fact that there are currently over 2 million acres of oil and gas leases and 250,000 acres of mining claims in these areas? What is not mentioned in the discussions on impacts from grazing rangeland manipu- lations is that the acres listed include only current proposals for developments, not future possibilities, which would be much greater. Also not listed are the many thousands of acres which potentially would be seeded to exotic grasses following wildfire. Does the 215,000 acres of Table 66 (No Action Alternative) take into account not only current proposals for devel- opments but also corridors for scenic parkways and other highway boondoggles; lands inundated by future hydroelectric boondoggles; strip mines; powerline corridors and powerplants; massive developments and transportation corridors associated with nuclear waste dumps, as will probably be reconsidered in fu- ture decades for lands adjacent to Canyonlands Nation- al Park and the Abajo Mountains; further military withdrawals in the West Desert, including possible bombing ranges and missile sites; ORV racetracks; waste disposal sites; sale or other disposal to private hands of public lands as has been openly advocated by this administration; or any of the many other uses often advocated and executed for "vacant" desert lands? Without consideration of these and similar fac- tors, there can be no adequate evaluation of the value of designating wilderness. f. Producing 10 million barrels of oil may involve a field of approximately 2,500 acres and require a reasonable estimate of the impacts on wilderness val- ues, wildlife habitat, etc., from these activities. As currently presented, the impacts on those values iden- tified in most site-specific WSAs do not appear to be GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES logical or accurate. If 160 acres of disturbance is dis- persed over a 2,500-acre field, it is not logical to assume that only 160 acres of wilderness values will be impaired. The impacts from 160 acres of disturb- ance will impair most of the wilderness values within the 2,500-acre field because sight, sound, and dis- turbance interact with resources. This, of course, depends on topography, vegetation, and other factors. The present analysis of determining merely that 160 acres of wilderness values is not consistent with the assessment of impacts by existing development. This problem is very evident in WSAs such as Mancos Mesa. In Mancos Mesa, the partial alternative was de- veloped because of past development which has im- pacted wilderness values in that WSA. It was deter- mined that 20 pads disturbing 5 acres and 25 miles of road from previous development had impacted over 5.000 acres of wilderness values. Field development in the rest of the WSA will result in disturbance of 200 acres; however, the impact on wilderness values is estimated to be only confined to the 200 acres of disturbance. This is not realistic. g. The descriptions of the alternatives, especially for minerals, contain some information, but stop short of providing estimates of major actions that will occur in the WSAs. A projection of the type, amount, and location of development is needed before an analysis can be completed. Projections should de- scribe what the development would involve, includ- ing roads, drill pads, open-pit mines, underground mines, and ancillary facilities, and how disturbance would be distributed in the WSA. These projections should be based on what is realistically anticipated. This type of information can be found in the EIS, but is scattered from the Appendices through the impact analysis. If several scenarios are possible, BLM should use the most likely one and assemble it on the location where the scenario is described for each alternative. The primary problem is that development is predicted but, in many WSAs, it is not adequately described. h. The mineral and energy development scenarios in the EIS are weakly portrayed. It is very useful to know that a WSA is potentially believed to contain 3 million barrels of oil, 18 billion cubic feet of gas, 700.000 tons of coal, and 100 tons of uranium oxide, for example. However, missing and most relevant, is how much roading, surface area disturbance, new fa- cility development, and water disposal could be asso- ciated with the recovery of these resources. It is these actions that cause environmental impact, not the resources themselves. i. Throughout the entire EIS, arbitrary figures are used for estimated tonnage and estimated surface disturbance. Use of these numbers is specious. With- out a detailed drilling program, it is impossible to pre- dict the amount of resource within an area. The state- ment that "there could be 500 tons of some mineral commodity in a WSA" has little credence without any data to base it on. There very well could be 500 tons of this mineral, but there could also be 0 to 5 million tons as well. As for predicting surface disturbance on a mining claim, disturbance could range from none at all to the entire mining claim being disturbed. The scope of disturbance would depend on the operator, the mining method selected, the mineral commodity being mined, and a host of other variables. To make an assumption that minerals are spread uniformly in a WSA is ludicrous. The determination of the exact amount of disturbance would be made when a plan of operations wsa filed under 43 CFR 3809. To try to predict surface disturbance beforehand is not pru- dent. j. Do the acreage disturbance figures include roads needed for access or do they just cover the mining sites? If roads are included, then the acreage- disturbance figures are low. k. Oil and gas acreage disturbance figures are low because topography has not been taken into considera- tion. 9.12 RESPONSE: Disturbance estimates have been revised for the Final EIS. The methodology for projec- ting mineral and energy developments and related sur- face disturbance is explained in Appendix 6 and Appen- dix 10. These projections are based on feasibility and demand and are reasonably foreseeable as required by the CEQ guidelines for situations where data is lacking. The larger acreage disturbance figures shown for nonwilderness assume that, in some cases, new leases or claims would be developed in the foresee- able future. It is further assumed that, once leases have expired in wilderness areas, they would not be renewed; therefore, no surface disturbance would occur in these areas. However, this would not be the case if the area under consideration was not desig- nated wilderness. The difference in disturbance esti- mates is simply based on acres available for energy GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES and mineral development. Appendix 10 has been clari- fied to reflect this information. For the most part, dis- turbance estimates are linked to known sites from which quantities of mineral resources comparable to those projected to be in the WSAs have been extract- ed. The short term is defined as that time from the present to the year 2020. However, within this short- term period, the quality of data varies. From the pres- ent time to about the year 2005, there are relatively good data with which to make development projec- tions. From the year 2005 to the year 2020, no data exist and the mineral development expectations are speculative. Development in the short term is pro- jected for some WSAs which have a high favorability and/or certainty rating for any given mineral or en- ergy resource. However, certain other WSAs with high favorability and certainty ratings are projected for only long-term development due to conditions de- scribed below. Long-term development potential is defined as that which could occur beyond the year 2020. It is recognized that, in certain WSAs, mineral or energy resources are known or are believed to occur but do not have a high favorability rating. In other WSAs, mineral or energy resources may have high favora- bility but are expected to be developed only in the long term due to several factors, including market costs, development costs, projected demand, etc. A general description of the most probable location of and nature of the disturbance is also provided. Be- cause direct disturbance estimates have been reserv- ed only for those developments in the foreseeable future, the overall estimates of disturbance have been reduced from those analyzed in the Draft EIS. In addition to direct disturbance estimates, zones of influence surrounding disturbed areas where oppor- tunities for solitude and primitive recreation would likely be affected have also been projected. The analy- sis has been revised accordingly. Acreage disturb- ance figures do include access roads, and topography was considered for the specific WSA conditions. In addition to mineral- and energy-related disturbance, disturbance from vegetation treatment, proposed rights-of-way, ORV use, etc., have been added or re- vised for the Final EIS. These disturbance estimates are, of necessity, based on the present BLM land use plan (No Action/No Wilderness) and identified project proposals. The projections of economic trends, population growth, and movement, or other factors relating to future land use, are highly speculative. It should also be noted that many of the WSAs are presently road- less and natural in character because of their rough topography, remoteness, and/or lack of exploitable resources. Potential changes and impacts with each of the alternatives are compared to the existing situa- tion and the projected future environment without wil- derness designation (e.g., future situation with the No Action/No Wilderness Alternative). Also, see the response to General Comment 8.10 which discusses de facto wilderness. 9.13 COMMENT: The EIS portrays wilderness desig- nation as fraught with many dire environmental conse- quences when in reality, it will only stop BLM's de- structive management practices (e.g., such as chain- ing). [Dennis Slifer, et al.] It seems the EIS portrays potential wilderness designation as something very drastic and fraught with many dire environmental consequences. Some ex- amples: (1) "Wilderness designation could mean unac- ceptable soil loss due to foregone erosion control mea- sures (which would be precluded from designated areas)." What soil? This is an arid slickrock desert or badlands. The natural geologic erosion rate in "unpro- ductive wastelands" is something to fear or manipu- late? What erosion control measures could BLM be contemplating? Stockwatering ponds perhaps? (2) "Wilderness designation would prevent certain future rangeland improvements." This means BLM would no longer be allowed to use bulldozers to chain down un- told acres of the native pinyon-juniper vegetation as one of their "land treatments." I don't need to elabor- ate on the horrifying environmental impacts of chain- ing. Chapter 4, Environmental Consequences, is for the most part an elaborate sham, designed to make wilderness designation look bad and to imply that BLM management and manipulation of these areas under multiple use is good (or more accurately, that the pre- vention of these activities, because of wilderness con- straints, will be a bad thing). Chapter 4 should be re- evaluated and rewritten. 9.13 RESPONSE: FLPMA (1976) and the Wilderness Study Policy (USDI, BLM, 1982a) require BLM to con- sider wilderness designation in the context of BLM multiple-resource planning process. In Chapter II, paragraph C, the Wilderness Study Policy states that: "Areas recommended as suitable for wilderness GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES designation should possess wilderness values and mul- tiple resource benefits capable of balancing the bene- fits of other resource values and uses which would be foregone due to wilderness designation." The EIS addresses the opportunities for alternative manage- ment and production strategies that would be fore- gone with wilderness designation. The opinion expressed in the comment is noted. However, the statement concerning lack of soils is generalized; many areas in WSAs have soils suffi- cient for vegetative manipulation and successful re- seeding. A large body of literature on the effects of pinyon-juniper chaining indicate that this method of "land treatment" can be beneficial in reducing soil erosion, improving big game habitat, providing live- stock forage, and increasing prey-base for raptors and other predators. For example, Baker and Frisch- knect (1973) found that the number of deer mice and pocket mice (prey-base for predators) increased greatly on chained areas 2 years after treatment, then declined sharply, but remained at a level that was still higher than the pre-treatment level. These types of trade-offs and opportunities are considered in BLM land use plans that would be implemented in the WSAs, as described for the No Action/No Wilder- ness Alternative. 9.14 COMMENT: The EIS does not describe how BLM defines a management conflict or its authority under law for such decisions. [Utah Wilderness Coali- tion, et al.] a. The Proposed Action fails to adequately define what a conflict is. Some conflicts are realistic pro- posals for nonwilderness uses of these WSAs. Most of the conflicts are unsubstantiated guesses that develop- ment may occur. In several cases, BLM concludes that development is highly unlikely, yet drops the area because of development conflicts. The Draft EIS should only consider real conflicts and give no weight to unlikely or infeasible develop- ments. Tar sand development within the Tar Sand Tri- angle is infeasible. BLM concludes this without explain- ing why. The explanation is found in the Tar Sand Tri- angle Combined Hydrocarbon Draft EIS and needs to be included in this EIS. Several factors make development infeasible. Any of the proposed development schemes would vio- late the air quality standards and ground water pro- tection standards of adjacent national park lands. Transportation difficulties, the only moderate grade of the deposits, limited water resources, and limited access to the resource combine to make this one of the most expensive-and thus least promising--of potential energy sources. It is probable that the ener- gy consumed in developing this resource and protect- ing the environment may exceed the energy the re- source produces. Development of even high-quality deposits without these limitations is not considered commercially feasible in the distant future for eco- nomic reasons. The points made here can be applied equally to tar sand deposits in the Circle Cliffs and the San Rafael Swell. In this case, BLM falsely stated on page 70 that there is a ". . . medium to high energy and/or mineral potential." This table is grossly mis- leading because many of the potentials listed are exag- gerated. BLM failed to consider the feasibility of de- velopment as a factor. This table simply assumes that, if a resource is present in some quantity, it is a certainty for commercial production. This approach, regardless of the agency's intention, has the obvious effect of overstating the significance of the conflict. Wilderness, whose significance the Draft EIS never overstates, is the loser. b. What constitutes a management conflict in des- ignated wilderness areas? In the reports for several areas, oil and gas leases and mining claims were alleged to represent management conflicts. BLM did not state any justification under law for reaching such a conclusion. BLM's EIS response (No. 367): "Conflicts have been identified and quantified insofar as possible in the individual analyses for the WSAs and in the Statewide alternatives in the EIS." BLM response does not answer either our specific question or our concern: What criteria does the agency use to determine when a management conflict exists suffi- cient to justify the deletion of land from wilderness designation? And where in BLM's policies, regula- tions, and directives does BLM find authority for mak- ing such a determination in the first place? The Draft EIS contains neither answer. We request that BLM pro- vide them in the Final EIS. 9.14 RESPONSE: In general, a conflict is defined as any resource or activity that would adversely affect wilderness values and/or wilderness management. A conflict may result from existing conditions, from actions planned in the foreseeable future, or from the long-range potential use of nonwilderness resources that may be present in an area. In order to describe the long-range potential, certain assumptions must be GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES made based on available information, professional knowledge, and judgment. As noted in the responses to General Comments 9.4 and 9.12, the likelihood for mineral development has been reviewed and revised with updated assump- tions. BLM does not believe that potential conflicts are overstated. Manageability conflicts are defined as those actions or activities that must be allowed by law, such as prior existing rights (e.g., certain leases and mining claims), and access to State or private in- holdings. Administrative problems include actions or activities which BLM would have difficulty preventing with reasonable efforts due to terrain features or adjacent land use. In Volume I, Chapter 2, of the Draft EIS the de- scription of the Manageability Alternative describes manageability conflicts. The Wilderness Study Policy (USDI, BLM, 1982a), Chapter II, paragraph (b), states that BLM does not view wilderness desig- nation as a form of temporary resource protection and will recommend as suitable for designation only those areas that can be managed as wilderness in the long term. The use of manageability as a criteria for suitability recommendations was incorporated into the Wilderness Study Policy through normal regula- tory procedures pursuant to FLPMA. The conditions contributing to management problems include sub- stantial private or State in-holdings, existing valid mining claims with likelihood of development, and pre- FLPMA leases or leases held by oil and gas unit pro- duction. This information is included in the Final EIS in the Volume I, Chapter 2 discussion of Alternatives Considered and Eliminated from Detailed Study. Also, see the responses to General Comments 1.13, 3.11, and 8.23. 9.15 COMMENT: The discussions of impact in the Environmental Consequences section of each document should include an identified conclusion for each analy- sis. [Utah Wilderness Coalition, Joelle Buffa, et al.] a. Discussions of impact in the Environmental Con- sequences sections should not leave the "bottom line" unstated. There should be an identified conclusion, pre- ferably by using subtitles under each significant anal- ysis topic, which provides specifically the final word on the degree and importance of the impact expected. The environmental consequences under each topic of an alternative should contain an analysis of the actions, developing the cause-and-effect relation- ships, and a conclusion on what the impacts are of various actions on the resource. b. The development actions in WSAs are never completely explained and vary from worst-case (which is no longer required by CEQ), to reasonable development, to no development. Therefore, a firm analysis of the expected impacts for the alternative cannot be completed. The information developed in the appendices is not realistically applied. Therefore, the impacts identified are often understated. In most cases bottom-line conclusions are not reached, leav- ing the analytical discussions hanging and uncertain. 9.15 RESPONSE: A bottom line for each impact analysis and separate conclusion statements has been added to increase the clarity of the analysis. Also, see the responses to General Comments 9.4 and 9.8, which discuss development assumptions and methodologies. 9.16 COMMENT: The Draft EIS lacks a growth pro- jection and a proper baseline against which to com- pare impacts. [Utah Wilderness Coalition, et al.] a. Impacts of wilderness designation should be de- termined in comparison with probable future condi- tions in the absence of designation. A modeling analy- sis should be performed that accurately projects eco- nomic and social conditions in several scenarios in- volving more and less wilderness. b. All of the alternatives assume the same rate of growth. In fact, the rate of growth itself is an issue that needs consideration. Growth is used to evaluate the net benefits from wilderness designation. BLM uses growth of nonwilderness activities to justify an unsuitability recommendation. Much of the pro-economic development bias seems to relate to BLM's use of the Utah Baseline Pro- visional Population Projections. Utah’s public officials continue to use the projections as though they were precise and reliable descriptions of the future rather than guidelines for what might happen if present trends continue. Indeed, in the past 5 years, the popu- lation trends in Utah have changed dramatically, with both the migration and birth rates decreasing signifi- cantly. To use such projections of population or eco- nomic potential as a basis from which to exclude 1 4 GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES areas from wilderness status or study is an abuse of responsible analysis. We request BLM use trends which have been corrected with current information. We also request that BLM indicate the confidence factor or margin of error in growth estimates used. BLM needs to apply growth rates consistently in estimating benefits. c. The Draft EIS makes predictive statements about future employment opportunities unsupported-- or inadequately supported--by analysis. It ignores, too, the impact that the predicted development will have on a community. Bluntly stated, the Draft EIS falls far short of doing a comprehensive impact analysis. d. Planning, analysis, and evaluation of environ- mental issues have been done haphazardly or one- sidedly in Utah. This wilderness "analysis" is one more example. We have no comprehensive growth management plans for the State or regions in Utah. Utah has never conducted a valid assessment of the residents' goals and desires, the local first step in the development of such a plan. Without a clear state- ment of growth management policy to be used as a critical reference tool when important environmental and socioeconomic decisions are made, crucial deci- sions, such as for wilderness, will continue to reflect only the goals and desires of those doing the study. e. BLM needs to clearly state the assumptions it makes on growth and growth management. It is impos- sible to balance decisions on public land use if conflict- ing assumptions (e.g., environmental protection and unlimited growth) are used. BLM needs to identify these assumptions, report them in the EIS, and show the varying levels of conflict with varying levels of growth. f. BLM needs to consider alternatives that reflect realistic rates of growth within the range defined by the accuracy of the forecasting tools. The methods of forecasting and their application need to be described in the Draft EIS. A range of rates is the best that can be forecast. In this case, BLM needs to have low growth rate, moderate growth rate, and high growth rate alternatives within the accuracy of growth fore- casts. g. We contend that the EIS is inadequate for, among other things, its: (1) lack of rationale for its Proposed Action; (2) lack of analysis to back up its predictions; (3) use of population projections, a pronouncement of unalterable conditions; (4) lack of adequate assessments of impacts; and (5) lack of a firm foundation, in the form of publicly assessed growth management policies, for responsible decision- making. 9.16 RESPONSE: BLM believes that the most appro- priate population and growth information is that pro- vided by the several agencies with this specialized expertise, particularly the U.S. Bureau of the Census and the Utah Office of Planning and Budget. Economic expertise resides with the U.S. Bureau of Economic Analysis, the Utah Department of Employment Secur- ity, and the Utah Department of Community and Eco- nomic Development. BLM has used the best available information from these and other sources. Current information has been used to the extent available. Confidence factors vary with the different data and data sources. Because of the relative uncertainty of future socioeconomic conditions, as affected by na- tional and international markets, it must be recogniz- ed that the socioeconomic predictions are estimates subject to considerable change due to unpredictable outside influences. This constitutes greater forecast- ing difficulty than more localized, on-the-ground re- sources. Given this situation, BLM believes that the EIS provides a comprehensive impact analysis, com- mensurate with the scope of the subject and the avail- able data. The issues and concerns raised during the scoping process are addressed. Given the degree of uncertainty concern-ing future population develop- ment, demand for recreation, etc., detailed modeling is not warranted. The fact that the State of Utah has no formal growth management plans is not within the purview or remedial responsibility of BLM. The Utah BLM Statewide Wilderness EIS is not considered the proper forum for a detailed analysis of Utah growth rate alternatives. The analysis of the No Action/No Wilderness Alternative provides the future baseline without wil- derness designation and makes comparisons against the existing affected environment. The analyses of the Proposed Action and other wilderness designation alternatives are compared against the No Action/No Wilderness Alternative in Table 2, Impact Summary (Chapter 2). On a very localized basis, wilderness designation may affect future growth and economic conditions GENERAL COMMENTS AND RESPONSES SECTION 9: ANALYSIS ASSUMPTIONS AND GUIDELINES but, on a Statewide basis, the effect would be imper- ceptible. Also, see the responses to General Comments 3.37, 8.8, 9.10, and 9.11, which list questions and comments on future conditions. 9.17 COMMENT: If minerals are not already locat- ed and active claims made, then it should be assumed that there is no interest in developing new or existing claims. [George Hinde, et al.] 9.17 RESPONSE: BLM does not agree with the com- ment. As technology or demand for certain energy and mineral resources changes, areas or minerals pre- viously thought to be unimportant can become ex- tremely important, even vital, in a very short period of time. Therefore, the assumption cannot be made in the Final EIS that, if an area currently does not have leases or claims, there will not be any interest in de- veloping new leases or claims in the area in the fu- ture. The Final EIS does note which energy and miner- al resources are most likely to be developed in the foreseeable future. It must also be noted that designa- tion of an area as a WSA does not preclude the loca- tion of new mining claims. Also, see the responses to General Comments 1.13 and 15.54. GENERAL COMMENTS AND RESPONSES - SECTION 10 AIR QUALITY INDEX 10.1 The Draft EIS failed to consider that the State risks losing its primacy over air quality protection due to wilderness designation, (p. 1) 10.2 The EIS needs to address the impacts of exchang- ing lands between Federal agencies and whether these lands will become subject to Class I air quality desig- nation. (p. 2) 10.3 The Draft EIS needs to address the cumulative impacts of wilderness designation and subsequent air quality designations from Class II to Class I on indus- tries, lands, and communities located near WSAs. Also, future industrial development operations will (or will not) be inhibited by air quality or atmospher- ic visibility standards for protection of wilderness areas, (p. 3) 10.4 The potential for exceeding PSD increments in nearby Class I areas should be evaluated as part of the EIS process. The present restrictions on develop- ments near PSD Class I areas are not analyzed in the Draft EIS. (p. 4) 10.5 Although the Draft EIS declares that air quality Class II ratings will not be redesignated to Class I rat- ings, there is no assurance this declaration will hold up when challenged by someone else. The State will likely redesignate air quality standards to accommo- date wilderness designation. Existing Class II designa- tions should be legally guaranteed permanent, (p. 4) 10.6 The EIS should also include an evaluation stating which existing emission facilities, if any, would be subject to modification under the best retrofit technol- ogies described under the visibility provisions of the Clean Air Act. (p. 5) COMMENTS AND RESPONSES 10.1 COMMENT: The Draft EIS failed to consider that the State risks losing its primacy over air qual- ity protection due to wilderness designation. [Utah Counties, Chevron Resources Company, et al.] a. Utah currently has assumed primacy over air quality protection within the state. Presumably, as a result of this primacy, only the state may elevate Class II air quality areas to Class I. Also, presumably the state will determine the means by which air qual- ity will be maintained. The State's plan for exercising this primacy is set forth in the State Implementation Plan. The Plan must be reviewed and accepted by the Federal government. If the Federal government finds the Plan unacceptable, the State risks losing its pri- macy. Clearly, the State's primacy over air quality is at the pleasure of the Federal government. Equally clear is the Federal government's intent to maintain pristine conditions in Federally designated Class I air quality areas (835,000 acres in southern Utah) and in designated wilderness areas. Retention of primacy over air quality matters by the State of Utah is con- ditioned upon the State's continued placation of the Federal grantor of that authority. The Federal govern- ment clearly has its own agenda for maintenance of certain environmental conditions in and around areas of particular concern to it. Partly in response to this Federal agenda, Utah is currently reviewing the possi- bility of designating integral vistas from the State's national parks. b. Sixty-seven of Utah's 82 BLM WSAs are with- in identified integral vistas (Draft EIS, Volume I, page 59). Twenty-seven of the 82 WSAs are contiguous to or in close proximity to designated Class I areas. The proximity of these WSAs to Class I areas "suggests that their air quality related values are similar to those found in Class I areas" (Draft EIS, Volume I, page 59). Management of a designated wilderness area will, of necessity, reflect area-specific fea- tures and values, including air and visual resource values. Therefore, if the majority of Utah WSAs are within proposed integral vistas, if their air quality is similar to contiguous or nearby Class I air quality areas, if their visual quality is considered one of their values, and if the imprint of man is to be largely removed, there can be no doubt that pressure, both legal and political, will soon come to bear upon the State to bring designated wilderness areas up to Class I air quality standards. In 1985, the Utah Air Conservation Committee denied itself by one vote the authority to designate areas requiring "further air quality protection," or in other words, State-desig- nated quasi Class I air quality areas. 1 GENERAL COMMENTS AND RESPONSES SECTION 10: AIR QUALITY c. Proliferation of Class I air quality areas across the southern and eastern portions of Utah will be one more significant obstacle to the future economic growth of the region. Because the State currently has primacy over air quality issues, the potential for ele-vation of Class II to Class I areas and the potential for designation of integral vistas, with their attendant socioeconomic impacts, were not addressed in the Draft EIS. The circumstances as described, however, penetrate this obfuscation and give clear warning to local and State decisionmakers as to the potential course of events, relative to air quality protection, following final designation of Utah BLM wilderness. Scant comfort is derived from the State’s assumption of primacy over air quality matters when the once-inviolate State's rights over water have been cast into a morass of litigation following the wilderness reserve water right decision. d. The BLM Draft EIS states that 27 of the 82 WSAs border existing Class I national park areas and that, under current PSD regulations, these areas could be recommended for Class I redesignation if adopted as wilderness. The EIS also states that sev- eral WSAs are currently impacted by air pollution coming from the Uinta Basin and surrounding area (i.e., Jack Canyon, Desolation Canyon, etc.). It may be too early to tell exactly what the outcome of this hearing and visibility protection regulations may bring; however, if results follow the aforementioned scenario, they could further impact rural communi- ties around the proposed wilderness areas. The multi- ple-use concepts adopted by the government land man- agers in the past have served the West well and pro- vided both recreation and economic growth. Why throw a good thing away and risk further economic hardships on local economies? e. The Utah Air Conservation Committee is still in an investigation and planning phase in respect to an EPA mandate to develop visibility regulations. Past experience has shown State-adopted regulations to be tougher than EPA directives; therefore, it is likely that existing PSD regulations, along with stringent visibility regulations, could result in the redesigna- tion of many of the proposed wilderness areas from Class II to Class I after wilderness adoption. 10.1 RESPONSE: BLM's Wilderness Management Policy (BLM Manual 8560) states that: "The BLM will manage designated wilderness areas as Class II unless they are reclassified by the State as a result of the procedures prescribed in the Clean Air Act (as amended, 1977)." 10.2 COMMENT: The EIS needs to address the im- pacts of exchanging lands between Federal agencies and whether these lands will become subject to Class I air quality designation. [Carrel Magelby, et al.] a. Because of the number of BLM wilderness areas contiguous to wilderness or proposed wilder- ness of other Federal agencies, it is reasonable to expect that agency exchanges will occur between the Federal agencies. If exchanges occur, it must be assumed that the exchanged lands will be subject to management policies of the recipient agency. Of the 82 BLM WSAs, 30 are adjacent to units of the NPS. If any or all of these areas are transferred, it is not known whether they will become subject to the Class I air quality designation. The cumulative impacts of wilderness designation, including possible expanded Class I air quality areas in southern Utah, is a matter of deep concern that has not been adequately address- ed by BLM’s Draft EIS. 10.2 RESPONSE: BLM has no plans for exchanging land management responsibilities for WSAs with other Federal agencies. If exchanges were to occur, existing Class II areas would remain as such unless a formal reclassification process occurs. In addition, exchanges could occur through the normal land man- agement process and are not dependent on wilderness designation (see the response to General Comment 23.15). Class I areas were established at the time the Clean Air Act Amendments of 1976 were passed. These areas include defined boundaries of national parks 6,000 acres and greater and wilderness areas of 5,000 acres and greater at the time of the amend- ments. All other areas were classified as Class II and are required to go through the reclassification pro- cess for an upgrade to Class I. This process remains the State's prerogative and requires study and analy- sis of the health, environmental, economic, social, and energy effects of the proposed redesignation. The study must be made available to the public for review and comment, and public hearings must be held before final decisions on any redesignation are made by the State. No wilderness areas designated since the Clean Air Act Amendments of 1976 have been reclassified from Class II to Class I. 2 GENERAL COMMENTS AND RESPONSES SECTION 10: AIR QUALITY 10.3 COMMENT: The Draft EIS needs to address the cumulative impacts of wilderness designation and sub- sequent air quality designations from Class II to Class I on industries, lands, and communities located near WSAs. Also, future industrial development operations will (or will not) be inhibited by air quality or atmo- spheric visibility standards for protection of wilder- ness areas. [Emery County, Utah Power and Light, et al.] a. WSA No. 63 (Sids Mountain) is only 10 miles from the Hunter plant, Utah Power and Light's largest generating facility. Three WSAs are within 25 miles of the Hunter plant. Air quality and designation of inte- gral vistas are issues of substantial concern. Gener- ally, wilderness areas have a Class II PSD classifica- tion. Utah Power and Light's generating facilities are permitted by the £PA and fully comply with existing air quality classifications. The Draft EIS states that BLM will not seek to upgrade PSD classification to Class I in the final wilderness areas, and we would vigorously oppose such a request from any person or agency at any point in the wilderness study, designa- tion process, or thereafter because of the millions of dollars of increased environmental compliance cost that would have to be borne by rate payers to comply with Class I PSD air standards. While integral vistas generally have been designated as extensions of national parks, there is no assurance that, at some future date, these will not be asserted for wilderness areas, just as Federal reserved water rights have been in Colorado. Utah Power and Light’s existing steam electric generating plants are located in close proximity to several WSAs, as are its future plant sites and mining leases. b. Protection of integral vistas affects land man- agement policies as well. Land use options beyond Fed- eral areas receiving Class I protection are constrain- ed by the visibility provisions of PSD. Federal land managers are required to select and protect scenic vistas identified within Class I areas which may ex- tend 50 or more miles outside the Class I boundary. Clearly, siting for industrial uses, development stand- ards, and restoration requirements on both public and private lands adjacent to wilderness areas will be applied more stringently, resulting in development restrictions and negative economic consequences to the energy industry at a time when domestic oil and gas production is struggling to compete with foreign suppliers. c. The Draft EIS addresses the suitability for wil- derness designation of 82 WSAs totaling approximate- ly 3.2 million acres in Utah. However, from an indus- try perspective, the magnitude of cumulative impacts restricting the development of public and private lands is much greater. We submit that land manage- ment and air quality considerations affecting lands adjacent to wilderness areas result in an impact area significantly larger than the 3.2 million acres current- ly under wilderness review. d. The BLM Draft EIS is remiss in that it does not adequately address the impact that wilderness desig- nation will have on adjacent lands, communities, and economies if the current Class II air standard is ele- vated to a Class I standard. The Draft EIS assumes all WSAs will be designated Class II air quality areas. We have no assurance, either historically or within the wilderness statute, that this will be the case. In fact, Volume I, Chapter 3 of the Draft EIS indicates: "If, after wilderness designation, BLM determined that air quality related values were important attributes of some wilderness areas, it could recommend that the State of Utah consider redesignating such areas as Class I . . ." BLM has already ". . . considered rec- ommending the Sids Mountain area of the San Rafael Swell for redesignation as a Class I area because of its wilderness values" (Interstate Commerce Commis- sion, 1982). Congress can mandate Class I air quality standards in the enabling legislation that creates a wil- derness area; it may also establish Class I air quality by an amendment to the Clean Air Act, as it did in 1977 when all existing wilderness areas received mandatory Class I standards. e. Our economy is based primarily on an industry that is a contributor to the pollution problem. Our assessed valuation of $280 million comes primarily from this industry. Anything that might jeopardize this tax base would be opposed. Volume I, Chapter 3 of the Draft EIS indicates that "If, after wilderness designation, BLM determined that air quality related values were important attributes of some wilderness areas, it could recommend that the State of Utah con- sider redesignating such areas as Class I . . ." BLM has already ". . . considered recommending the Sids Mountain area of the San Rafael Swell ... for redesig- nation as a Class I area because of its wilderness val- ues" (Interstate Commerce Commission, 1982). f. BLM has stated that no Class I air quality redes- ignations will be recommended to Congress; however, they have and will continue to recommend Class I 3 GENERAL COMMENTS AND RESPONSES SECTION 10: AIR QUALITY redesignations to the State of Utah. Although a redes- ignation under air quality regulations to Class I pro- tection may be considered a separate action, BLM has recommended Class I redesignations in certain areas and additional Class I redesignations are foreseeable, pending completion of required impact analysis. In addition, Class I redesignations are directly related to wilderness land status, and it is consistent with the protection afforded other wilderness areas in 1977 following amendments to the Clean Air Act. For these reasons, resource impacts should be addressed in the EIS on the entire impact area rather than just within the boundaries of the WSA. Impacts of the Clean Air Act on the West, published by Enviro-Map, Inc. (September, 1980) provides graphic illustration of the magnitude of impact to adjacent lands that existing national park and wilderness areas can have concerning air quality protection and restrictions to development. 10.3 RESPONSE: See General Comment Responses 10.1 and 10.2 which discuss the State’s primacy in designation of PSD classes. All wilderness areas des- ignated after the Clean Air Act Amendments of 1976 have remained classified as Class II air quality. This is true for both wilderness areas of BLM, as well as those of the FS. No reclassification proposals have been initiated to reclassify Class II wilderness areas to Class I air quality standards. The integral vista provision applies only to "man- datory Class I areas." Mandatory Class I areas are those Class I areas established with the passage of the Clean Air Act Amendments of 1976. The visibility regulations subsequently promulgated by EPA made the provision for identification and consideration of protection of integral vistas from those mandatory Class I areas. The State of Utah has chosen not to establish integral vistas. It would be the prerogative of the State or Con- gress, not Federal land management agencies, to change the provisions. 10.4 COMMENT: The potential for exceeding PSD increments in nearby Class I areas should be evalu- ated as part of the EIS process. The present restric- tions on developments near PSD Class I areas are not analyzed in the Draft EIS. [Environmental Protection Agency, et al.] a. Under Sections 160-169 of the Clean Air Act of 1977, BLM lands in Utah are rural attainment areas as well as PSD Class II air quality areas. The requirements for Class II areas limit the allowable increases in total suspended particulates and sulfur oxides, while providing for moderate, well-controlled growth. The Draft EIS recommends certain areas as unsuitable for wilderness based on potentially extrac- table mineral resources. However, it does not take into full consideration that there may be constraints to development of those resources other than wilder- ness designation. An area may already by precluded in full or in part from resource development because it may exceed PSD limits. This is currently the case for some proposed developments near national parks. The potential for exceeding PSD increments in nearby Class I areas should be evaluated as part of the EIS process. b. The present restrictions on developments near PSD Class I areas are not analyzed in the EIS. This in- correctly leads the readers to the conclusion that wil- derness designation would inhibit development in these areas or that developments could proceed in these areas if they are not designated as wilderness. 10.4 RESPONSE: See the response to General Com- ment 10.3. Where applicable, the potential for restric- tions on major industrial developments in WSAs adja- cent to PSD Class I areas are noted in the Final EIS in the individual WSA analyses. Also, see the responses to General Comments 9.7 and 9.14. 10.5 COMMENT: Although the Draft EIS declares that air quality Class II ratings will not be redesig- nated to Class I ratings, there is no assurance this declaration will hold up when challenged by someone else. The State will likely redesignate air quality standards to accommodate wilderness designation. Existing Class II designations should be legally guaran- teed permanent. [Utah Power and Light and Mark Tanner] a. In order to ensure that, in the future, an inde- pendent group cannot advocate an upgrade of air stand- ards or creation of integral vistas, the wilderness- authorizing legislation must provide for permanent Class II PSD classification, prohibition of integral vis- ta designation from any created wilderness area, and specific permission for new heavy industrial develop- ment outside each created area. 4 GENERAL COMMENTS AND RESPONSES SECTION 10: AIR QUALITY b. There is much talk of the air quality standards. The Draft EIS declares that the Class II rating cur- rently governing the areas would remain. However, that assurance may not hold up when challenged by someone else. 10.5 RESPONSE: See the responses to General Com- ments 10.1 and 10.3. 10.6 COMMENT: The EIS should include an evalua- tion stating which existing emission facilities, if any, would be subject to modification under the best avail- able retrofit technologies described under the visibil- ity provisions of the Clean Air Act. [Unidentified] 10.6 RESPONSE: See the responses to General Com- ments 10.1 and 10.3. 5 GENERAL COMMENTS AND RESPONSES - SECTION 11 GEOLOGY AND TOPOGRAPHY COMMENTS AND RESPONSES 11.1 COMMENT: The sections labeled Geology are mainly discussions of topography and physiographic provinces. This section should be renamed in the Final EIS. [Composite Comment] 11.1 RESPONSE: In the Final EIS, this section has been retitled Geology and Topography. 11.2 COMMENT: More detail on geologic structure and stratigraphy is needed to provide a basis for con- clusions on oil and gas and mineral potentials. [State of Utah, Mining Industry, et al.] 11.2 RESPONSE: Additional pertinent information on geologic structure and stratigraphy has been in- cluded in the Final EIS for WSAs with high potential for oil and gas or other mineral extraction. 1 > GENERAL COMMENTS AND RESPONSES - SECTION 12 SOILS INDEX 12.1 Potential soil loss due to erosion has been under- estimated. (p. 1) 12.2 The Draft EIS fails to analyze potential loss of cryptogamic soils, (p. 1) 12.3 An in-depth soil analysis is needed for WSAs that BLM does not recommend for wilderness, (p.1) 12.4 The reclamation potential for soils in WSAs is not addressed, even though they are the key to under- standing long-range impacts of surface-disturbing activities, (p. 2) 12.5 Wilderness management and watershed preserva- tion may not be compatible, (p. 2) COMMENTS AND RESPONSES 12.1 COMMENT: Potential soil loss due to erosion has been underestimated. [Composite Comment] With the strong winds and sudden violent summer storms that occur in all of the proposed wilderness areas, erosion could be a very important issue. All of the wilderness areas in San Juan County drain into Lake Powell. The amount of soil loss could be more tremendous than it already is. It has been shown that the soil loss after chaining and reseeding is signifi- cantly less than from so-called natural undisturbed cover. The proposed wilderness areas could not only become the source of tremendous erosion, but con- sider the impact this erosion would have on low land users downstream or upwind. 12.1 RESPONSE: According to Payne (1980), there is disagreement among researchers concerning the relationship of pinyon-juniper chaining to runoff and sediment yield. Many factors apparently influence sediment discharge on a given site. So variable are these factors, that no consistent relationship has been found (Williams et al., 1972). It is BLM’s conclusion that wilderness designation would reduce the potential for surface-disturbing activities and, overall, would lead to reductions in sediment yield. 12.2 COMMENT: The Draft EIS fails to analyze po- tential loss of cryptogamic soils. [Utah Audubon Society; Sierra Club, Cache Group, et al.] a. Cryptogams are a combination of lichens, mosses, algae, and fungi. They stabilize soil in open areas between shrubs, protect soil from erosion by slowing and absorbing runoff, fix nitrogen, and create a microenvironment suitable for vascular plants. Cryptogamic soil covers about 50 percent of range- land soils in Utah's desert areas. b. It is becoming very well known that crypto- gamic soils are a very important part of the communi- ties of these WSAs. They participate in the cycling and the water status of the soil. An analysis is needed concerning the effects to these soils from increased use by wilderness users or grazers on the ecosys- tem. Livestock grazing and ORV use destroys crypto- gamic soils in Utah's desert areas. 12.2 RESPONSE: BLM recognizes that cryptogamic soil crusts are important in desert ecology. This is now cited in the Affected Environment sections of Vol- ume I in the Final EIS. However, grazing and recrea- tional use (either mechanized or primitive) will con- tinue with or without wilderness designation. It is acknowledged that potential for surface disturbance and, hence, destruction of cryptogamic soil would be reduced with wilderness designation. Another factor that must be considered is the potential effect of wild- fire, which, according to the Wilderness Management Policy (BLM Manual 8560), would be allowed to burn in wilderness areas. According to Harper (1986): "All studies dealing with cryptogams and fire show that even light burns destroy all components of the cryptogamic layers." Given these variables, BLM be- lieves that wilderness designation and management will not appreciably alter the present or future condi- tion of cryptogamic soils in Utah. 12.3 COMMENT: An in-depth soil analysis is needed for WSAs that BLM does not recommend for wilder- ness. [Sierra Club, Cache Group] 1 GENERAL COMMENTS AND RESPONSES SECTION 12: SOILS We request that an in-depth soil analysis be com- pleted in any WSA that BLM does not recommend for wilderness. This should include potential soil losses from nonwilderness-type uses. In particular, this loss analyses must include probable ORV use. 12.3 RESPONSE: The potential for increased ero- sion is analyzed in the individual WSA analyses where large activities or increase in ORV use are likely in the foreseeable future. There is no need to analyze impacts on soils where activities and disturbance are not likely with or without wilderness designation. 12.4 COMMENT: The reclamation potential for soils in WSAs is not addressed, even though these are the key to understanding long-range impacts of surface- disturbing activities. [Lucy Wallingford, et al.] Certain developments destroy the naturalness of the environment, and the disturbed areas can never be reclaimed. The desert is fragile and disturbed areas cannot be reclaimed. 12.4 RESPONSE: Generalized discussions of recla- mation potential for the range of soils found in WSAs have been added to the Final EIS. 12.5 COMMENT: Wilderness management and water- shed preservation may not be compatible. [Utah Cattlemen's Association] In the name of wilderness land management, those individuals who claim preservation of the natural beauty are missing the boat. Proper and modern in- sect control could stop a range from being destroyed in short order with the restricted wilderness land management. Dead ranges do not support good water- shed. I have never heard of anybody ever asking, "Is wilderness land management supportive of watershed preservation?" I question whether they are compat- ible under certain circumstances. 12.5 RESPONSE: See the responses to General Com- ments 1.12 and 12.1. Watershed restoration may be done where there is a threat to wilderness values or a definite hazard to life, property, or environmental quality outside of the wilderness areas. Therefore, major conflicts are not anticipated. 2 GENERAL COMMENTS AND RESPONSES - SECTION 13 VEGETATION INDEX 13.1 The analysis of threatened or endangered plant species is incomplete, (p. 1) 13.2 Rare, sensitive, and endemic plant species are often ignored in the EIS. (p. 2) 13.3 BLM should consider those species that may be common in other areas but are rare in Utah. (p. 3) 13.4 The EIS should recognize the importance of habi- tat protection for threatened, endangered, sensitive, and rare plant species, (p. 3) 13.5 Wilderness designation would protect threatened or endangered plant species, while nondesignation would not protect threatened or endangered plant species, (p. 3) 13.6 The EIS should state that the San Rafael pincush- ion cactus (Pediocactus despainii) is facing an increas- ing threat from ORV use. (p. 4) 13.7 The Bailev-Kuchler Ecosystems of the United States is too broad to be used for site-specific com- parisons. (p. 4) 13.8 The vegetation database is not sufficient for the decisionmaking process, (p. 5) 13.9 The plant species Penstemon nanus and Penste- mon dolius have been confused in the EIS. (p. 5) 13.10 The EIS does not correctly list the number of threatened or endangered plant species, and this num- ber does not correspond with the FWS listing, (p. 5) 13.11 The significance of riparian habitat in the WSAs has not been properly recognized, (p. 5) 13.12 The importance of vegetation in terms of diver- sity should be considered, (p. 5) 13.13 The EIS should recognize that the pinyon-juni- per woodland in the Great Basin (Pinus monQPhvJIa) is different than that found on the Colorado Plateau (Pinus edulis). (p. 6) 13.14 The importance of vegetation types in WSAs is higher than actual acreage figures would indicate. For example, the Great Basin WSAs contain conifer island ecosystems important for scientific study, (p. 6) 13.15 Vegetation communities in southern and west- ern Utah have not been completely studied, (p. 6) COMMENTS AND RESPONSES 13.1 COMMENT: The analysis of threatened or en- dangered plant species is incomplete. [Utah Wilder- ness Association: Sierra Club, Cache Group, et al.] a. Vegetation should be an issue in the EIS. Al- though BLM did recognize rare and sensitive plant spe- cies in the Draft EIS, the analysis was incomplete. The failure to identify vegetation as a major State- wide issue, particularly when three major issues deal with livestock grazing, shows a bias against natural values and an inconsistency in the selection of issues. b. BLM fails to recognize the potential for occur- rence of threatened or endangered plant species in some of the WSAs and additional studies are neces- sary. c. A large number of threatened and endangered plant species have been identified within WSAs. The EIS should identify lands that have been surveyed and inventories should be made of the remaining areas. 13.1 RESPONSE: BLM has considered potential im- pacts on threatened or endangered plant species. See the Draft EIS, Volume I, Chapter 5, Coordination and Consultation, Resources Not Addressed in Detail on a Statewide Basis, and the threatened and endan-gered plant species discussions for the individual WSAs (Vol- umes II through VI). In summary, it was concluded that wilderness designation would generally reduce the potential for inadvertent or illegal destruction of threatened or endangered plant species. It was also concluded that even implementation of the No Action/ No Wilderness Alternative would not directly result in a deterioration of the existing situation because threatened and endangered plant species receive sub- stantial protection by the Endangered Species Act and 1 GENERAL COMMENTS AND RESPONSES SECTION 13: VEGETATION BLM policy. Section 7 consultation under the Act is only one of several management tools available for protecting threatened or endan-gered plant species. Other specific protection actions that can be taken by BLM include preparation and implementation of Habi- tat Management Plans (HMPs), participation in prepa- ration of Recovery Plans, monitoring and inventory actions, fencing, closure of lands to ORV use, etc. Threatened or endangered plant species are not considered an issue in this EIS due to the reasons specified above, and also as discussed in Volume I, Chapter 1, Issue Identification. BLM has attempted to identify the potential loca- tions and habitats for special status species, including threatened and endangered plant species, plant spe- cies proposed for listing, Category 1 and 2 candidate species, and other species considered sensitive which are located in the WSAs. The information presented in the Final EIS is based on literature searches, studies, discussions with other experts such as personnel from FWS (see Appendix 4), local universities, and conservation organizations. It is recognized that this information is not complete. Additional studies are always helpful. Future studies are planned to inven- tory and study threatened and endangered plant spe- cies on a Statewide basis as time and funding permit. Recognizing this, BLM believes that sufficient infor- mation is available for the stated purposes of this EIS. This subject is discussed further in the response to General Comment 9.6. Also, see the response to General Comment 9.2 for information concerning scoping of issues. Lastly, the Wilderness Study Policy (USDI, BLM, 1982a) states that the evaluation of special features should be based on an assessment of the estimated (our emphasis) abundance or importance of the speci- fic value being analyzed. 13.2 COMMENT: Rare, sensitive, and endemic plant species are often ignored in the EIS. [Utah Wilderness Association and Marvin Poulson] a. Examples include Draba kassii (a rare plant spe- cies in the Deep Creek Mountains), Hackelia ibapansis. Pediocactus winRleri, and Erigeron kachinensis. b. While botanical information is not complete for much of the land involved in the wilderness study pro- cess, there is a high potential that some plants occur in certain WSAs. BLM notes this for some WSAs, but fails to recognize the same potential for others. Simi- larly, some species of plants are recognized, while other species seem to be excluded, either arbitrarily or out of ignorance. We believe that greater attention to the existence and distribution of rare plants should be made in the Final EIS. Only with diligent study of known species occurrence can BLM hope to achieve the recognition and understanding this resource de- serves as a significant supplemental wilderness value. c. Although the Draft EIS generally includes listed and proposed species as part of the description of veg- etation, many WSA discussions lack full representa- tion of the species and typically ignore rare and en- demic species altogether. 13.2 RESPONSE: The Draft EIS was carefully re- viewed and additional information on threatened, en- dangered, rare, sensitive, and endemic plant species has been included in the Final EIS, where appropriate. The status of the individual species has been clarified (see Volume 1, Appendix 4). The rare plant in the Deep Creek Mountains is Draba kassii, a narrow endemic located in the pinyon- juniper woodland, white fir, and mountain brush com- munities. It is found mainly in granite crevices and is restricted in distribution. Draba kassii is a Category 2 candidate species. It is discussed in Volume II, Deep Creek WSA (Welsh et al., 1987). Hackelia ibapansis is found on exposed granite outcrops in mountain brush and Douglas fir communi- ties in the Deep Creek Mountains. It is endemic to this area (Welsh, et al., 1987). Hackelia ibapansis is a Category 2 candidate species. Pediocactus winkleri is a Category 1 candidate species which is endemic to the Wayne County area. It is believed possibly to occur in the Mt. Pennell, Mt. Ellen-Blue Hills, Bull Mountain, and Mt. Hillers WSAs. This is a remarkable tiny plant species found in salt desert shrub communities on poor quality saline fine- textured substrates. This species may be proposed by FWS as endangered. Erigeron kachinensis (Category 2 species) is known to occur in three locations in southeastern Utah (San Juan County) and Colorado. The habitat for this narrow endemic is moist sandstone outcrops in hanging garden communities in the Grand Gulch, Fish 2 GENERAL COMMENTS AND RESPONSES SECTION 13: VEGETATION Creek Canyon, and Cheesebox Canyon WSAs, and in the Dark Canyon ISA. BLM has funded detailed studies of these species dur- ing the past few years and plans to continue these stu- dies into future years. The information obtained is available for public review at the Utah State office or the District office in the district which these species occur. 13.3 COMMENT: BLM should consider those species that may be common in other areas, but are rare in Utah. [Marvin Poulson and Utah Wilderness Associa- tion] While general recognition is given to species that occupy a narrow niche in the environment and are rare throughout their range, range extensions of some species represent potential evolutionary links with the past and may indicate how a species is de- veloping. In this regard, several species that are com- mon in areas outside of Utah are rare in the state. Such populations may offer opportunities for under- standing speciation within a complex. We believe that BLM should be considering vegetative resources on a more in-depth basis, and that such information pro- perly belongs in the Statewide Wilderness EIS. 13.3 RESPONSE: A specific response is difficult without knowing exactly what species are referred to in the comment. BLM recognizes that such species exist and that they are of scientific importance. The Final EIS does contain a listing of special status spe- cies including rare, sensitive, and endemic plant spe- cies that are included in Category 1 or 2 listings in the Federal Register (USDI, FWS, 1990). It is also noted in the Final EIS that these species have potential scientific value. 13.4 COMMENT: The EIS should recognize the im- portance of habitat protection for threatened, endan- gered, sensitive, and rare plant species. [Marvin Poulson, et al.] Conservation of our native flora depends on the preservation of plant habitats where rare, sensitive, threatened, and endangered species grow. Recognition of the importance of habitat protection is paramount if many of these plant species are to survive. A com- prehensive understanding of how a specific habitat meets the special needs of a species is essential in plant conservation. For rare plants, active prevention of habitat loss and protection of existing populations may provide the only means of conserving the dwindling genetic diversity necessary for their survival. Controlling and managing human development of the land is vital to assure preservation of our natural heritage repre- sented in natural vegetative resources. This includes rare plants and their habitats. It is not merely the conservation of plants spe- cies that is essential. Full recognition and active pre- servation of plant habitats underlies the successful achievement of plant conservation. 13.4 RESPONSE: See the response to General Com- ment 13.1. It has been noted in the Final EIS that wil- derness designation would generally protect the habi- tat of selected plant species. It has also been noted that many species receive protection through other avenues such as the Threatened and Endangered Spe- cies Act and BLM's land use planning process, which provides for ACECs, HMPs, Recovery Plans, ORV closures, etc. 13.5 COMMENT: Wilderness designation would pro- tect threatened or endangered plant species, while nondesignation would not protect threatened or endan- gered species. [Scott Mills, Marvin Poulson, et al.] a. Additional analysis of the No Action Alterna- tive is necessary. The statement that Section 7 con- sultation will occur is not enough. b. Along with habitat and plant conservation, we must identify and mitigate the threats facing the spe- cies involved. BLM has a stated policy of protection for sensi- tive, threatened, and endangered plants that has gain- ed recognition in the Federal Register. Unfortunately, however, the agency in Utah has a lackluster record of effective management of even listed endangered plants. The Dwarf Bear Poppy (Arctomecon humilis) is a case in point. While this species does not occur in or even near any WSAs, the agency has failed to effectively prevent deterioration of populations. This situation prevails despite the fact that the plant was listed nearly 7 years ago. 13.5 RESPONSE: See the responses to General Com- ments 13.1 and 13.4. It is generally agreed that imple- mentation of the wilderness designation alternatives analyzed in the EIS would result in additional 3 GENERAL COMMENTS AND RESPONSES SECTION 13: VEGETATION protection for threatened or endangered plant spe- cies. It is important to note as well that even imple- mentation of the No Action/No Wilderness Alternative would not directly result in a deterioration of the ex- isting situation since threatened or endangered plant species are protected under the Endangered Species Act. Nevertheless, inadvertent or other unlawful dis- turbances could still occur which could threaten some of these species. The fact that these threats would be minimized if the species were located in a wilderness area has been noted in the EIS. Regarding the Dwarf Bear-claw poppy (Arcto- mecon humilisL BLM has invested substantial funds and time in an attempt to understand and protect this species. Specific actions taken include closing known habitat areas to ORV use, signing and patrolling these areas, implementing a public awareness program, pro- viding funds to Brigham Young University to aid in a detailed study of the species, and preparation and im- plementation of an HMP and other land use planning. It is therefore inaccurate to suggest that BLM is not do- ing anything to protect this species. 13.6 COMMENT: The EIS should state that the San Rafael pincushion cactus (Pediocactus despainii) and other species are facing an increasing threat from ORV use. [Marvin Poulson, Scott Mills, et al.] a. Known to occur in at least two WSAs, Crack Canyon and Sids Mountain, the San Rafael pincushion cactus may also be found in the Mexican Mountain WSA. This diminutive cactus faces increasing num- bers and frequency of ORV use in its habitat. BLM even sponsors an annual ORV event that sees hun- dreds of ORVs run with loose supervision near the Crack Canyon WSA and adjacent to critical habitat for this beautiful little cactus. Since the agency has spon- sored the motorcycle event each spring, increasing numbers of ORV tracks have been observed criss- crossing the terrain where these rare endemics are found. The disregard for the species and the habitat vital to its survival is of great concern. This case represents only one circumstance, but we fear that it depicts the approach and policy that BLM intends to use in addressing their land management trust. b. Although BLM recognizes the mandate of the En- dangered Species Act in many of the WSAs, the way in which BLM describes impacts on threatened and en- dangered species is inadequate. In a great many of the WSAs, a statement in the No Action/No Wilderness Alternative says that, before development occurs, BLM will initiate Section 7 consultation with the FWS, and necessary measures will be taken to protect sen- sitive, candidate, and threatened and endangered spe- cies. Based on this premise, BLM then concludes that those species will not be adversely impacted. The major flaw here is that one does not know how exten- sive the Section 7 mitigation measures may have to be. The Draft EIS should specifically list possible im- pacts on these species because, by the time all of the Section 7 requirements are fulfilled for several dif- ferent species, any development which is planned for the WSA may have to be eliminated or severely limit- ed. 13.6 RESPONSE: See the response to General Com- ment 13.1. Pediocactus despainii, which is now a list- ed endangered species, is found in the San Rafael Swell area. It is possibly located in up to six WSAs; however, additional studies are necessary to confirm whether or not this is actually the case. ORV activi- ties occur in the general area; however, use is limit- ed a great deal by terrain and is not threatening the existence of the cactus. This finding is supported by Dr. Stanley L. Welsh of Brigham Young University. The cactus is currently the subject of studies and observations by BLM and others. If it is documented that damage is occurring to the species or its habitat, action will be taken to provide the appropriate protec- tion. Specific actions could include ORV closure, fenc- ing, establishment of ACECs, no surface occupancy for mineral operations, etc. BLM does not sponsor ORV events. Any organized ORV events on public lands in Utah are proposed and sponsored by outside interests. BLM prepares the nec- essary environmental documentation for the event, with appropriate mitigation and stipulations to pre- vent loss of habitat or destruction of any of the threatened, endangered, or sensitive plants. 13.7 COMMENT: The Bailev-Kuchler Ecosystems of the United States is too broad to be used for site-spe- cific comparisons. [State of Utah, Marvin Poulson, et al.] BLM treats vegetation values with little detail and with negligible recognition for their intrinsic worth. We believe that greater understanding and detailed analyses of vegetative resources should be presented in the EIS to better reflect the on-the- ground situation. Simply lumping vegetation zones in- to a sketchy and overly general rating system inade- quately represents the subject. 4 GENERAL COMMENTS AND RESPONSES SECTION 13: VEGETATION For example, the pinyon-juniper type found on the Kaiparowits Plateau (Carcass Canyon WSA, Fifty Mile Mountain WSA, Death Ridge WSA, Wahweap WSA, and Burning Hills WSA) is only superficially similar to that found in the Moquith Mountain or Notch Peak WSAs. All of these WSAs have pinyon-pine and Utah juniper growing in general association, but they dif- fer in habitat types and associated plants. In fact, two different species of pinyon pine are involved (Pinus edulis and Pinus monophylla). The ecological diversity this represents should be addressed in the EIS and presented in terms that recognize the intrin- sic values of each area. Just as animals deserve con- certed conservation attention, plants do also. It is upon plants that all animal life, human included, de- pend. 13.7 RESPONSE: The Bailev-Kuchler Ecosystems of the United States (USDI, Geological Survey, 1978) was selected by BLM for use in comparing diversity of natural systems and features as represented by ecosystems and landforms. Use of this system is man- dated by notice in the Federal Register, Volume 47, No. 23, Wednesday, February 3, 1982, pages 51 06- SI 07. This system is, of necessity, general in nature as it identifies general landforms and ecosystems. 13.8 COMMENT: The vegetation database is not suf- ficient for the decision making process. BLM must de- velop a better database. [State of Utah] 13.8 RESPONSE: BLM believes that the vegetation database is sufficient to make the required decisions regarding wilderness or nonwilderness for the rea- sons given in General Comment Responses 9.6 and 13.1. BLM has been developing a Statewide vegetation base for several years. The most recent efforts are vegetation/soil type studies. Unique vegetation areas receive attention during land use planning efforts and are often recommended for special management. When appropriate, this information has been incorporated in the analyses of individual WSAs. 13.9 COMMENT: The plant species Penstemon nanus and Penstemon dolius have been confused in the EIS. The EIS discussion needs to be corrected. [State of Utah] 13.9 RESPONSE: According to Dr. Stanley L. Welsh of Brigham Young University, both Penstemon nanus and Penstemon dolius are relatively common and wide- ranging inhabitants, with slightly overlapping habitats in the West Desert area of Utah. The two species are very similar and are mainly distinguished only by a slight difference in the structure in the flowers. Nei- ther Penstemon nanus or Penstemon dolius are listed as threatened or endangered, proposed for listing, or Category 1 or 2 species (Federal Register. Volume 50, No. 188, Friday, September 27, 1985). They are not listed as a sensitive species by the State of Utah. It has been determined that neither species would be significantly affected by implementation of any of the alternatives considered in the Final EIS. 13.10 COMMENT: The EIS does not correctly list the number of threatened or endangered plant species. [Utah Wilderness Association] a. The number of threatened and endangered plant species noted in the EIS should correspond with the FWS listing. b. Why were numerous species listed by the FWS omitted from the analysis in the Draft EIS? Examples include a rare plant in the Deep Creek Mountains, Hac- kelia ibapensis and Pediocactus winkleri and Erigeron kachinensis. In all, Volume I of the Draft EIS (page 64) listed only 17 threatened and endangered or proposed threatened and endangered plant species. Yet, later, the FWS lists 44 plant species in this category. Why is there such a discrepancy? 13.10 RESPONSE: See the response to General Comment 13.2. This has been reviewed and the cor- rect information has been incorporated into the Final EIS per the Federal Register Notice (USDI, FWS, 1990). 13.11 COMMENT: The significance of riparian habi tat in the WSAs has not been properly recognized. [The Wildlife Society and John Veranth] a. Additional discussion is needed on the manage- ment of riparian areas. b. Page 79 (Volume I of the Draft EIS) states that the acreage of riparian habitat in the WSAs is small. This ignores the fact that there is little riparian habi- tat in Utah, and that the portion in the WSAs is a signi ficant portion of the total. 13.11 RESPONSE: BLM recognizes that riparian habitat is important. The Final EIS notes this fact in both Volume I and, where appropriate, in the indivi- dual WSA analyses (Volumes II through VI). It is fur- ther noted that wilderness designation would likely 5 GENERAL COMMENTS AND RESPONSES SECTION 13: VEGETATION result in additional protection to riparian areas, even though structures could be built protecting these areas from grazing and allowed use in wilderness areas. In areas not designated wilderness, the exist- ing situation would remain the same. BLM attempts to carefully manage riparian areas. 13.12 COMMENT: The importance of vegetation in terms of diversity should be considered. [Utah Wilder- ness Association, et al.] a. Utah’s many unique wild places contain delicate ecological relationships that would be lost and des- troyed by the development of other natural resour- ces. Wilderness areas cannot be replaced once they are lost or destroyed. BLM's wilderness proposal deletes many unique and valuable natural areas that would benefit wildlife, native plants, and biologic diversity. b. Vegetation is an important resource in terms of diversity. As noted, the various types found within one of BLM's broad categories are very diverse and important. They tell a story of evolutionary history and species dispersal. Although BLM has recognized the importance of threatened, endangered, and sensi- tive plant species that occupy narrow niches, the im- portance of other species (which may be rare in Utah WSAs and common elsewhere) or species living on the edge (as many plant communities do in the desert envi- ronment) has not been recognized. 13.12 RESPONSE: Vegetation diversity is an im- portant criterion used in considering wilderness val- ue. This is discussed in the Special Features portion of the Wilderness Values sections of the Final EIS. 13.13 COMMENT: The EIS should recognize that the pinyon-juniper woodland in the Great Basin fPinus monophvllal is different than that found on the Colo- rado Plateau (Pinus edulisL [Utah Wilderness Asso- ciation and Marvin Poulson] This broad classification downplays the impor- tance of each vegetation type and does not recognize the difference and ecological values of areas lumped into one large classification. Using a refined Bailey- Kuchler, one which breaks the broad types into sub- groups, would help alleviate this concern. 13.13 RESPONSE: See the response to General Comment 13.7. The Final EIS has been revised to note the difference between the Great Basin and Colorado Plateau woodlands. It is important to recognize that lack of detail in the EIS does not mean that BLM feels an area is unim- portant. Discussions focus on those areas that could receive the greatest environmental impact resulting from implementing any of the alternatives. BLM does not believe that implementation of any of the alterna- tives considered in the Final EIS would have a signifi- cant impact on pinyon-juniper woodland of either the Great Basin or the Colorado Plateau. Very few ecosys- tems are completely uniform throughout their extent. When dealing with several large areas, it is a com- mon, accepted scientific practice and is often neces- sary to group similar smaller areas that are not ex- actly the same from a vegetation or ecological stand- point. This does not necessarily diminish the import- ance of these areas. If a smaller area is especially important from a vegetation or ecological standpoint, it is specifically noted in the Final EIS, regardless of its size. 13.14 COMMENT: The importance of vegetation types in WSAs is higher than actual acreage figures would indicate. For example, the Great Basin WSAs contain conifer island ecosystems important for sci- entific study. [Utah Wilderness Association] 13.14 RESPONSE: Special vegetation types, such as the bristlecone pine forest and other island ecosys- tems, have been identified in the Final EIS (see Vol- ume I and the individual WSA analyses [i.e., Deep Creek Mountains]). Their potential scientific value has also been noted. 13.15 COMMENT: Vegetation communities in south- ern and western Utah have not been completely stud- ied. [Sierra Club, Cache Group] We are concerned that BLM has not completely studied the vegetative communities of southern and western Utah during its current study and previous inventories. BLM should develop an in-depth analy-sis of vegetation in nonrecommended wilderness areas and determine the subsequent degradation of this re- source due to the potential development and motor- ized recreational use. 13.15 RESPONSE: See the responses to General Comments 9.6, 13.1, and 13.8. Potential impacts to areas not recommended as wilderness in each of the alternatives have been considered in the Final EIS. 6 GENERAL COMMENTS AND RESPONSES SECTION 13: VEGETATION BLM recognizes that no area is ever completely stud- ied. Additional studies will be done as time and fund- ing allow. However, BLM believes that sufficient in- formation is available for the purposes of the wilder- ness review. 7 GENERAL COMMENTS AND RESPONSES - SECTION 14 WATER RESOURCES INDEX 14.13 The EIS should analyze the relationship of wilderness designation and Colorado River salinity, (p. 8) 14.1 Water is an issue and should be analyzed in de- tail. (p. 2) 14.14 The effect of wilderness designation on water quality should be addressed, (p. 9) 14.2 The Draft EIS analysis of water and water rights is inadequate, (p. 2) 14.15 The State's concern for water resources should be acknowledged, (p. 10) 14.3 The subject of Federal reserved water rights needs further analysis, (p. 3) 14.16 Local concern for water resources should be acknowledged, (p. 1 0) 14.4 Reserved Federal water rights should not be an issue because existing rights would not be affected. (P- 4) 14.17 A special provision to exclude reserved water rights is proposed, (p. 10) 14.5 The EIS does not adequately discuss the limited availability of water in Utah and its importance to the economy, (p. 5) 14.18 BLM should modify wilderness proposals to allow certain water projects, and the EIS should point out that water proposals can be consistent with wil- derness designation, (p. 11) 14.6 Wilderness water rights conflict with Utah water laws. (p. 5) 14.19 The Zion headwater areas are important to water resources, (p. 11) 14.7 The analysis of the effect of wilderness water rights on other water uses is wrong, (p. 6) 14.20 The EIS should identify Deep Creek as a Nationwide Rivers Inventory Stream, (p. 11) 14.8 The off-site impacts of Federal reserved water rights should be addressed, (p. 6) 14.21 The analysis should indicate that wilderness protects watershed and water quality, (p. 12) 14.9 The EIS should address four threats to use of water resources: uncertainty, historic flows, mini- mum flows, and priority to nonconsumptive uses. (p. 7) 14.22 The EIS analysis should state that water for livestock will be lost with wilderness designation, (p. 12) 14.23 The analysis should indicate that wilderness 14.10 The restrictions placed on the use of appropri- ated water in wilderness areas is not adequately addressed, (p. 7) designation will make water unavailable for coal de- velopment. (p. 12) 14.24 Wilderness designation for areas with potential 14.11 A wilderness reserve water right could pre- vent changes in points of diversion or conversion of existing rights from diversion to consumptive use. (p. 7) for water yield improvement by weather modification should contain appropriate provisions in the enabling legislation to permit such activities, (p. 13) 14.25 The BLM Wilderness Management Policy (BLM 14.12 The EIS should point out that wilderness desig- nation could cause Utah to lose its share of Colorado River compact water, (p. 8) Manual 8560), imposes serious restrictions on the collection of hydrologic data in wilderness areas, (p. 13) 1 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES 14.26 Specific water and related economic data for the San Rafael River, and the Muddy, Huntington, Cottonwood, and Ferron Creeks should be incorpor- ated into the Final EIS. (p. 13) 14.27 The analysis of hydroelectric power potential is inaccurate or incomplete, (p. 14) COMMENTS AND RESPONSES 14.1 COMMENT: Water is an issue and should be analyzed in detail. [Wayne County Water Users, Utah Farm Bureau Federation, and Paul McMullin] a. In the Draft EIS, Volume I, Overview, Summa- ry, page 3, Major Issues, 12 major issues are listed that become the framework of the entire study. The impact of the WSA upon water resources and water rights not only within WSAs, but for miles and miles around, is not listed as a major impact or evaluated in any way within the statements. As such, we feel the statements are incomplete and grossly inadequate because potential impacts of wilderness areas upon water resources and, in turn, upon many of the major issues discussed, are not addressed. The tip of the ice- berg, so to speak, of this huge problem is only very briefly mentioned and dismissed on the basis that it "may not significantly affect the unappropriated water existing in some of Utah's BLM WSAs." b. The Draft EIS recognized that there are peren- nial streams located within or bordering the WSAs. The complications implied by the recent Colorado Court ruling on Federal reserve water rights in wil- derness areas in themselves constitute the serious im- pacts that could develop under wilderness designa- tion. This court ruling requires the managing agency to submit a plan "to comply with their statutory duty to protect wilderness resources," which does not specifically address the quantity of water required to meet this charge. Unquantified interpretations of such law could, in fact, jeopardize agricultural water users' ability to divert water in or upstream from these areas. Water rights obtained by private land- owners after 1912 could also be preempted. This issue will involve municipalities as well and, in a re- gion that is already so heavily dependent on scarce water resources, these communities simply cannot afford to have their futures gambled away. We regard this as perhaps the most serious issue that under- mines this proposal. We suggest, therefore, that, until this reserved water right issue is resolved, added wilderness designation in Utah or any other State for that matter should not even be a consid- eration. c. The issue of Federal reserved water rights and water adjudication is bigger than this county, State, or wilderness issue. It will have a profound effect on every State west of the 100th meridian and all cur- rent existing Federal reserves in America. This de- bate will not be settled by local water conservancy districts, commissioners, State delegations, gover- nors, or BLM. It will be settled by the Supreme Court who has determined the issue of reserved water rights since 1906, when a Federal reserve Indian reservation in the State of Montana was granted the first valid water right for primary usage. 14.1 RESPONSE: The Final EIS includes impacts on water uses as an issue. The topic is discussed in sev- eral locations in Volume I, Chapters 1, 3, and 4 of this Final EIS. 14.2 COMMENT: The Draft EIS analysis of water and water rights is inadequate. [Emery County, Utah Power and Light, et al.] a. In light of the decision in Sierra Club vs. John Block et al., (622 F. Supplement 842 [D. Colorado 1985]), the Draft EIS is wholly inadequate in its dis- cussion of impacts related to any claim of water rights or water uses for wilderness areas created in Utah. If, as the Draft EIS indicates, 85 to 90 percent of Utah's water is already appropriated, the last 10 to 15 percent becomes more valuable for all uses, including municipal, agricultural, recreational, min- ing, and industrial uses. Any Federal reservation of water rights or any claims arising from wilderness designations, from any source, for instream flows for water quality, recreation, bank stabilization, fish and wildlife propagation or a variety of other possible uses will cripple Utah's future growth and develop- ment potential and, most importantly, conflict with and endanger current uses. b. We can never lose sight of the value water has to wilderness. It simply makes no sense to dewater a wilderness area, thereby destroying the natural val- ues-wildlife, fish, and riparian habitat--the wilder- ness was designated to protect. All avenues must be pursued to assure there will be adequate water to pre- serve wilderness values within these areas. Since wil- derness is a nonconsumptive use of water, it assures 2 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES downstream users of a constant supply. The inven- tory of major surface water supplies within or bor- dering WSAs (Table 24, Volume I) should be upgraded. Some of the major water supplies missing from the list are Rock Creek and Flat Creek in Desolation Can- yon, Indian Farm Creek in the Deep Creek Mountains, and the Little Delores in Westwater Canyon. c. The BLM Draft EIS is remiss in that it fails to adequately address water rights and how they will be affected by wilderness designation. There should be no wilderness designation until the issue of Federal reserve water rights, raised in the United States Dis- trict Court for the District of Colorado decision in Sierra Club vs. Block, is resolved. It appears from that case that wilderness designation may compel maintenance of historic stream flows at levels which prohibit any future upstream water development (i.e., no future enhancement of water resources on the San Rafael River, Muddy River, Green River, Price River, White River, and no future growth beyond present water resources in Emery County, Duchesne County, Uintah County, Daggett County, northwest Colorado, or southwest Wyoming). In addi- tion, it could jeopardize the Central Utah Project to the extent that it draws water from the Uinta Basin. Yet, there is no mention of the serious potential ad- verse impacts in the Draft EIS. Further, Sierra Club vs. Block casts a shadow on all existing water rights as established under State law. d. The Utah BLM Statewide Wilderness Draft EIS has not considered the potential economic implications of the wilderness water right reservation on affected areas of the economy. Until this economic impact issue is resolved, BLM cannot generate a competent economic analysis of the impact of wilderness desig- nation on local economies. Without such an analysis, it is impossible to make competent recommendations for wilderness designations on public lands. The Draft EIS is seriously inadequate in its analysis of water right issues and related economic impacts. 14.2 RESPONSE: The analysis of water resources has been expanded in this Final EIS, particularly for the Statewide alternatives in Volume I. Pertinent points raised in the comment have been addressed in the expanded information and analysis. 14.3 COMMENT: The subject of Federal reserved water rights needs further analysis. [Sierra Club, Utah Counties, et al.] a. Courts for a long time determined in a series of cases since 1908 that, when the Federal government sets aside or reserves land for certain particular pur- poses, an amount of water sufficient to meet those purposes is also set aside at that time. It is an implied doctrine because, in many cases, Congress does not speak about the amounts of water that should be set aside to protect those purposes when the land is set aside. Currently, national parks, national monuments, national forests, wildlife refuges, recreational areas, and Indian reservations have Federal water rights. The water requisition is in the words of most courts, quote: "A minimal amount of water necessary to meet the purposes of the reservation." The Federal government, as the holder of the water rights, must govern the State court along with the water right holders in streams in order to fulfill the purpose of the reservation. A wilderness area would have prior- ity as of the date of designation of the area of wilder- ness, and so the very earliest and most optimistic possible date here in Utah by the BLM wilderness area would be 1987. Too late in time. The Sierra Club went to Federal District Court in early 1984 to seek water rights in Colorado. It was for a very simple and important reason. Colorado, un- like Utah, is in the midst of an ongoing Statewide adju- dication of all water in the State. The Federal govern- ment has already gone into court to assert water rights for all of the Federal reservation but, for some reason, they have failed to go into the water courts as suggested by the Sierra Club and reserve the water rights for these areas. We went into court to ask for two very straightforward rulings: One, a dec- laration by the court that wilderness areas have re- served water rights, just like other Federal reserva- tions, and they should be protected as such; and two, that we get an order from the court that we be per- mitted to assert those rights. There was nothing in the Sierra Club's original report, through all the reams of paper and all the way through the final deci- sion, that dealt with anything about the standard or quantification of any kind of water rights. The assertion by county officials that the court is here seeking to lock up the areas and the waters is simply not true. The statements made by the county officials are simply misinforming. Additionally, it is very important that the citi- zens of Utah understand just what the court did. The 3 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES court declared that wilderness areas do have water rights and that Federal land managers have a duty to protect water resources in wilderness. The court did not order the FS to get into water court at this time in Colorado but instead ordered the FS to prepare a plan to submit to the court to show just how they in- tended to protect those water resources in the wilder- ness areas. The assertion by one county official, that with wilderness water rights the Central Utah Project will be halted, is so exaggerated that it tends to be laugh- able, if not irresponsible. Wilderness areas need water rights just like our other Federal areas. It is all too often said that water is the lifeblood of the arid West. b. There is concern that a Federal reserve water right may already exist on BLM lands. In November 1984, the House Appropriations Committee issued a report which said that in order for the BLM "... to comply with Congressional intent regarding the utili- zation of public rangelands, it is essential for BLM to have the use and control of all water on the public do- main necessary to support the proper use and manage- ment of its lands." The reservation of the public do- main for grazing purposes occurred in 1934 with passage of the Taylor Grazing Act. Prior to advent of the wilderness concept, use of water on the BLM was primarily for either diversive or consumptive pur- poses. With the wilderness concept now suggesting that historic flows and qualities must be maintained in designated areas, it is fully reasonable to expect that, once established, BLM wilderness-reserved water rights will date from the passage of the Taylor Grazing Act of 1934. Such a finding, after the Utah BLM wilderness has been designated, could be deva- stating to Utah. 14.3 RESPONSE: On July 26, 1988, the U.S. Attor- ney General took the position that wilderness water rights do not exist without explicit language reserv- ing such water rights in the legislation designating wilderness areas (Meese, 1988). The Attorney General's opinion stated that water could be set aside through existing State law. BLM recognizes that current Utah law regarding instream flows generally is not compatible with uses that do not involve a physical diversion of water from the stream channel (Bangerter, 1986). Only recently has the State legislature recognized a legally beneficial instream value, and only the Utah Division of Wildlife Resources is entitled to obtain an instream right. An existing perfected right may be purchased and trans- ferred to the wildlife agency, but only with case-by- case legislative approval (Utah Code Annotated). Therefore, impacts on water rights are not signifi- cant issues for the Statewide EIS. Also see the re- sponse to General Comment 14.8. 14.4 COMMENT: Reserved Federal water rights should not be an issue because existing rights would not be affected. [Sierra Club, Cache Group; Utah Wilderness Association; et al.] a. The issue of Federal reserved water rights in wilderness areas (the Kane decision), while hotly de- bated at present, is likely to become the biggest non- issue in the BLM wilderness review. The status of re- served water rights in wilderness is such that they cannot usurp existing rights, nor can water be reserv- ed by the Federal agency unless available water ex- ists, and then only to preserve wilderness values. Those who have attempted to raise the issue to a fev- erish pitch have simply found an argument of conven- ience and a "red-herring" to further their anti-wilder- ness arguments. b. Throughout the public hearing process, many elected and appointed public officials voiced concerns that wilderness designation would affect their pre- sent water supplies. This was generally based on the late 1985 court decision involving Federal reserve water rights in Colorado. We feel that these officials have overreacted and, in essence, are spreading bad information. We urge BLM to begin an active campaign to correct this misinterpretation of the Colorado water case. The Draft EIS has information which backs up our argument, including: "... 85 to 90 percent of the water in Utah is already appropriated" (Volume I, page 184) and the outcome of the water suit in Colo- rado ". . . appeal process may not significantly affect unappropriated water existing in some of Utah's BLM WSAs" (Volume I, page 184). An extensive part of the Final EIS should include a complete review of this controversial court decision. 14.4 RESPONSE: BLM has included impacts on water uses as an issue in this Final EIS because of the concern expressed by many people and because of the controversial nature of the subject. The expanded information in the Final EIS is intended to help correct 4 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES misinformation and misperceptions regarding the subject. Also, refer to the responses to General Comments 14.2 and 14.3. 14.5 COMMENT: The EIS does not adequately dis- cuss the limited availability of water in Utah and its importance to the economy. [Utah Board of Water Resources, Normal Gubler, Carvel Magelby, et al.] a. The water supplies of Utah are very limited and, in many cases, development of a given source of water is physically and economically feasible only in specific locations. Where possible, wilderness desig- nation which will prevent or severely inhibit develop- ment of a significant source of water should be avoid- ed. b. According to Dr. Theron P. Allgood, USDA State Soil Scientist, only 3 percent of the State, or 2 million acres, are currently under cultivation. If more water were made available, as much as 8.5 million acres or more could be used for farming and pasture. However, approximately 34 of southern Utah's major perennial water sources will be affected or potential-ly affected by wilderness water reserva- tion. c. The majority of Utah's BLM WSAs are situated in or adjacent to the State's most arid regions. The ability to constructively divert the region's limited supply of fresh water is central to the economic liveli- hood of the region. Pursuant to Sierra Club vs. Block (November 25, 1985), access to limited water re- sources in and about Utah WSAs is cast into serious doubt. Although the case is on appeal, both the Sierra Club vs. Block case and historical precedent clearly indicate that a Federal reservation of land does in- clude a reservation of water rights sufficient to meet the purposes of the reservation. It is claimed by some that this Federal reserve water will be junior to ex- isting water rights and, therefore, not injurious to current rights. However, management of designated wilderness areas is intended to maintain or to restore conditions within a designated area to those condi- tions which existed prior to the influence of man. Accordingly, the wilderness water right reservation would not be a diversion or a consumptive use right but, rather, it will become a reservation and mainte- nance of historic flow patterns and qualities. Accep- tance of anything less than historic flow patterns would be contrary to the BLM mandate to manage wil- derness areas "for the protection of their wilderness character," absent the imprint of man. Endless oppor- tunities for litigation are available under the pretense of a wilderness water reservation. d. Southern Utah and southern Nevada are the fu- ture fast-growing areas of the USA. Water is the im- portant factor, and production of this water will have to come from these wilderness areas. This will re- quire new dirt roads, new pipe lines, new water wells, new fencing, and new maintenance. All will have no effect on the beauty of this area. Also, new dirt roads for good reasons do help in fire fighting. e. The Utah BLM Draft EIS has not given adequate analysis and potential impact to several areas which may drastically affect the economics of the region. The most notable of these is the seriously inadequate analysis of water rights issues addressed in the Draft EIS and the economic impacts related to those water rights. Since management of designated wilderness areas is intended to maintain or restore those lands to conditions which existed prior to the influence of man, the full impact of a recent court decision, Sier- ra Club vs. Block, is not fully understood, but places in serious doubt the preservation of historical water rights. The ability to constructively divert the re- gion's limited supply of fresh water is essential to the economic livelihood of this region, and any change in these historical rights demands full impact consid- eration. 14.5 RESPONSE: BLM concurs that availability of water is a limiting factor in many locations in Utah. Also, there are other limiting factors. Economic poten- tial of any region or locality requires consideration of all of the factors pertinent to the particular develop- ment proposal. An overview discussion of this sub- ject, including the contribution of water resources, has been added to Volume I, Chapters 3 and 4 of this Final EIS. The potential for conflicts of wilderness management with future consumptive use of water upstream of WSAs is also analyzed. 14.6 COMMENT: Wilderness water rights conflict with Utah water laws. [State of Utah and Utah Board of Water Resources] a. Current State law is not compatible with appro- priation of water (without a physical diversion) for instream flow purposes. However, when considering an application to appropriate for approval, the State Engineer considers its impact on the natural stream environment. The 1986 Utah Legislature approved HB-58, which provides for instream flows if an 5 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES existing perfected water right is transferred to UDWR with legislative approval. Any change applica- tion then filed by UDWR is considered for approval by the State Engineer. b. At the present time, Utah water law permits UDWR to establish water rights for instream flows. This is the only entity recognized by the Utah statute with the ability to acquire this type of water right. Therefore, it should be understood that designation of an area as wilderness in no way implies that surface or emerging subsurface water flows can be author- ized as instream flows without proper filing by UDWR 14.6 RESPONSE: This information has been added to the discussion of water resources in Volume I of the Final EIS. 14.7 COMMENT: The analysis of the effect of wil- derness water rights on other water users is wrong. [Wayne County Water Users, Utah Counties, et al.] a. The Draft EIS wrongly supposes that only unap- propriated (consumptive use) water is at risk. In addi- tion, approved but undeveloped water rights, future nonconsumptive water uses, and future changes upon existing water rights are at risk. Even water quality improvement projects would be at risk. The Draft EIS infers that since "... 85 to 90 percent of the water in Utah already is appropriated" that whatever the results of court appeals and the possible existence of unappropriated water in some of Utah’s BLM WSAs, water matters are not significant and are not dealt with in depth. This is wrong. Due to the transient na- ture of water, its needfullness in almost all activities of man, and the far-reaching possibilities of conflict with wilderness areas in place and Federal reserve water rights, the Draft EIS is inadequate and does not fulfill its purpose of objectively analyzing the environ- mental impacts. 14.7 RESPONSE: Refer to the responses to General Comments 14.2, 14.3, and 14.5. 14.8 COMMENT: The off-site impacts from Fed- eral reserved water rights should be addressed. [Emery County Attorney, Utah Counties, and Wayne County Water Users] a. A Federal reserved water right for down- stream wilderness areas could affect the entire reaches of streams and rivers by requiring mainte- nance of historic flows, thus impacting nearly all western water projects and even curtailing some. The Utah Association of Counties repudiates the Colorado district court decision rendered in Sierra Club vs. Block as being counter to the interest of the west and its citizens. b. A proposed water action many miles away from a wilderness area could be opposed by the Fed- eral government based upon Federal reserve water rights doctrine, and the result could have extensive impacts. The Draft EIS does not address possible WSA impacts upon off-site water rights and water re- sources nor the impact this will have on the major issues that are discussed. The result is the Draft EIS is grossly inadequate because of its failure to consid- er the impact upon water matters and the impact of the ripple effect upon the whole social and economic fabric of Utah. c. It appears from this case that wilderness desig- nation compels the government to maintain stream flows at the levels which prohibit any future up- stream water development. That would mean no fu- ture enhancement of water resources on the San Rafael, the Muddy, the Green, the Price, and the White Rivers. That would mean no future growth beyond present water resources in Emery County, Carbon County, Duchesne County, Uinta County, Dag- gett County, northwest Colorado, and southwest Wyo- ming. In addition, that could mean the jeopardizing of the Central Utah Project, to the extent that it draws water from the Uinta Basin, and yet there is no men- tion of this potential adverse impact in the Draft EIS. 14.8 RESPONSE: The views expressed have been reviewed and addressed in the expanded discussion of water resources in Volume I. Also, see the response to General Comment14.3. BLM's analysis is that water uses would not be significantly affected by wil- derness designation at 74 of the 83 WSAs. Designa- tion of nine WSAs would constrain future water diver- sion and use upstream of the wilderness areas in Se- vier, Wayne, Garfield, Emery, and Carbon Counties. See Volume I, Chapter 4, for more details. 14.9 COMMENT: The EIS should address four threats to multiple use of water resources: uncer- tainty, historical flows, minimum flows, and priority to nonconsumptive uses. [Emery County and Wayne County Water Users] 6 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES a. Wilderness areas are created to preserve areas in the "natural wilderness state" in which they existed at the time of designation. This includes water flowing through a WSA or supplying natural vegetation within it. In Volume I, Chapter 5, page 184 and Appendix 2, page 232, the water rights and water resource problems are very briefly introduc- ed. The problem is centered upon Federal reserved water rights. The Federal Court decision (Civil Action No. 84-K-2) in Colorado on November 25, 1985, stat- ing that Federal reserved rights exist in National Forest wilderness areas in Colorado must make us assume in these considerations that Federal reserved water rights will also exist in BLM wilderness areas in Utah. As such, any future action in an area up- stream, upslope, lateral to, or in an artesian system that is source to any WSA that could possibly alter quantity, quality, or pattern of flow either of surface or subsurface water is at risk. b. The designation of wilderness presents four threats to our wise multiple use and conservation of our water resources: (1) the uncertainty of Federal reserve rights; (2) the impact of a return to histori- cal flows; (3) the threat of minimum flows; and (4) giving priority to a nonconsumptive water use. 14.9 RESPONSE: See the responses to General Comments 14.3, 14.5, and 14.8. Minimum flow prac- tices are a valuable aspect of multiple-use resource management and are not viewed as a threat. In some cases, giving priority to a nonconsumptive use would be appropri-ate and consistent with State and Federal law (see the response to General Comment 14.6). Ri- parian habitats are significant in the west and receive management attention through BLM's planning system. Allocation of water resources is a very impor- tant matter, and each situation merits careful review of all possible uses. Each drainage basin has its own mix of domestic, agricultural, industrial, and in- stream flow needs. Minimum flows and nonconsump- tive water use are normal multiple-use considera- tions. The Final EIS addresses these relationships. 14.10 COMMENT: The restrictions placed on the use of appropriated water in wilderness areas are not adequately addressed. [Utah Woolgrowers, et al.] Under the decision made on Colorado wilderness: "Any unappropriated water now in wilderness can be adjudicated to wilderness. New water, which is not appropriated, will not be allowed to be appropriated unless it has no adverse impacts on the wilderness." I don't know anybody that could develop water and use it that will not have any adverse impacts on wilder- ness. The question which is not addressed is one about appropriated water that arises on wilderness areas. Can it be developed? How? What are going to be the rules and regulations? I think a logical person would realize that even appropriated water that's owned by somebody or appropriated by the State of Utah cannot be developed economically in a wilderness area. This has not been addressed in the EIS and it should be addressed. 14.10 RESPONSE: See the response to General Comment 14.9. Water which "arises on wilderness areas" (i.e., headwater areas) may be diverted and used down-stream from the wilderness areas, con- sistent with State water law. Since wilderness water use essentially would be nonconsumptive, wilderness would not affect water availability and use down- stream. Additionally, in many instances, spring devel- opments could be designed and installed consistent with wilderness protection criteria. 14.11 COMMENT: A wilderness reserve water right could prevent changes in points of diversion or conversion of existing rights from diversion to con- sumptive use. [Utah Counties and Washington County Water Conservancy District] a. Such massive projects as the Central Utah Pro- ject could possibly be prevented if the Federal govern- ment ruled that diversion of Uinta Basin water could alter flows or quality in downstream wilderness areas such as those proposed in Desolation Canyon and Canyonlands National Park. b. The statement found on page 16 of the Parunu- weap Canyon section of the EIS, that ". . . there are no known private water rights located on public lands within the WSA" is misleading. All of the water in the Virgin River has either been primarily appropri-ated by the State of Utah or secondarily appropriated in re- sponse to surplus applications on file in the State Engi- neer's Office. The diversion point at which rights of the various downstream users are presently identi- fied for is the Virgin River. The State of Utah has a procedure through which diversion points or storage sites on a river can be changed. The Washington County Water Conservancy District has made appro- priate application to the State for such changes as diversion points and storage sites on the Virgin River. These procedures could allow the District to transfer 7 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES its water rights into the area of the proposed WSA in order to allow for the development of a storage res- ervoir. 14.11 RESPONSE: As of the printing of the Final EIS, there have been no changes in points of diversion to locations within the Parunuweap Canyon WSA; consequently, the sentence in question concerning private water rights on public lands within WSA is considered correct at the time of EIS preparation. Regarding the general matter of changes in points of diversion to locations on public lands, BLM has op- portunity to provide input (protest, concur, or make no comment) to the State Engineer on each application filed. In the case of applications in WSAs or in desig- nated wilderness areas, the usual BLM position is a protest. This protest has nothing to do with the exer- cise of the applicant's existing, basic water right (at some other location); rather, it is intended to alert the applicant and the State Engineer that BLM will not issue a right-of-way for development of facilities on public lands in those areas unless special conditions are met. In many cases, the development proposals cannot meet wilderness nonimpairment conditions, thereby making moot the change in point of diversion. However, changes in points of diversion to locations upstream of WSAs could be affected; this situation is noted in the Final EIS. 14.12 COMMENT: The EIS should point out that wil- derness designation could cause Utah to lose its share of Colorado River compact water. [Washington County Water Conservancy District, et al.] If, in the event that wilderness eliminates future water development opportunities and the storage capa- city is not available on the Virgin River and in other parts of the region, then there's no place to store that water. If there's no place to store that water, then it must go downstream. If it does go down- stream, not only does this area lose its ability to meet the water needs for its own development, but the State of Utah loses its share of the Colorado River that it has been adjudicated and worked out in the allocation of various compacts. 14.12 RESPONSE: A discussion of the Colorado River compact has been added to Volume I of the Final EIS. 14.13 COMMENT: The EIS should analyze the rela- tionship of wilderness designation and Colorado River salinity. [U.S. Environmental Protection Agency, Emery County, Wasatch Mountain Club, et al.] a. Designation of public lands for wilderness pre- servation in most instances is fully consistent with Clean Water Act and Clean Air Act requirements. How- ever, we have identified several areas that need fur- ther discussion and analysis within the Draft EIS to ensure compliance with water quality and air quality standards. Potential water quality impacts that need further consideration are salinity mitigation mea- sures and antidegradation requirements. In particular, we offer two examples: Salinity standards developed under the Clean Water Act and supported by the Colorado River Basin Salinity Con- trol Act (PL 93-320) are based on an antidegradation approach (i.e., maintenance of salinity levels at or below the 1972 levels in the river). This is inconsis- tent with the approach in the EIS where "credit" is taken for salinity benefits derived from the wilder- ness designations that do occur (see BLM Draft EIS, page 233 and page 272). Any increases over earlier levels, such as those from increased grazing or min- ing activities, need to be mitigated. Because most of the WSAs are pristine, undeveloped areas now, any changes in salinity levels due to increased activity should be considered an adverse impact and mitigation measures need to be identified. The Paria River is identified as a major source of non-point salinity and sediment to the Colorado River. The EIS states that the Bureau of Reclamation, the agency responsible for reducing Colorado River sedi- ment and salinity, has yet to evaluate the Paria River for possible control measures. The Colorado River Basin Salinity Control Act Amendments (PL 98-569) require BLM to develop a policy for control of salinity on BLM-administered lands by July 1, 1987. There- fore, as part of the Final EIS, we suggest BLM identi- fy any salinity control measures it proposes, consis- tent with this mandate. The EIS should also identify any proposed salinity control projects that would be affected by wilderness designation. b. Being that the San Rafael and the tributaries to the San Rafael are major contributors to the Colorado River salinity problem, we are concerned with what measures might be taken if downstream areas are des- ignated wilderness. c. The Colorado River serves more than 20 mill- ion people in seven western States and Mexico. The 8 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES eastern half of Utah and a majority of Utah's BLM WSAs lie within the Colorado River drainage. Agri- culture currently uses more than three-quarters of Utah's Colorado River water allocation. The options facing Colorado River water users are (1) to accept higher salinity levels and the attendant damage; (2) invest nearly $1 billion in salinity control projects; or (3) impose water use limitations to control salin- ity. Building more dams is not a solution to this pro- blem. Dam construction is followed by rapid silting, sidewall deterioration, and increased evaporation in the Colorado River drainages, all of which have unfav- orable impacts on water quality. Appropriate alterna- tives include cessation of irrigation in areas of high- saline pickup, improving irrigation efficiency, limit- ing scale of water-dependent development, restrict- ing reservoir evaporation, and limiting grazing on public land in July and August. Given the above options, it is clear that develop- ment in Utah's BLM WSAs is severely limited by water use constraints. Retaining qualified regions of the Colorado River Basin as wilderness would help stabilize soils and reduce Colorado River salinity, relieving taxpayers of billion-dollar desalinization projects or unacceptable damage to vital croplands. 14.13 RESPONSE: Information and analysis of the effect of wilderness on Colorado River salinity have been added to Volume I, Chapters 3 and 4 of this Final EIS. Volume I, Table 34, lists those WSAs with moder- ately saline and/or strongly saline soils that may contribute to river salinity. The individual analyses (Volumes II through VI) for these WSAs also address salinity impacts related to projected development and disturbance. 14.14 COMMENT: The effect of wilderness designa- tion on water quality should be addressed. [U.S. Envi- ronmental Protection Agency, Roger Jenkins, David Orr, et al.] a. Observance of the Clean Water Act is an essen- tial component of the BLM land use planning criteria as envisioned under Section 202(c)(8) of FLPMA. Dur- ing the wilderness study process, 42 WSAs have been found to have notable amounts of surface water. These streams require consideration under the Clean Water Act to maintain designated beneficial uses. In particular, BLM's management actions should strive towards compliance with water quality standards, including antidegradation requirements. The antidegradation policy includes: (1) at a mini- mum, all existing uses and the level of water quality necessary to protect these uses needs to be fully maintained and protected; (2) where higher quality waters exist, such quality needs to be maintained un- less certain minimum requirements are met before allowing lowered water quality; and (3) in outstand- ing national resource waters, no lowering of water quality is allowed. We recommend that the EIS contain a discussion of these water quality antidegradation requirements and define how wilderness management or multiple-use management for the Proposed Action and alternatives will help achieve these conditions. Similarly, the EIS could also address Utah's State antidegradation requirement. b. Consider the impacts of continued livestock grazing on water quality in wilderness (indeed, every- where!). Could not some provisions be made to keep livestock out of springs and streams and riparian areas in order to protect water quality? For exam- ple, wilderness areas with such aquatic resources could have grazing permits modified in such ways that would make the permittee responsible for confin- ing livestock to areas where they could not impair water quality. c. Recreationalists who prefer to drink water less polluted by cattle manure and quick sand-trapped cattle carcasses may be more inclined to visit the can- yon areas. Some people move here to escape pollution and contaminated water supplies in their former area. Wilderness will provide increasing protection for the nation's watersheds. 14.14 RESPONSE: Water quality is discussed in the EIS. State antidegradation classifications have been added to the individual WSA analyses (Volumes I through VI). In general, wilderness designation would have little or no effect on existing water quality. Grazing permits and/or practices affecting water quality are not expected to change due to wilderness designation. Also, see the response to General Com- ment 18.2, which addresses comments on livestock grazing. 14.15 COMMENT: The State’s concern for water resources should be acknowledged. [Utah Board of Water Resources] The Utah Board of Water Resources is extremely concerned about the recommendations for wilderness designation in the Utah Statewide Wilderness Draft 9 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES EIS released by BLM. As an expression of this con- cern, the Board passed the attached Resolution at its July 11, 1986, meeting: NOW, THEREFORE BE IT RESOLVED, that the Board of Water Resources opposes designation of any public lands as wilderness unless it can be demonstrated conclusively that such designation will not adversely affect present or future water resources develop- ment and management. 14.15 RESPONSE: When expanding information and analysis of water resources for the Final EIS, BLM consulted with the Utah Division of Water Resources. The concerns noted have been addressed to the extent that information is available. Since many of the water right filings with the State are old and incomplete and since historical data are not available for all stream and other water sources, it is not possible to precise- ly define and quantify all WSA waters, those already committed to use, and any residual. The information presented in the EIS is a combination of filing data, field data, implied or interpolated data, and profes- sional estimates. The extent to which wilderness des- ignation would affect present or future water re- sources development and management on a Statewide basis is addressed in Volume I, Chapters 3 and 4, and where applicable in the individual WSA analyses. 14.16 COMMENT: Local concern for water re- sources should be acknowledged. [Orangeville City] Our community, like so many others, is con- cerned about the implications of the Federal District Court of Colorado ruling; in this case, of Sierra Club vs. Block, which held that wilderness designation creates a Federal reserve water right in areas of designation. Accordingly, we have adopted the attach- ed resolution repudiating this decision. We, as members of the Orangeville City Council, find: Now, therefore, we, the members of the Orange- ville City Council, recommend the repudiation of the Colorado District Court decision rendered in the Sier- ra Club v. Block as being counter to the interests of Utah and its citizens. We recommend that Orangeville City file an ami- cus curiae brief, in conjunction with the Utah League of Cities and Towns, Utah Association of Counties, and with the Western Interstate Region of the National Association of Counties, through Mountain States Le- gal Foundation in Denver, with the Tenth Circuit Court of Appeals and, when appropriate, with the United States Supreme Court, to overturn this unacceptable District Court decision. We further recommend that there be no wilder- ness designation considered until the Sierra Club v. Block decision be overturned. 14.16 RESPONSE: The views expressed are noted. BLM intends no change in water rights law. 14.17 COMMENT: A special provision to exclude reserved water rights is proposed. [State of Utah and Wayne County Water Users] a. Because of legal uncertainties and many un- known physical conditions, it is not possible to evalu- ate water-related impacts of the WSAs at this time. However, the potential impacts are there and are so great that they could mean the difference between a normal future growth and almost no further change in the large areas of Utah in the drainages of the WSAs. Until water-related impacts are properly addressed for each WSA, this matter should not proceed fur- ther. An alternate approach would be to remove the requirement of a continuance of natural water condi- tions within wilderness areas and abandon any possi- ble use of Federal reserve water rights with respect to wilderness areas. b. The recent Colorado case, Sierra Club vs. Block (1985), has sparked a lot of controversy over water rights in wilderness areas. The District Court held that Congress impliedly reserved water rights with the passage of the 1964 Wilderness Act. This rul- ing concerns appropriators whose water rights may be negatively affected or lost with a wilderness desig- nation. To avoid potential conflicts, a wilderness bill could specifically exclude reserved water rights from a wilderness area. 14.17 RESPONSE: Refer to the response to General Comment 14.3. 14.18 COMMENT: BLM should modify wilderness proposals to allow certain water projects, and the EIS should point out that water proposals can be con- sistent with wilderness designation. [Washington County Water Conservancy District] GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES The BLM's Proposed Action for Parunuweap Can- yon WSA would disallow the construction of a reser- voir on the East Fork. Each of the other partial wilder- ness proposals would also make it impossible to devel- op the water resources of the East Fork of the Virgin River. A possible variation could be a modification of the Proposed Action similar to that contained in the rec- ommended proposals for the Cottonwood Canyon WSA, Volume lll-A. Since the time the city of St. George has started developing culinary wells in Wash- ington County in order to increase its municipal sup- ply, BLM has recommended the implementation of a modified wilderness proposal which would allow new water resource facilities or watershed activities not otherwise related to rangeland or wildlife manage- ment, if they were found to be enhancing to wilder- ness and necessary to correct conditions imminently hazardous to life or property, or if they were found to be authorized by the President pursuant to Section 4(d)(4)(1) of the Wilderness Act. BLM proposal also designated that the area pro- posed for future development by the city of St. George was an area which could be expanded to allow for further water resource facility developments, if those were completed in accordance with the MFP and with attention to the concern for wilderness values. When Congress created the Wilderness Act, it was clear that it did not want to interfere with exis- ting water projects. For example, with respect to the La Garita Wilderness, Congress stated that: "Water diversion facilities exist within a portion of the pro- posed additions, and it is the committee's intention that wilderness designation not interfere with neces- sary preparation, maintenance or repair of such facil- ities" (H.R. Report No.617, 86th Congress 1st Ses- sion at 9 [1979]). Additionally, with respect to the Holy Cross Wil- derness Area, Congress stated that: "No right, or claim of right, to the diversion and use of existing conditional water rights for the Homestake Water De- velopment project by the cities of Aurora and Colo- rado Springs shall be prejudiced, expanded, diminish- ed, altered, or affected by the Act. Nothing in this Act shall be construed to expand, abate, impair, im- pede, or interfere with the construction, maintenance or repair of said project, nor the operation thereof, or any exchange or modification of the same agreed to by the cities and the United States, acting through any appropriate agency thereof" (Public Law No. 96- 560, 102(a)(5); 94 Statute 3265 [1980]). A review of the legislative history behind the Wil- derness Act indicates Congressional support for con- servation of water and improvement of water quality and flows for the benefit of the downstream user. It also indicates a concern for meeting the needs of local communities by making sure that water development projects are not thwarted by wilderness designation. In light of this legislative history, the development of the two upstream projects proposed by the District is consistent with the intent of the Wilderness Act. 14.18 RESPONSE: BLM believes that the comment does not accurately reflect the water resource ac- tions allowed by the Presidential exemption provision of the Wilderness Act. The examples cited are direc- ted at specific, preexisting conditions which are not necessarily comparable to Utah situations. BLM be- lieves that the Presidential authority primarily is directed at clear emergency situations where public health and safety are at considerable risk. This would not be the situation in most Utah WSAs. BLM believes that the projects (in the Virgin River Basin) referred to in the comment would be incompatible with wilder- ness; this is reflected in the EIS analysis. Also, see the response to General Comment 3.26. 14.19 COMMENT: The Zion headwater areas are important to water resources. [Miki and John Magyar] We are pleased to see the proposed alternatives for the WSAs adjoining Zion National Park. It is criti- cal to keep these headwaters as safe as possible from development and abuse. Zion is very much a "river" park and, as such, needs a natural water regime. 14.19 RESPONSE: Refer to the response to General Comment 8.7. 14.20 COMMENT: The EIS should identify Deep Creek as a Nationwide Rivers Inventory Stream. [National Park Service] In reviewing the subject Draft EIS from the pers- pective of Nationwide Rivers Inventory Streams, we find in general that it was very well done. Virtually all relevant inventory streams are discussed in an appropriate manner and context. However, in Volume III, Deep Creek from its confluence with the North Fork of the Virgin River to its source should be discus- GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES sed as an inventory stream in a manner similar to the other inventory stream discussions. 14.20 RESPONSE: The suggested discussion has been added. 14.21 COMMENT: The analysis should indicate that wilderness protects watershed and water quality. [Randolph Jorgen, et al.] Wilderness is by far the best protector of water- shed by virtue of its prohibition on surface disturb- ances, including ORV use; highway construction; defoliation and herbicide use; and pollution-intensive developments such as strip mining, tar sand develop- ment (especially with its associated proposals for ground water use and its potential for ground water pollution from extremely toxic hydrocarbon resi- dues), and oil well drilling (with its toxic drilling muds and the possibility of cross pollution between previously separated layers of aquifers). 14.21 RESPONSE: The view expressed is noted. It is recognized that wilderness designation would facili- tate certain land management measures that tend to reduce the risk of water pollution. Also, see the re- sponses to General Comments 12.5 and 14.14. 14.22 COMMENT: The EIS analysis should state that water for livestock will be lost with wilderness designation. [David Adams, et al.] It must be recognized that, in order to have gra- zing, water must be provided in these WSAs. Most of the water is provided by stock ponds and developed springs. In this area, we have frequent heavy thunder- showers. And all of the water that runs into the reser- voir then is filled with silt and the reservoirs are filled--no longer capable of storing water. On the areas that I once used, occasional heavy thundershow- ers would destroy the producing value of springs. And the stockman does not have the capability of restor- ing the stock ponds and producing and using machinery to put the springs back in production. Even though you say grazing is allowed, it will be impossible without water. 14.22 RESPONSE: With wilderness designation, ex- isting grazing and existing water sources would be allowed to continue. Construction of new stockwater- ing facilities would be limited or prohibited. Also, see the response to General Comment 18.1. 14.23 COMMENT: The analysis should indicate that wilderness designation will make water unavailable for coal development. [Consolidated Coal Company] We anticipate that future Federal coal leasing deci- sions, which are essential for a stable coal mining in- dustry in Utah, will be negatively influenced by BLM's responsibilities to maintain and improve air and water quality in designated wilderness areas. This conflict will increase pressures on BLM to delete cer- tain coal tracts from the competitive leasing process if it is perceived that development may have negative impacts on wilderness values. Future coal production throughout Utah will be reduced by this process. Efforts to enhance water quality of streams flow- ing through wilderness areas will likely be directed at upstream point source discharges, which will include coal mine discharges. More stringent effluent limita- tions applied to coal mines through the NPDES permit- ting process would likely increase production costs and possibly preclude future mine expansions. Coal resources are located on upstream water- sheds of streams which flow through the proposed wil- derness areas. A wilderness designation would impart to the Federal government a reserved right to all un- appropriated waters which flow through the wilder- ness area. This water right is considered superior to the rights of all future appropriators. Such a restric- tion could mean that water would be unavailable for future mining needs including coal cleaning, dust sup- pression, drinking water, and irrigation during recla- mation, and thus eliminate the possibility of future mine expansions. 14.23 RESPONSE: Impacts on water use for coal operations have been analyzed in Volume I, Chapter 4, and the appropriate WSA analyses. Designation of wil- derness downstream on the Muddy Creek, San Rafael River, Dirty Devil, and Price River drainages could affect availability of water for coal mining in Carbon and Emery Counties. 14.24 COMMENT: Wilderness designation for areas with potential for water yield improvement by wea- ther modification should contain appropriate provi- sions in the enabling legislation to permit such activi- ties. [Utah Board of Water Resources] The areas in which snowpack augmentation (wea- ther modification) for increased water yield is feasi- ble is necessarily limited to areas with the proper 12 GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES combination of topographic and climatic conditions. The BLM Wilderness Management Policy (BLM Manual 8560) imposes conditions on operational weather mod- ification programs that are not attainable with pres- ent technology and evaluation techniques. 14.24 RESPONSE: The WSAs with the most likely opportunities for snowpack augmentation have been identified and listed in Volume I, Chapter 3, Land Use Plans, in this Final EIS. It is recognized that wilder- ness designation may pose limits on placement of equipment in these areas for snowpack augmentation and recording purposes; however, there are no active weather modification projects involving BLM WSAs, therefore, any impacts would be minimal. 14.25 COMMENT: The BLM Wilderness Management Policy (BLM Manual 8560) imposes serious restric- tions on the collection of hydrologic data in wilder- ness areas. [Utah Board of Water Resources] Restrictions range from requiring "primitive means" only for snow measurement and prohibiting permanent installation of telemetry equipment, to requiring Presidential approval for establishing any new data sites. Data collection within wilderness areas is often vital to management of water resour- ces outside the wilderness areas; in these cases, enabling legislation should contain provisions to relax these requirements. 14.25 RESPONSE: There are no existing or pro- posed hydrologic equipment or data sites known to exist in the BLM WSAs. Therefore, conflicts would be minimal. 14.26 COMMENT: Specific water and related eco- nomic data on the San Rafael River, and the Muddy, Huntington, Cottonwood, and Ferron Creeks should be incorporated into the Final EIS. [Emery County] The two streams in Emery County that would be adversely affected are the San Rafael and the Muddy. The San Rafael consists of the Huntington, Cotton- wood, and Ferron, and we take a great deal of pride in our development, conservation, and wise multiple use of these streams. On the Huntington drainage, with its long-time average of 160,000 acre-feet, we have reservoir storage for agriculture use around 15,000 to 16,000 acre-feet. We also have a 30,000 acre-foot reser- voir for industrial use. We have 691 stockholders, irrigate 24,000 acres, and serve a population of 3,200 people in four rural communities, and we pro- vide water for two power plants. On the Cottonwood Creek, with the yield almost identical to that of Huntington, we have the Joes Valley Reservoir, with 62,500 acre-feet, and five smaller reservoirs, which we have reserved for fish culture and recreation. The Cottonwood area has 400 stockholders. It irri- gates 12,000 acres, provides 14,000 acre-feet of water for industry, and serves a population of around 3,000. In addition to that, it provides water through numerous tunnels and transmountain diversions to the cities of Ephraim, Spring City, and Mt. Pleasant. For the Ferron River, the annual yield is around 40,000 acre-feet, and it has a reservoir capacity of around 18,000-acre feet. It irrigates 10,000 acres, provides 7,000 acre-feet of water for industry, and provides sustenance for around 2,000 people. These three streams, in addition to providing wa- ter for the agriculture and domestic use for 10,000 people, provide water for an industry that employs in its coal fields 1,182 people with an annual payroll of $40 million. It also provides for the utility industry, which has a payroll of $23 million going to 720 peo- ple. The industrial expenditures from these indus- tries, the State collects sales tax from $158 million. The revenue for the State and Federal government mineral leases exceeds $40 million. The taxes deriv- ed from this industry provide $14 million, the bulk of which goes into the uniform school fund. The threat of withdrawing water rights with the land would upset and possibly destroy this lucrative industry. The Muddy River is ready for development. At present, it provides water for 8,000 acres and a population of 350. 14.26 RESPONSE: Present uses would not be affected by wilderness designation. The potential for conflicts with future changes in use or points of divi- sion is analyzed in the Final EIS. 14.27 COMMENT: The analysis of hydroelectric power potential is inaccurate or incomplete. [Washing- ton County Water Conservancy District, George Hinde, Utah Power and Light et al.] GENERAL COMMENTS AND RESPONSES SECTION 14: WATER RESOURCES a. Statements concerning hydroelectric power de- velopments are not consistent. The statement on page 99 should be added to the statement on page 63, or at least a reference to page 99 should be given. Refer- ence to page 74 should also be made, page 74 gives the impression that the Deep Creek Mountains WSA has low hydroelectric potential, since this WSA is not one of the four WSAs listed as having medium to high potential. The statement on page 99 says that al- though most of the two proposed projects are outside the WSA, a right-of-way for some pipeline within the WSA has been granted. This statement does not give the same impression as other statements concerning hydroelectric power. Other statements say that pro- jects within WSAs are not likely to be built even with- out wilderness designation (pages 114, 123, 130, 140, 149, 159, and 168). All statements concerning hydroelectric generation projects should be changed so that readers will get the same impression from each statement. As the Draft EIS is now written, some statements imply that hydroelectric projects may be allowed, while other statements imply they will not be allowed. The two stream diversions for hydroelectric power generation in the Deep Creek Mountains WSA should not be allowed. Page 74 and Table 3, page 70, imply that this WSA has low hydroelectric potential, and these diversions are an unnatural development in an area which is supposed to have change due only to nature. b. Hydropower does not even warrant mention in the few remote lands in which the Draft EIS suggests potential; as we know, these are desert streams in question, with barely enough water to cover their mudbars most of the year. We have gone this far with- out their development in certain places for good rea- son; they are not crucial or strategic when in-situ amid the West Desert outback. c. The EIS does not reflect the benefits of hydro- electric output associated with either a 35,000-to 40,000-acre-foot reservoir, or a reservoir which is used in connection with the hydroelectric facilities now in place, and others which may be constructed in connection with the Quail Creek project. The ability to coordinate releases and impoundments between two projects will greatly increase the efficiency, output, and profitability of the Quail Creek hydroelectric pro- ject. d. The Draft EIS inadequately addresses hydroelec- tric development potential in the WSAs included in the alternatives. A study entitled Resource Survey of Hv- droelectrical Power Potential in Utah and Southeast Idaho, by Calvin G. Clyde, Eugene K. Israelsen, and Win-Kai Lin, prepared by the Utah Water Research Laboratory, identifies potential hydroelectric sites in or adjacent to WSAs 19, 24, 25, 29, 31, 38, 41, 63, 64, 66, and 73. Utah Power and Light has not in- vestigated each site and independently determined its hydroelectric potential; however, Dr. Clyde did appear as an expert witness for a Utah State agency before the Utah Public Service Commission in the Co- generation Hearings in 1985. Utah Power and Light strongly recommends that the Final EIS review Dr. Clyde's study in relationship to hydroelectric poten- tial in the proposed wilderness areas. 14.27 RESPONSE: Additional information on hydro- electric power has been included in the Final EIS in the Energy and Mineral sections. The potential for devel- opment of hydropower in the WSAs is projected. BLM does not anticipate any major hydroelectric projects in WSAs in the foreseeable future (see Appendix 6). Also, see the responses to General Comments 9.4 and 9.12 that deal with development and disturbance assumptions. 14 GENERAL COMMENTS AND RESPONSES - SECTION 15 MINERALS INDEX 15.1 Energy and mineral resources were not fully con- sidered in the EIS. BLM relied too heavily on outdated and inadequate information for its mineral resource analysis, (p. 3) 15.2 The energy companies rated many of the WSAs higher for oil and gas potential than SAI. (p. 5) 15.3 The SAI oil and gas ratings for Behind the Rocks, Negro Bill Canyon, and Mill Creek Canyon are too high. (p. 5) 15.4 The information used (mostly from SAI) is not always clearly explained and interpreted in the EIS. (P- 6) 15.5 The SAI date used in the EIS are insufficient and often incorrect. No field work was done by SAI. (p. 6) 15.6 The SAI report is insufficient for predicting lost energy and mineral resource development opportuni- ties. (p. 7) 15.7 SAI's "overall importance rating" is misleading. (P- 7) 15.8 There is confusion in the EIS regarding the differ- ence between favorability and certainty, (p. 7) 15.9 There are major problems with the favorability ratings, (p. 7) 15.10 Favorability should be a resource per acre bas- is and should identify zones within each WSA. (p. 8) 15.11 The rankings for energy and mineral potential are based strictly on quantity and not on the likeli- hood for development, which is more important, (p. 8) 15.12 The EIS underestimates Utah's mineral poten- tial. (p. 8) 15.13 The EIS should point out that virtually nothing is known about the mineral and energy potential of the nearly 300 million acres of public lands already with- drawn from multiple use. (p. 8) 15.14 Important roadless areas may have been elimi- nated from consideration from wilderness based on inaccurate mining claim information, (p. 9) 15.15 A more thorough discussion of the potential for several minerals is needed, including sediment hosted disseminated gold deposits, carbonaceous limestone, dolomite, mercury, arsenic, antimony, tungsten, molybdenum, etc. (p. 9) 15.16 Potential mineral production from the WSAs should be compared to State and national production levels, (p. 9) 15.17 Different authorities provide varying esti- mates on mineral potential in the different WSAs. (p. 10) 15.18 BLM lacks the date and expertise to make a can- did and unbiased appraisal of the resource potential for mineral and energy resources in the WSAs. (p. 10) 15.19 How will BLM check the accuracy of the "pro- prietary information" of the oil and gas companies? (P- 11) 15.20 Mineral resource analysis is inadequate be- cause it does not apply a gross economics or feasibil- ity of economic development factor to the SAI ratings, (p. 11) 15.21 The EIS should show that the mining industry has been leaving the State not because of wilderness but because of labor costs and because the mining in- dustry has made itself economically uncompetitive. (P- 11) 15.22 Mineral deposits, their value (including reve- nues), and the costs associated with failure to devel- op deposits located in the WSAs are inadequately addressed in the Draft EIS. (p. 11) 15.23 It should be made clear in the EIS that land use plans do not close lands to mineral entry. This can only be done by withdrawal, (p. 12) 15.24 Approximately 48 percent of the Federal land in Utah is already closed to mineral exploration. 1 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES Closing more land would preclude new discoveries, (p. 12) 15.25 The Final EIS should include leasing maps. (p. 12) 15.26 Does the acreage-disturbed figures include roads needed for access or do they just cover the mining sites? (p. 13) 15.27 How can larger amounts of disturbed acreage be shown for nonwilderness than for wilderness areas? (p. 13) 15.28 No uranium mine can show a valid discovery because of the depressed price of uranium at this time. Therefore, uranium mining claims can be de- clared null and void. (p. 13) 15.29 BLM has refused to provide current informa- tion regarding the number of valid claims in WSAs. (p. 13) 15.30 BLM should enforce Section 314 of FLPMA and eliminate the thousands of stale claims in WSAs. (p. 13) 15.31 Page 177 of the Draft EIS should note that de- velopment could occur on claims discovered on or before wilderness designation, (p. 14) 15.32 The EIS should address the important issues of mineral potential and possessory real property inter- ests in WSAs rather than the presence of speculative mining claims. The presence of speculative mining claims should not preclude wilderness designation, (p. 14) 15.33 BLM, in making its uranium resource appraisal, failed to utilize the definition of potential uranium re- sources used by NURE and SAI. (p. 14) / 15.34 There is no potential uranium resource in any of the WSAs. (p. 14) 15.35 Recognizing that the EIS must portray a "worst- case" scenario, it must also provide a realistic view of resource potential, (p. 15) 15.37 The methodology for oil and gas analysis is faulty and there are very few oil and gas discoveries to support conclusions reached in the EIS. (p. 16) 15.38 The EIS confuses potential or hypothetical re- sources with proven resources, (p. 16) 15.39 Oil and gas companies are not environmentally responsive and unobtrusive, (p. 16) 15.40 Tar sand resources have been vastly over esti- mated, especially in the Tar Sand Triangle, (p. 17) 15.41 The evidence is overwhelming that tar sand de- posits will not be developed in the foreseeable future. (P- 17) 15.42 Pertinent tar sand publications were not used in the EIS. BLM should not make any wilderness recom- mendations until a better review and study by a reput- able company is made. (p. 18) 15.43 The coal contained in BLM WSAs will (or will not) be needed, (p. 18) 15.44 A much more comprehensive analysis is needed to determine which coal deposits would be most likely to be mined in the foreseeable future, (p. 19) 15.45 Nowhere in the EIS is the confusion over prov- en reserves and potential resources more severe than in the coal analysis, (p. 19) 15.46 Valuation of coal deposits in the Kaiparowits coal field should be based on the willingness of the lessees to continue to make rental payments, (p. 20) 15.47 The All Wilderness Alternative will so encum- ber coal mining that no coal can be developed on the Kaiparowits Plateau, (p. 20) 15.48 Mining coal in the Kaiparowits coal field would require longwall methods that would result in lower overall recovery rates, (p. 20) 15.49 Despite a favorable geologic rating, an econom- ic analysis would suggest that no significant potash resources are present in the WSAs. (p. 21) 15.36 BLM has omitted any discussion of the automat- ic contraction provisions that are part of unit agree- ments. (p. 15) 2 15.50 It is impossible to compare proven reserves with hypothetical/speculative reserves as was done in Volume I. (p. 21) GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES 15.51 Saleable minerals are ignored in Volume I. (p. 21) 15.52 Certain statements indicate that industry has special influence with BLM in rating the WSAs. (p. 21) 15.53 Data used to estimate the amount of minerals foregone are incomplete and does not consider the potential of large acreages that have yet to be ade- quately explored, (p. 22) 15.54 BLM estimates of mineral quantities, poten- tials, and the probability of development of minerals in the WSAs are too high. (p. 23) 15.55 Wilderness designation would not permanently lock up mineral resources, (p. 24) 15.56 The EIS should recognize that the long-term future of the nation's mineral and petroleum industry is directly linked to public land access, (p. 24) 15.57 Wilderness lands in Utah are unique, which is not the case with mineral and energy resources, (p. 25) 15.58 Energy development and wilderness are (or are not) compatible, (p. 25) 15.59 The EIS should report that wilderness designa- tion will lock up major known belts of mineralization in Utah. (p. 25) 15.60 The EIS should quantify the amount of energy being foregone in more understandable numbers, such as decatherms. (p. 26) 15.61 Man's imprints do not last forever. They are removed by reclamation and by nature over time. (p. 26) 15.62 The EIS used outdated 1982 leasing informa- tion. The Final EIS should use more updated informa- tion. (p. 27) 15.63 A national energy policy should be established in order to make decisions on domestic exploration and development, (p. 27) 15.64 Areas should not be recommended as unsuitable because of resource conflicts that are low in favora- bility with a high degree of certainty, (p. 27) 15.65 Conclusions regarding mineral potential on the part of BLM prior to USGS field work is unsupported and should be rescinded, (p. 27) COMMENTS AND RESPONSES 15.1 COMMENT: Energy and mineral resources were not fully considered in the EIS. BLM relied too heavily on outdated and inadequate information for its mineral resource analysis. [Consolidated Coal Com- pany, Exxon Corporation, Utah Mining Association] a. The mineral inventory section relies solely on information supplied by SAI. The EIS does not reflect the most current state-of-the-art energy and mineral information. BLM has not used or has ignored specific information supplied by energy companies. b. Our primary concern with the EIS is the fact that BLM continues to use SAI's reports as the basic reference on mineral and energy potential in its EIS, even though it acknowledges that SAI's dual system is subjective and that estimates of mineral quantities and importance could change with new data, econom- ic conditions, or refinements in extraction technol- ogy (p. 67 of the Overview). Further, BLM makes it clear that it has received specific geological informa- tion from oil and gas companies and that this informa- tion indicates the mineral potential of wilderness study areas to be greater than those reported by SAI. What is not clear is how BLM has used company pro- vided information which it solicited during the EIS scoping period and upon the completion of the site- specific analyses. We believe the Final EIS should clearly indicate how company information was used to make boundary or other adjustments. c. Mineral deposits, their value, and the costs associated with failure to develop these deposits are inadequately addressed by the Draft EIS. Such defi- cient treatment leaves the reader with the incorrect impression that there is negligible or valueless ener- gy or mineral deposits lying within the boundaries of the WSAs. By BLM's own admission, the information relied upon in judging the mineral and energy re- sources (leasable and locatable) was limited. The Draft EIS has apparently ignored all energy and miner- al data provided to BLM by industry members over the last several years. Therefore, the "overall im- portance rating system" developed by BLM is fatally reliant upon inadequate data as to the amount of 3 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES deposits located within the WSAs and the economic benefits that would be gained from careful and thor- ough removal of those deposits. The overall impor- tance rating system applies artificially low values to the minerals and, therefore, disguises the real costs of leaving those deposits undeveloped. This system also overrates the economic and environmental diffi- culties associated with development of the resources. d. In reviewing the Draft EIS, it appears that the SAI report is insufficient for predicting lost energy and mineral resource development opportunities. In- dustry reports predicting a moderate to high poten- tial for commercial oil and gas discoveries must be considered. A more detailed assessment of these values should be included in the Draft EIS. e. Similarly, recent drilling activity has resulted in new field discoveries adjacent to some of the wil- derness study areas, but no mention is made of their significance in the EIS. As an example, Gulf's #1 Norris Federal (sec. 8, T. 18 S., R. 16 E.,) and #1 Range Creek Federal (sec. 6, T. 18 S., R. 16 E.,) wells, both new field discoveries, were reported in August 1984 and January 1983, respectively. Both discoveries are left out of the analysis for the Deso- lation Canyon wilderness study area. The two wells are proximal to the boundary of the study area and both reservoir and source rocks are known to under- lie the entire 289,650 acres which comprise Desola- tion Canyon. What is even more disturbing in this par- ticular example is that BLM has available to it, from its own files, the necessary information with which to update SAI's mineral reports. This information in- cludes well completion reports, sundry notices, and monthly production reports (BLM forms 3160-4, 3160-5, and 3160-6 respectively). Further, BLM has on its "Known Geological Structures" staff, an exten- sive body of relevant information and geological ex- pertise which should have been used to update the SAI reports. By doing so, BLM would have improved the accuracy of the resource assessments, and ultimate- ly, the usefulness of the document. f. The mineral evaluation reports prepared by Science Applications, Inc. (SAI) were compiled and submitted to BLM in 1982. The evaluations were based largely on outdated publications and other infor- mation. On July 30, 1982, BLM published a notice in the Federal Register requesting that the petroleum and mineral industries complete mineral evaluation forms for the wilderness study areas under considera- tion. It as our hope that new industry data would be utilized in the decisionmaking process. However, BLM has admittedly not utilized the mineral information supplied by these industries. The Draft EIS states, "At this time, BLM has not made an independent assessment of all information gathered by oil and gas companies and some of the data are proprietary." We are unsure as to the reason for this delay. If BLM has had trouble understanding the data or additional in- formation was required, those companies which sup- plied the data should have been contacted prior to the completion of the Draft EIS. It is our opinion that the mineral information supplied by SAI is outdated and that BLM's mineral evaluations are therefore lower than they should be. The energy resource potential which will be foregone due to the Proposed Action is likely to be more than the 50 percent BLM has indi- cated. Nevertheless, BLM has this one last opportu- nity to review and evaluate the data which has been submitted, along with new additional data which may be submitted during the comment period on the Draft EIS. 15.1 RESPONSE: BLM did rely heavily on the infor- mation supplied by Science Applications, Inc. (SAI) during preparation of the Draft EIS. BLM specifically contracted with SAI to supply the needed mineral in- formation as an independent information source. The information supplied by SAI was, in most cases, found to be consistent with other available data. How- ever, SAI was not the only source of information used. As stated on page 65 of the Draft EIS, "Several government publications were also used for reference material. Where other specific information is readily available, it is presented in the individual WSA analy- ses and supplements the SAI information." In many cases, this is data supplied by energy companies as well as other sources. Further, on page 67 of the Draft EIS, it states, "Although the SAI (1982) report is used as the basic reference on mineral and energy potential for this Environmental Impact Statement (EIS), information provided by the oil and gas industry will continue to be reviewed by BLM prior to making final wilderness recommendations to the Secretary of the Interior. Also, the mineral resources of WSAs recommended as suitable will be studied by the USGS and USBM in independent mineral investigation reports. Reports will be made available to the public and will be submit- ted to the President and Congress as required by the FLPMA. BLM and the Secretary of the Interior will also consider these reports prior to making final wilderness recommendations." 4 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES Regarding the comment that BLM has ignored in- formation submitted by energy companies, it should be noted that much of the information submitted by industry for the Draft EIS is general in nature and consists of undocumented ratings of the oil and gas potential of the WSAs as high, moderate, and low. This information is not quantified and cannot be docu- mented for reference in the Final EIS. Oil and gas com- panies have been invited to provide specific informa- tion to BLM for use in both the Draft and Final EIS. Many companies have declined to provide specific in- formation due to its proprietary nature. Where specif- ic information was provided, it has been utilized in the analysis of mineral and energy resource potential of the WSAs. Because substantial concern was raised concern- ing the mineral and energy resources portion of the Draft EIS, a team of BLM geologists carefully review- ed all available data and made the necessary revi- sions for the Final EIS. Copies of the individual re- ports prepared by the team are available for review at the Utah State Office. As a result of these efforts, BLM believes that the most recent and comprehensive information is used in this Final EIS and that energy and mineral resources have been fully considered. Also see the response to General Comment 8.25 for a discussion on the use of proprietary data in the EIS. 15.2 COMMENT: The energy companies rated many of the WSAs higher for oil and gas potential than SAI. [Marathon Oil] 15.2 RESPONSE: As stated in response to General Comment 15.1, the geologic team reviewed all sour- ces of data including the information provided by ener- gy companies. This review resulted in changes in the ratings of certain of the WSAs. BLM feels that the ratings shown in the Final EIS represent an objective assessment of the mineral and energy potential of the WSAs based on available information. 15.3 COMMENT: The SAI oil and gas ratings for Be- hind the Rocks, Negro Bill Canyon, and Mill Creek Can- yon are too high. [Utah Wilderness Coalition, Roy Young] a. We examined drilling records in the vicinity of three representative WSAs to determine whether the SAI ratings themselves were reasonable. The utter lack of significant discoveries strongly suggests that the favorability ratings for these areas are too high, and hence are suspect for other areas as well. Our assessment focused on the Negro Bill Canyon, Mill Creek, and Behind the Rocks WSAs near Moab. The EIS states that, "the potential for oil and gas with- in the [Behind the Rocks] WSA is believed to be moder- ate (f3) for Mississippian-aged rocks and lower for Pennsylvanian-aged rocks." (Volume 5, Behind the Rocks analysis, page 11; similar statements are made for Mill Creek and Negro Bill). The Draft EIS further states that the best potential is in Missis- sippian-aged strata. This potential is based partially on the structural similarity of the WSAs to the Lisbon Valley area and partially on the proximity of past pro- ducing reservoirs in the Big Flat area. However, the Big Flat field was rapidly depleted and most authors agree that the Lisbon field is one of a kind; generali- zations from these fields are not appropriate. Over 70 wells have been drilled between and around the three WSAs within a radius of about 15 miles of the center of the three areas (see figure). Nearly half of the wells (35) tested Mississippian or older strata. Nine wells produced some oil, but only two are produc- ing today. None of the 70+ wells had significant shows in or produced from Mississippian-aged rock. The nearest wells with good shows or production are all 5 miles or more west or southwest of the Behind the Rocks WSA. Each of these wells produced from or had shows in Pennsylvanian-aged strata. The three WSAs were rated f3 based on the poten- tial of the Mississippian limestones; however, none of the 70+ wells had shows, much less production, from the Mississippian. Therefore, based on actual drilling, the ratings appear to be high for these WSAs. To the extent that other WSAs are subject to similar discre- pancies between the SAI ratings and actual drilling records, they should be revised as well. b. Negro Bill is assigned an "Overall Importance Rating" of 3 by SAI. This is based upon ratings for uranium (f3/c2), oil and gas (f3/c2), and potash ( f 3/c 3 ) . No historic production has ever come from Negro Bill for any of these three resources. The OIR rating of 3 assigned by SAI to Negro Bill should be adjusted downward for all three "resources" based on the pro- blems of access, steep topography, depth to potential deposits, current and likely future market conditions, and the existence of other more abundant, higher qual- ity resources elsewhere. With 1 1 existing leases, no oil and gas has ever been shown or produced from the WSA. SAI's analysis is admittedly highly speculative and based upon the extrapolation of trends, not field 5 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES work. Given the costs of exploration and the exis- tence of much more promising localities, it is unlikely that oil and gas development will ever occur. The pot- ash deposits below 7,000 feet will never be develop- ed with high-grade near surface deposits elsewhere. Uranium shows only slight favorability at depth and does not exist as a potential resource in any event. A copy is attached of a BLM action sheet which lists the major reason Negro Bill and Mill Creek Can- yon have been dropped from the "tentative Proposed Action" is "mineral potential." The sole basis for this appears to be the SAI OIR rating. This conclusion on the part of BLM prior to U.S. Geological Survey field work is unsupported and should be rescinded. The SAI conclusion is based upon a cursory literature search and is unsupported by any real geologic data. In any case, the Geological Survey, not BLM, is the agency with the competence to make this decision. 15.3 RESPONSE: The oil and gas ratings for the WSAs mentioned above have been reviewed. Based on available information and judgment of the team of geologists described in Response 15.1, only one minor change was made. The favorability and certainty rat- ing for Behind the Rocks WSA was changed from f3/ c2 to f3/c3. The other oil and gas ratings remained the same (f2/c2) as described in the Draft EIS. Based on all of the available data, Behind the Rocks WSA has moderate oil and gas potential, while Mill Creek and Negro Bill have low potential. All three WSAs are in- cluded in the Proposed Action Alternative. 15.4 COMMENT: The information used (mostly from SAI) is not always clearly explained and inter- preted in the EIS. [Utah Wilderness Association and Utah Wilderness Coalition] For example, the quantity estimates are based on geology within an area and what that geology can be expected to produce. These estimates are not based on the size of the WSA. It is not logical to assume that a 5,000-acre WSA will have the same quantity of re- source as a 50,000-acre WSA with the same mineral potential rating. 15.4 RESPONSE: The review made by the BLM team of geologists has clarified the quantity esti- mates made in the Draft EIS for many of the WSAs. However, it should be noted that more data are avail- able in some areas than in others. In some cases, esti- mates based on geology alone were necessary due to scarcity of data. The results were approximate fig- ures identified by wide ranges (e.g., 10 to 50 million barrels of oil). 15.5 COMMENT: The SAI data used in the EIS are insufficient and often incorrect. No field work was done by SAI. [Exxon Corporation] In our last area of concern, Exxon believes that the geologic favorability and certainty criteria, as used by SAI for assessing subsurface resources be- neath wilderness study areas, is inappropriate. Our reviews of Appendix 5 of the EIS and the fourty-ninth annual report by the Committee on Statistics of Drill- ing (American Association of Petroleum Geologists Bulletin V. 69, No. 10, p. 1455-1484) indicate ques- tionable linkage between the use of drilling statistics and BLM’s evaluation of undiscovered mineral re- sources beneath unexplored wilderness study lands. It is our understanding that the purpose of the commit- tee's report is to present basic statistical data on the number of wells and their footage drilled in the United States, Canada, and Mexico, and incorporates rec- ords from onshore and offshore exploration and devel- opment wells. It also presents a section on reserve size estimates for new oil and gas discoveries. It is this section which was modified by SAI in order to extrapolate "sizes" of hydrocarbon pools beneath wilderness candidate lands (page 326 of the Over- view). We believe SAI's modification and use of new field reserve figures to predict undiscovered oil and gas under study lands is erroneous because the reserve size estimates are based on actual discoveries of com- mercial deposits and on the amount and specificity of technical information derived from discovery wells. In contrast, SAI's modification and use of the statis- tical data is risky because they are used for "barrels of oil" implications for land which is relatively unex- plored. For example, the favorability or "f" rating as used by SAI does not reflect true geologic favorabil- ity in terms of source rocks, reservoir rock, or structural and stratigraphic relationship, but is used to establish thresholds of barrels of oil. Further, SAI's certainty or "c" rating does not identify the accuracy or reliability of the data used to determine the favorability rating. 15.5 RESPONSE: BLM reserved the right to modify SAI material when it was deemed appropriate (see the response to General Comment 15.1). Also, the SAI material was supplemented with additional infor- mation provided by the geologist team for the Final 6 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES EIS. Field work is being done by Geological Survey and Bureau of Mines personnel as part of their report pre- paration which will be submitted to the President and Congress as part of the wilderness package. No specific data were given concerning SAI's mis- application of the fourty-ninth annual report by the Committee on Statistics of Drilling. Therefore, BLM is not able to directly respond to this comment and can only assume that SAI correctly applied the infor- mation given in the report. 15.6 COMMENT: The SAI report is insufficient for predicting lost energy and mineral resource develop- ment opportunities. [Consolidated Coal Company] 15.6 RESPONSE: The SAI report has been supple- mented regarding the potential loss of energy and mineral resources. BLM has projected what energy and mineral resources would be foregone if wilder- ness designation were to occur. This projection is both by alternative and individual WSA and is based on the best available data. Development scenarios are provided in the Final EIS for analysis purposes. Assumptions for these scenarios are provided in the Description of Alternatives and in Appendix 6. It is recognized that opinions vary on this subject. 15.7 COMMENT: SAI's "overall importance rating" is misleading. [Exxon Corporation] SAI's "overall importance rating" is misleading because it combines individual mineral resource eval- uations with the locations of proposed energy corri- dors and gross economics. Minerals should be evaluat- ed on its own merits without regard to rights-of-way or economics because these factors are unpredic- table. 15.7 RESPONSE: BLM agrees that the "overall im- portance rating" is misleading and has deleted its use from the Final EIS. The favorability and certainty rat- ings are sufficient to evaluate each energy and miner- al resource on its own merit. Mineral development scenarios are based on location, transportation, gross economics, size and grade of deposits, type of development, etc. (see Appendix 6). 15.8 COMMENT: There is confusion in the EIS re- garding the difference between favorability and cer- tainty. [Art Voelker] 15.8 RESPONSE: The text for the Final EIS has been clarified to eliminate the confusion in the discus- sions of favorability and certainty. Footnotes are pro- vided for the Chapter 3 tables entitled Mineral and En- ergy Resource Rating Summary, which discuss the favorability and certainty ratings given in the table. 15.9 COMMENT: There are major problems with the favorability ratings. [Utah Wilderness Associa- tion] a. There is also a problem with the favorability ratings, i.e., how high is "high" or f4. An example of this problem can be found in the analysis for the Deep Creek Mountains WSA. The Deeps are given a favora- bility rating for gold of f4, the highest rating possi- ble. What rating would be given to the world's largest gold mine? An f4, of course, the same as the Deep Creek Mountains! Desolation Canyon rates an f4 for hydropower. What would the Columbia River score? An f4, same as Desolation Canyon! Are some of Utah’s WSAs really as "favorable" for all oil and gas as Oklahoma and Texas oil fields? This might seem a bit facetious, but again, the point is the analysis is giving the mineral and energy potential of WSAs un- due significance. We recognize that placing all resour- ces in one of only four possible rankings will result in some gross disparities. But it simply points out the need for the EIS to do a much better job in identifying the real significance of these WSAs to development locally, and in the State and nation as a whole. If the EIS cannot do this, the minerals analysis is useless. This is a critical shortcoming in the Draft EIS because mineral potential has been the deciding factor for many WSAs. b. Page 67 "favorability" - although used very often, even by USGS, this term does not exist in ei- ther the Webster Ninth New Collegiate Dictionary, or in the Glossary of Geology (Second Edition, 1980), or in the Dictionary of Mining, Mineral, and Related Terms (1968). 15.9 RESPONSE: See General Comment Response 2.20. The Final EIS text has been clarified to elimi- nate the confusion in the discussion of favorability and certainty. The favorability ratings are only de- signed to be an indicator of the geologic favorability of occurrence of a certain mineral or energy re- source. An estimate of the range of potential quanti- ty of minerals is also provided. The Volume I analy- sis provides comparisons and perspective on the 7 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES local, regional, and national importance of the mineral deposits in the WSAs. 15.10 COMMENT: Favorability should be on a re- source per acre basis and should identify zones within each WSA. [John Veranth] The EIS assumes uniform potential which gives artificially high resource favorabilities to large WSAs and artificially low oil and gas favorability to other WSAs. 15.10 RESPONSE: See the response to General Comment 15.4. In those areas where sufficient data exists, specific areas within individual WSAs have been identified as having high potential for certain minerals (e.g., coal, certain hard rock minerals). In other WSAs, sufficient data does not exist to make determinations on specific areas within an individual WSA and the broader assumptions (uniform potential) must be used (e.g., oil and gas). 15.11 COMMENT: The rankings for energy and min- eral potential are based strictly on quantity and not on the likelihood for development, which is more im- portant. This process is biased against large WSAs. [Utah Wilderness Association, et al.] The concern with the rankings is they are based strictly on quantity and not the likelihood for develop- ment, which is far more important. This process is severely biased against large wilderness areas. For example, if a 300,000-acre WSA contains an estima- ted 12 million barrels of oil, and a 5,000-acre WSA contains an estimated 8 million barrels of oil, the 300,000-acre unit receives a higher "f" rating (f3 versus f2 for the smaller area). However, which one is more favorable for development? The larger area which might require hundreds of wells and a 1,000 miles of pipeline to extract the resource, or the small area which could extract nearly as much with a few wells and a few miles of pipeline? Obviously, the "fav- orability" rating is generally unimportant in determi- ning the viability of areas for development. 15.11 RESPONSE: See the responses to General Comments 9.4, 9.10, 15.7, and 15.20. The Final EIS has been revised to address the likelihood of develop- ment of the major resources found in the WSAs. This information is presented in both Volume I and in the individual WSA analyses. These discussions are based on the best information available to BLM (see Append- ix 6 in Volume I). 15.12 COMMENT: The EIS underestimates Utah's mineral potential. [Chevron Resources Company, John Fercik, et al.] Any sign of mineral or energy resource should be left open for possible marketing. Public lands should not be closed or restricted from resource develop- ment. 15.12 RESPONSE: See the responses to General Comments 8.16, 8.17, 15.1, and 15.2. BLM believes that based on the available information and judgment of experts in the field, that the energy and mineral resource potentials in Utah are adequately described in the Final EIS. BLM further believes that energy and mineral development is a legitimate use of the public lands. BLM is reviewing potential wilderness in the State of Utah per the Wilderness Act (Eighty-Eighth Congress of the U.S., 1964) and the Federal Land Poli- cy and Management Act (Public Law 94-579, ninety- fourth Congress). In certain instances, it is the judg- ment of BLM that wilderness values outweigh the po- tential energy and mineral value of a specific area and that the area is suitable for wilderness designa- tion. 15.13 COMMENT: The EIS should point out that vir- tually nothing is known about the mineral and energy potential of the nearly 300 million acres of public lands already withdrawn from multiple use. [Chevron Resources Company, et al.] Current land use policies pose a significant pro- blem for the petroleum industry. Governments at all levels are active in restricting access to land and im- posing stringent permanent procedures for accessible lands. Virtually nothing is known about the mineral and oil and gas potential of the nearly 300 million acres of public lands already withdrawn from multi- ple use. Withdrawal of these areas prohibits geophysi- cal and geological surveys and exploratory drilling. These withdrawals limit domestic petroleum and natu- ral gas availability. The loss of future domestic pro- duction will increase the nation's reliance on imports and its vulnerability to disruptions in foreign sup- plies. 15.13 RESPONSE: See the response to General Comment 15.12. When Congress sets an area aside such as a national park or a wilderness area, it has been determined that natural values outweigh poten- tial energy and mineral values. However, it should be understood that the majority of public land in Utah 8 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES administered by BLM is open to some form of energy and mineral development. In general, of the approxi- mately 22 million acres of public land in Utah, about 17 million are available for some sort of mineral leasing or mining claim location. 15.14 COMMENT: Important roadless areas may have been eliminated from consideration from wilder- ness based on inaccurate mining claim information. [Michael Skolnick, et al.] a. Important roadless areas may have been elimi- nated from consideration for wilderness designation based on supposed mineral potential and inaccurate information about unpatented claims. The Utah State Legislature has passed a resolution urging BLM not to designate any wilderness land, citing untapped miner- al potential in WSAs and economic considerations by way of rationale. This is an area that deserves prob- ing investigation. I suggest the best source of accur- ate information regarding mineral potential may be obtained from past production records and a tabula- tion of claims in any given area which were profitable enough to receive a patent. Past production can be accurately assessed through consultation with the Utah State Tax Commission. Patented claim informa- tion is already on file with BLM. b. The use of what appears to be highly specula- tive mineral values is questionable. Mineral values, seemingly found within the wilderness study areas, if projected throughout the State, would certainly make Utah a very rich mineral State, far beyond what it is in real life. The recommendation formed in the Draft EIS often uses the presence of mineral leases to dis- qualify the area, when in fact, there are little or no mineral values present, only the existence of a min- eral lease. 15.14 RESPONSE: See the responses to General Comments 9.6, 15.1, and 15.2. During the original wilderness inventories, energy and mineral potential and mining claims were not a consideration in evalu- ating roadless areas. Many WSAs have mining claims and mineral leases or otherwise have energy and min- eral potential. BLM recognizes that energy and miner- al data are scarce in many areas. However, BLM be- lieves that the information used in the Final EIS for mining claims and energy and mineral potential is as accurate as possible. 15.15 COMMENT: A more thorough discussion of the potential for several minerals is needed, including sediment hosted disseminated gold deposits, carbon- aceous limestone, dolomite, mercury, arsenic, anti- mony, tungsten; molybdenum, etc. [State of Utah, et al.] BLM should have included a more thorough discus- sion of the potential for sediment hosted, disseminat- ed gold deposits in the WSAs. Information on favor- able stratigraphic units (impure, carbonaceous lime- stone and dolomite), presence of positive geochemical indicators (mercury, arsenic, antimony, barium, tung- sten, and molybdenum), evidence of paleo hot springs type of alteration, and presence of favorable struc- tures (brecciation, faulting, etc.) should all be discus- sed. 15.15 RESPONSE: See the response to General Comment 15.1. The emphasis of the Final EIS is on those energy and mineral resources expected to be found in larger quantities in the WSAs or those which may be significantly impacted by wilderness desig- nation. Many of the minerals mentioned by the corn- mentor are specifically discussed in the Final EIS. 15.16 COMMENT: Potential mineral production from the WSAs should be compared to State and na- tional production levels. [Roger Jenkins, Utah Wilder- ness Coalition, et al.] a. The Draft EIS fails to provide any broad per- spective on mineral and energy resources, thereby precluding assessment by the general public of the relative importance of these areas. For example, while BLM has relied on the Science Applications, Inc./Oak Ridge National Laboratory reports on prob- able levels of resources in the wilderness areas, no mention is made as to how these areas compare with those managed by BLM outside the WSAs in the State of Utah, or across the country. If that informa-tion is available, it is a mistake not to include it in the Final EIS. If that assessment has not been made, how could BLM have possibly reached a decision to recommend nonwilderness using a mineral or energy resource argument? If all the WSAs were declared wilderness by Congress and resources were distributed evenly across wilderness and nonwilderness areas, more than 85 percent of all of the BLM managed resources would be available for extraction. The roadless areas remaining in the State of Utah are in that condition for good reason. They are remote, rugged, and con- tain few economically extractable resources. This is according to the Department of Energy's own reports. If such resources did exist in commercially viable 9 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES quantities, the WSAs would have been developed long ago, as have the uranium mining areas around Moab. b. Even those areas which were identified as hav- ing moderate or high potential for oil and gas re- serves were still proposed for wilderness designa- tion, ignoring the need for production of such re- serves for America's future energy requirements. The loss of production from these resources will effect the nation’s balance of trade, energy indepen- dence, and national security. We are not against wil- derness areas. We are against setting aside limitless acres for use by only those people who are interested in and capable of hiking or riding horseback, and, in so doing, precluding the use of these lands forever from production of much needed oil and gas reserves. Re- serves that you admit are there, reserves that we can prove are there, and even more reserves that no one knows about yet. c. During scoping, we asked how wilderness desig- nation will affect the regional land national supply for products and services? These products include miner- als, firewood, water, wildlife, grazing forage, etc. Services also include wilderness activities, ORV use, etc. The regional and national scope of this issue is not specifically stated in current issues. In the past, BLM has not considered sources or availability of products and services from outside the roadless area. BLM's EIS response to this issue (No. 462) is: Gen- erally, wilderness designation in Utah WSAs would have little, if any, effect on the current region-al and national supply for products and services. In the long term, designation of an area could limit use of certain resources and have related localized effects. Since the Draft EIS was prepared on a Statewide basis and the lands involved are Federal, the indivi- dual WSA analyses should compare all values on a Statewide and national basis. For example, the amount of extractable coal from a given WSA should be compared to the total proven and potential re- serves for Utah and the United States. Such a com- parison is the only method by which comparative worth can be obtained-and is also a critical factor in determining the likelihood of development. BLM's re- sponse is far too general. The analysis should be pre- pared for each product and each service. And, as re- gards the opportunity for wilderness-based activi- ties, the agency's response is flatly wrong: designa- tion of Utah WSAs as wilderness would have a signifi- cant impact on both the regional and the national avail- 1 0 ability (or supply) of lands dedicated to the support of such activities. We request that BLM analyze the im- pact both of designation and nondesignation upon the full range of commodity products and services and of wilderness opportunities. Furthermore, one of the benefits of wilderness designation is that it serves to preserve natural re- sources for future development. Areas should be iden- tified according to their suitability for development under current technologies. Those areas offering only marginal productivity may best be reserved for fu- ture exploration when more refined and efficient tech- nologies are developed. We recommend that BLM use relative ratios of the fraction of the resource that would be foregone with wilderness designation in the comparison table found in the front of the Draft EIS. The large numbers do not readily convey the trade- offs being made. 15.16 RESPONSE: See the responses to General Comments 2.20, 9.10, and 15.8. State and national production levels were discussed on pages 67 through 70 of the Draft EIS (see Tables 25, 26, and 28). This information has been reviewed, updated, and correct- ed where necessary and carried forward in the Final EIS. 15.17 COMMENT: Different authorities provide varying estimates on mineral potential in the differ- ent WSAs. [Exxon Corporation, et al.] 15.17 RESPONSE: See the responses to General Comments 15.13 and 15.18. There are varying esti- mates of mineral potential in the WSAs. BLM has attempted to determine which are the most correct for use in the EIS and has provided a range of values. This results in some controversy regarding mineral potential, however, BLM feels that the best available data have been used. The Final EIS recognizes that estimates provided by different experts vary. 15.18 COMMENT: BLM lacks the data and expertise to make a candid and unbiased appraisal of the re- source potential for mineral and energy resources in the WSAs. [Roy Young] 15.18 RESPONSE: See the response to General Comment 15.13. Several BLM geologists and minerals specialists have worked on the EIS. They have attempted to use all available data, including infor- mation submitted during the public comment period for the EIS, to provide the most accurate estimates GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES possible regarding mineral potential and likelihood of development. BLM is confident that the appropriate expertise and avail-able data have been used in pre- paring the Final EIS. 15.19 COMMENT: How will BLM check the accur- acy of the "proprietary information" of the oil and gas companies? [Sandra Long] In Volume II, six areas that were rated low by SAI were rated high by industry representatives in the specific issues identified in scoping. (Deep Creek Mountains, Fish Springs, Swasey Mountain, Howell Peak, Notch Peak, Wah Wah Mountains.) In the individ- ual reports, often it was pointed out the geologic favorability was poor. 15.19 RESPONSE: See the responses to General Comments 8.25 and 15.1. After meeting with oil and gas com-pany representatives and reviewing pro- prietary data, discussions were held among profes- sional BLM geologists knowledgeable about oil and gas deposits in Utah. It was determined that the site- specific proprietary information supplied by the oil and gas companies represents reasonable geologic in- terpretations of the oil and gas potential of the areas being studied. Much of the information was not new, was extremely general in nature, and had already been provided for the Draft EIS. 15.20 COMMENT: Mineral resource analysis is in- adequate because it does not apply a gross economics or feasibility of economic development factor to the SAI ratings. [Environmental Protection Agency, Utah Wilderness Coalition, et al.] a. Without consideration of feasibility of develop- ment, the impression is that minerals will be devel- oped regardless of the cost of extraction. This over estimates the importance of minerals in the WSAs. b. In order to strengthen the utility of the EIS in aiding informed decisions on the full range of options for multiple resource management in Utah, including wilderness designation, give further consideration on how to apply feasibility of mineral developments to conflicts that might exist with wilderness designation by including a factor of "gross economics" and poten- tial feasibility of resource development in the criter- ia used for the energy and mineral resource rating system. 15.20 RESPONSE: See the responses to General Comments 9.4, 9.10, and 15.11. BLM recognizes that not all energy and mineral deposits located in WSAs would be developed in the absence of wilderness des- ignation. The Final EIS contains a discussion of energy and mineral resources that BLM projects would be de- veloped in the foreseeable future based on technol- ogy, market conditions, and other economic factors. Thus gross economics and feasibility of economic de- velopment have been considered in the evaluation of energy and mineral resources in the Final EIS (see Appendix 6 in Volume I). 15.21 COMMENT: The EIS should show that the min- ing industry has been leaving the State not because of wilderness but because of labor costs and because the mining industry has made itself economically uncom- petitive. [Glen Brown] The mining industry has been leaving the State and leaving the nation as a whole. They have not left because of proposals for wilderness. Labor costs have simply made it impossible for them to operate in many instances in the country. And so they have moved their operations to foreign lands. Mining people should recognize the fact that they have made them- selves economically uncompetitive. Many countries and cities are in financial straits because of the fact that the energy companies cannot compete right now. They can't sell oil they would produce in southern Utah. They can't sell the minerals and so they have pulled out. If southern Utah wants economic indepen- dence and wants to begin to build something that is really going to last for the future, they should look to other industries and hopefully attract them by a beau- tiful environment and a very good working environ- ment. 15.21 RESPONSE: See the response to General Comment 15.20 regarding feasibility of mineral ex- traction. Economic cycles are common in the energy and mining industries. Energy and mineral resources that are actively sought after today may not be eco- nomically important in the future. On the other hand, resources thought to be relatively unimportant today, due to economics, abundance, etc., may become im- portant in the future. BLM has attempted to project which energy and mineral resources located in the WSAs would be developed in the absence of wilder- ness designation in the foreseeable future. BLM has also analyzed the effects of various levels of wil- derness designation on energy and mineral develop- ment. Current trends in economics are reflected in GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES the development assumptions as explained in Append- ix 6 in Volume I. 15.22 COMMENT: Mineral deposits, their value (in- cluding revenues), and the costs associated with fail- ure to develop deposits located in the WSAs are inad- equately addressed in the Draft EIS. [Utah Mining Association] 15.22 RESPONSE: The Final EIS discusses the var- ious effects of wilderness designation on mineral and energy resources. This includes resource develop- ment foregone (discussed in the Mineral and Energy Resources sections) and revenues not realized by Fed- eral, State, and local entities (discussed in Socioeco- nomics sections). Discussions are on both a Statewide and individual WSA basis. BLM believes that the major aspects of energy and mineral development have been analyzed in the Final EIS. 15.23 COMMENT: It should be made clear in the EIS that land use plans do not close lands to mineral en- try. This can only be done by withdrawal. [Mining Industry] Alternative 2. The second paragraph under speci- fic actions states that 333,083 acres would remain closed to mining claim location under current land use plans. Land use plans do not close land to mining claim location. Only a formal withdrawal can close lands to mineral entry. If the 333,083 acres are under cur- rent withdrawal, this should be stated. 15.23 RESPONSE: The alternative has been rewrit- ten. The Final EIS has been revised to note that lands can only be closed to mineral entry by a formal with- drawal. Land use plans do, however, provide the con- ditions under which discretionary decisions such as mineral leasing and the disposal of mineral materials are allowed. 15.24 COMMENT: Approximately 48 percent of the Federal land in Utah is already closed to mineral ex- ploration. Closing more land would preclude new dis- coveries. [Mining Industry] What are the reasons for not making it designated wilderness? Right now, approximately 48 percent of the Federal land in this State is closed to mineral ex- ploration for one reason or another. That includes Indi- an reservations, all of the military reservations. They don't allow anybody to go in there for any rea- son. There are national parks, national monuments, and everything else, where only about 60 percent is currently available for exploration. Now, what is the problem with this? Basically, while only maybe 1 per- cent or 0.50 percent would be developed for mineral use, there really isn’t any way of telling which one percent it is. The Federal government, including the USGS, has been woefully underestimating the mineral potential. It is important that as much land be opened for the mineral prospecting potential. Cutting off ano- ther 10 percent of land available to exploration is go- ing to cut off approximately 10 percent of new discov- eries; this is excluding extensions of currently known reserves. In Jarvey, Nevada, which is the only town next door to Nevada's sole wilderness area, every store owner in town and every other local person were in complete agreement that there had been no economic benefit whatsoever from having the wilderness area there. The same thing was in Salmon, Idaho. The river rafters who agree that the wilderness-the scenic river designation-actually harmed their industry be- cause they could only raft down the river a certain length. So I wish to point out that the supposed eco- nomic benefits of the wilderness area simply do not exist. 15.24 RESPONSE: See the responses to General Comments 8.16, 8.17, and 15.13. 15.25 COMMENT: The Final EIS should include leas- ing maps. [State of Utah, Utah Wilderness Associa- tion, et al.] The Final EIS should include leasing maps (pre- and post-FLPMA leases), such as was done in many of the SSAs. Mining claims, coal leases, and other perti- nent mineral information should also be shown. Maps showing the locations of mineral and energy potential should also be included for each WSA analysis (as was done in the Oregon Wilderness EIS). 15.25 RESPONSE: See the response to General Comment 26.1. The Final EIS contains a description of the acres under lease or mining claim for each WSA. Because the acreage under lease or mining claim is subject to change, it was determined that the maps would be obsolete before they could be published. Leasing data will be updated in the Wilderness Study Reports that will be submitted to the President and Congress. It was decided, therefore, not to print maps depicting leases and mining claims in the WSAs. This is public information and is available for review GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES at the BLM State Office Public Room in Salt Lake City, Utah. 15.26 COMMENT: Do the acreage-disturbed figures include roads needed for access or do they just cover the mining sites? If roads are included, then the acre- age disturbed figures are low. [George Hinde] 15.26 RESPONSE: See the response to General Comment 9.12. 15.27 COMMENT: How can larger amounts of dis- turbed acreage be shown for nonwilderness than for wilderness areas? [Washington County Water Conser- vancy District] a. Faulty logic is used when a worst-case analy- sis for disturbance on 190 acres is determined for the No Action Alternative. But the analysis for soil disturbance under the All Wilderness Alternative only assumes 20 acres will be disturbed. How can this be? Aren't the claims and leases the same on the same land under either alternative. This is a patent case of pro-wilderness bias. If worst-case analysis results in 190 acres of disturbance, shouldn't it also show the same figure under the All Wilderness Alterna- tive? In referring to Appendix 10, Vol. I, page 370, section "All Wilderness and Partial Wilderness Alter- natives, under Locatable Minerals," in trying to find out the methodology used for determining the number of acres disturbed under, "All Wilderness Alterna- tive," we read the following: "Where the location of minerals in the WSA was unknown, the disturbance estimated for the No Action Alternative was assigned to designated and nondesignated portions of the WSAs, based on relative proportions of the WSA that would be designated and nondesignated. Where the position of the locatable minerals in the WSA was known, disturbance was specifically assigned to the designated or nondesignated area." This does not clarify how only 20 acres will be disturbed in this WSA under the All Wilderness Alter- native. It doesn't clarify anything. Any reference to Appendix 10 in response to these comments will be as useless as trying to decipher some substantive mean- ing from the bureaucratic gobbledygook quoted above. 15.27 RESPONSE: See the response to General Comment 9.12. 15.28 COMMENT: No uranium mine can show a valid discovery because of the depressed price of uranium at this time. Therefore, uranium mining claims can be declared null and void. [Mr. Johnson] 15.28 RESPONSE: BLM does not determine the vali- dity of mining claims unless the claims are in conflict with another management program or until the claim- ant applies for patent. Should an area be designated wilderness, it is assumed that the validity of claims would be determined. Recent Interior Board of Land Appeals (IBLA) decisions have recognized that the val- ue of mineral commodities is cyclic in that it may be high for a period of time and then the price or value may drop. IBLA has ruled that such cyclic periods must be taken into account in validity determinations and assumptions made that the value of a given com- modity could again raise to a former high level. 15.29 COMMENT: BLM has refused to provide cur- rent information regarding the number of valid mining claims in WSAs. [Michael Skolnick] 15.29 RESPONSE: See the responses to General Comments 15.25 and 26.1. Mining claims can be locat- ed in WSAs until the date of wilderness designation. The information provided in the Final EIS is the most current and accurate information available. It should be noted that acreage figures are subject to change. Specific information regarding location of mining claims can be obtained at BLM's Public Room in Salt Lake City, Utah. BLM has provided a summary of this information in the Minerals section of the EIS. 15.30 COMMENT: BLM should enforce Section 314 of FLPMA and eliminate the thousands of stale claims in WSAs. [Michael Skolnick, et al.] a. BLM should obey Section 314 of FLPMA and eli- minate the thousands of stale claims in WSAs. Accu- rate unpatented claim figures should be made part of the public record. Eradication of stale claims would greatly reduce the total number of claims, enabling BLM to go for- ward with the important task of evaluating the legiti- macy of assessment work on claims which meet the proof/notice requirements of FLPMA. b. Recently, the Supreme Court of the United States decided United States v. Madison D. Locke. This was a lawsuit brought by BLM which sought to enforce Section 314 of FLPMA. Section 314 requires unpatented mine claimants to file an annual notice of intent to hold or proof of assessment work on their GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES claim. If the annual notice or proof is not filed by December 30, every year, the claim becomes auto- matically void. The Supreme Court upheld the consti- tutionality of Section 314 on April 1, 1985. The court's opinion states that the purpose behind Section 314, the consolidation of claim information in one cen- tral location and the automatic elimination of stale claims, was a rational and entirely sensible goal. An examination of the Draft EIS indicates that BLM has not complied with the Supreme Court’s rul- ing. Attached is an area-by-area breakdown of unpat- ented claim information provided regarding the num- ber of claimants who filed annual notice or proof in 1985. BLM’s stated policy is that validity assess- ments will be conducted on a case by case basis. De- spite the fact that all annual notice or proof forms are filed in a central location, BLM refused to provide me with current information regarding the number of valid claims in WSAs. Unsurprising, considering that BLM did not provide accurate information in the EIS. 15.30 RESPONSE: BLM does enforce Section 314 of FLPMA and issues decisions declaring claims aban- doned and void if an assessment affidavit or notice of intent to hold a claim is not filed for the previous assessment year. Records of such actions are avail- able at the BLM Utah State Office. 15.31 COMMENT: Page 177 of the Draft EIS should note that development could occur on claims disco- vered on or before wilderness designation. [Mining Interests] 15.31 RESPONSE: See the responses to General Comments 1.13 and 9.16. The first sentence on page 1 77 of the Draft EIS has been changed to read as fol- lows: "In some areas designated as wilderness, ener- gy and mineral development could occur on mining claims where a valid discovery was made on or be- fore the date of wilderness designation . . ." 15.32 COMMENT: The EIS should address the impor- tant issues of mineral potential and possessory real property interests in WSAs rather than the presence of speculative mining claims. The presence of specu- lative mining claims should not preclude wilderness designation. [Michael Skolnick] Unless BLM considers possessory real property interests irrelevant to ultimate wilderness designa- tion, it is incumbent upon BLM to provide the public and Congress with current information about those interests. In the case of unpatented mining claims, the information is readily accessible and centrally compil- ed in the State Office of BLM. 15.32 RESPONSE: See the response to General Comment 15.29. The presence of mining claims in WSAs was considered during the formulation of devel- opment scenarios. However, energy and mineral po- tential rather than the presence of mining claims was the overriding factor. 15.33 COMMENT: BLM, in making its uranium re- source appraisal, failed to utilize the definition of potential uranium resources used by NURE and SAI. BLM has not used the latest uranium information which reflects the current depressed status of the market. [Utah Wilderness Coalition] The Draft EIS should take into account the current- ly depressed market for uranium. The SAI evaluations used by BLM are based primarily on USGS studies con- ducted for the Department of Energy under the NURE and on the DOE report, "An Assessment Report on Uranium Resources in the U.S., 1980." At that time, there were considerably better prospects for uran- ium recovery in Utah at the then current price of $30/lb for uranium oxide. However, demand has fallen considerably with the apparently long-term slackening of electric demand and the problems be- setting the nuclear power industry. The current price of about $1 5/lb appears likely to remain for some time or even go lower. The Draft EIS should take into account the probable unfeasibility of uranium extrac- tion in the remote, rugged WSAs and avoid state- ments about resources foregone under wilderness des- ignation. Furthermore, costs of mining and enrich- ment have risen as higher grades of ore have been exhausted. 15.33 RESPONSE: See the responses to General Comments 9.12, 15.20, and 15.28. BLM data recog- nize the current depressed status of the mining indus- try in general, including uranium. BLM has factored the past demand, as well as the current status, and projected future demand into the Final EIS. See Appendix 6 in Volume I. 15.34 COMMENT: There is no potential uranium resource in any of the WSAs. No rationale exists for the exclusion of acreage based on unsupported specu- lation about the future of uranium. [Roy Young] 1 4 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES 15.34 RESPONSE: See the responses to General Comments 8.3, 15.20, and 15.28. As discussed in the Draft EIS, potential for uranium does occur in many of the WSAs. The Department of Energy indicates that 8 to 9 percent of our energy consumption in the year 2000 will be provided by nuclear energy (DOE, 1987). BLM believes that exploration for and develop- ment of uranium resources will continue on the public lands. The potential for uranium exploration and development in the foreseeable future is analyzed in the Final EIS. 15.35 COMMENT: Recognizing that the EIS must portray a "worst-case" scenario, it must also pro- vide a realistic view of resource potential. For exam- ple, using only the 950 million barrel number biases the study against wilderness. More realistic numbers should be used. [Utah Wilderness Association] Another indication of the inaccuracy in using the figures in the Draft EIS comes from reviewing the study conducted by Oak Ridge National Laboratory (ORNL), "Wilderness Designation of Bureau of Land Management Lands and Impacts on the Availability of Energy Resources." According to ORNL, the amount of oil and gas that can be "reasonably attributed" to the 25 million acres of WSAs throughout the West is 500 million barrels (page 7). This is 53 percent of the 950 million barrels the Draft EIS attributes to Utah WSAs alone! While the Draft EIS does question the accuracy of the 950 million-barrel figure, it is still the only number used as an indication of the mineral potential of WSAs Statewide. This gross exaggeration is made for other resources as well. The Oak Ridge study indicates the potential oil and gas resources for Utah WSAs is closer to 100 million barrels (page 43). Therefore, BLM's description of the mineral and ener- gy potential for individual WSAs is generally 10 times higher than is reasonable to assume. It should be noted that Oak Ridge estimates are described as "reasonable upper limits" (page 38). The Draft EIS must portray the "worst-case" scenario, but it must also provide a realistic view of resource potential. Using only the 950 million barrel number biases the study against wilderness. Consideration of the Oak Ridge analysis sheds new light on the resource poten- tial of individual WSAs. Those with an f2 rating for oil and gas are generally described in the Draft EIS as having potential for 3 million barrels of recoverable oil. If the Statewide total (derived from the individual WSAs) is overstated by a factor of 10, then the poten- tial for individual WSAs with an f2 rating is likely closer to 300,000 barrels. This is a significantly dif- ferent potential and further indicates the importance of WSAs for mineral and energy production. More realistic numbers should be used in BLM's analysis. 15.35 RESPONSE: Regulations now require that a "most probable" rather than a "worst-case" scenario be analyzed in EISs. BLM has re-studied the oil and gas figures used in the Draft EIS. The figures used in the Final EIS reflect the modifications resulting from these studies. 15.36 COMMENT: BLM has omitted any discussion of the automatic contraction provisions that are part of unit agreements. The EIS should give the dates of contraction for each affected unit. BLM also needs to state that a pre-FLPMA lease being held by production does not guarantee that it will be drilled or that it will expire due to lack of diligence. [Mark Pearson] In Desolation Canyon WSA, and in many other areas in the EIS, BLM has taken a somewhat devious position with respect to pre-FLPMA oil and gas leases, and particularly pre-FLPMA leases held by production within established oil and gas units. Fre- quently, the production which is holding a lease occurs on leased lands outside of the WSA, so there is no physical impact to the WSA. This is frequently the case with pre-FLPMA leases throughout the Book Cliffs WSAs. What BLM has conveniently omitted from its analysis in the EIS is any discussion of the automatic contraction provisions that are a part of every unit agreement. Unit agreements require dili- gent drilling operations by the unit operator to the tune of a new well being drilled within 90 days of com- pletion of the last well. If these provisions are not be- ing fulfilled 5 years after the effective date of the unit agreement, the unit automatically contracts to the participating areas within the unit, and the "re- leased" areas revert back to standard leases which may only be held for an additional 2 years, after which they expire if no exploration occurs. In the in- terests of fairness and full disclosure, the EIS must contain an analysis of the unit agreements which cov- er the leases held by production. In particular, if the EIS is going to be a useful information tool, it needs to give the dates of contraction for each unit. BLM also needs to state in the EIS that the simple fact of a pre- FLPMA lease being held by production does not guaran- tee that it will be drilled, or that it will never expire due to lack of diligence. Is BLM honestly enforcing its oil and gas leasing regulations with respect to diligence? 1 5 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES 15.36 RESPONSE: The automatic contraction provi- sion for the Book Cliffs and Willow Creek East units located within the WSA have already occurred. All leases partially and fully contained within the units are considered held indefinitely regardless of any development. BLM has no diligence program for pre- or post- FLPMA leases. Any lease will be held indefinitely as long as it contains at least one well capable of produc- tion in paying quantities, regardless of the actual producing status. 15.37 COMMENT: The methodology for oil and gas analysis is faulty and there are very few oil and gas discoveries to support conclusions reached in the EIS. Different methodology should be used for oil and gas and hard rock minerals. [Utah Wilderness Coalition, et al.] a. The major problem with BLM's work on this particular section of the Draft EIS is their ignorance of the fact that oil and gas are considered fugitive minerals. That is, "proven reserves" are far more difficult to ascertain without actual discoveries. As I read the Draft EIS, there are very few discoveries supporting the conclusions drawn by BLM and, on that basis, the results are conjectural. b. There also does not appear to be a significant nexus between the conclusions drawn by BLM in the Draft EIS and the data apparently collected or re- viewed in SAI. The same methodology seems to be applied to review the potential oil and gas deposits as was applied to hard minerals land other energy "re- serves." In fact, it is much more difficult to predict the extent of an oil and gas pool than the extent of a seam of coal or a stratigraphic layer of tar sand and, on that basis, a different methodology should be applied. [Utah Wilderness Coalition] 15.37 RESPONSE: See the responses to General Comments 15.1, 15.17, and 15.18. BLM feels that it has utilized the most practical methodology for oil and gas analysis in the Draft and Final EIS. This me- thodology recognizes the differences between oil and gas and hard rock minerals discoveries and their ultimate development. 15.38 COMMENT: The EIS confuses potential or hy- pothetical resources with proven reserves. The analy- sis does not take into account technological, econom- ic, and environmental constraints on oil and gas re- covery. Many oil and gas deposits will never produce. It is, therefore, not reasonable to ascribe the "loss" of such resources to wilderness designation in all cases. [Utah Wilderness Association] The Mineral and Energy Resources section of Vol- ume I is very disappointing because it fails to do what a Statewide analysis should do-give some indication of the comparative significance of the mineral and energy values in WSAs to the State and nation as a whole. An attempt is made in Volume I, but the analy- sis is one of "apples and oranges." It compares prov- en reserves for the entire State vs. hypothetical/ speculative resources for the WSAs. The numbers bear out the futility of such a comparison. The WSAs contain more than five times as much oil and gas as the rest of the State combined, including WSAs! This holds true for other resources as well. While the com- parison is absurd, it nevertheless tends to bias the analysis of WSAs' importance for minerals and ener- gy- Any accurate and fair analysis should consider proven reserves in WSAs vs. proven reserves for the State and nation as a whole, or hypothetical/ speculative reserves for the WSAs vs. hypothetical/ speculative reserves for the State and nation. This would provide a reasonable basis for comparison of the relative importance of WSAs. If such numbers cannot be obtained, then the comparison in the Draft EIS should be eliminated from the Final EIS. Then we can assume what the industry has assumed all along- that the WSAs have the least potential for develop- ment. Otherwise, they would not be the last lands remaining undeveloped. 15.38 RESPONSE: See General Comment Responses 15.1 and 15.20. The Final EIS has been corrected where necessary to clarify the differences between potential or hypothetical resources and proven re- serves. The definitions of these terms have been in- cluded in the Glossary in Volume I. Due to differences in available data, certain areas are discussed in terms of proven reserves while others (due to a lack of site-specific data) are discussed in terms of poten- tial or hypothetical resources. BLM recognizes the fact that certain energy and mineral deposits will only be developed in the long term. The Final EIS contains assumptions regarding which minerals and energy resources BLM believes would be developed in the foreseeable future. The impact analysis is based on these assumptions. The GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES loss of various resources referred to in the Final EIS describes potential mineral and energy resources that could not be developed due to wilderness designation. The probability of development of these resources in a nonwilderness situation is discussed in the EIS. 15.39 COMMENT: Oil and gas companies are not environmentally responsive and unobtrusive. They maximize profit by getting in and out of an area quickly and cheaply. [Wasatch Mountain Club] We dispute claims by oil companies and other de- velopers that sufficient regulations are in place to prevent environmental damage from their activities. This May, we hiked from the Thompson Canyon jeep trail (Floy Canyon WSA) along a road cut to a drill site identified by Tenneco Oil as Bogart Canyon Unit State Well #14-4, Sec. 14 T. 19 S., R. 20 E., Grand County, Utah. The unreclaimed road terminated at a drill site the size of a football field bulldozed into the side of a hill. Tenneco Oil entered the area circa 1980, drilled their dry well, and left. All the major equipment was removed. Left behind was the trash, now percolating to the surface through the sand. Barbed wire; cable; rubber grommets; shattered plastic; discarded clothing; oily, contaminated dirt; cans; bottles . . . ; none of this was removed when Tenneco vacated the site. This fairly typical site dis- credits testimony by oil company representatives that they are environmentally responsible and unin- trusive. Oil companies maximize profit by going in and out of an area quickly and cheaply. At the Tenneco site, they found it expedient to simply bulldoze over the trash and clear out of the area, hoping that no one would complain about the mess. We find the destruction and abandonment prac- tices of oil exploration companies intolerable. We urge BLM to adopt a policy requiring prospective developers to post bond before they are given access to public lands under interim management plans. The bond would cover the cost of site restoration and would be administered by individuals trained in envi- ronmental management. In this way, sites would be inspected and compliance with environmental regu- lations could be enforced. 15.39 RESPONSE: The drill site referred to in the comment is not on Federal land. BLM finds that the ma- jority of oil and gas companies are environmentally responsive in performing exploration and develop- ment activities. Specific rules and guidelines govern their activities on the public lands. They are also required to post a performance bond prior to any on- the-ground activities. If reclamation is not performed in a satisfactory manner, the bond is forfeited. In addition, oil and gas reform legislation passed in 1987 requires reclamation before additional leases can be issued to a company. 15.40 COMMENT: Tar sand resources have been vastly over estimated, especially in the Tar Sand Triangle. New studies by the Utah Geological and Mineral Survey show the amount of resource to be much lower than reported in the Draft EIS. [Utah Wilderness Coalition, et al.] 15.40 RESPONSE: Tar sand resource estimates have been re-evaluated and updated figures have been included in the Final EIS. BLM agrees that the re- source figures reported in the Draft EIS for the Tar Sand Triangle were over estimated and the figures have been adjusted accordingly. Based on data obtain- ed from the Utah Geological and Mineral Survey, approximately nine billion barrels of oil are located in three separate forma-tions in the Tar Sand Triangle. 15.41 COMMENT: The evidence is overwhelming that tar sand deposits will not be developed in the foreseeable future. [Utah Wilderness Coalition, et al.] Utah's wild lands overlie substantial deposits of tar sand, which could theoretically produce huge amounts of petroleum products. The evidence is over- whelming, however, that these deposits will not be worked in the foreseeable future owing to the severe economic, technological, and environmental problems unrelated to wilderness designation. Statements in the Draft EIS regarding tar sand resources foregone owing to wilderness designation should be deleted. The following background information is offered to support this comment. The only successful commercial-scale tar sand ex- traction and upgrading operations in the world is the Syncrude project in Alberta, currently operating un- der heavy subsidy from the Canadian government. The deposit contains more than 700 billion bbl of oil, of which about 70 billion bbl are recoverable by sur- face mining methods. About 125,000 bbl/day are being extracted. Utah's total tar sand resource is estimated at 28 billion bbl of oil, of which a similar percentage would be recoverable by surface mining. According to the USBM (Report under Contract SO-241129, The Pro- GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES duction of Oil from Intermountain West Tar Sand Depo- sits), "... a 100,000 barrel/day plant would be the minimum economical plant capacity from oil extrac- tion, upgrading, and refining operations." The report further states, "The magnitude of the . . . operation required to supply tar sand feed to a 100,000 barrel per day plant almost boggles the mind . . . Such a min- ing operation would be about 85 percent of the size of the mining operation of the Kennecott Copper Corpor- ation at their Bingham Canyon mine ... the largest surface mining operation in the world." The huge amounts of water required for tar sand operations are not available in Utah. According to Bu- reau of Reclamation studies done in the 1970s, Utah will have committed all but 107,000 acre-feet per year after all authorized BOR projects. Unperfected claims exist for 13,056,000 acre-feet, according to the Bureau of Mines report. Purchase of water rights as done for the IPP plant would be required, present- ing a severe economic roadblock to an already uneco- nomic venture. The Bureau of Mines report concludes, "The eco- nomics of a tar sand oil production project are specu- lative. Unless the plant operates continuously near de- sign capacity, losses will occur. Even with operations above design capacity, only a modest profit can be ex- pected." A number of companies have attempted tar sand operations in Utah, including Arizona Fuels, Fair- brim, LDK, and Bingham Mechanical and Metal Pro- ducts. All failed to be profitable. In addition to the giant Syncrude project, the list of other failed tar sand projects is significant. Shell, Canada's steam in situ project, Home Oil Company's 103,000 bbl/day venture, and the consortium pro- ject headed by Pacific Petroleum have all been termi- nated with no plans for reactivation. These projects were all based on Canadian tar sand, which is of far higher quality and quantity than the Utah deposits. If BLM believes that Utah tar sand constitutes a developable resource, then the enormous environmen- tal impacts of such an operation alone would justify a wilderness recommendation. But in fact, such an oper- ation is not now feasible, nor is it likely to be in the foreseeable future. Consequently, tar sand should not be treated in the Draft EIS as a resource that would be foregone through wilderness designation. 15.41 RESPONSE: BLM has evaluated the potential for development of the tar sand resource in the short- term future. Based on this evaluation, BLM believes that the only tar sand deposits likely to be developed in the short-term future are the Asphalt Ridge, Win- ter Ridge, and P.R. Spring deposits in the Uintah Bas- in. This is discussed in the Final EIS. The Final EIS also assumes that the Tar Sand Triangle will not be devel- oped in the short-term due to economic, transporta- tion, development, and environmental problems. How- ever, it could be developed in the long-term future. 15.42 COMMENT: Pertinent tar sand publications were not used in the EIS. BLM should not make any wil- derness recommendations until a better review and study by a reputable company is made. [Southeastern Utah Association of Local Governments] Looking at the bibliography at the end of the sec- tions of the individual WSAs, I could find no refer- ences on tar sand publications such as: 1) Major Tar Sand and Heavy Oil Deposits of the U.S. Interstate Oil Compact Commission (1934). 2) Geologic and Petroleum Resources of the Major Oil-impregnated Sandstone Deposits of Utah, Special Studies 50, Utah Geologic and Mineral Survey (1979) Jack Campbell, Howard Ritzma. 3) Surface and Shallow Oil-impregnation Rocks and Shallow Oil Fields in the U.S., U.S. Bureau of Mines monograph 12, U.S. Bureau of Mines and Inter- state Compact Commission (1965). The review of the literature on the tar sand and not listing the above references is not very profes- sional in my estimation. I strongly recommend that BLM not make any recommendation for any BLM wil- derness land to be designated prior to a better review and study of the natural resources by a reputable com- pany that will do a more professional job on the min- eral evaluations: and that all new and up-to-date in- formation be included in this study. 15.42 RESPONSE: BLM's geologist team has re- viewed all of the available data pertaining to tar sand. This updated information is reflected in the Final EIS. BLM believes that this information represents the best available and is sufficient for the needs of the EIS. The publications and documents reviewed and used by the geologist team are referenced in the Bibliography of the Final EIS. In addition, the SAI study references many documents that are not individually identified in the BLM EIS. GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES 15.43 COMMENT: The coal contained in BLM WSAs will (or will not) be needed. [Chevron Resources Com- pany, Utah Wilderness Coalition, Jack Madsen, et al.J a. The Book Cliffs and Kaiparowits areas are two of the major coal fields in the State. That coal may be needed some day especially in light to the opposition to nuclear power. b. No public lands should be closed or restricted from resource development and nonwilderness multi- ple uses in the absence of compelling national inter- est, which override the need for domestic oil and natural gas, coal, water, agricultural products, min- erals, timber, and other valuable resources. c. Virtually all of Utah's coal production (12 to 17 million metric tons [MMT] per year since 1980) has come and will continue to come from other lands not under consideration for wilderness designation. The Draft EIS should note this fact and place the coal un- derlying WSAs into a realistic perspective. For ex- ample, the impact summary in chapter 4 (Draft EIS, Volume 1, pages 129-130) should note that current levels of coal production in Utah could be maintained by mining non-WSA deposits for the indefinite future- on the order of 1,000 years. The Draft EIS should also note that the market for coal has become very soft in recent years owing to declining growth in elec- tricity consumption and other factors, and is likely to continue to decline. Even mines in the Powder River Basin of Montana and Wyoming, where coal seams are many times thicker than in Utah and unit production costs are lower, are finding it difficult to sell coal. Placing WSA coal deposits in their proper perspective will show that designation of wilderness will not mea- surably affect the availability of coal resources in Utah or in the nation. 15.43 RESPONSE: The Mineral and Energy Re- sources section of the Final EIS notes that no coal pro- duction is currently occurring in WSAs. The Final EIS also notes that at the present time, the coal market is very soft. This situation is always subject to change as has been observed in past years. BLM recognizes the importance of the Book Cliffs and Kaiparowits coal fields. In the Final EIS, projec- tions have been made for development possibilities of these areas in the foreseeable future. No development in the short term is projected for either the Book Cliffs or Kaiparowits Plateau. 15.44 COMMENT: A much more comprehensive analysis is needed to determine which coal deposits would be most likely to be mined in the foreseeable future. WSAs will probably not be affected. [Utah Wilderness Coalition] 15.44 RESPONSE: See the responses to General Comments 9.10 and 15.43. An analysis has been made on potential development of coal deposits in Utah. The results of this analysis are included in the Final EIS. Appendix 6 in Volume I summarizes the assumptions for development scenarios. No development of coal is expected in BLM WSAs in the short term due to eco- nomic and environmental conditions, as well as the availability of coal from other areas within the State. However, it is projected that Kaiparowits coal would be mined in the long-term future (beyond the year 2020). 15.45 COMMENT: Nowhere in the EIS is the confu- sion over proven reserves and potential resources more severe that in the coal analysis. [Utah Wilder- ness Coalition] Nowhere in the Draft EIS is the confusion of prov- en reserves and potential resources more severe than in the coal analysis. The Draft EIS inappropri- ately compares the two to conclude that under the All Wilderness Alternative, "up to about 60 percent of the in-place coal resource . . . could be foregone." (Draft EIS, Volume I, page 51, Table 17). This is a wild exaggeration and is seriously misleading. The Draft EIS should use a much lower figure that accur- ately represents the very low potential of Utah WSAs to produce coal in the foreseeable future. It is not clear how BLM arrived at their 60 per- cent figure. According to Table 29 (Volume I, page 69), Utah WSAs contain a total estimated in-place coal resource of about 5,400 MMT, including hypo- thetical and speculative resources. To yield a ratio of 60 percent, one must use a figure of 9,000 MMT for total Utah in-place coal resources. Such a figure is far too small. The USBM, in "Resource Base of U.S. Coals-Western States" (Circular 8693, 1975) uses a figure of 39 thousand MMT for Utah bituminous coal reserves (not resources). Using this figure yields a ratio of less than 14 percent. But even this compari- son exaggerates the significance of WSA coal re- sources. As the Draft EIS correctly points out, the 5,400 MMT of coal resources in WSAs "includes any possible resource that may be present based on geologic conditions" and hence the figure may be GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES "substantially higher than those shown for proven reserves in the entire state" (Volume I, page 69, Table 29 footnote). A meaningful comparison can only be drawn when WSA resources are compared to State- wide resources, or reserves to reserves. To com- pare WSA resources (in effect, the most generous estimate) to Statewide proven reserves (a much more limited estimate) greatly exaggerates the sig- nificance of the coal resource in WSAs. The Draft EIS should be revised to include a pro- per assessment of the significance of the coal resour- ces, using current estimates of economically recover- able proven reserves in WSAs. 15.45 RESPONSE: The discussion on coal deposits has been carefully reviewed. The discussion regard- ing proven reserves and potential resources has been revised and corrected. In most of the WSAs, the only available data on coal has been obtained from out- crops. There are little drill data within the WSAs to confirm proven reserves. 15.46 COMMENT: Valuation of coal deposits in the Kaiparowits coal field should be based on the willing- ness of the lessees to continue to make rental pay- ments. [Utah Mining Association] For example, BLM's proposed alternative includes designation of the majority of the Wahweap and Fifty Mile Mountain WSAs as wilderness. Both of these WSA's contain coal deposits on or adjacent to the Kai- parowits Plateau. By BLM's own figures, the inclusion of these WSAs would prohibit the extraction of approximately 1,147,000,000 tons of coal. Both of these areas received "f4" and "c4" ratings under BLM's overall importance rating system. To support its contention that this coal resource should remain undeveloped, the BLM suggests that development of the resource will create significant economic and envi- ronmental difficulties. The majority of these econom- ic and environmental difficulties are the direct result of BLM's current management of practically the en- tire Kaiparowits Plateau as a WSA. Valuation of these deposits should be based upon the willingness of the lessees of the 25 current coal leases within these WSAs to continue to make rental payments. Valuation should not be diminished by artificial BLM-created obstacles. 15.46 RESPONSE: It has been noted in the Final EIS that lease payments have been maintained on the ma- jority of coal leases located on the Kaiparowits Pla- teau. Whether or not they will be kept up in the future is difficult to determine. Diligent development require- ments as outlined in Section 7 of the Federal Coal Leasing Amendments Act, must also be met, or the lease will terminate. It is recognized that if the WSAs on the Kaiparowits Plateau are designated wilder- ness, that new leases would not be issued and the coal would not be developed. The BLM Proposed Action Alternative for the Final EIS does not include the Wah- weap WSA. 15.47 COMMENT: The All Wilderness Alternative will so encumber coal mining that no coal can be de- veloped on the Kaiparowits Plateau. [Utah Power and Light] In 1982, UP&L was awarded Federal coal lease U- 1362 in the northern part of the Kaiparowits coal field, which is part of the Kaiparowits Known Reco- verable Coal Resource Area (KRCRA). U-1362 con- tains post-FLPMA environmental stipulations. This lease covers more than 18,000 acres of Federal lands administered by BLM just north of the Re- sources Company leases. Utah Power and Light also leases 5,000 acres of contiguous State lands. The All Wilderness Alternative states that about 79,221 acres of existing coal leases, most in the Kai- parowits Plateau, would be phased out if diligent de- velopment criteria are not met prior to wilderness designation. The EIS also points out the major difficul- ties which will be encountered in development of the Kaiparowits coal leases. The All Wilderness Alterna- tive so encumbers mining development within the KRCRA as to almost prohibit it altogether. It is unlike- ly that the existing coal leases could be developed pri- or to wilderness designation, especially since private investment in the KRCRA has been hampered by threatened wilderness designation. Utah Power and Light and the other lessees' investments in the KRCRA leases risk loss by continued wilderness study and threat of designation. 15.47 RESPONSE: See the response to General Comment 15.46. It is true that the All Wilderness Alternative would generally prohibit coal develop- ment on the Kaiparowits Plateau. Some coal develop- ment on existing leases could occur by underground methods accessed from outside the WSAs. With the No Action/No Wilderness and Partial Wilderness Alterna- tives designed to reduce or eliminate conflicts, the Final EIS projects that coal development could occur 20 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES on portions of the Kaiparowits Plateau in the long- term future. 15.48 COMMENT: Mining coal in the Kaiparowits coal field would require longwall methods that would result in lower overall recovery rates. [Utah Wilder- ness Coalition] The Kaiparowits coal field underlies many WSAs in southern Utah and has a total of about 5.1 MMT of recoverable reserves (Keystone Coal Industry Man- ual, 1980). However, the field has not produced sub- stantial quantities of coal owing to its remoteness, lack of railroad service, and rough topography (Key- stone, 1980). Mining would most likely have to be by longwall methods in most areas of the Kaiparowits field. Over- burden thicknesses are generally too high for strip or underground mining (1,000 to 3,000 feet in the wes- tern part of the field, deeper in the east). Longwall mining would recover significantly less of the total resource. Moreover, coal quality is generally poorer than in many producing fields (ash contents of 13 per- cent and moisture contents of 18 percent are typi- cal). This would further restrict coal recoverability. 15.48 RESPONSE: The longwall mining method gen- erally results in a higher rate of recovery rather than lower. The use of this method is determined by the uniformity of the coal bed (depth, thickness, etc.). No indication has been given by industry on ex- actly what mining methods would be used in mining Kaiparowits coal. It is believed that the Kaiparowits coal is not as uniform as is the central Utah coal, therefore, longwall mining may not be feasible in por- tions of the Kaiparowits coal field if it were develop- ed. The quality of coal (high Btus, low sulfur, etc.) in the Kaiparowits coal field is very good and general-ly exceeds that of other western major coal fields with the exception of the coal in central Utah. It should also be noted that quality of coal generally does not affect recovery rates. 15.49 COMMENT: Despite a favorable geologic rat- ing, an economic analysis would suggest that no signi- ficant potash resources are present in the WSAs. Discussions and tables should be revised to note that potash resources in WSAs are unlikely to be devel- oped in the foreseeable future. [Utah Wilderness Coalition] 15.49 RESPONSE: The Final EIS has been revised to indicate that potash resources in the WSAs would not be developed in the foreseeable future. 15.50 COMMENT: It is impossible to compare prov- en reserves with hypothetical/speculative reserves as was done in Volume I. This biased the study against wilderness. [Utah Wilderness Association] The Minerals and Energy Resources section of Vol- ume I is very disappointing because it fails to do what a Statewide analysis should do-give some indication of the comparative significance of the mineral and energy values in WSAs to the State and nation as a whole. An attempt is made in Volume I, but the analy- sis is one of "apples and oranges." It compares prov- en reserves for the entire State vs. hypothetical/ speculative resources for the WSAs. The numbers bear out the futility of such a comparison. The WSAs contain more than five times as much oil and gas as the rest of the State combined, including WSAs! This holds true for other resources as well. While the com- parison is absurd, it nevertheless tends to bias the analysis of WSAs' importance for minerals and ener- gy* Any accurate and fair analysis should consider proven reserves in WSAs vs. proven reserves for the State and nation as a whole, or hypothetical/ speculative reserves for the WSAs vs. hypothetical/ speculative reserves for the State and nation. 15.50 RESPONSE: See the responses to General Comments 15.11, 15.20, 15.38, and 15.45. Volume I of the Final EIS contains information on proven re- serves, as well as hypothetical/speculative re- sources found in the United States as well as in the State of Utah. Resources suspected to occur in the WSAs generally fall in the hypothetical/speculative category because there has been little or no drilling to confirm their existence. The favorability/certain- ty rating developed by SAI further delineates and categorizes these resources. 15.51 COMMENT: Saleable minerals were ignored in Volume I. [Mining Interests and USGS] 15.51 RESPONSE: A section on saleable minerals has been added to the Affected Environment (Chapter 3) in Volume I in the Final EIS. However, it should be noted that due to the wide availability of saleable min- erals, wilderness designation is not expected to signi- ficantly conflict with saleable minerals in a Statewide 21 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES basis. This is restated in the Issue Identification sec- tion in Chapter 1 of Volume I. 15.52 COMMENT: Certain statements indicate that industry has special influence with BLM in rating the WSAs. [Art Voelker] The discussion of gold and silver resources raises yet another question concerning objectivity. The dis- cussion includes the following statement, "because of the proximity of known mines and the historic produc- tion of the mining districts in the area, BLM and indus- try representatives rate the favorability high for the WSA." The statement raises the question of the role of industry in a supposed independent assessment. Are the environmental groups correct in charging that industry has special influence within BLM? State- ments like the one above do little to relieve the natu- ral fears of the environmentalists. Unless it is clear what industry contributed, doubts about its influence will persist. We also tried to use industry input in our assess- ment and found that the natural reticence of the min- eral industry to reveal assessment results kept it from supplying us with little more than assurances of high value without much proof. I am fearful that the BLM geologist who wrote the statement above had no more substantive information than we obtained. Ideal- ly, if new and better information exists, it should be made available to all interested parties by means of the EIS. At a minimum, the EIS should include refer- ences to new material used in the assessment and not listed in the SAI documents. 15.52 RESPONSE: BLM used all available sources of information in deriving the necessary data regard- ing mineral and energy resources. The information provided by industry was used along with that obtain- ed from all other sources but did not have any special influence with BLM. Industry data were only one of many considerations in rating the mineral and energy resource values of the WSAs. See the response to Gen- eral Comment 15.1. 15.53 COMMENT: Data used to estimate the amount of mineral foregone are incomplete and does not consider the potential of large acreages that have yet to be adequately explored. [Mineral Land Re- search, Utah International, Inc., et al.] a. We also disagree with the statement on the same page that "This foregone (mineral) potential is likely overstated because 182,136 acres are under mining claim in wilderness areas." This statement is based on the assumption that "development work, ex- traction, and patenting would be allowed to continue on valid claims after wilderness designation under un- necessary or undue degradation guidelines" (last sen- tence on page 114). But, in the reality, even though the law allows for the development of pre-existing valid claims, no actual mining development has ever occurred within a wilderness area. Some wilderness bills have even precluded the patenting of valid mining claims. In addition, the data used to estimate the amount of mineral potential foregone is incomplete and does not consider the potential of large acreages that have yet to be adequately explored or the fact mineral exploration is a dynamic science wherein new ideas and concepts are constantly being generated and our understanding of geological conditions is continual- ly changing. As the need for new mineral commodities continues to grow, areas that have not been actively explored in the past suddenly become of great inter- est. For example, the current interest in gallium and germanium deposits in southwestern Utah was spark- ed by a recent mine development for these minerals. Thus, an area of Utah that received little attention in the past is now being closely scrutinized by mining companies. Many of the obvious mineral deposits that could be found by simple mapping and surface sampling were found long ago. To turn up new deposits requires use of more subtle clues and detailed exploration work. Indeed, much needs to be done before the areas listed in the EIS can be dismissed as having no mineral potential. Exploration techniques, such as satellite re- mote sensing and new geophysical methods, can now help to locate mineral deposits that were previously hidden because surface expressions of their presence were lacking. Most geologists in economic mineral exploration feel that hard rock mineral exploration is still in a youthful stage of development with many new ideas and concepts yet to be tested. Removal of access to public lands, such as would result from the inclusion of vast acreages within the wilderness system, would have a critical effect on the continued growth of this critical segment of the mining industry. b. In this modern era of high-tech, metals hereto- fore little utilized are gaining increasing use in appli- cations where no substitute currently exists. Further- more, supplies of these metals are limited and know- 22 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES ledge about their occurrence and availability are poor- ly known. Such metals include germanium, gallium, in- dium, the rare earths, the platinum group, and many others. Reliable forecasts of consumption indicate that most of these metals and others unmentioned will grow at a rate greater than the GNP in the future. In our opinion, a major oversight or deficiency of wilder- ness proposals in general is that they fail to take account of the future with respect to matters that may play a small or insignificant role at present. 15.53 RESPONSE: See the responses to General Comments 3.37, 15.1, 15.13, and 15.18. The discus- sion on mineral and energy resources in the Final EIS is based on the best available data. BLM recognizes that large acreages are not fully explored. This fact was noted on pages 65 and 66 of the Draft EIS (Vol- ume I) and has been included in the Final EIS. The Final EIS notes that the rating system is subjective and estimates of mineral quantities and importance could change rapidly with new field data, economic condi- tions, or changes in extraction technology. 15.54 COMMENT: BLM estimates of mineral quanti- ties, potentials, and the probability of development of minerals in the WSAs are too high. [Utah Wilderness Coalition, David Susong, et al.] a. The Draft EIS exaggerates the extent of oil and gas resources foregone through wilderness designa- tion by failing to take into account two key factors: the likelihood of locating deposits and the feasibility of producing from those deposits. The Draft EIS appears to base its resource estimates on only the favorability portion (fl to f4) of the SAI ratings. That rating hypothesizes the size of any oil and gas reservoir that could be found beneath a WSA. This rating does not take into account the likelihood of finding such deposits, for which SAI assigns a sepa- rate rating (cl to c4). Both ratings must be taken together to assess the likelihood of finding a resource of a certain size. For example, the Paria-Hackberry, Mill Creek, and Death Ridge WSAs are all assumed to have a poten- tial resource of 3 to 15 MMbbl of oil, apparently based on their common f3 rating. However, the likeli- hood of finding deposits of this size ranges from low (cl) for Paria-Hackberry to high (c4) for Death Ridge. Mill Creek is of low-intermediate likelihood (c2). Clearly Death Ridge is more likely to contain oil; this fact should be considered in the analysis of poten- tial resources. One might assign a subjective probabil- ity to each area, based on the SAI rating, and then multiply this figure times the hypothetical resources in that area, to derive an expected resources figure that would be fairly meaningful. (This is the basic statistical procedure of "expected outcomes.") To illustrate the point, we use a subjective proba- bility of cl =0.20, c2=0.50, c3=0.75, and c4=0.90. These are probably generous. Multiplying these fac- tors by the hypothetical resources found in each of the 19 favorable WSAs gives a total expectable re- source of 60 MMbbl of oil. This is one-sixteenth the figure BLM uses in Table 17. The point of this calculation is not to suggest that such numbers have any precision, but rather to point out the enormous discrepancy between using fairly reasonable assumptions and BLM's unstated, but high- ly generous assumptions. Absent any explanation of BLM's figures, we can only conclude they are serious- ly exaggerated. b. Most of the oil and gas production in Utah is from the Paradox, Uintah, and Green River basins and from the thrust belt. In 1984, there were 34.689 thousand barrels of oil produced in Utah. None of this production came from wilderness study areas. BLM estimates that 12 percent of Utah's proven and indi- cated reserves lie within WSAs. This is less than 0.4 of 1 percent of the U.S. proven and indicated re- serves, which is an insignificant amount, and I be- lieve is an overestimate. BLM's wilderness study area contains 2.7 percent of the estimated natural gas reserves. However, quot- ing from the EIS, quote: "This is an overestimation because of the amount of natural gas estimated in wilderness study areas represents hypothetical and speculative amounts. The overestimation of oil and gas poten- tial is shown even more clearly in specific wilder- ness study areas. For example, for the Road Can- yon WSA, BLM estimates an oil potential of less than 10 billion barrels of which 3 million might be recoverable. The adjacent Fish Creek Canyon WSA is estimated to contain the same amount of oil po- tential. However, if a map of wells drilled in the vicinity of these WSAs is compiled, you will soon see that all of them are dry holes. The entire area has been perforated with wells. There have been wells drilled in every single unit. There have been 88 wells which have been drilled within 6 miles of 23 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES the WSAs and only nine of these wells produced something. They have all since been capped and abandoned." BLM in the EIS for both of these WSAs indicates that the likelihood of recovery is low and the loss of development opportunity would not be significant if the areas were designated wilderness. I believe that BLM is correct in this assessment. However, it is ridiculous to assume there is any potential where there are 79 completely dry holes perforating the area. The 20 million barrels of oil potential and the 6 million acres of estimated recoverable oil should be subtracted from total estimates. This is a significant point, for if it is true for other WSAs, then the oil and gas potential for the Utah BLM WSAs has been grossly overestimated. 15.54 RESPONSE: See the responses to General Comments 15.1, 15.2, 15.3, 15.6, 15.12, 15.17 and 15.20. The estimates on energy and mineral resources received by BLM from different sources often varied greatly. In such cases, BLM has attempt- ed to determine which figures are the most correct. This has resulted in some disagreement on the figures used. However, recognizing that data are scarce in many areas for many minerals, BLM believes that the figures used in the Final EIS represent the best avail- able data. The figures used in Volume I, Chapter 3, have been adjusted for the Final EIS. 15.55 COMMENT: Wilderness designation would not permanently lock up mineral resources. [Wendell Anderson, et al.] a. Any mineral or oil resources that may be in- cluded within a designated wilderness area are not lost to the nation. They are being held in a strategic reserve for any real future needs. Congress desig- nates wilderness and can modify these laws if future critical needs develop. For example, tar sand of a marginal value today may be a treasure trove in half a century. b. As the years go by, mineral resources will un- doubtedly become more valuable. On the other hand, as the years go by, the wilderness will become much more valuable. And it would seem to me that making a wilderness area does not necessarily permanently lock up these resources. If some tens or hundreds of years down the road it becomes necessary for what- ever reasons to develop some of these, technology will have improved so that maybe they will be extrac- table with less impact on the land. And, you know, leaving them in the ground a couple of hundred years will only increase the value of them for the compan- ies which might be involved in that development. If we leave them there now, they will be there later if they are deemed necessary. 15.55 RESPONSE: See the reponse to General Comment 1.1. Wilderness designation is a long-term commitment that would prohibit development of min- eral and other resources, thus resulting in "foregone" resources. Wilderness designation also withdraws the land from further entry for mining claim location or mineral leasing, thus making these lands unavailable for exploration or development. As stated in the Wil- derness Act (Eighty-Eighth Congress of the U.S., 1964): "... it is hereby declared to be the policy of the Congress to secure for the American people of present and future generations the benefits of an en- during resource of wilderness." Also, ". . . these (lands) shall be administered ... in such a manner as will leave them unimpaired for future use and enjoy- ment as wilderness, and so as to provide for the pro- tection of these areas, the preservation of their wil- derness character . . ." (Refer to Chapter 1, Purpose of BLM's Wilderness Study Section, pages 7 and 8 of the Draft EIS). 15.56 COMMENT: The EIS should recognize that the long-term future of the nation's mineral and petrole- um industry is directly linked to public land access. [Exxon Corporation, et al.] a. The long-term future of the nation's mineral and petroleum industry is directly linked to public land access. Since 1960, enactment of over 25 sepa- rate pieces of Federal legislation authorizing the with- drawal of public lands has virtually closed 60 percent of these lands to mineral exploration and develop- ment. These closures have been made through direct withdrawal procedures and through restrictive land- use classifications. b. In 1971, domestic reserves were 39 billion bar- rels of oil and 291 trillion cubic feet of natural gas. This represents a 30-percent decrease in reserves, and we believe demonstrates the need to explore high potential areas to determine if they have oil and gas deposits. The current level of adequate supplies should not lull us into a false sense of confidence and distort our thinking about the continued need for access to areas with the potential to help meet our nation's energy needs. 24 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES 15.56 RESPONSE: See the response to General Comment 2.20. BLM recognizes the significance of public lands in energy and mineral resource produc- tion. The Final EIS provides a State and nationwide perspective of the energy and mineral resources located in the WSAs. The fact that wilderness desig- nation would result in the foregoing of energy and mineral exploration and development in the affected areas has been noted. 15.57 COMMENT: Wilderness lands in Utah are unique, which is not the case with mineral and energy resources. [Proger Jenkins, et al.] In addition, the exploitation of unique scenic and recreational resources for extraction of commonly found energy and mineral resources makes a mockery of common sense. The wild lands of the Colorado Pla- teau are like no other in this country. The same can- not be said for the mineral and energy resources found there. Does one destroy the wilderness quali- ties of, for example, the area in and around Little Death Hollow in the eastern section of the North Esca- lante Canyon/The Gulch WSA, to get more of the same kind of ore that could be extracted near Moab? This is, in effect, what action BLM is encouraging in many of its recommendations for partial wilderness designation. This is a bewildering course of action, indeed. BLM's stated emphasis on commodity produc- tion in their Proposed Action ( Volume I, p. 25, Draft EIS) is simply out of step with the times and the needs of our technological society. It fails to recog- nize the shift toward a consumption of less beef, oil, and uranium, and greater use for leisure time for tra- vel and the need for solitude and opportunities for primitive recreation. Wilderness is where you find it. Unlike so many other States, Utah has a considerable amount. BLM should be acting to recommend the maxi- mum amount of land for wilderness designation in order to preserve the maximum number of options for future generations. 15.57 RESPONSE: See the response to General Comment 2.20. The trend toward greater use of lei- sure time and travel and the need for solitude and opportunities for primitive recreation are discussed in detail on pages 86 to 89 in Volume I of the Draft EIS (National Perspective; Recreation section). This discussion has been carried forward to the Final EIS. Local, regional, and national perspectives for mineral and energy resources have also been included. 15.58 COMMENT: Energy development and wilder- ness are (or are not) compatible. [Utah Wilderness Coalition, Patricia Thompson, et al.] a. BLM correctly finds that mining claims are not conflicts with wilderness designation. The current law requires that BLM manage wilderness study areas to protect wilderness values. This applies to mining claims as well. In most cases the claims are invalid and, even when valid, do not represent signifi- cant management problems under wilderness study or designation. b. Boundaries are highly irregular which will be a future headache for managers and the public. I realize that you are trying to "balance" the need for energy and wilderness, but you should not do this accommo- dating both entities in the same area. Energy develop- ment and wilderness do not mix and the boundaries for each extend well beyond where they are drawn. What good is it to have a wilderness area surrounded by the sight of well rigs and roads? Certain areas should be managed for wilderness and other areas managed for development. I am talking about large areas. For example, all WSAs adjacent to national parks and Forest Service wilderness areas should be recommended for wilderness by BLM. It is totally ridi- culous to plan for energy recovery adjacent to these already protected lands. Energy needs should be com- promised in this situation, no matter what is found in these areas. 15.58 RESPONSE: See the response to General Comment 1.13. BLM believes that energy and mineral development and wilderness designation may not be compatible. This is recognized in the Wilderness Act of 1964 and FLPMA, and in subsequent rules and regu- lations. This Final EIS attempts to analyze the effects that energy development and wilderness designation would have on each other. 15.59 COMMENT: The EIS should report that wilder-ness designation will lock up major known belts of mineralization in Utah. [Jack Madsen] In Utah, there are three major mineral belts. One of them goes through the Bingham/Park City area which is a fairly short one. We have the Deep Creek Tintic Belt in which we have the bulk of mineraliza- tion; and the third is the Pine Valley, Wah Wah Moun- tain, Marysville Ligament. These areas are marked by major structures that existed at the time of the intrusion. They are mostly granite type rocks and 25 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES this is very important from the standpoint that this is where our mineral deposits are coming from. With these designated wilderness areas or potential wilder- ness areas, we will be locking up the known belts of mineralization. They are the only places we're going to find minerals. In the Deep Creek range we have Trout Creek. This is tungsten at the top of the range, and the Queen of Sheba Gold Mine. There is a short mineral belt from the House Range of the Painter Springs intrusive (Notch Peak WSA), around its east- ern parameters. Some minerals may not shown up as major deposits at this time. This is very misleading. For example, in the Wah Wah Range, even though everyone thought that there were only minor deposits of lead and zinc, two major companies drilled holes up to 5,000 feet deep in a particular area and discov- ered a major tungsten-molybdenum deposit and we have to go mine where mother nature put the miner- als. For your record, Utah Geological Mineralogical Society and USGS collaborated on a report in 1964 in which they show these mineral belts. 15.59 RESPONSE: See the responses to General Comments 8.17, 15.1, 15.2, 15.12 and 15.56. The Final EIS discusses that fact that wilderness desig- nation would result in energy and mineral resources being foregone. See Chapters 3 and 4 in Volume I for a Statewide and national perspective and the individual WSA analyses for site-specific discussions. The im- portance of mineral deposits in WSAs is analyzed in relation to local, regional, and nation perspectives. 15.60 COMMENT: The EIS should quantify the amount of energy being foregone in more understand- able numbers, such as decatherms. [Celsius Energy Company] To quantify the amount of energy that is being giv- en up to wilderness, we recommend that BLM convert energy figures into more understandable numbers. For example, a typical GS-1 residential customer of Mountain Fuel Supply Company uses 115 decatherms of natural gas per year. If BLM would divide all of the energy figures by 115 decatherms, it would show how many homes could be heated by the lost energy. One standard Mcf of gas is roughly equal to one deca- therm and a barrel of oil is roughly equal to six deca- therms. Thus, if a WSA holds one bcf of gas, that is equal to the energy necessary to heat 8,696 homes per year, or a city about the size of Bountiful, or all the homes in Tooele County. 15.60 RESPONSE: The units of measure used for energy and mineral resources in the Draft and Final EIS are those most commonly used and easily under- stood. Additional local, regional, and national perspec- tives have been added to this Final EIS. 15.61 COMMENT: Man's imprints do not last for- ever. They are removed by reclamation and by nature over time. [Celsius Energy Company, Michael Fercik, et al.] a. Imprints of man, at the present time and in the future, can economically be removed when man has used up resources needed in the area. Environmental- ists like to think man scars the earth forever. The days of the 1850 California hydraulic mining are gone. In this day and age, even strip mining can be done without impact to the environment, sometimes with improvements. Even if man did scar the earth and not reclaim it, mother nature would reclaim it naturally over a hundred or so year period. We are gambling with high paying jobs, United States tax revenues, and national deficit over existing and pro- posed national wilderness preservation systems. Man, nature, and environment can work hand-in-hand instead of on opposite sides of the fence if man would give man a chance. I believe Congress should once again amend min- ing and energy exploration laws that were amended December 31, 1983. Withdrawn lands are not what the United States needs in this day and age. b. We ask that you examine the Bridger Lake area on the north slope of the high Uintas. That is an area that has a virtually primitive campground, beaver ponds, and recreation area directly over a producing oil and gas field. I might note that we have heard some pro-wilderness groups base their arguments on the theory that oil and gas development creates a sur- face scar forever. Yet many FS wilderness areas and BLM WSAs already contain reclaimed oil and gas areas that are unnoticeable. These same groups say that oil and gas development is shortsighted and wil- derness takes in the long-term perspective. We say that oil and gas development is a short-term impact with long-term acceptability when fully reclaimed. 15.61 RESPONSE: See the response to General Comment 3.1. BLM recognizes that man's imprints do not always last forever and can be reclaimed over time. However, it is important to understand that BLM is now guided by the Interim Management Policy, 26 GENERAL COMMENTS AND RESPONSES SECTION 15: MINERAL AND ENERGY RESOURCES Guide-lines For Lands Under Wilderness Review (December 12, 1979, and revised July 12, 1983), that require WSAs to be managed in a manner so as not to impair the suitability of the WSAs for preser- vation as wilderness and to protect wilderness val- ues. This means that man's imprint must be substan- tially unnoticeable by the time Congress makes a deci- sion on the area. As a practical matter, this means that a given WSA must meet this definition by the time the Secretary of the Interior reports his or her recommendation to the President of the United States, because the President may immediately send his or her recommendation to Congress and Congress might act immediately. Once designated, wilderness values must be preserved. 15.62 COMMENT: The EIS used outdated 1982 leas- ing information. The Final EIS should use more updated information. [Utah Wilderness Association] 15.62 RESPONSE: The Final EIS has been revised and is based on the leasing status of WSAs as of 1988. Leasing status is constantly changing and the information also will be updated for the Wilderness Study Reports that will accompany the Final EIS when it is submitted to the President and Congress. Also refer to the response to General Comment 15.1. 15.63 COMMENT: A national energy policy should be established in order to make decisions on domestic exploration and development. [Texaco, Inc.] We believe a national energy policy needs to be established so that a conscious and deliberate decision can be made as to what amount of domestic explora- tion and production is needed to ensure a strong do- mestic economy and national security. We are not advocating that all areas studies in the Draft EIS should not be wilderness. However, as to those areas in which potential hydrocarbons exist, we believe mul- tiple use application ensures the public of the most beneficial use of its "public lands." 15.63 RESPONSE: The nation does have a national energy policy. BLM's minerals policy recognizes and implements the national policy as it relates to the public lands. Establishment of a national energy policy is beyond the scope of this EIS. However, the Final EIS does consider energy and mineral resources on both a Statewide and national level. 15.64 COMMENT: Areas should not be recommend- ed as unsuitable because of resource conflicts that are low in favorability with a high degree of certain- ty. [Sandra Long] 15.64 RESPONSE: See the reponses to General Comments 8.3, 8.16, and 8.17. The Final EIS does not project mineral and energy exploration or develop- ment in the foreseeable future for those WSAs with low favorability and high certainty ratings. Appendix 11 in Volume I summarizes the rationale for the BLM Proposed Action Alternative. 15.65 COMMENT: Conclusions regarding mineral potential on the part of BLM prior to USGS field work is unsupported and should be rescinded. The SAI con- clusion is based upon a cursory literature search and is unsupported by any real geologic data. In any case, the USGS, not BLM, is the agency with the compe- tence to make this decision. [Roy Young, et al.] 15.65 RESPONSE: In compliance with the National Environmental Policy Act (NEPA), it is BLM's respon- sibility to prepare the EIS using the best information available. This includes formulating the Proposed Action and conducting the analysis. Information from the USBM and USGS has been used for those areas where it is available. The study schedules for those two agencies are such that not all information can be provided to BLM with sufficient lead time to include all forthcoming information in the Draft and/or Final EIS. The Wilderness Act and FLPMA requirement is that the USBM and USGS data be available at the time the Secretary of the Interior transmits the wilder- ness study reports to the President, and hence to Congress. If USBM/USGS studies provide significant new information subsequent to the completion of this Final EIS, a change in the Proposed Action may be consid- ered and a supplemental NEPA document would be pre- pared (USDI, BLM, 1985a). 27 . ' GENERAL COMMENTS AND RESPONSES - SECTION 16 WILDLIFE INDEX 16.1 Wildlife does not appear as an issue even though it was specifically identified in the scoping process. (P- 2) 16.2 The lack of a Statewide analysis on the impact to wildlife and a detailed analysis by alternative makes it impossible to determine what could be ex- pected under the various alternatives, (p. 2) 16.3 Threatened, endangered, and other species lists are incomplete, and the general statement that these species will not be impacted should be expanded to identify species needs and potential impacts by alter- native. (p. 4) 16.4 The EIS ignores the diversity and importance of nongame wildlife, and data are lacking to make an anal- ysis of no impact, (p. 5) 16.5 Wilderness areas provide a diversity of habitat for all types of wildlife and, in so doing, they provide a gene pool resource. BLM should identify those spe- cies and habitats, (p. 6) 16.6 There should be a list of estimated wildlife popu- lations by species and methods allowed for control. (P- 6) 16.7 The various project developments, habitat devel- opments, and other actions that will modify the natur- al character of the areas have not been fully discus- sed with respect to potential impacts to wildlife, (p. 7) 16.8 Areas that have unique biological values should be classified as RNAs to protect those values and still allow necessary research, (p. 8) 16.9 The bison herd at Yellowstone Park is also now hunted, so the statement that the Henry Mountain herd is the only hunted herd in the continental U.S. is incorrect, (p. 8) 16.11 The Draft EIS states that wildlife would benefit from WSA designation. However, if livestock over- grazing continues, how would wildlife benefit? (p. 9) 16.12 There is no basis to propose a limiting factor for wildlife in a WSA. (p. 9) 16.13 It is not clear how wildlife would be managed in wilderness areas, (p. 10) 16.14 Volume I, Table 39 (page 78) should include the word "some" at the beginning of the title since it is not a complete listing of nongame wildlife species, (p. 10) 16.15 Page 77, Big Game Species, paragraph 5, should note that the UDWR has also identified Fish Springs WSA as a proposed desert bighorn sheep transplant site. (p. 11) 16.16 Table 40, page 79, lists the golden eagle as present in 54 WSAs, although page 80 states that the golden eagle is found in all 82 WSAs. (p. 11) 16.17 BLM should more clearly specify in which WSAs sensitive species occur. Table 40, page 79, should be expanded to include this information. Also, Table 30, page 70 (minerals potential) does not de- serve easier cross-referencing than wildlife, (p. 11) 16.18 Because only foot access is allowed in wilder- ness areas, designation would limit opportunities to help endangered wildlife species, (p. 11) 16.19 Wildlife habitat designations are unclear, (p. 11) 16.20 The title of Table 37 should be changed from "Statewide Wildlife Habitat Summary" to "Statewide Big Game Habitat Summary," and the table should be expanded to provide the information for each WSA. (P- 12) 16.10 Predator control must be allowed within wilder- ness areas, and it must conform to the Wilderness Management Policy (BLM Manual 8560). (p. 9) 1 GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE COMMENTS AND RESPONSES 16.1 COMMENT: Wildlife does not appear as an issue even though it was specifically identified in the scoping process. [Scott Mills, Utah Wilderness Coalition, et al.] a. Compared to the number of comments received during the scoping session, wildlife should be identi- fied as an issue. Thirty-five different general com- ments oriented toward wildlife were received during the scoping period. By comparison, a total of seven comments concerning impacts on livestock grazing levels were received, yet this was considered one of the 12 dominant issues. Similarly, impacts on land use plans and controls received 24 comments, 11 less than the comments on wildlife, yet this, too, was listed as a dominant issue. So the logic for not includ- ing wildlife as a dominant issue is not clear. Besides the assertions that the public did not iden- tify wildlife values as dominant issues, BLM states that the reason wildlife was not analyzed on a State- wide basis was because there would be very little effect on wildlife under any of the alternatives. They give no data to support the assertion that various sorts of development and WSAs would not significant- ly disrupt any wildlife on a Statewide basis. Deleting wildlife from the Statewide analysis is a significant and important deletion because Chapter 2 and Chapter 3 list no specific impacts of the alterna- tives on wildlife. Recent research development con- cerning ecosystems indicates that alternatives as different as all wilderness or no wilderness could have a drastic impact on a host of different wildlife species. b. One of the fundamental foundations of wilder- ness and a major reason for its existence would be passed over if wildlife is not identified as an issue. The statement that an alternative would have little effect on wildlife because of the limited acreage also would hold true for livestock, and yet livestock is analyzed on a Statewide basis. c. The omission of wildlife as a major issue jeop- ardizes the EIS's analysis of one of the most critical values of wilderness. 16.1 RESPONSE: The Draft and Final EISs provide information on wildlife habitats and populations and analyze wildlife issues in the individual WSA analy- ses. BLM recognizes that wilderness can be of great benefit to some wilderness dependent and climax eco- system species of wildlife. Wildlife was not identified as an issue because of the stated reasons in the Issue Identification section of Chapter 1 in Volume I of the Final EIS. Not only is acreage of wildlife ranges in WSAs a small portion of that available in the State, but neither nonwilderness or wilderness management can be judged as good or bad for wildlife. For exam- ple, some elements of the wildlife community such as early successional and midsuccessional species will be adversely impacted by wilderness management, while wilderness management would benefit those spe- cies that are late successional or wilderness depen- dent and adapted to a climax vegetative community. Impacts on special and wilderness dependent wild- life species are addressed as part of the analysis of impacts on wilderness special features in the Wilder- ness Values sections of the EIS. 16.2 COMMENT: The lack of a Statewide analysis on the impact of wildlife and a detailed analysis by alternative makes it impossible to determine what could be expected under the various alternatives. [Utah Wilderness Coalition, Utah Wilderness Associa- tion, Scott Mills, et al.] a. Wildlife is an integral part of wilderness and it should be properly analyzed in the EIS. The lack of de- tailed analysis and information on the WSAs and in Vol- ume I make it impossible to determine what impacts could be expected under the various alternatives. The following is an example of this poor wildlife analysis: "About 46 percent of the substantial value yearlong desert bighorn sheep range in the WSA would be dis- turbed; therefore, desert bighorn sheep would avoid the disturbed area and would not become established. Some mobile wildlife would either perish or coexist at smaller and less viable population levels. Peregrine falcon and some sensitive species . . . would avoid the disturbed area . . . Others, such as the dwarf shrew, would probably perish." (Example from French Springs-Happy Canyon WSA analysis, page 230). This analysis is used to partly justify nonwilderness desig- nation for a portion of the WSA. The disturbances would involve surface mining. Note that the analysis does not explain where the bighorn sheep would go. It also puts the value of wildlife population at a mini- mum; there is a lack of concern in the analysis for species that would "perish" or exist at "less viable population levels." Examples like this can be found 2 GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE throughout the Draft EIS. BLM also shows their appar- ent anti-wildlife bias in the Summary of Significant Environmental Consequences section for each WSA analysis. We find it hard to believe that, if wilderness is designated, then, as BLM states, the only benefit for wildlife would be solitude. Other wildlife needs, such as natural habitat protection and historical environments, need to be considered. b. Another fundamental problem with the Draft EIS is its statements which are vague and unsubstanti- ated to the point of confusion. Data addressing the im- pacts of specific activities on a variety of wildlife species is available for BLM to cite. The Draft EIS does occasionally mention that bighorn sheep are sen- sitive to human activity (i.e., North Stansbury Moun- tain WSA), but more consistent, detailed, and better referenced impact analysis on all wildlife is expected. c. Besides being confusing, the vagueness through- out the Draft EIS is troubling because it is inadequate for decisionmaking. Since Congress will ultimately be the decisionmaker, details on specific impacts should be included in the EIS. At present, in the analysis of impacts of the No Action Alternative, there is a ten- dency to make statements saying that disturbances would not significantly affect overall wildlife condi- tions in the WSA, with no reference to what is signifi- cant, what is wildlife, or why local disturbances could not actually have far-reaching ramifications. There is almost never actual data. d. The wildlife data offer only the barest inven- tory data and do not represent professional quality wildlife, biological, or ecological data. Routinely, BLM ignores wildlife studies and data needed to make ade- quate wildlife decisions. Not one SSA reveals a detail- ed discussion of impacts relating to changes of habitat or changes in reproductive rates or production rates due to potential changes in habitat resulting from de- velopment. There are no discussions of travel routes and how they may be altered, nor are there detailed discussions relating to habitat or space requirements of individual species. The wildlife sections basically inventory some wildlife species and their habitat and then it appears as guesswork. This is not only true of the individual analyses, but the absence of Statewide analysis in Volume I gives nothing to the public, re- source managers, or decisionmakers about the im- pacts to wildlife under the various alternatives. e. There is no analysis of impacts to wildlife on a Statewide basis without which the EIS cannot meet the requirements of NEPA or the Wilderness Study Policy. f. There is a tendency to dismiss disturbances to wildlife by referring to the WSAs in total. g. A section is needed under each alternative to discuss the impacts of wilderness designation on man- agement of fish and wildlife resources at the State and Federal levels. 16.2 RESPONSE: NEPA requires analysis of signifi- cant impacts. In BLM's judgment, the effects of desig- nation or nondesignation are significant to wildlife on a site-specific basis, as analyzed in the individual WSA analyses, but are not significant on a Statewide basis. The analysis presented was based on available data. Some general conclusions on impacts were made in the individual analyses based on existing informa- tion and past experience. Some generalities were in- complete, and these have been corrected. For exam- ple, the statement "movement of animals away from disturbed areas" has been changed to reflect that those individuals affected will probably not survive due to competition from individuals already estab- lished. Some species would not benefit from wilder- ness designation while other species would flourish. Those that benefit from climax vegetation communi- ties would increase, while those that benefit from sub- climax communities would decrease in the long term. Wildlife management options could be curtailed at both the State and Federal level under wilderness des- ignation. Habitat manipulations and structural im- provements would not be allowed. The State's use of aircraft and motorized vehicles in capturing animals for transplant would possibly no longer be allowed. However, the State and Federal wildlife agencies have not specifically identified proposals for these types of projects in BLM WSAs. The overall impacts would vary, depending on the species being managed, degree of management, habi- tat improvements needed, harvest needs (if any), and other related factors. Some species would increase in numbers while some economically important species and others would decrease in numbers. It is not possible or necessary to provide site spe- cific analysis for all species because of the variations in habitat and species needs. 3 GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE 16.3 COMMENT: Threatened, endangered, and other species lists are incomplete, and the general statement that these species will not be impacted should be expanded to identify species needs and po- tential impacts by alternative. [Utah Wilderness Coa- lition, Utah Wilderness Association, Richard Fredrick- son, Scott Mills, Utah Audubon Society, Randolph Jorgen, Joelle Buffa, Michael Fercik, et al.] a. The impacts by alternative should be described before Section 7 consultation is required on specific projects. It would seem logical to describe specifical- ly the impacts of these species now in the EIS because by the time BLM did Section 7 consultation on endan- gered species, whatever development had been pro- posed may very well be prevented under the terms of the Endangered Species Act. It may be that wilder- ness designation, in this case, would save time, money, and uncertainty on Section 7 consultation down the line. b. The Draft EIS unrealistically assumes that threatened and endangered species would automatic- ally be protected through Section 7 consultations at the project planning stage. Section 7 consultation will not protect threatened and endangered species. All WSAs should be inventoried before an area is declar- ed as nonwilderness. Those consultations typically come as the project promoter (BLM or private) has invested considerable funds and time in the project and is not about to be deterred from completing it. This creates pressure to issue favorable biological opinions, despite evidence of impacts on sensitive species. The effects on endangered species can be ex- pected to be significant on a Statewide basis. Laws and good intentions do not provide the protection that wilderness can. The Endangered Species Act requires BLM to consider habitat needs for such species early in the planning process. Considerable weight should be given to designating an area as wilderness if known or suspected threatened or endangered species are present. c. Impacts on threatened, endangered, and other species should be addressed on a species specific bas- is. Negative or positive impacts on one type of wild- life do not necessarily mean the same for all types. d. Endangered and nongame species can best be protected by protecting and preserving natural wild lands. Utah's many unique wild places contain delicate ecological relationships that would be lost and des- troyed by the development of other natural resour- ces. Wilderness areas cannot be replaced once they are lost or destroyed. BLM's wilderness proposal de- letes many unique and valuable natural areas that would benefit wildlife, native plants, and biologic di- versity. Wilderness is the largest reservoir of uniden- tified and endangered species. We must maintain a large reservoir of wild lands to keep wildlife from ultimately becoming just occasional adornments on a near empty landscape or scientifically managed herds of a few big game species, as though they were cattle. e. The positive effects of wilderness designation on threatened and endangered species are frequently understated by use of the phrase "wildlife would bene- fit from solitude." f. Threatened and endangered species are summar- ily dismissed with no reference to species present by WSA. The Draft EIS statement (Volume I, page 78) that no terrestrial threatened and endangered species are found in WSAs and the only nonaquatic threatened and endangered animals are migrant bald eagles and peregrine falcons is incorrect. It fails to note bald eagles are not mere migrants to Westwater Canyon WSA (they are permanent residents). Only the Horse- shoe Canyon North WSA is listed in Volume I as home to resident peregrine falcons. Why weren't other areas listed? Likewise, the findings on terrestrial threatened and endangered species are flawed. The FWS letter (Draft EIS, Appendix 4) indicates the black- footed ferret may inhabit several WSAs (Dirty Devil, Horseshoe Canyon (North and South), Behind the Rocks, Desolation Canyon, Floy Canyon, Spruce Can- yon, Flume Canyon, Westwater Canyon, Lost Springs Canyon, and Daniels Canyon). It also indicates the desert tortoise may inhabit Red Mountain and Cotton- wood Canyon WSAs. g. There should be a discussion of potential pro- ject impacts to avoid areas being declared nonwilder- ness because of other (development) values. Although BLM recognizes the mandate of the Endangered Spe- cies Act in many of the WSAs, the way in which BLM describes impacts on threatened and endangered spe- cies is inadequate. In a great many of the WSAs, a statement in the No Action/No Wilderness Alternative says that, before development occurs, BLM wili initi- ate Section 7 consultation with the FWS, and neces- sary measures will be taken to protect sensitive, can- didate, and threatened and endangered species. Based on this premise, BLM then concludes that those spe- cies will not be adversely impacted. The major flaw 4 GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE here is that one does not know how extensive Section 7 mitigation measures may have to be. The Draft EIS should specifically list possible impacts on these spe- cies because, by the time all of the Section 7 require- ments are fulfilled for several different species, any development which is planned for the WSA may have to be eliminated or severely limited. h. One group of persons cannot actually say for sure that multiple use will endanger an endangered species. There is no scientific proof of such. As men- tioned earlier, animals have a sixth sense as to when man is actually endangering their existence. I have seen big game thrive around mineral and energy facili- ties. On this basis, I again say there is no actual scien- tific proof that multiple use endangers the endangered species. i. BLM should identify all plant and wildlife habi- tats of WSAs and the percentage of each habitat type represented, the inventories performed, and, where applicable, the inventories that have not been done. 16.3 RESPONSE: Table 55 in Volume I of the Final EIS identifies the threatened and endangered and other special status species that may occur within one or more WSAs. Due to the sensitive nature of the threa- tened and endangered species program, specific infor- mation on the location of these species will not be pre- sented. In addition, information concerning the exact location of threatened and endangered species habitat is not available for general use. Many threatened and endangered species habitat needs are still unknown, as well as the potential impacts from various activi- ties. As stated in the analysis, wilderness designation should, in general, have positive impacts to such spe- cies, both plant and animal. Some species that do well in disturbed areas would probably be negatively im- pacted. The Endangered Species Act requires all Federal agencies to ensure that any action taken will not re- sult in an adverse effect on threatened and endan- gered species. BLM's policy on threatened and endan- gered species management reiterates that position and includes sensitive species that have not been listed as threatened or endangered. 16.4 COMMENT: The EIS ignores the diversity and importance of nongame wildlife, and data are lacking to make an analysis of no impact. [Utah Wilderness Association, John Wahl, Scott Mills, Randolph Jorgen, et al.] a. No information is given about bear or cougar or the potential impacts to the WSAs containing these species if these areas are not designated as wilder- ness. Virtually nothing is said in Volume I about large predators (cougar and bear), other than Utah's popu- lations are limited and that bears are found in 12 WSAs and cougars are found in 52 WSAs (page 77). No population numbers or habitat acreages are given for these species, although it is stated that the areas around Zion National Park and the Deep Creek Moun- tains WSA are important for cougar, and the four Book Cliffs WSAs (Floy, Coal, Spruce, and Flume Can- yons) are important for black bear. It is also stated throughout the SSAs that both cougar and bear are sensitive to disturbance. What happens then if the Deep Creek Mountains are not designated wilderness and development renders them unsuitable for cougar? What happens to black bear under the proposed No Wilderness Alternative in the Book Cliffs WSAs? Cer- tainly, loss of the black bears' habitat in what many believe to be its last stronghold in Utah is going to have a significant impact on that species. These two examples contradict the statements in Volume I. It cannot be concluded all alternatives will have little negative effect on some species. b. Turning to wildlife, I refer to Volume I, page 77, first paragraph under the Small Game Species section. Aside from the absurdity of bears and cou- gars being called small game, I am troubled that no estimate or acreage is given with regard to crucial habitat, as was done for big game species. c. The references to wildlife present in the EIS are strongly and nearly completely oriented to game animals, with very little data or specific information on nongame animals. d. There is no justification, for example, for the Draft EIS to limit its description of impacts to rep- tiles, amphibians, and small mammals throughout all WSAs to this: "Less mobile animals would either per- ish or coexist with disturbances at smaller population levels." e. Wilderness is the largest reservoir of unidenti- fied species and endangered species. Nongame species thrive in true wilderness. f. Wildlife considerations center around game and endangered species. BLM does not state what its ob- jectives are with regard to wildlife. An impact can only be deemed positive or negative in relation to a 5 GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE stated objective. Also, BLM's view of wildlife cen- ters almost entirely around game species and endan- gered species. The WSAs offer much more diversity. 16.4 RESPONSE: Wilderness designation of areas would generally have a beneficial impact on bear or cougar. This would be tempered by the continuation of hunting, which would tend to hold the populations in check. In addition, if predation on livestock is occur- ring, the authorized agency is allowed to remove the offending animals. Since the Board of Big Game Con- trol does not have jurisdiction over bear or cougar, they are classified by the State of Utah as small game. Full discussion of all the nongame species in Utah BLM WSAs would not be appropriate in the EIS. Whe- ther or not a particular species will benefit from wil- derness designation depends on the habitat type that best suits the species needs. The EIS addresses big game and threatened and endangered species because they have some effect on local income or are protect- ed by law. Some species in Utah's desert habitats will probably disappear from the designated areas, and di- versity of the fauna will probably decrease as the hab- itat changes to a climax vegetative condition. Such shifts cannot be judged as good or bad (Maser and Thomas, 1983). BLM's objectives for wildlife manage- ment in wilderness areas will be coordinated with UDWR; however, habitat manipulation would be very restricted. The importance of specific WSAs (i.e., the Deep Creek Mountains) to certain species is analyzed in the individual WSA analyses. Also, see General Comment Response 16.1. 16.5 COMMENT: Wilderness areas provide a diver- sity of habitat for all types of wildlife and, in so do- ing, they provide a gene pool resource. BLM should identify those species and habitats. [Scott Mills, Utah Audubon Society, Utah Wilderness Association, Wasatch Mountain Club, et al.] a. Wilderness areas and parks may be considered islands which supply a source pool of potential colon- izers. When connected with travel corridors such as riparian strips, these islands of protected habitat could maintain biotic diversity even in a sea of human diversity. b. Wild places contain delicate ecological relation- ships that would be lost and destroyed by the develop- ment of other natural resources. The current propo- sal deletes many unique and valuable natural areas that would benefit wildlife, native plants, and biolo- gical diversity. c. Wilderness designation maintains undisturbed, unmanaged habitat for a host of nongame creatures. Designation of large tracts of wilderness promotes biotic diversity and the maintenance of natural pro- cesses, which are growing increasingly rare. d. Wildlife that makes WSAs their home are impor- tant indications of a region's diversity and health. In addition, WSAs, if protected, may become more important for wildlife as other areas are developed and habitat is severely altered or lost. e. Utah's unique Basin and Range physiography hosts relict plant and animal communities found no where else. BLM should place high priority on the pre- servation of these areas. 16.5 RESPONSE: Any unique, sensitive, or threat- ened and endangered species known or suspected to occur in WSAs have been noted in the EIS. A complete inventory of the species present or all the habitat types that may occur in WSAs is not necessary to make recommendations on wilderness. The WSAs would provide a source of animals if their populations reach the carrying capacity of the habitat. If unique species are found they could be moved into adjacent suitable habitat if it was determined that the species would benefit from such an action. The animal species available for distribution will change over time as the local habitat types change. It is difficult to project what habitat type will be present at any future date and, concurrently, what species will be present. With or without wilderness, BLM utilizes other land use designations, such as ACECs or RNAS, to pro- tect unique habitats or species. 16.6 COMMENT: There should be a list of estimated wildlife populations by species and methods allowed for control. [Utah Wilderness Association and Hardy Redd] a. It would be very valuable if the site-specific analyses provided estimates of prior stable popula- tions. At the present time, due primarily to historic management practices, populations of many wildlife species in WSAs are a mere fraction of what they once were, and many species have been extirpated. Therefore, looking only at present populations gives a distorted view of the wildlife values of most WSAs. It 6 GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE would be very valuable if the site-specific analyses provided estimates of prior stable populations, such as has been done in grazing EISs. This would give some indication of the wildlife potential of WSAs and what we might expect in some areas if they were designated wilderness and management emphasized wildlife values. b. How wildlife can be managed in wilderness areas is not adequately discussed. What means of con- trol will be used if wildlife increases causing detri- ment to the soil, grass, and the ecosystem? Will they be hunted, will they be removed, and if so, how? 16.6 RESPONSE: An estimate of stable population numbers by species is not possible. Nongame species populations often fluctuate so rapidly, even within 1 year, that any estimate would have no or little value. Prior stable numbers for big game are estimated by the UDWR by big game herd unit. Herd unit boundaries do not coincide with WSA boundaries and mathemati- cal interpolation would not be meaningful. The Wildlife Board, Board of Big Game Control, or the State Department of Agriculture (for predator control) are responsible for controlling wildlife that damage livestock or other property. BLM management in wilderness areas will maintain natural conditions, and the State of Utah will control animal populations. Predators will be controlled as outlined in the Wilder- ness Management Policy (BLM Manual 8560) guide- lines (see the response to General Comment 1.5 that addresses predator control). 16.7 COMMENT: The various project develop- ments, habitat developments, and other actions that will modify the natural character of the areas have not been fully discussed with respect to potential im- pacts to wildlife. [Scott Mills, Richard Fredrick-son, Utah Wilderness Association, Michael Fercik, Martin Bray, Dirk Van Vurem, George Hinde, Utah Farm Bureau Federation, Marathon Oil, National Park Service, et al.] a. There needs to be more analysis on the effect to wildlife if areas are not designated wilderness. Also, the statement that sensitive animals could move into adjacent areas if incompatible develop- ments occur is not likely. b. Statements addressing impacts to wildlife are vague and unsubstantiated. In the impact analysis for the No Action Alternative, there is a tendency to make statements that disturbances would not signifi- cantly affect overall wildlife conditions, with no ref- erence as to what is significant or why local disturb- ances could not actually have far-reaching ramifica- tions. c. The impact of various alternatives to wildlife is generally described in acres of vegetation disturb- ed by development, which is not an accurate indica- tion of habitat lost. The real impacts come from in- creases in other activities, such as hunting and ORV use. d. The impact of the average man far exceeds the impact of industries, ranchers, exploration corpora- tions, mining companies, and prospectors to the envi- ronment. The industries, ranchers, exploration cor- porations, mining companies, and prospectors have a respect for the lands. Some average men also respect the lands, but the majority of average men do not. Re- spect of the lands comes from making a living off and on the lands. Most of the disrespect for the lands comes from the floundering ideas of this is a beautiful site so let's lock it up so only one group can use it. There is proof that such ideas are the real culprit in environmental impact by the average man. e. The impact of mining activities on wildlife has been underestimated. Activity around a development will cause an increase in air and road travel, heavy equipment noise, and living facilities for workers, thus causing an impact to wildlife. f. Bison in the Henry Mountains are extremely sen- sitive to disturbance. Any increase in vehicle travel or any sort of mining operation will have an extreme- ly serious impact on bison behavior and distribution. g. If any development is to be allowed for live- stock, then development must also be allowed for wildlife. It is much better not to allow any further livestock developments in wilderness areas. h. It is contradictory to assume that restricting maintenance and improvement practices will benefit wildlife when, in fact, in many instances they thrive because of manmade and maintained water develop- ments for livestock, especially in the arid southern portions of the State where most of the WSAs are located. i. Wilderness designation is not a panacea for wild- life because of the inability to use equipment for 7 GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE making stock ponds, water guzzlers, habitat improve- ments, brush removal, etc. j. Proposed treatments and improvements for big game benefit only a small percentage of wilderness users (hunters). Improvements for big game can be done with fire, which is a natural component in the wilds. k. Comments should be made on environmental im- pacts on the bighorn sheep, cougar, black bear, and antelope. If such species are in danger of existence, then instead of using multiple lands as an excuse to their endangered existence, let’s put a complete stop to sportsmen hunting such species. At least put a stop to hunting endangered species until such species are no longer on the endangered species list. One example is the bighorn sheep. Utah puts a price on its head by bidding to the highest bidder the right to kill such an animal. l. Chainings, reseedings, land treatments, etc., are proposed on 57,250 acres in WSAs for wildlife improvement. Chaining within wilderness would appear to be in violation of the Wilderness Act. In Wildlife Habitats in Managed Rangelands - The Great Basin of Southeastern Oregon. Mule Deer (USDA GTR- PNW 139), Leckenby, et al., stated that "forage areas wider than 820 feet create less than optimum conditions" for mule deer use. This is only an exam- ple, and exact impacts will depend on the specific size, shape, success, and components of the seeding; but, in general, large seedings are harmful to wild- life. This proposal should be reevaluated. 16.7 RESPONSE: The individual WSA analyses list the proposed developments for each alternative and analyze the effects of developments on game, and sen- sitive, threatened, and endangered species. Multiple use may or may not have an adverse or beneficial impact on wildlife. Some activities result in an increase in road access and associated traffic, noise, dust, etc. Bison, deer, elk, and other game and nongame species may or may not react in the same way to similar disturbances. Cougar, bighorn sheep, black bear, antelope, and others will generally benefit from wilderness designation. These effects are des- cribed and analyzed in the individual WSA analyses in the EIS. The objective of wilderness management is to achieve natural conditions. Some actions are allowed for wildlife activities as well as for livestock. The 57,250 acres proposed for treatment in the Draft EIS have been reduced to 28,209 acres for the Final EIS. These treatments are not in one contiguous block and would be configured to provide benefits to wildlife as required by BLM guidelines. 16.8 COMMENT; Areas that have unique biological values should be classified as RNAs to protect those values and still allow necessary research. [Utah Nature Study Society] We have some misgivings about wilderness land classification for these areas, both from an adminis- trative point of view and from a research point of view. We can see years of valuable time lost in get- ting the necessary permits and review to do research in these areas, and even legal challenges. These de- lays certainly would not allow graduate students any opportunity for study. The major problem in wilder- ness classification is one of access and minimizing hu- man impacts. Research (for instance, a rodent popu- lation dynamics study in an area that has never been grazed by domestic or wild herbivores which could involve carrying into the area many dozens of small animal traps and pounds of oatmeal, besides food and water for the investigator, and all the 21st-century research equipment that might be utilized) might be prohibited by a District Manager afraid of allowing motorized access into a wilderness area. By the time the red tape is finalized, the opportunity for research may have lapsed. We would encourage BLM to work closely with the investigators, maintain reports of the results, and encourage publication in reviewed journals. 16.8 RESPONSE: Research is an allowable use of wilderness areas; however, there are restrictions on equipment, including motorized vehicles. If the pro- posed research is nonimpairing to wilderness values, it would normally be allowed. As stated in the com- ment, ACECs and other designations can also be used to protect unique resource values of scientific inter- est. 16.9 COMMENT: The bison herd at Yellowstone Park is also now hunted, so the statement that the Henry Mountain herd is the only hunted herd in the continental U.S. is incorrect. [Kevin O'Brien] Volume I, Appendix 2, page 23, response to Com- ment Number 237: The bison herd at Yellowstone National Park is also now hunted when the animals 8 GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE cross out of the park into Montana; therefore, your response is now incorrect. 16.9 RESPONSE: The Yellowstone buffalo are hunt- ed outside of the habitat or population area only as a depredation or disease control measure. The Yellow- stone herd is not a self-sustained hunted herd. 16.10 COMMENT: Predator control must be allow- ed within wilderness areas, and it must conform to the Wilderness Management Policy (BLM Manual 8560). [Utah Wilderness Association, Utah Wool- growers, et al.] a. Predator control in wilderness and in WSAs must be carried out in a manner which targets the offending individual animal(s). The statement that wil- derness areas could become "sanctuaries" for preda- tors and could result in additional livestock losses is not true. b. The promotion of predators and wild game transplants to enhance the wilderness qualities of des- ignated areas is a threat to the livestock industry that should be addressed in the Final EIS. For exam- ple, a few years ago some Rocky Mountain sheep were planted in one of the wilderness areas, and they mated with domestic ewes. The result was that about 200 ewes belonging to one sheepman became pregnant by the Rocky Mountain sheep rams. These ewes were either aborted, or their lambs were born and the hy- brid lambs simply could not survive. This was a mi- nor economic tragedy to this sheep operation. Wild game implantations into wilderness areas also pose other dangers to livestock grazing. For example, there are some special interest groups in Montana and northern Idaho who would like to see the wolf pre- served and have offered to ship them out to different States. They sent out questionnaires asking if other States would like to have some wolves. Needless to say, the general reply was no thank you, we were not interested. That may seem farfetched to think that wolves might be introduced into this State, but I'm telling you that a good number of our members are fully convinced, although there aren't any hard facts to back it up, that bears are being transplanted into the State of Utah on a regular basis. The promotion of predators and wild game transplants to enhance the wilderness qualities of designated areas is a threat to the livestock industry that should be addressed in the Final EIS. c. If there is no predator control, the predators can actually destroy the game animal population. 16.10 RESPONSE: Predator control is allowed in wilderness areas under specific guidelines, one of which limits control to the offending individual animal and not the population as a whole. Also, see the responses to General Comments Responses 1.5 and 16.6. 16.11 COMMENT: The Draft EIS states that wild- life would benefit from WSA designation. However, if livestock overgrazing continues, how would wildlife benefit? [Roger Jenkins, et al.] No assessment was made of the magnitude of the economic impact an increase in wildlife concomitant with a reduction in grazing would have on the local economies. Presumably, an increase in big game hunt- ing opportunities (such as deer and bighorn sheep) would bring additional revenues to local communities. Also, those recreationalists who prefer to drink water less polluted by cow manure and quicksand- trapped cattle carcasses may be more inclined to visit canyon areas and spend money. 16.11 RESPONSE: Livestock grazing is recognized by Congress as a valid use of public lands, both within and outside wilderness areas. Wilderness designation would benefit wildlife by protecting habitat from dis- turbance, destruction and provision of solitude, as stated in the EIS. As planning documents are complet- ed, monitoring systems will be established to deter- mine if livestock overgrazing is occurring. As these situations are identified, actions will be taken to cor- rect the problem. Any economic impact from increased wildlife num- bers would be of a speculative nature. A population in- crease for most species (except possibly bighorn sheep) would not result in a direct corresponding in- crease in revenue because the number of hunters in Utah has not fluctuated more than about 10 percent in the last 8 to 9 years. During this time, wildlife popula- tions have been high, but hunter numbers have not changed. 16.12 COMMENT: There is no basis to propose a limiting factor for the wildlife in a WSA. [Scott Mills] Although one may appreciate BLM's attempt to determine ways in which wildlife habitat may be 9 GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE improved, the attempt must be tempered with real- ity. Several WSAs state that water or some other re- source factor "limits" wildlife in the WSA, and that an improvement of manipulation of the limiting factor will be beneficial to wildlife. Although resource pop- ulation limitation has been a traditional tenet in wild- life biology, Wiens (1984) reviews the subject and concludes that "there is surprisingly little direct evi- dence of clear resource limitation in natural popula- tions " (page 417). BLM's use of limiting factors is especially misleading because it creates the impres- sion that the proposed manipulation or improvement will benefit all wildlife. A given resource, such as water, may be limiting for one or two species, but until much more data are available, there is no basis to propose a limiting factor for wildlife in a WSA. 16.12 RESPONSE: The limiting factor concept is a viable tenet in wildlife biology as described in the fol- lowing references: Caughley, C. 1979. "What is This Thing Called Carrying Capacity?" In North American Elk: Ecology. Behavior and Management. University of Wyoming, Laramie, Wyoming, pp. 2-8. Dasmann, W. P. 1971. If Deer Are to Survive. Wildlife Management Institute, Washington D.C. 128 pp. Maser, Chris and Thomas, Jack W. 1983. Wild- life Habitats in Managed Ranoelands--The Great Basin of Southeastern Oregon. Introduction. Gen- eral Technical Report PNW-160. U.S. Department of Agriculture, Forest Service, Pacific North- west Forest and Range Experiment Station. 15 pp. Russo, J. P. 1984. The Kaibab North Deer Herd. Game and Fish Department. Wildlife Bulletin 7. Phoenix, Arizona. 195 pp. Thomas, Jack Ward and Bell, Evelyn L. 1987. "Wildlife Habitat in Managed Forests: What To Think About While Chopping." In Western Wild- lands. Spring. 7 pp. 16.13 COMMENT: It is not clear how wildlife would be managed in wilderness areas. [Hardy Redd, Wasatch Mountain Club, et al.] a. What happens if wildlife increases are detrimen- tal to the soil, grass, and ecosystem? Will they be hunted or will they be removed? And, if so, how? b. We are disturbed by the hunting practices used in Utah. Although few bear remain in the State, there is no limit on the number of hunting licenses issued. This is clearly a threat to the surviving bear popula- tion. c. BLM's management objectives for wildlife are not made clear in the descriptions of the alternatives. How can the impacts of BLM's multiple-use manage- ment be analyzed if objectives for big game, small game, nongame, and threatened and endangered spe- cies are not clearly stated? d. What impacts are predicted on wildlife inven- tory and monitoring, habitat project development, wildlife introductions, etc.? Although fish and wildlife management actions associated with each WSA are an- alyzed in Volumes II through VI, the reader is not giv- en an overall perspective of the impacts, negative or positive, of wilderness designation on wildlife re- sources. It is essential that we give the public and other agencies a clear and concise picture of how BLM intends to manage fish and wildlife resources in wil- derness areas and what will be incorporated in Wil- derness Management Plans. 16.13 RESPONSE: BLM's objective for wildlife management is outlined in the Wilderness Management Policy (BLM Manual 8560) which, in general, states that wilderness areas will remain in a natural condi- tion, with habitat manipulation normally being restric- ted to that needed for management of threatened and endangered species. Hunting is a recognized use of wil- derness areas and is regulated by the State of Utah. Specific restrictions and opportunities will be consid- ered when wildlife plans are developed for wilderness areas. The description of the No Action/No Wilder- ness Alternative in the individual WSA analyses out- lines proposed developments and activities in WSAs. 16.14 COMMENT: Volume I, Table 39 (page 78) should include the word "some" at the beginning of the title since it is not a complete listing of nongame wild- life species. [Scott Mills and George Hinde] a. Volume I, Table 39 page 78: This table should include the word "some" at the beginning to the title since it is not a complete listing of nongame wildlife species. GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE b. Table 39 page 78: the bird list is nowhere near complete. There are over 350 species of birds which may be seen in Utah. Between 82 WSAs, you should be able to see most of them. I am also disturbed by the lack of mention of en- dangered species. There are five threatened aviant species and birds that are not mentioned: five fish and several birds have not made it into the Draft EIS. 16.14 RESPONSE: The table mentioned in the com- ment (Table 54 in the Final EIS) has been retitled "Typical Nongame Species Present in WSAs" to ack- nowledge that the list is not complete. 16.15 COMMENT: Page 77, Big Game Species, par- agraph 5 should note that UDWR has also identified Fish Springs WSA as a proposed desert bighorn sheep transplant site. [State of Utah] 16.15 RESPONSE: The transplant list of April 19, 1985, only identifies the "West Desert Mountains" as a possible area. This may or may not include the Fish Springs WSA. The Final EIS notes that potential desert bighorn sheep habitat is present in the Fish Springs WSA. 16.16 COMMENT: Table 40 page 79, lists the gold- en eagle as present in 54 WSAs, although page 80 states that the golden eagle is found in all 82 WSAs. [Scott Mills] 16.16 RESPONSE: Table 40 of the Draft EIS (Table 55 in the Final EIS) has been revised to reflect that golden eagles are present in all 83 WSAs. 16.17 COMMENT: BLM should more clearly specify in which WSAs sensitive species occur. Table 40, page 79, should be expanded to include this informa- tion. Also, Table 30, page 70 (minerals potential), does not deserve easier cross-referencing than wild- life. [Bridgerland Audubon Society and Scott Mills] a. BLM should more clearly specify in which WSAs sensitive species occur. Table 40, page 79, should be expanded to include this information. This would make cross-referencing easier. BLM lists WSAs with minerals potential (i.e., Overview, Table 30, page 70), and minerals do not deserve easier cross-referencing than wildlife. In which WSAs are found the desert shrew, dwarf shrew, spotted bat, Bell's vireo, ferruginous hawk, fox sparrow, golden eagle, grasshopper sparrow, Lewis woodpecker, mountain bluebird, roadrunner, gila monster, chuck- walla, and many-lined skink? b. Table 40, page 78: Given the mandate stres- sing the values of wildlife, this table should at least be presented in the detail and format given mineral potential in Table 30, page 70. 16.17 RESPONSE: The numbers of WSAs where special status species is noted. Many could occur in a large number of WSAs (54, 83, etc.) Additional exten- sive lists of WSA names would not be particularly helpful. The individual WSA analyses and Appendix 4 provide the requested information. 16.18 COMMENT: Because only foot access is allowed in wilderness areas, designation would limit opportunities to help endangered wildlife species. [Michael Fercik, et al.] If tracts II through VI are designated wilderness, then the only possible way to help endangered species of wildlife and plant life would be by foot; access by motorized vehicles would not be allowed. The environ- ment would suffer from designated wilderness. Desig- nated wilderness would deregulate the impact that the average man and tourist has on the environment. With- out access roads, the government has no probable means of regulating man's impact to the environment. 16.18 RESPONSE: The Wilderness Management Poli- cy (BLM Manual 8560) allows for habitat manipula- tion, including chemical and mechanical means, for the benefit of threatened and endangered species. 16.19 COMMENT: Wildlife habitat designations are unclear. [Francis Fereks, Riki Darling, et al.] What is the difference among such terms as cru- cial, critical, crucial-critical, high priority, etc.? The Glossary definition is very generic and does not distinguish among the terms. A complete explanation, such as the one for visual resources in the Appen- dices, would be very helpful. 16.19 RESPONSE: The Glossary definitions of the terms listed in the comment have been expanded. 16.20 COMMENT: The title of Table 37 should be changed from Statewide Wildlife Habitat Summary to Statewide Big Game Habitat Summary and the table should be expanded to provide information for each WSA. [Scott Mills, et al.] GENERAL COMMENTS AND RESPONSES SECTION 16: WILDLIFE Chapter 3 of Volume I, Table 37, is titled State- wide Wildlife Habitat Summary. In actuality it is a table summarizing two habitat types and the habitats of five big gam© animals. The table should not imply wildlife when it means game animals. 16.20 RESPONSE: The title to Table 37 (page 76 of the Draft EIS; Table 52 in the Final EIS) has been changed to read, "Summary of Wildlife Ranges for Selected Species." GENERAL COMMENTS AND RESPONSES - SECTION 17 FOREST RESOURCES COMMENTS AND RESPONSES 17.1 COMMENT: The EIS states that forest resour- ces in WSAs are insignificant. [Consolidated Comment from Several Sources] 17.1 RESPONSE: BLM agrees with the conclusion of the commentors, and this information is included in the Issue Identification section in Chapter 1, Volume I, of the Final EIS. 17.2 COMMENT: Wilderness designation would im- pact the Navajo people's ability to obtain firewood in San Juan County. [Utah Navajo Development Council, et al.] 17.2 RESPONSE: Wilderness designation would pre- clude the harvest of forest products, except for the harvest of pinyon nuts or noncommercial gathering of dead-and-down wood, if accomplished by other than mechanical means for use in the wilderness. BLM recognizes that the designation of wilderness areas in San Juan County could force people to look for firewood in other areas of the county. However, a large percentage of the Navajo wood supply is obtain- ed from national forest lands in the region. On BLM- administered land, many suitable wood harvest loca- tions occur outside of the WSAs, and these will be made available consistent with the South San Juan MFP or the forthcoming San Juan RMP. Nearly all har- vest in the past has occurred in readily accessible areas on the mesas which are not included in the WSAs. Wilderness designation would not have a signifi- cant affect on the opportunity for wood harvest by the Navajo or by others. 17.3 COMMENT: How will illegal woodcutting be monitored? [Utah Wilderness Coalition] 17.3 RESPONSE: Illegal woodcutting would be moni- tored in the same manner as any other illegal acts that could occur in wilderness areas. For each WSA, a specific Wilderness Management Plan would be devel- oped to govern the use and protection of the wilder- ness area. Wilderness area boundaries would be mark- ed and the necessary information dispensed to the gen- eral public regarding wilderness area location and activities allowed in wilderness areas. 17.4 COMMENT: The Draft EIS uses 40 percent slope as a criterion for classifying forest lands as unsuitable. Slope is not an appropriate classification standard. Suitability should be based on biological fac- tors. Therefore, these lands should not have been clas- sified as unavailable for forest management. [Forest Interests] 17.4 RESPONSE: It is important to realize that there is a difference between timber and woodland management and timber and woodland harvest. All tim- ber and woodland resources located on public lands in Utah are managed; however, not all are available for harvesting. Management is based on both physical and biological factors as clearly set forth in Utah State Office Manual 5400 (Sales of Forest Products, pub- lished October 1, 1986) and Utah Supplemental Guid- ance: Management of Woodland Resources, (USO In- struction Memorandum No. UT 86-371). In summary, unavailable woodlands (those woodlands not available for woodland harvest) are those that meet any one of the following criteria: (1) stands withdrawn from har- vest of woodland products to protect other uses; (2) stands not capable of producing merchantable wood- land products due to poor site and product quality; (3) stands located on public lands with no legal or physi- cal access; (4) stands located on slopes over 30 per- cent; or (5) stands containing woodland volume rates (mature stand) of less than 350 cubic feet per acre. Therefore, slope is both a legal and important management consideration factor in determining the availability of forest and woodland resources for har- vest on the public lands in Utah. This is commonly accepted practice which considers safety as well as environmental factors. The Final EIS has been updated to reflect the 30-percent-slope figure, which would make even more land unavailable for timber and wood- land harvest than the 40-percent-slope figure indicat- ed in the Draft EIS. 1 . . /- GENERAL COMMENTS AND RESPONSES - SECTION 18 LIVESTOCK AND WILD HORSES/BURROS INDEX 18.1 The analysis underestimates the effect of wil- derness designation on livestock grazing, (p. 1) 18.2 Livestock grazing adversely affects other uses and should be eliminated from WSAs and wilderness areas, (p. 2) 18.3 Additional analysis of the effects of wilderness on grazing of in-held State lands is needed, (p. 3) 18.4 The Draft EIS analysis of forage use and poten- tial production and losses is inadequate, (p. 3) 18.5 A cumulative analysis is needed to provide for a national perspective of grazing, (p. 4) 18.6 Livestock control can be accomplished outside of WSAs, as well as within, (p. 4) 18.7 The location of sheep grazing reported in the EIS is wrong, (p. 4) 18.8 There are editorial errors in the livestock graz- ing analysis, (p. 5) COMMENTS AND RESPONSES 18.1 COMMENT: The analysis underestimates the effect of wilderness designation on livestock grazing. [Hardy Redd, Utah Counties, Utah Board of Water Re- sources, Utah Woolgrowers, Utah Farm Bureau Fed- eration, et al.] a. Grazing permits would be taken from us. Has grazing been preserved in other wilderness areas in the past? Will there be any grazing? Has grazing been reduced in these areas? The livestock industry was the first to utilize these lands, and we feel they should be the last. History shows that the restric- tions placed on ranchers will make it impossible to continue livestock operations due to problems with predator control, vehicle access, salting, fencing, well and stock pond maintenance, and veterinary prac- tices. b. Although livestock and mining interests now in place are supposed to be permitted to continue opera- tions, change or improvements may not be permitted. Also, the Secretary of the Interior can change the reg- ulations at any time and ban certain allowable uses at will. Pressures from interest groups can also force him to do this. c. The Draft EIS is remiss in that it does not ade- quately address the impact that wilderness designa- tion will have on the grazing levels presently permit- ted, and it does not adequately address the equally adverse impact on the ranchers owning the permits. d. It has been the practice of BLM to act in two ways when faced with a shortage of grazing lands dur- ing the year. One method is to limit ranchers in the amount of land they can use. This limits the number of animals the rancher can run. The other method is to limit the amount of time that the land can be used. This latter method is the most devastating. This ulti- mately forces the rancher to disrupt the economies of scale that he works at and find other employment. e. Can watershed and forage improvements for both wildlife and livestock be made in wilderness areas? If so, can they be done mechanically or how can they be done? Can water be economically develop- ed? Can water be hauled in drought years? Can feed be hauled during blizzards? It would be impossible for the livestock permittees to manage their operations including herding, and maintaining and constructing fences, water systems, roads, and ponds. A total of 423 permittees will be affected Statewide. Grazing will be impossible without water. When there is a heavy thundershower, the springs are destroyed and require heavy equipment to restore, which is not allowed under wilderness. f. The economic loss to livestock users by not be- ing able to develop improvements and rescue live- stock in an emergency (such as winter snows trap- ping the animals) will be tremendous in wilderness areas. Many ranchers depend on the ability to use mo- torized vehicles to run their operations. They must travel 70 to 100 miles from their ranches to their 1 GENERAL COMMENTS AND RESPONSES SECTION 18: LIVESTOCK AND WILD HORSES/BURROS permitted grazing grounds. In some cases, livestock would have to be driven 20 miles before reaching a point outside a WSA. Our ranchers don't have this kind of time on their hands. g. BLM should evaluate some of its current wil- derness areas to see if they are doing what they were supposed to do. For example, the south side of Pine Valley Mountain is no longer used for livestock. The sportsmen wanted the deer and others wanted it for hiking. The roads are in such a deplorable state, you can't get up there now. The trails are overgrown and can't be found. There's no salt for the deer. For- est fires are a constant rampant threat. That's what wilderness achieves for us, dilapidation. 18.1 RESPONSE: The Wilderness Act, Conference Report S.2009, and Flouse Report 96-1126 make it clear that Congress intended that livestock grazing continue in wilderness areas where grazing was esta- blished prior to the effective date of the Act (see Draft EIS, Appendix 1, Part A. III. FI). In Region 4 of the FS, which includes the State of Utah, Randall R. Flail, Director, Range and Watershed Management, reported in a letter to Bill Swan (past President of the National Cattlemen’s Association), dated January 6, 1987, that: "There are no documented instances where there have been significant impacts or reduc- tions in livestock use resulting from areas being desig- nated as Wilderness in Region 4. Between 1980 and 1986, there were no decreases in permitted live- stock in Wilderness, although a few sheep permittees took personal preference non-use due to the economic structure and condition of their operations." Range- land analysis in wilderness areas will follow normal BLM standards, with any adjustments in livestock numbers being based on range condition and not be- cause of the wilderness designation. The Act also pro- vides for emergency use of motorized equipment for bona fide emergencies, such as stranded livestock, etc. The construction of new rangeland improvements is permissible, if determined necessary for resource protection (rangeland, wildlife, watershed, and/or wilderness) and the effective management of these resources. (Improvements to accommodate increased number of livestock are not allowed.) When permit- ted, new or existing improvements will be made of materials which harmonize with the area's wilder- ness character to reduce the impact of artificial ob- jects on the natural environment. The use of motor- ized equipment may be allowed after a complete envi- ronmental analysis is made. The criteria shown in Appendix I, Part A-lll. H. I.d (Volume I, page 209 of the Draft EIS) will be considered in the analysis, and mitigating measures will be developed to protect the area's wilderness values. Also, see paragraphs 2 and 5 of the excerpt from House Report 96-1126 included in Appendix 1, Part A, concerning motorized access for livestock management. 18.2 COMMENT: Livestock grazing adversely affects other uses and should be eliminated from WSAs and wilderness areas. [Michael Salamacha, David Orr, Jean Soko, Roger Jenkins, et al.] a. Congress should be made aware of the conflicts between grazing and recreation and wildlife. Grazing is an unnatural impact in a wilderness area. Grazing should be discontinued in wilderness areas. Grazing brings with it fouled water for both humans and wild- life; overcompetition with native wildlife (the origi- nal users) for both water and vegetation; a continued impact on natural native vegetation due to soil com- paction and overgrazing by livestock; encouraged growth of cheatgrass and Russian thistle; and soil erosion, resulting in thicker siltation of rivers. This is all due to overgrazing lands that have minimal val- ue for grazing in the first place. b. Could some provision be made to keep livestock out of springs, streams, and riparian areas to protect water quality? c. Grazing levels should be adjusted before wilder- ness areas are designated. This is needed since many allotments are currently in very poor condition. Much of the land in southern Utah is so badly overgrazed that only the sagebrush is left to graze on. d. Livestock grazing reduces wildlife numbers through both competition and range improvements. Grazing should be eliminated. Grazing is not natural, and BLM should not allow an element so incompatible with wilderness. Grazing also conflicts with recrea- tional uses. e. A better economic analysis is called for. Graz- ing revenue losses would be more than offset by gains in hunting and recreational areas. 18.2 RESPONSE: Section 4(d)(4)(2) of the Wilder- ness Act, and Section 603(c) of FLPMA (1976) pro- vide for continued livestock grazing where grazing had been established prior to designating the area as wilderness. Congress provided further insight on the subject in Conference Report S.2009 (House Report 2 GENERAL COMMENTS AND RESPONSES SECTION 18: LIVESTOCK AND WILD HORSES/BURROS 96-1126). See Draft EIS, Volume I, Appendix A-lll. H for additional details. The laws also state that any ad- justments in grazing levels will be made through standard BLM rangeland management procedures. These procedures do consider wildlife needs of the area. 18.3 COMMENT: Additional analysis of the effects of wilderness on grazing of in-held State lands is need- ed. [Utah Farm Bureau Federation, Utah Counties, et al.] The Draft EIS fails to recognize related complica- tions on 192,758 acres of State land in-holdings that exist within 53 of BLM's 82 WSAs. Also, 139,492 acres of State lands considered as being adjacent to WSAs will be impacted by management conflicts. As we understand it, adjacent State lands are not those lands that merely abut against the outside boundary of a given WSA, but those lands that are largely en- compassed by the WSA itself. In other words, the cherry-stem concept has been applied to State lands as it was with roads. It then appears that there are an additional 330,250 acres of State lands that will be directly affected by wilderness and, therefore, should be added to the 3.2 million acres being assess- ed by BLM. There are 423 livestock permittees that will have their problems compounded now since the majority of the respective in-holdings and adjacent lands are leased by these permittees. Permittees have spent much money improving these lands and value them as much as their own private lands. There needs to be additional analysis of the effects of wil- derness grazing on in-held State lands. 18.3 RESPONSE: Section 5(a) of the Wilderness Act provides that a State or private owner shall be given such rights as may be necessary to assure ade- quate access to such State-owned or privately owned land by such State or private owner and their succes- sors in interest. See the responses to General Com- ment 18.1 regarding livestock grazing in wilderness areas and General Comments 6.1 and 6.2 regarding impacts on in-held lands. 18.4 COMMENT: The Draft EIS analysis of forage use and potential production and losses is inadequate. [Utah Wilderness Association, et al.] a. Is the amount of forage actually utilized in WSAs less than the 10-percent figure which is allo- cated Statewide? How was the licensed use figure of 96,521 AUMs calculated? On page 32, third para- graph, is the actual forage use unknown? If so, how can any acreage be dropped from a WSA because of grazing conflicts? The forage allocation figures asso- ciated with the various alternatives need better analy- sis. Table 9 (Volume I, page 29) gives various figures of potential AUMs from improvements that could ex- ist within WSAs. However, there is no discussion in the Draft EIS whether these AUMs are, in fact, perma- nent. Vegetation treatments only increase AUMs over the short term. In addition, there are no numbers given for changes in AUM numbers from improving water, grazing systems, or improved management. It appears that all changes are attributed to vegetation manipulations. b. The acreage of potential land treatments listed for the nondesignated portion under the Proposed Ac- tion is 25,014 acres (3,056 AUMs). This amounts to 8.2 acres of treatment per AUM of forage, which is less productive than the 3.6 acres of treatment per AUM in the portion that would be designated wilder- ness. c. BLM does not show how much of a "tempor- ary" loss of forage would result from mineral activ- ity in areas not designated as wilderness in the Pro- posed Action. Given the unlikely event of seeding or reseeding areas with less than 11 inches of precipita- tion per year, it appears many WSAs would have little chance of recovery of surface disturbance since rainfall is less than 11 inches in the nonmountainous WSAs. Therefore, these "temporary" forage losses could become permanent. If the 63,853 acres of sur- face disturbance in the nondesignated portion of Alter- native 1 were as productive as the 25,014 acres of land scheduled for vegetation manipulation, there would be a net loss of AUMs. 18.4 RESPONSE: The licensed use figure of 96,521 AUMs was calculated as a ratio of the total AUMs and acres established for each allotment and the acres of the allotments within WSA boundaries. WSAs contain portions of several grazing allotments with very few allotments being totally contained within WSAs. This situation makes it impossible to determine actual live- stock use in WSAs, and the 96,521 AUM figure is the best available estimate. The AUM figure shown for range improvements is based on land treatments that would be done outside designated wilderness areas and would be managed as permanent AUMs up to a permittee's authorized permit. No increase in live- stock use above a permittee's grazing privileges will be allowed. Land treatments would not be allowed 3 GENERAL COMMENTS AND RESPONSES SECTION 18: LIVESTOCK AND WILD HORSES/BURROS within designated wilderness areas. Range improve- ments such as corrals, fencing, wells, spring develop- ments, etc., inside designated wilderness areas would be for the enhancement of livestock distribution (see Draft EIS, Volume I, page 31). The difference in AUM figures shown for what is being allowed outside the designated wilderness areas and what was dropped is due to different sites that are involved. Reclamation of mined areas is required. Based on an average of 33.5 acres per AUM (3,237,327 acres divided by 96,521 AUMs) for WSAs in general, and 8.18 acres per AUM in treated areas (25,014 acres divided by 3,056 AUMs), forage production would increase with reclamation of disturbed sites. The figures and projec- tions have been updated for the Final EIS, but the con- clusions remain the same. Also, see the response to General Comment 24.5, which discusses the economics of land treatments. 18.5 COMMENT: A cumulative analysis is needed to provide for a national perspective of grazing. [John Veranth, Randolph Jorgen, et al.] a. The potential 7,373 AUMs foregone is a very minor price to pay for the preservation of over 3 million acres of wild lands. This foregone loss needs to be put in perspective with national concerns and desires to keep its importance from being overblown. The potential loss of future land treatment areas and other grazing is overstated throughout the Draft EIS. The current oversupply of cattle in this country and the very small percentage (20 percent) of cattle grazed on public lands make this loss insignificant. A national perspective outweighs a local rancher's per- spective in this situation. b. What percentage of AUMs are in wilderness areas compared to the total AUMs available in the State? In the nation? How many cattle can actually be raised with those AUMs? c. The appropriate level of grazing may be less than historical levels and should be determined on a year-to-year basis by local managers. The total live- stock grazing within WSAs is not compared to nation- al production. Since the table on page 81 shows only 96,251 AUMs, the size of the livestock production is obviously insignificant from a national standpoint. 18.5 RESPONSE: The economic effect of wilder- ness designation has been discussed on a State and local level in Volume I, and Volumes II through VI. It is recognized that the elimination of livestock use in des- ignated wilderness areas would have a very minor im- pact on livestock production nationwide, but would have an impact on a local and Statewide basis; how- ever, livestock grazing will continue with or without wilderness designation and adjustments in livestock number will follow standard BLM rangeland practices. See General Comment Response 18.1 for further de- tails. 18.6 COMMENT: Livestock control can be accom- plished outside WSAs as well as within. [Utah Wilder- ness Association] We fully support the rights of any rancher to use existing grazing areas. We want to emphasize, and BLM should too, that grazing can be controlled in non- wilderness areas just as easily as in wilderness areas. These controls are implemented if problems with water quality, wildlife habitat, and overuse occur. BLM must address this point in the Final EIS. 18.6 RESPONSE: Rangeland analysis in wilderness areas will follow normal BLM standards. These stand- ards are the same procedures used to establish graz- ing levels, both outside and within wilderness areas. The EIS points this out in the description of the alter- natives. Also, see the response to General Comment 18.1. 18.7 COMMENT: The location of sheep grazing re- ported in the EIS is wrong. [Utah Wilderness Associ- ation] The Draft EIS is flawed in its analysis of impacts on ranching practices. Under the heading "Impacts On Ranching Practices" (page 116), it lists five WSAs with sheep that could be affected by limiting use of ways for water hauling or salting purposes under the Proposed Action. However, the SSAs for those speci- fic acres note that little motorized use for grazing is currently taking place. The ways on the benches that are used for these purposes are excluded in BLM's Proposed Action in the Notch and Howell Peak WSAs. Even more disturbing is the listing of Floy Canyon. The sheep allotments occur in the southwest corners of the WSA. However, this alternative only selects the northern third of the WSA for wilderness. There is no sheep grazing within the Partial Wilderness Alternative in this alternative. 18.7 RESPONSE: Generally, sheep use in these areas occurs in the winter, with sheep relying on rain 4 GENERAL COMMENTS AND RESPONSES SECTION 18: LIVESTOCK AND WILD HORSES/BURROS and snow for water; therefore, only limited vehicle use is required. However, on the occasions when it was necessary to haul water, vehicle use would be limited in designated wilderness areas. The sheep use mentioned on page 116 refers to the West Desert and Book Cliffs Allotment and does not include Floy Can- yon. 18.8 COMMENT: There are editorial errors in the livestock grazing analysis. [Utah Wilderness Associa- tion and State of Utah] a. Table 67 on page 116 conflicts with Table 70 on page 141, and the other tables in Chapter 4 show- ing existing and proposed range improvements as to what improvements would be allowed in designated wilderness. The footnotes are placed in the wrong spots on Table 67, which would seem to indicate all improvements would be banned. This is obviously not intended and, in fact, conflicts with the statements throughout the Draft EIS that most improvements would be allowed. The placement of footnotes on Table 70 are correct. b. Page 119, items 1, 2, 3, and 5: It should be made clear that items 1-3 apply only to grazing. Sec- tion 65 is the correct reference for item 5. 18.8 RESPONSE: The table referenced in the com- ment has been revised and incorporated into Table 12 in the Final EIS. Items 1 through 6 applied to all re- sources involved, not just grazing. The reference for item 5 should have been 65 rather than 64. Most of this section has been removed in the Final EIS in re- sponse to the current State of Utah policy on ex- change of in-held lands. 5 GENERAL COMMENTS AND RESPONSES - SECTION 19 VISUAL RESOURCES INDEX 19.1 The BLM scenic inventories and analysis used in the EIS are inadequate and subjective. BLM used inval- id comparisons for visual quality, (p. 1) 19.2 The EIS should recognize that wilderness designa- tion will protect scenic values and limit disturbing im- pacts. Desert environments are fragile, (p. 2) 19.3 Aircraft use over wilderness areas should be allowed so that people can enjoy their beauty from the air. (p. 3) 19.4 The scenic values of the WSA should be arrayed in tables and maps throughout the EIS. (p. 3) 19.5 Grazing should not continue in wilderness areas, especially in VRM Class I areas, (p. 3) COMMENTS AND RESPONSES 19.1 COMMENT: The BLM scenic inventories and analysis used in the EIS are inadequate and subjec- tive. BLM used invalid comparisons for visual quality. [Valarie Cohen, Owen Severance, et al.] a. Quite often in the Draft EIS, BLM finds areas to possess "low primitive recreation values" or "low scenic values." It is clear that the people making such judgments are operating with an inapplicable aesthet- ic bias. BLM tends to judge recreation (camping, hik- ing) by forest standards. But the deep forests and pretty mountainsides found on FS lands do not exist in Utah BLM desert lands. I believe all findings of "low" values should be restudied by specialists who like desert scenery and desert camping. b. VRM rating system (Volume I, page 353 of the Draft EIS): That BLM should presume to rate Utah's wilderness areas according to this "scenic quality" rating system is inappropriate. Moreover, this artifi- cial system has been used to drop areas or recom- mend no wilderness in absolute contradiction of true beauty. Clearly, BLM's scenic decisions are based on an archaic aesthetic taste, a taste developed in green, mountainous landscapes. I do not believe BLM can say what is pretty and what is not by using FS standards. Another case of subjectivity. Scenic val- ues are largely personal-what one person would con- sider "monotonous" (using BLM's Class C definition), another may consider exquisitely serene, lovely, and fascinating in its simplicity. Dramatic landscapes are not always necessary for wilderness experience, sce- nic beauty, or solitude. BLM's judgments seem more determined by mining interests than by any standard of scenic value, if such a standard is even possible. I am appalled at BLM's repeated omission of true wil- derness on the basis of biased opinions. Again, BLM must acknowledge its subjectivity so that the reader who has never seen this country is made aware these judgments are not necessarily in agreement with his own ideas about beauty and scenic value. c. In the Deep Creek Mountains WSA, the claim is made that Class C scenic quality is "average." In the King Top WSA, areas having "low scenic values" are determined to be Class C. According to Volume I, Appendix 7, Class C areas are "monotonous." I don't equate "average" with "monotonous." Average scenic quality should be rated Class B. One of the most glar- ing examples of mislabeling scenic quality occurs in the Road Canyon WSA in Volume V where the Valley of the Gods is rated as Class C instead of Class A. 19.1 RESPONSE: The scenic/visual value system generally used by BLM evaluates scenery within indi- vidual physiographic provinces to reduce the bias that would occur if timbered landscapes were compared with desert landscapes. These physiographic pro- vinces are not compared with each other, but land- scapes within a province are evaluated to determine where the greatest scenic/visual values exist. The Basin and Range, sometimes referred to as Great Basin (plains with widely spaced hills or mountains,) are not evaluated against the Colorado Plateau (par- tially dissected tablelands) or the Middle Rocky Moun- tains (high mountains) physiographic provinces. The FS's scenic/visual value standards were not used in a comparison with BLM land for two reasons. First, the criteria for the FS landscape management system are similar but not identical to BLM's VRM system evaluation criteria. Second, except for two areas being studied by the Colorado BLM, West Cold 1 GENERAL COMMENTS AND RESPONSES SECTION 19: VISUAL RESOURCES Springs and Diamond Breaks, none of the BLM WSAs fall in the Middle Rocky Mountain physiographic pro- vince. Potential wilderness areas were not taken out of wilderness consideration solely on the basis of scenic quality because scenery is a supplemental wilderness value and is only one of the many values identified in the Wilderness Act, Section 2.C. criteria. The Wilder- ness Act states that wilderness "may also contain" these values. Scenic quality is not required for wilder- ness, but it is important that this quality be noted and considered in assessing the wilderness potential of a unit. The presence of this value does enhance wilder- ness quality. Appendix 1 1 summarizes BLM's ration- ale for the Proposed Action. Not all landscapes will possess high scenic/visual values under any evaluation system, but areas with a lower scenic/visual value may offer serenity, simpli- city, and solitude and may be suitable for wilderness designation. Some desert landscapes will have a reduc- ed scenic/visual value as compared with other desert landscapes. The BLM Wilderness Study Policy (UASI, BLM 1982A) directs BLM to assess the importance of special features in each WSA. The scenic/visual evaluation system is a subjec- tive measure of the visual appeal of the land or land- scape type. Any evaluation system for scenery will, of necessity, be subjective, and agreement from everyone would be impossible to achieve. BLM's VRM system has been in use since 1975 and provides a standard methodology for BLM to identify land-scapes with the highest scenic/visual values for considera- tion when evaluating against other resource values. Scenic/visual quality of a landscape type is eval- uated on variety and composition. Those with greater variety and composition are considered to have the highest scenic value because the viewing public appre- ciates variety and composition in the landscape. The criteria and terms utilized in the rating system are explained in Appendix 7 of the EIS. Appendix 7 has been revised. The word "monoto- nous" has been removed and replaced by an explana- tion of the meaning of Class C scenery. The words low, average, etc., have been deleted and replaced by a reference to the definition of Class C scenery. 19.2 COMMENT: The EIS should recognize that wil- derness designation will protect scenic values and limit disturbing impacts. Desert environments are fragile. [Utah Wilderness Coalition, Randolph Jorgen, Lucy Wallingford, et al.] a. In the long run, scenic beauty is southern Utah's greatest asset. Mineral resources are quickly exhausted by mining which leaves a ruined landscape. Properly protected, the scenic aspects of Utah will continue to draw people from all over the country for lifetimes to come. Once roaded and exploited, it is damaged for lifetimes to come. b. Other issues not analyzed on a Statewide basis but for which impacts would be significant on a State- wide basis include visual resources, wildlife, cultural resources, air quality, water resources, and social impacts. The preservation of visual resources is one of the greatest reasons for the popularity of the wil- derness system, since wilderness designation pre- serves visual resources far better than any mitiga- tive or planning measures with development. The 1 percent of Statewide area mentioned as potentially disturbed (page 184), even though in itself an under- statement, would have a visual impact far beyond the actual acreage disturbed, especially since it would be to the degradation of some of the finest wild areas left in the State. c. If we allow certain developments to mar the natural state of our beauty, you can't reclaim it later. The desert where we live is very fragile and, even though BLM often claims they can reclaim cer- tain roads an certain areas, it can't be done. I have visited these sites, and it is simply not true. 19.2 RESPONSE: The Visual Resource section in each of the individual WSA analyses recognizes that wilderness designation would reduce the potential for surface-disturbing activities that could impair visual quality. In addition, potential effects on visual quality are analyzed for each State alternative in the Special Features portion of the Wilderness Values sections. Additional information on the reclamation poten- tial for disturbed areas has been included in the indi- vidual WSA analyses in the Final EIS. Also, see Gene- ral Comment Response 12.4 which addresses reclama- tion potential. Reclamation of disturbed lands is only one method used to minimize change in visual quality. Location, screening, and use of less disturbing techniques for 2 GENERAL COMMENTS AND RESPONSES SECTION 19: VISUAL RESOURCES projects are also effective means of reducing visual impacts. 19.3 COMMENT: Aircraft use over wilderness areas should be allowed so that people can enjoy their beauty from the air. [Mark Tanner] I had the opportunity yesterday to fly over many parts of the WSAs. I was awestruck at their beauty as seen from above. This having been my first oppor- tunity to view the area from the sky, I wondered how many people would be denied this wonderful tour if wilderness designation prevents air travel above wil- derness areas. 19.3 RESPONSE: Aircraft use may continue over wilderness areas where such use was established pri- or to the date the area entered the NWPS. There is no specific prohibition of overflights above wilderness areas by aircraft. However, low-flying aircraft do disturb an area's solitude. Where low overflight is a problem or is expected to become a problem, such use will be monitored. Liaison with proper military author- ities and the FAA will be established, along with con- tact with pilots in the general area, in an effort to preserve the wilderness character. In general, the FAA promotes a 2,000-foot minimum altitude for overflights. Military aircraft and operations over wil- derness areas will likely continue in the same manner as before designation. Also, see the response to Gen- eral Comment 22.7. Wilderness values are best enjoyed when exper- ienced from the ground; air travel is not the best way to enjoy the wilderness experience. However, limited wilderness experience can be enjoyed from an eleva- ted observation position, either at a low level or at a greater distance for high-level flights. Most land- scapes are not fully appreciated until viewed from the ground. Distance reduces visual detail and, thus, makes dissimilar landscapes appear similar. 19.4 COMMENT: The WSAs' scenic values should be arrayed in tables and maps throughout the EIS. [State of Utah, Frances Fericks, et al.] a. Tabular presentation of visual resources in- cluded in Volumes II and IV by the Richfield District is effective and informative. A similar chart should be included in all WSA analyses. b. Charts and maps in the Draft EIS were gener- ally very helpful. However, special features identi- fied in the text were sometimes not identified on the maps. This made it very difficult to determine how partial boundaries affect special features, canyons, mesas, bristlecone pine stands, etc. Visual resource charts were very helpful when they were used. The Richfield District did a good job of quantifying visual resources in the charts. 19.4 RESPONSE: Scenic values were not always tabulated because the narrative form is just as effec- tive when only one or two VRM classes are represen- ted in a WSA. The same level of information on visual resources is included for each WSA. Verbal descrip- tions are often used in place of maps. Also, see Gen- eral Comment Response 26.1. 19.5 COMMENT: Grazing should not continue in wil- derness areas, especially in VRM Class I areas. [George Hinde, et al.] How can the WSAs designated as wilderness be managed under VRM Class I (which generally allows for only natural ecological change) when domestic livestock grazing would continue without change? 19.5 RESPONSE: Section 4(d)(4)(2) of the Wilder- ness Act provides for continued livestock grazing where established prior to the area's designation as wilderness. Congress decided that, if grazing had been established prior to this process and the area under study still possessed wilderness and scenic values, continued grazing at that same level would not adversely affect those values. Maintaining the visual qualities at the same use level, including esta- blished grazing, would be the goal of VRM Class I. Also, see the response to General Comment 18.2, which discusses livestock grazing wilderness areas. 3 . * GENERAL COMMENTS AND RESPONSES - SECTION 20 CULTURAL RESOURCES INDEX 20.1 The Draft EIS incorrectly assesses the impact of wilderness designation on vandalism rates. Wilder- ness designation reduces (or increases) vandalism activities, (p. 1) 20.2 BLM needs to conduct an inventory of the cultur- al resources in WSAs. Why is a cultural resource in- ventory lacking or inadequate for the Draft EIS? (p. 3) 20.3 There are discrepancies in the Draft EIS concern- ing BLM's management plans. How does BLM plan to manage the cultural values in wilderness areas? (p. 5) 20.4 The Final EIS should specifically address BLM's enforcement capabilities, the extent of new roads and ORV corridors in areas not designated wilderness, special problems caused by population influxes associ- ated with energy or mining projects, and the effects these would have on cultural resources under each alternative, (p. 6) 20.5 The analysis of historical resources is incom- plete and unprofessional, (p. 6) COMMENTS AND RESPONSES 20.1 COMMENT: The Draft EIS incorrectly asses- ses the impact of wilderness designation on vandalism rates. Wilderness designation reduces (or increases) vandalism activities. [Randolph Jorgen, John Noxon, Utah Wilderness Coalition, University of the Wilder- ness, William Hause, Wasatch Mountain Club, Steven Manning, Megadon Energy Corporation, et al.] a. The statement that to leave lands open to devel- opment will preserve cultural resources almost as well as would wilderness designation is indefensible. Many of the areas in the State with the highest poten- tial for new and significant archaeological finds in an undisturbed condition lie in these relatively unexplor- ed areas. To say that they would be protected by laws just as well as by their present remoteness is clearly not true. The actual effect of wilderness des- ignation is to limit mechanized access by which most vandals do their business, as well as to eliminate the possibility of destruction by ORV activity. It is well known that archaeological studies which result from finds in an area marked for development are general- ly of the salvage variety, hurried and not in depth, re- sulting in much less information being gained than if the site had been preserved for more careful study or for future generations to study with their better me- thods. As acknowledged, prohibition of development would also lessen the likelihood of inadvertent de- struction of sites. In light of this marked protective effect and the importance of cultural resources, why has this issue not been given at least as much atten- tion as minor considerations such as ranching opera- tions? b. The Draft EIS states: "Vandalism of sites would be expected to increase in proportion to the general population increase" (Volume I, page 185). This naive concept does not take in account the mounting problem of commercial vandalism, which is far more destruc- tive than the "malicious" or "unintentional" vandalism effected by local populations. BLM must address the problems of commercial vandalism and the projected effects of this activity on cultural resources in the proposed wilderness areas. As an example, commercial vandalism is now be- ing conducted with helicopters. How will wilderness status protect or impede helicopter vandalism? c. The Draft EIS assumes that cultural resources will not be adversely impacted because BLM has a legal requirement to protect such resources. This is unrealistic. Some losses, probably significant, would occur if WSAs were opened to widespread ORV use and road access. The presence of a legal requirement to protect the nation's vanishing archaeological and historic resources does not guarantee that further losses will not occur. The Draft EIS should be revised to acknowledge that losses are more likely to occur if areas are not designated wilderness and vehicle ac- cess is eventually allowed. The Draft EIS should fur- ther acknowledge that wilderness designation can aid BLM in preventing losses through restriction of motor- ized access. The Draft EIS does acknowledge that some "wilderness special features," notably unusual 1 GENERAL COMMENTS AND RESPONSES SECTION 20: CULTURAL RESOURCES plant or animal communities and geologic features, could be lost in areas not designated (Volume I, page 112). An equivalent logic applies to historical and archaeological resources. BLM simply does not have the money and personnel to police every area where vandals and pot hunters have easy vehicle access to cultural resource sites. The best intentions and legal requirements have so far barely slowed the alarming loss of these irreplaceable treasures. The key is ac- cess: the easier it is to haul out quantities of arti- facts, the more likely they will be lost, and wilder- ness designation can be one means of controlling ac- cess. By and large, recreational users of wilderness respect cultural resource sites. The presence of hik- ers and backpackers probably discourages commer- cial pot hunters. These considerations should be addressed in the Draft EIS. d. The foremost value and use of wilderness in the future will be for educational and scientific pur- poses. For 13 years, we have conducted educational and research activities, primarily by backpack, in a number of the areas proposed for wilderness designa- tion. Included are areas in the Escalante, Cedar Mesa and Lower San Juan, Henry Mountains and Dirty Devil, Canyonlands, San Rafael Swell, and Book Cliffs regions. In all these areas, there are irreplaceable archaeological sites, petroglyphs, and pictographs that will be lost to future generations unless steps are taken immediately to keep motorized looters off the public lands. We all know that there are laws against removal or disfacement of archaeological artifacts, and also we all know that it is impossible to enforce those laws in the vast areas of public land suitable for wilderness designation as long as motor vehicles are allowed to roam the backcountry. e. There is little debate that some of the most sig- nificant archaeological properties in the nation are found in areas Utah BLM will recommend for wilder- ness. These sites must be protected. The Central Ida- ho Wilderness Act calls for a program that: (1) en- courages scientific research into man's past use of the area; (2) provides for protection of cultural re- sources, including protection from vandalism and loot- ing; and (3) encourages development of a public inter- pretation program. Utah BLM will make specific rec- ommendations on wilderness acreage to the Secre- tary of the Interior. When this information is submit- ted to the Secretary, BLM should also recommend that specific language preserving and protecting cul- tural resources be included in the proposed legislation submitted to Congress by the Department of the Interi- or. This issue will be raised during Congressional hearings on Utah BLM wilderness; hence, the agency should begin to plan for this at the present time. f. There is a strong relationship between ease of vehicular access in undesignated/unprotected BLM areas and cultural resource vandalism. Rock art pan- els along roads through the San Rafael Swell and Sego Canyon have been shot in senseless acts of wanton destruction. Other vandals, determined to leave their marks on the world, have written over some of this priceless Native American art. Still others have apparently taken a fancy to the art and removed slabs. Damage continues unabated to this date, as the 1985 autographs on the Sego Canyon panels testify. Looting and destruction have also occurred at burial or habitation sites. Many sites in the Grand Gulch region, accessible by ORVs or motorized trail bikes, have been potted. Rare Basketmaker antiquities, unique to the area, have been removed from BLM lands and sold on the black market. BLM has also inad- vertently contributed to the destruction by careless- ly chaining down sites while chaining juniper trees south of Highway 95 near Mule Canyon WSA. We urge BLM to place more emphasis on protecting these sites through enforcement of antiquities laws, and to per- form surveys before chaining juniper stands. It is ob- vious that current regulations and enforcement are in- sufficient to prevent the continued destruction of our Native American heritage. Our members who have monitored cultural sites note a direct relationship be- tween site accessibility by road and the degree of damage. One obvious solution is to limit damage by limiting access to those who are willing to visit the sites through nonmotorized travel. We recommend wilderness designation as one means of limiting motor- ized access and the attendant damage to these out- standing natural and cultural resources. g. I am intimately acquainted with almost all of the WSAs. I have spent over 20 years exploring these remote areas. During these years I have searched for and found thousands of unrecorded archaeological sites. I have noted that destruction (both knowingly and unknowingly) is in direct proportion to visitor access and publicity. Thus, I take complete exception to the often-repeated statement in the Draft EIS con- cerning cultural resources: "Protection afforded by wilderness management would outweigh any potential vandalism problems caused by recreational activity, and the overall impact would be positive." This is not a demonstrated nor a proven fact. In fact, the direct opposite is true. Additional visitation into all the 2 GENERAL COMMENTS AND RESPONSES SECTION 20: CULTURAL RESOURCES WSAs as a result of their becoming wilderness areas will accelerate destruction of cultural resources. There is no other conclusion that can be reached. As a member of the Utah Governor's Task Force of Archae- ological Preservation, I confirmed my knowledge that vandalism has increased dramatically in all areas where recreational use has increased. One of the best methods of protecting cultural resources is preserv- ing their anonymity. The designation of an area as a wilderness will only increase visitation with result- ant loss of anonymity and destruction of those cul- tural resources that we are trying to protect. h. It has been my experience that many of these withdrawals become invitations for vandalism. Many of the people visiting the areas desecrate and destroy the antiquities and culture by taking souvenirs and painting crude words or pictures on the canyon walls. These same areas and antiquities have survived many centuries and generations in their present state when special attention is not drawn to them by a wilder- ness or park designation. If tracts II through VI are designated wilderness, then the only possible way to fight fires, retrieve lost individuals, make archaeo- logy data recordings, help endangered species of wild- life and plant life, graze livestock, regulate tourism’s environmental impact, etc., would be on foot access only. All of the above would suffer from designated wilderness. Many archaeological sites have been van- dalized from tourism because the vandals know and are getting away with such tactics because of no or little access to many of the tracts studied for the NWPS. 20.1 RESPONSE: Statistically, it has been shown that most collectors and amateur diggers prefer accessible areas, while commercial diggers prefer remote, inaccessible areas (Nickens, et al., 1981). It is concluded that, although accessibility is a factor influencing pot hunting, the degree of impact is essen- tially the same everywhere on public lands where known sites occur. With the exception of potential pro- blems in manageability and monitoring sites, designa- tion should not alter this situation. BLM could monitor these activities, develop specific cultural resource management plans, and adjust protection efforts accordingly with or without wilderness designation. Those who chose to confront laws designed to protect cultural resources would likely disregard restrictions on use of motorized vehicles and helicopters. Wilderness designation will afford additional pro- tection to cultural resources by reducing the potential for disturbance by projects, road developments, and use of ORVs as stated in the EIS analysis. The Final EIS concludes that there is no permanent relationship between wilderness designation and in- creased visitation. See General Comment Responses 21.15 and 21.17. Overall, designation should benefit cultural re- sources through priority to planning and protection efforts. This conclusion is reflected in the analysis of cultural resources in the specific WSA analyses in Final EIS. 20.2 COMMENT: BLM needs to conduct an inven- tory of the cultural resources in WSAs. Why is a cul- tural resource inventory lacking or inadequate for the Draft EIS? [Utah Wilderness Association, Utah Wilder- ness Coalition, John Noxon, Uintah Mountain Club, et al.] a. Inventories for cultural resources in WSAs are not planned. In Volume I, page 243, BLM states: "Wil- derness designation would not change intensity or number of proposed archaeological inventories. Arch- aeological inventories would not be done in all WSAs prior to Congressional action." Nor, it seems, are they even allowed unless approved by the State Direc- tor, except on a case-by-case basis. BLM admits less than 1 percent of the acreage under review has been inventoried for cultural resources and that the poten- tial for discovery of additional sites (beyond the 1,600 already known) is high within 50 WSAs. Yet nowhere is there even mentioned that a complete list of the known sites exists detailing the location, site type, site condition, site inventory, site ranking, present management direction, future management goals, etc. BLM admits many more sites could exist and that they have no plans for any surveys to find them. Once found, it appears the management direc- tion includes essentially either nomination of im- portant sites to the National Register or leaving them "to the forces of nature in the same manner as other wilderness resources." No complete inventory has been done and there are no plans to do one. There is no mention of the range of site protection measure, possible damage from ORV use, archaeological consul- tation agreements with State universities, etc. The management options are vague and limited and do not seem to address any specific area or objective. All of this would seem to indicate BLM has tried to make the idea of cultural resources a nonentity in the wilder- ness study process. In the least, that is unfortunate 3 GENERAL COMMENTS AND RESPONSES SECTION 20: CULTURAL RESOURCES and would appear to go against the direction of the Wil- derness Study Policy, which states: "However, as part of the wilderness study process, these (optional wilderness) characteristics should also be thoroughly considered when assessing an area's overall value as wilderness . . . These special features of the area and the degree to which their presence enhances its suita- bility for wilderness designation should be addressed through consideration of the area's ecological, geolog- ical, scenic, and cultural features, and its scientific and educational values. The evaluation should be based on an assessment of the estimated abundance or im- portance of each of these values to the area." With no inventories, it is impossible to adequately address cultural resources. b. Considering the immense total acreage being considered for wilderness designation, there is poten- tially an immense number of significant cultural re- sources involved. Recreation, fire control, mining, and grazing have Wilderness Management Plans. Why not cultural resources? We recognize that wilderness designation has some positive effects on cultural re- sources; namely, the limitation of motorized access. However, it cannot be assumed that the mere limiting of motorized access will negate impacts to cultural resources within wilderness areas. The increased vis- itation to wilderness areas will make it mandatory that cultural resources be actively protected. Public interpretation and education will also be critical to mitigate potential damage to cultural resources. A full Class III level cultural resource inventory of wil- derness areas would provide the data to not only un- derstand the scope of the resource, but to formulate a cultural resource management plan. c. Wilderness values are assumed by BLM to be absent when not inventoried. BLM has failed to inven- tory current wilderness use. Monitoring of the num- ber of hunters, hikers, and wildlife is absent. BLM doesn't know the number of archaeological sites found in roadless lands. Even without this comprehensive in- ventory, what little is known irrefutably makes these lands some of the most remarkable in the country. d. The estimate of approximately 4 percent cul- tural resource sites (1,600) based on current infor- mation is deceptively low. This misleading estimate will lead to inadequate assessment, planning, and poor management consideration of cultural resources in proposed wilderness areas. The bulk of cultural re- source sites are added to the Historical Society regis- ter as the direct result of archaeological clearance for energy exploration and public-works development (power access corridors, well pads, road corridors, etc.). Most development projects are conducted in areas of existing roadways or easy access outside of the proposed wilderness areas that are generally characterized by rugged terrain. It is, therefore, nec- essary to develop a realistic formula, and a projected calculation of cultural resource sites is necessary to adequately assess the value and merit of these sensi- tive resources in the proposed wilderness areas. The issue of cultural resources (Volume I, page 185) is inadequately addressed. e. The BLM Draft EIS estimate of 40,000 cultural resource sites for Utah is deceptively low. Record en- coding into the Utah State Historical Society (the prime data collection center for Utah) has been inef- fective and slow until recently. A recalculation of data based upon recent site encoding times the per- centage of new sites being added to the register year- ly, with an adequate assessment of cultural resource potential based on environmental/cultural prefer- ence, will provide a more realistic calculation for evaluation and future projection of cultural resource sites in Utah. I believe that this projection is neces- sary to adequately address, plan, and manage cultural resources for present and future needs. f. With yet so many cultural sites (page 85) unin- ventoried, is there justification in rating potentials of this resource on BLM WSAs? In my experience, cul- tural sites abound in southern Utah on and off the lands in question and we should not equate potential for cultural resources on the same basis as one might rate mineral potentials. I believe the Anasazi cultural remnants found on BLM lands, in general, represent a national treasure irreplaceably unique and should not be discounted in lieu of something so ubiquitous as a bed of coal or barrel of oil. Cultural resource explora- tion ranks foremost in my wilderness experience, and I've found several BLM WSAs to harbor inspiring and life-enriching displays of Native American culture. g. BLM always puts off inventories of historic and archaeological sites until the last minute-when devel- opment is imminent. You stay just a jump ahead of the heavy equipment. Inventories done in this manner are often rushed and incomplete, and site studies are typi- cally perfunctory. Time is money to the extraction industries, and no one heels to pressure as easily as BLM. We know what roading and development have done to southern Utah. We feel that roading and motor- ized activities increase the possibility that sites will 4 GENERAL COMMENTS AND RESPONSES SECTION 20: CULTURAL RESOURCES be discovered and disturbed prior to adequate study and inventory. 20.2 RESPONSE: No direct or indirect effects to cultural resources from wilderness designation could reasonably be expected to occur and, therefore, no field inventories of WSA's have or will be conducted. In referring to scientific and educational values, the BLM Wilderness Study Policy states that the evalua- tion should be based on an assessment of the estimat- ed abundance or importance of the values to the area. The BLM has projected the nature, diversity, and dis- tribution of cultural resources for WSAs based on ex- isting knowledge and data. This existing knowledge allows an estimate of the relative abundance and im- portance of cultural resource values in the WSAs. With or without wilderness designation of any of the areas being considered in this EIS, the Bureau will follow standard procedures for assessment and miti- gation of effects resulting from site-specific projects in these areas in the future. The number of sites recorded in Utah as of Sep- tember 1988 was 45,235, and this figure has been included in the Final EIS. Also, refer to the response to General Comment 9.6. 20.3 COMMENT: There are discrepancies in the Draft EIS concerning BLM's management plans. How does BLM plan to manage cultural values in wilder- ness areas? [Utah Wilderness Association, et al.] a. BLM offers specifics concerning its manage- ment approach to cultural resources in Appendix 1, Part A, page 202 of the Draft EIS. "Cultural resour- ces, in most instances, will be subject to the forces of nature in the same manner as other wilderness re- sources. Study or management will not normally in- clude any excavation, stabilization, or interpretation activities. Salvage, rehabilitation ... on archaeologi- cal and historic sites; excavation; and intensive inven- tories may be permitted on a case-by-case basis . . . State Director approval is required on such projects . . . Those sites or structures that do not qualify for the National Register may be allowed to deteriorate naturally, or be removed or obliterated." The above management approach specifically counters what BLM writes in Volume I, page 85. "Long-term strategies for management of cultural resources revolve around the following use categories: (1) current scientific use; (2) potential scientific use; (3) conservation for future use; (4) management use; (5) sociocultural use; (6) public use; and (7) discharged use." Why does this discrepancy exist? And which management direction will BLM follow when it comes time to man- age BLM wilderness? Volume 47, No. 23, page 5108 of the Federal Register states: "A detailed Wilderness Management Plan for each area will not be developed during the wilderness study . . . However, the wilder- ness study should consider the basic thrust of the wil- derness management appropriate to the area in view of the expected uses and activities in the area . . . Attention should be given to means for protecting wil- derness characteristics (including special features) . . ." The confusion in the Draft EIS concerning how BLM will manage for cultural resources does not satis- fy the detail necessary in the "basic thrust" concept required above, and BLM needs to correct this pro- blem in the Final EIS. b. BLM has a unique opportunity to begin to crea- tively address the issue of management of cultural re- sources in wilderness areas. They also have the opportunity to define the concept of a wilderness area designated specifically to protect cultural resources. Disregarding these opportunities in the Draft EIS only compounds the other problems in the Draft EIS and indicates a lack of vision that will prove more harm- ful to cultural and historic resources than any of the "forces of nature." c. Under Executive Order 11593, the Federal gov- ernment is directed "... to administer and protect the cultural properties under their control; and to direct all pertinent actions towards the protection, maintenance, and restoration of archaeological, archi- tectural, and historic resources." Further, NEPA of 1969 (Public Law 91-190, 31 Statute .852; 42 USC 4321-4347) ensures that the Federal government will ". . . utilize all practical means to aid in the pre- servation of significant archaeological, historic, cul- tural, and natural aspects of American heritage." How will these important Federal laws concerning cultural resources be addressed by wilderness desig- nation? Specifics have not been outlined in the BLM EIS. d. Aggressive action concerning cultural re- sources in Utah is necessary to maintain and pre- serve the integrity of the resource. 20.3 RESPONSE: There is no discrepancy in the description of cultural resource management given in the Final EIS. The discussion on page 85 relates to the affected environment and describes BLM’s strategies 5 GENERAL COMMENTS AND RESPONSES SECTION 20: CULTURAL RESOURCES for protection of cultural resources as part of the normal BLM planning and management system. The management strategy given in Appendix 1, Part A, page 202 of the Draft EIS, is the strategy that would be followed in designated wilderness areas. A compar- ison of the strategies shows that wilderness designa- tion will result in less excavation and stabilization of cultural resources than at present. With wilderness, BLM will monitor impacts and protect cultural re- sources until perpetuity or until a critical research need or other issue becomes the overriding factor. A description of the management of cultural resources has been added to the description of the alternatives in the Final EIS. 20.4 COMMENT: The Final EIS should specifically address BLM's enforcement capabilities, the extent of new roads and ORV corridors in areas not designated wilderness, special problems caused by population in- fluxes associated with energy or mining projects, and the effects these would have on cultural resources under each alternative. [Utah Wilderness Coalition et al.j "is impressionistic and incomplete," "is not profes- sionally acceptable," and expresses dismay that the bibliographies to the various sections of this sample volume" cite not one single primary or secondary his- torical source," in spite of a Memorandum of Under- standing between the Division and BLM that a liter- ature search would be conducted. This is an additional example of the Draft EIS's serious lack of balance and comprehensiveness. 20.5 RESPONSE: BLM has reviewed the cited re- port and has consulted with the Division of State His- tory. None of the quoted conclusions were found. The Memorandum of Understanding referred to in the com- ment is located in Appendix 8 of the EIS. The standard procedure for literature search is for BLM to consult the District site maps and forms and then report on the number and type of sites present. A specific refer- ence is not required since these maps and forms are located in the BLM Districts and, as pointed out in the Introduction to Chapter 3, unless stated otherwise, information was taken from BLM sources. Also, see the response to General Comment 20.2. The cultural resources sections of the Draft EIS should specifically address: (1) BLM enforcement cap- abilities given limited budgets; (2) the likely extent of new roads and ORV corridors in areas not desig- nated wilderness; and (3) special problems caused by population influxes associated with large energy or mining projects. These problems may cause greater losses in nonwilderness areas than in wilderness, which should be considered in the EIS. 20.4 RESPONSE: The EIS analysis is based on the assumption that BLM will receive sufficient funding for wilderness management. The potential effects of ORVs, roads, and large developments on cultural re- sources are analyzed in the individual WSA analyses, Volumes II through VI. Analysis indicates that wilder- ness designation would provide additional protection for cultural resources by reducing potential for sur- face disturbance. 20.5 COMMENT: The analysis of historical re- sources is incomplete and unprofessional. [Dennis Willigan] In regard to historical resources on BLM lands to be preserved under wilderness designation, the Divi- sion of State History chose to analyze Volume V, Southeast Region, as a representative sample of the Draft EIS. The Division concludes that the Draft EIS 6 GENERAL COMMENTS AND RESPONSES - SECTION 21 RECREATION INDEX 21.1 ORV recreation should be recognized as a legiti- mate use of public lands. ORVs have significant eco- nomic and recreational benefits, yet limitations on their use are increasing, (p. 1) 21.2 The EIS should note that four-wheel drive ve- hicles provide access to backpacking areas. Road clo- sures may negatively impact visitors' wilderness ex- perience by limiting access to backpacking areas, (p. 2) 21.3 The term OHV should be used instead of ORV. (p. 3) 21.4 Wilderness designation will enhance primitive recreation but will not significantly hurt ORV use. ORV use and cherry-stemming are incompatible with wilderness, (p. 3) 21.5 Visitor use estimates and projections are incon- sistent and may be in error, (p. 4) 21.6 There are inconsistencies in discussions of rec- reational opportunities and impacts, (p. 6) 21.7 The Draft EIS's assessment of wilderness de- mand is incorrect, (p. 6) 21.8 There is (is not) a need for more wilderness in Utah. (p. 7) 21.9 Characteristics of wilderness users should be discussed in the Final EIS. (p. 7) 21.10 The EIS should analyze the effect of limiting vehicle use on hunting, (p. 7) 21.11 The effect of designation on ORV use on sur- rounding State and private lands has not been evalu- ated. (p. 7) 21.12 Must opportunities for primitive and uncon- fined recreation be outstanding? (p. 8) 21.13 Population control is needed. The EIS should note that overuse of wilderness areas will occur in the future because of population increases, (p. 8) 21.14 Demand for outdoor recreation in Utah is grow- ing. The EIS should recognize that the majority of Utahns use and enjoy wild lands, (p. 8) 21.15 The EIS analysis should show that wilderness will not stimulate tourism as much as recreational development, (p. 9) 21.16 BLM should promote tourism, (p. 10) 21.17 The EIS fails to adequately discuss the effect of wilderness designation on visitor use and the econ- omy. (p. 11) 21.18 The EIS should state that designation limits rec- reation use to a narrow range of recreational activi- ties and users, (p. 12) 21.19 The EIS fails to adequately assess the economic value of wilderness recreation, (p. 12) 21.20 BLM and the EIS are biased against ORV use. (p. 15) 21.21 The EIS should point out that designation of wil- derness areas may lead to overuse of nonwilderness recreation areas, (p. 15) COMMENTS AND RESPONSES 21.1 COMMENT: ORV recreation should be recog- nized as a legitimate use of public lands. ORVs have significant economic and recreational benefits, yet limitations on their use are increasing. [Utah Four- Wheel Drive Association, et al.] a. Recreational four-wheelers are generally fami- ly recreationists who use 4x4 vehicles to escape the pressures of overcrowded campgrounds. They are people who care about nature and the outdoors. They do not use their vehicles to damage natural values. These people have volunteered thousands of hours in cleanup and reforestation activities. They appreciate the fact that public land management agencies have 1 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION few funds available for the enhancement of recrea- tional activities. The desire of this group is to be recognized as legitimate recreational users of public lands, and that multiple use be the guiding force of public land manage- ment. They want four-wheel drive trails kept open for public use. b. Off-highway vehicle recreation has increased significantly in popularity in recent years. Sales of four-wheel drive vehicles and equipment account annu- ally for $12 billion of the $44 billion recreational ve- hicle industry. Off-highway vehicle owners are re- sponsible for the payment of millions of dollars in taxes and fees to various government agencies. Even as the popularity and use of off-highway vehicles increases, more and more lands are being closed to their use. About a third of the United States is owned by the Federal government. About 30 per- cent of the Federal lands are closed to motorized vehicle traffic. c. There are nearly 200 million acres within des- ignated or de facto wilderness areas at this time, and the total is still growing. Unfortunately, only a small percentage of recreationists are able to use this vast acreage. Surveys have shown that only small percen- tages of the recreational users are backpackers, while much larger numbers use vehicles for recrea- tion. It is true in Utah, as well as nationally, that most recreationists use motorized transportation. d. Recreation four-wheelers will not argue with preserving true wilderness. The beautiful, truly prime remnants of our national heritage should be pre- served. They will argue, however, with the creation of wilderness by calling an area roadless simply be- cause the roads have not been maintained by mechani- cal means on a regular basis. This constitutes a taking of our lands without justice or prudence. Wilderness eliminates legal roads and public access to public recreation. It intensifies use instead of dispersing it. 21.1 RESPONSE: BLM recognizes ORV use as one of the legitimate recreational uses of public land. The agency has been directed to categorize lands as open, closed, or limited for such uses. BLM has also been directed to study potential wilderness areas and to recommend areas to Congress for possible designa- tion as wilderness areas. Such designations would eliminate the use of ORVs within the boundaries of designated wilderness areas. The Draft EIS (Volume I, page 89) indicates that only about 4 percent of vehicle ways are located in WSAs within the three multi-county planning dis- tricts, which contain about 96 percent of the WSAs in the State. Eighty percent of WSAs contain vehicle routes within their boundaries; however, penetration of vehicle routes into WSAs has been greatly limited by topography. The impacts to ORV use occurring un- der each alternative are analyzed in Chapter 4 of the Draft EIS. Please note that, under the BLM Proposed Action, about 210 miles of existing ways currently open to ORV use would be restricted or eliminated. This is less than 1 percent of the existing ORV trails in the State as estimated by the 1980 Utah SCORP. This is not judged to be a significant decrease in the opportunities for motorized recreation activities in the State or on public lands within Utah. The impacts of ORV use on primitive recreation under various alternatives, including the BLM Pro- posed Action, have been identified in the Draft EIS. This will facilitate decisionmaking on wilderness designations. Also, refer to the responses to General Comment 1.3 which discusses access to wilderness areas, and General Comments 1.1 and 1.2 which address the val- ue of wilderness and the relationship of wilderness to the multiple-use concept. 21.2 COMMENT: The EIS should note that four- wheel drive vehicles provide access to backpacking areas. Road closures may negatively impact visitors' wilderness experience by limiting access to backpack- ing areas. [Dave Jarvis, Harry Melts, et al.] a. Four-wheel drive vehicles provide access on primitive roads and trails to areas where backpacking begins. Many backpackers combine this interest with recreational four-wheeling. Part of the adventure of backpacking in southern Utah is the access. If a large part of the four-wheel drive access is closed as part of the process of creating wilderness, a negative effect will be created in the wilderness experience of many people. b. If they would use more cherry-stemming, they would still have the wilderness character and will still make the logistic so much simpler and the areas usable for people who are not young and not willing to 2 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION backpack 20, 30, or so many miles. It will be utilized a lot more. BLM's Proposed Action will push out the ORV semiprivate recreationist from many traditional ORV use areas. The semiprivate motorized projected increase in use is consistently too low. The steady increase of ORV sales figures disputes that. 21.2 RESPONSE: It is recognized that many back- packers use and enjoy four-wheel drive vehicles as part of their recreational experience. However, statu- tory limitations exist on the use of vehicles in wilder- ness areas. Designation will eliminate vehicle use within wilderness areas. In many cases, developed WSA boundary roads allow the use of vehicular access routes to hiking areas. It is likely that four- wheel drive use will continue to be necessary in the future to reach backpacking areas designated as wilderness. This use is likely to increase in certain WSAs as noted in the Final EIS. Also, see the re- sponses to General Comment 4.1, 4.5, 21.5, and 21.7. 21.3 COMMENT: The term OHV should be used in- stead of ORV. [State of Utah] "Off-highway vehicle" (OHV) is the preferred terminology instead of "off-road vehicle" (ORV). The term off-highway vehicle seems to more accurately capture the essence of this activity. Most four wheel- ing occurs on some type of road, rather than as a cross-country event, and is generally done on under- developed or primitive roadways. The Utah Division of Parks and Recreation has encouraged various agen- cies to adopt a standard term, off-highway vehicle, in order to prevent confusion and inconsistency. 21.3 RESPONSE: The term ORV is used by BLM to describe all off-highway or off-road activities. The term, as used by this agency, can apply to vehicles, such as four-wheel drive vehicles, that are used primarily off-highway, but on some type of road or way. It is also used to describe vehicles, such as motorcycles, that are frequently used for cross- country travel or play, not necessarily on a road or way. The use of ORV in the EIS recognizes that both cases may apply. The term is defined in the Glossary of the EIS. 21.4 COMMENT: Wilderness designation will en- hance primitive recreation but will not significantly hurt ORV use. ORV use and cherry-stemming are in- compatible with wilderness. [Utah Wilderness Coali- tion, Berek Novak, et al.] a. Both wilderness-type activities and ORV activi- ties are growing. These conflicting interests will ine- vitably clash, given the growth trends, increasing free time, and the devotion to outdoor recreation pur- suits in Utah. While nonmechanized primitive recrea- tional activities, such as backpacking, are comple- mented and accentuated by large roadless tracts, motorized vehicles are best used on roads or ways. b. Most ORV areas are not presently within WSAs. However, the WSAs represent the only remain- ing areas where outstanding wilderness values exist. These areas should not be compromised to expand ORV areas. Backpackers do not greatly interfere with the enjoyment of ORV activities; however, ORV use is not compatible with backpacking or primitive recrea- tion. Contacts with ORVs will significantly disrupt the experience of primitive recreationists. c. The Draft EIS notes that much ORV use in WSAs has been associated with other types of recreation. This means that the large jeep-type vehicles are used mainly for access to remote areas for backpacking, camping, river use, etc., and not for ORV use as an end in itself. Existing or cherry-stemmed access roads may be appropriate in some places to provide access to especially remote areas. There is danger, however, that these ways could quickly become path- ways for generalized destruction if ORVs are permit- ted uncontrolled. Since there is currently no reasonable way to dis- tinguish between types of ORVs, it will require some careful attention and creative effort to deal with the issue of reasonable access and ORV use. We would like to see complete restriction of the ATV-type vehicles in WSAs. We also believe it is critical to leave dirt roads in their existing conditions and not upgrade them to surfaced roads. These just invite more and different traffic and are destructive to wilderness. 21.4 RESPONSE: Research has shown that incom- patibility exists between hikers and motorized recrea- tional users. The conflict is one-sided because mechan- ized users do not mind foot-travelers, but hikers very much dislike encounters with machine users (Lucas, 1971 and 1980). It is true that wilderness designation will pre- clude vehicle-oriented recreational activities within the boundaries of the designated area. As indicated in General Comment Response 21.1, WSAs contain very few of the existing ORV trails in the State. BLM’s 3 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION Proposed Action would not significantly reduce exist- ing opportunities for ORV recreation within Utah. It is also true that wilderness designation will protect wilderness users from encounters with ve- hicles which damage their recreational experiences. Cherry-stemming has been used in the BLM pro- posal to exclude roads penetrating into WSAs. Cherry- stemmed roads are not part of the WSA; they are ex- cluded from WSA status and form a linear penetra- tion of land without wilderness potential into the WSA. In a few cases, cherry-stemming provides ac- cess to trailheads or "jumping off" points for wilder- ness users on ways (vehicle routes which are not maintained by mechanical means). It is possible, depending on the terrain, that such routes could provide access for activities not author- ized in a designated wilderness area. Special manage- ment attention may be needed in these areas and other areas where the potential for unauthorized use is greater than normal to prevent prohibited encroach- ments or damage to wilderness area values. Paving of a cherry-stemmed road or way would probably not be compatible with preserving the char- acter of a designated wilderness area. Such deci- sions, however, would properly be made as part of a Wilderness Management Plan developed after designa- tion of the area. A decision on paving or upgrading of a road may also depend on the ownership of the road of underlying lands. This analysis has been included in the Final EIS. Also, see the responses to General Comments 4.1, 4.2, and 4.5, which respond to questions concern- ing the definition and use of roads and ways. 21.5 COMMENT: Visitor use estimates and projec- tions are inconsistent and may be in error. [State of Utah, Roger Jenkins, Sierra Club, et al.J a. What was the methodology used to determine visitor use days in WSAs, both actual and projected? It would be useful to include an appendix which ex- plains methodology. It would also be helpful to identi- fy studies or inventories that were used. b. Estimates of recreation use and of growth rates applied to recreation estimates are unsupport- ed. While the 1980 SCORP is cited, the growth rates that BLM applied are two to three times lower than those estimates. Two percent per annum is probably not a good average to use. Perhaps that may be appro- priate for some areas, but WSAs that are nearby to urban population centers, such as the Wasatch Front, warrant a much larger estimate. c. There is some question, also, concerning un- known usage of a specific area. In many of the dis- cussions, there is a statement to the effect that pres- ent usage levels are unknown, but BLM estimates "X" usage per year (usually quite low). There is no docu- mentation for this estimate and, for many areas, it is believed that estimates may be in error. When an im- precise growth factor is applied, errors are multi- plied by errors. The result is even larger possible errors. These estimates and multipliers are used through- out the volumes. It would be useful to approach this problem in specific rather than generic terms. In other words, estimates of usage and growth should be derived for specific areas whenever possible. For geo- graphic areas that are proximal to highly urbanized population centers, it would be reasonable to assume that (1) current use is higher because access is bet- ter and the area is closer; and (2) growth in future use is apt to be significantly higher than the 2 percent per year figure applied by BLM. d. Each volume should deal with recreational use projections consistently. Volumes II and III in particu- lar do not go into the same level of detail as other vol- umes. This dissimilarity and inconsistency among vol- umes prevents comparisons of anticipated usage among WSAs. e. Why were estimates of 5-hours driving time from a SMSA to a WSA and 12 hours for a visitor day used? What studies were done to determine these fig- ures? Cite the sources. f. A thorough analysis of recreational use of WSA lands is needed. This should include participation in hiking, camping, photography, fishing, river rafting, canoeing, rockhounding, technical climbing and boul- dering, orienteering, cross-country skiing, and wild- life and plant life studying. It should include recrea- tional visitor days for current and projected usage. 21.5 RESPONSE: Estimates of actual visitor use days in WSAs were made in several ways, with vary- ing reliability. In a few cases, where permits are re- quired for use, exact numbers are known and were 4 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION used in the Draft EIS. In other situations, visitor regi- sters or self-issued hiking permits have been used to estimate levels of visitor use. Research has shown that visitor registration rates at voluntary trail regi- sters are variable but are often low, reflecting as little as 20 percent of the actual long-term use of vis- itors. Short-term users of wilderness often do not register at all (Lucas, 1983 and 1985; Lucas, Schreu- der, and James, 1971; Lucas and Kovalicky, 1981). Where trail registers or self-issued permits are used, BLM field personnel have made estimates of total use by extrapolation, applying experience and research from trail registers. In past years, BLM has not had the means to study visitor use in most WSAs, and no data exist except the observations of BLM field personnel. In such cases, the estimates of BLM personnel have been included in the EIS as the best available estimate of visitor use. It is recognized that the reliability of these estimates is lower than where sampling has been conducted. Most WSAs in Utah (60 of 83) are within one day's drive of a major population center. Most WSAs are only lightly used. Only 23 WSAs receive 1,000 or more visitor days of use annually, and only six WSAs receive more than 10,000 visitor days of use per year. Most WSAs are within 1 -day's drive of the Wa- satch Front; however, the level of use in most WSAs is very low and the growth rates of visitor use are low. It appears that driving distance is a less critical factor in attracting visitor use than other factors. It is likely that well known areas will continue to receive greater visitor use than lesser known areas. If visitor use growth rates exceed the rate of popula- tion growth, this will probably occur in the few well known areas where most of the visitor use is occur- ring at the present time. The effect that wilderness designation might have on visitor use is not known; however, research indicates that, in the past, a per- manent relationship has not been shown to exist be- tween designation and a growth in visitor use (Jungst, 1978; Peterson, 1981; McCool, 1985). Experience in a recently designated, well known BLM area, Paria Canyon, indicates that visitor use since designation is at about the same level as that prior to designation. It is probable that this will continue to be the case as additional areas are designated. According to the 1985 Utah SCORP (Utah Outdoor Recreation Agency, 1986), based on estimates of the Utah Office of Planning and Budget, population growth in the State of Utah is expected to occur at an annual rate of 2.01 percent. Cordell and Hendee predicted that the demand for wilderness-type recreation would grow through the year 2000 at a rate slightly greater than that of population growth. Cordell and Hendee (1982) also found that recreational use of wilderness areas appears to be increasing most in well-known wilderness areas. In contrast, the 1985 SCORP projected annual increases in wilderness de- mand at about 7 percent through 2000. The response to General Comment 21.7 further discusses the 1985 SCORP estimates. Because most WSAs are little known and used, and there are a relatively large number of better known areas available to wilderness users in the re- gion, it is possible that growth rates in visitor use for many WSAs may be even smaller than that for the general population. However, there is considerable uncertainty in predicting a use figure for wilderness areas and considerable variation in the information available on this subject. Because of this uncertainty, the Final EIS pre- sents a range of possible future outcomes in visitor use. The Cordell and Hendee (1982) estimated growth rate, which approximates the rate of population growth of about 2 percent per year, has been used as the lower limit of the range, with the 1985 SCORP estimate being used as the upper limit. The assump- tion that future use of WSAs will increase between 2 and 7 percent per year is reasonable, based on the information available at this time. It was noted above that inaccuracies may exist in estimates of past visitor use to WSAs. It is also rec- ognized that estimates of future growth rates may also be inaccurate. However, it is reasonable to use the best possible data and most logical assumptions in developing projections and estimating impacts in the EIS. Only future experience can validate these esti- mates. Twelve hours per visitor day is the standard defi- nition for visitor use used by BLM, FS, and other agen- cies. BLM visitor use records and statistics are tradi- tionally reported using the 12-hour standard visitor day for all recreational activities. The Wilderness Study Policy (USDI, BLM, 1982a) requires the use of 5-hours' driving time from an SMSA to a WSA. As stated above, the best visitor use information available is included in the EIS. This information is often estimates based on experience of BLM field per- 5 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION sonnel. The attempt to further manipulate or refine these estimates would not be productive. 21.6 COMMENT: There are inconsistencies in dis- cussions of recreational opportunities and impacts. [Francis Fericks, et al.] There is a consistency problem in the Draft EIS in the way that recreation activities are handled. Some- times all actual and potential activities are listed, and several are identified as outstanding. In other in- stances, there is no indication of the quality or poten- tial opportunity for recreational activities. 21.6 RESPONSE: Revisions of the Draft EIS have been made in an effort to improve consistency; how- ever, the variability of basic data sometimes pre- vents a totally consistent treatment of recreational activities throughout the document. Also, see the response to General Comment 21.5. 21.7 COMMENT: The Draft EIS’s assessment of wil- derness demand is incorrect. [Randolph Jorgen, Utah Wilderness Coalition, et al.] A realistic estimate of wilderness demand is miss- ing from the EIS. BLM has relied on only one study in estimating the growth in demand for wilderness recre- ation in the future. Utah's unique and outstanding wil- derness opportunities are on the verge of a tremen- dous increase in notoriety and popularity. 21.7 RESPONSE: The 1985 Utah SCORP (Utah Out- door Recreation Agency, 1986) estimates the State- wide annual rate of population growth at 2.01 per- cent. It indicates that, in 1985, hiking/backpacking was the eleventh most popular outdoor recreation activity, with an estimated 4.57 million individual activity occasions. In 1995, demand for 9.11 million individual activity occasions are estimated, and 12.85 million in 2000. This is an annual increase of about 7 percent. In comparison, the 1985 SCORP estimates that, in 1985, motorcycling was the ninth most popular activity, with an estimated 5.57 million individual activity occasions. Four wheeling was judged to be the fifteenth most popular activity, at an estimated 3.27 million. Demand in 1995 was estimated to be 11.09 million for motorcycling and 6.52 million for four wheeling, annual increases of about 7 percent. These estimates were based on a Statewide sur- vey of outdoor recreation participation. Demand esti- mates were based on the TIM-P factor which is devel- oped using a formula deriving a single factor from several elements considered the most important com- ponents of recreational demand. The components used in the formula are leisure time, income, mobility, and population. Assumptions were made concerning future trends for each factor. These components were then combined and used as a multiplier on the 1985 esti- mated demand for recreation to determine projec- tions for the future. The authors of the SCORP recog- nized certain problems with data collection and analy- sis, but stated: ". . . the methodology presented is not without some inherent problems-but it is the best agency data we presently have" (Utah Outdoor Recrea- tion Agency, 1986). The demand estimates of the SCORP are in con- trast to the general estimates of future demand of Cordell and Hendee (1982). There are differences in the two sources. The SCORP estimates were directed at estimating demand Statewide for various activi- ties. While hiking/backpacking estimates can be assumed to be associated with backcountry or wilder- ness areas, estimates for ORV uses were not limited to primitive settings. The Cordell and Flendee esti- mates were directed to wilderness-type recreation and primitive and semiprimitive motorized recrea- tion. The Draft EIS cited Cordell and Flendee's (1982) conclusions that wilderness recreation demand through the year 2000 would grow at a rate slightly greater than that of population growth. They also con- cluded that demand for primitive and semi-primitive motorized recreation is expected to grow at about the same rate or slightly less than population growth. BLM recognizes that this estimate may be too low, given relatively low energy prices and the growth in the use of all-terrain vehicles. The SCORP information, not available during the preparation of the Draft EIS, provides additional in- sight into the difficult problem of estimating demand for recreation use of WSAs. This Final EIS allows for a range of possible future demand, using the Cordell and Flendee estimates as a lower limit and the SCORP estimates as a higher limit. Also, see the response to General Comment 21.5. 21.8 COMMENT: There is a need for more wilder- ness in Utah. [Utah Wilderness Coalition, et al.] 6 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION Demand for wilderness use will continue to in- crease. We can diffuse user impact in the future by increasing the lands designated as wilderness now. When population growth is considered, 5.1 million acres is a reasonable (or possibly low) estimate for the wilderness area that is needed. If we want wilder- ness solitude to have meaning in the year 2000 or 2042, we must act wisely now. 21.8 RESPONSE: Congress has recognized that the public lands of the United States may have the poten- tial to enhance the NWPS and to provide wilderness areas for future preservation and use. The process established by FLPMA is being followed to provide Congress with the information needed to help make decisions about how much land is needed and will qual- ify for the NWPS. This decision process is a difficult one. Certainly, setting aside large acreages now is a sure way of making wilderness available in the fu- ture. However, such action may have serious conse- quences for other public land values. BLM is com- mitted to providing factual input, with logical analy- sis of impacts and full public participation, to the President and Congress to assist in making the best possible decision. Also, see the responses to General Comment 8.9 which discusses the question of how much wilderness is enough, and General Comments 21.5 and 21.7 which discuss the future use of wilderness areas. 21.9 COMMENT: Characteristics of wilderness users should be discussed in the Final EIS. [Celsius Energy Company] The EIS does not address the type of person who uses wilderness. What do these persons need for a wil- derness experience? It is requested that the studies of Stankey and Lime be included in your decisionmak- ing process. You should then compare that data with the demographics of Utah to determine who it is who really will be using wilderness. Those studies indicate that: (1) all age groups use wilderness areas; (2) wil- derness users reflect the U.S. census in marital sta- tus; (3) wilderness recreation vacations are largely a professional and white collar phenomenon; (4) most wilderness users have above average education; (5) wilderness users come from high income tax brack- ets; (6) they are mostly urban dwellers; and (7) they claim some proficiency in wilderness skills. 21.9 RESPONSE: The characteristics of wilderness users are not considered a major factor in analyzing the significant issues of the EIS. Although this infor- mation is interesting and may be helpful in making certain management decisions, it is not a necessary factor in assessing the environmental impacts of wilderness designation. Also, see the response to General Comment 1.1 for information on the definition and purpose of the NWPS. 21.10 COMMENT: The EIS should analyze the effect of limiting vehicle use on hunting. [Mark Tanner, et al.] Motorized vehicle use will be prohibited in wilder- ness areas, but hunting will be allowed. What impact will there be on hunting if vehicles cannot be used in the hunt? Is hunting really left unrestricted? 21.10 RESPONSE: WSAs are generally not access- ible by vehicle. The Draft EIS (Volume I, page 89) indi- cates that only about 4 percent of vehicle ways are located in WSAs within the three multi-county plan- ning districts, which contain about 96 percent of the WSAs in the State. Eighty percent of the WSAs con- tain vehicle routes within their boundaries; however, penetration of vehicle routes into WSAs has been greatly limited by topography. Under BLM's Propos- ed Action, about 210 miles of existing ways current- ly open to ORV use would be restricted or eliminated. This is less than 1 percent of the existing ORV trails in the State, as estimated by the 1980 Utah SCORP (Utah Outdoor Recreation Agency, 1980). Since mo- torized access is physically impossible in the major- ity of lands included in WSAs, most hunting in WSAs is not dependent on vehicle use. The limitation of such motorized access would not significantly impact hunt- ing in the State of Utah as a whole. Specific instances where vehicle use for hunting in WSAs is an estab- lished practice have been noted in the individual WSA analysis, Volumes II through VI. 21.11 COMMENT: The effect of designation on ORV use on surrounding State and private lands has not been evaluated. [Utah Woolgrowers, Utah Counties, et al.] The impact on private and State lands surround- ing WSAs has not been evaluated. The statement is made that "wilderness areas will be closed to ORV use." Will this put a greater impact on surrounding public, private, and State lands? 7 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION 21.11 RESPONSE: As indicated in the responses to General Comment 21.1 and 21.10, the number of ORV trails in WSAs is a very small part of the total trails available in the State. ORV use in WSAs is not a signi- ficant part of ORV recreation within the State. Dis- placement of current ORV use will not result in a sig- nificant impact to State and private lands adjacent to WSAs. 21.12 COMMENT: Must opportunities for primitive and unconfined recreation be outstanding? [Bridger- land Audubon Society, et al.] BLM’s assessment of primitive and unconfined rec- reation is not satisfactory. The Wilderness Act states that primitive and unconfined recreation opportunities need only be present in an area; there is no require- ment for these opportunities to be "outstanding." Spe- cific reference is made to Table 53, Page 91. All WSAs should be reevaluated using the correct criter- ia for the number of acres with opportunities for primitive and unconfined recreation. SSAs for each should also be reevaluated using a proper interpreta- tion of the Wilderness Act. Corrections should be made where improper criterion has been used to de- lete acreage. 21.12 RESPONSE: The BLM Wilderness Study Poli- cy (USDI, BLM, 1982a) states: Section 2(c) of the Wilderness Act states that a wilderness area must have ". . . outstanding oppor- tunities for solitude or a primitive and unconfined type of recreation." The word "or" in this sentence means that it does not have to possess outstanding opportunities for both solitude and primitive recrea- tion; it only has to possess one or the other. The BLM wilderness study in Utah has been car- ried out in conformance with this policy. Also, see the responses to General Comment 2.12., 2.13, 2.14, 3.1, 3.17, 8.11, and 22.3, which discuss rating of wilder-ness values. 21.13 COMMENT: Population control is needed. The EIS should note that overuse of wilderness will occur in the future because of population increases. [Uniden- tified] Many people are supposedly in favor of protecting wilderness, but not one has mentioned the greatest threat to public lands, in general, and wilderness, in particular. The threat is out-of-control population growth in the State of Utah. If rapid population growth continues, even with wilderness designation there will be so many hikers that their experiences will be similar to those in Liberty Park in Salt Lake City. The hikers will probably all go to designated wilderness areas and leave the nonwilderness areas for those who really like to get away. 21.13 RESPONSE: Future demand for wilderness recreation in the State of Utah has been discussed in General Comment Responses 21.5 and 21.7 and in the Recreation sections of the EIS. 21.14 COMMENT: Demand for outdoor recreation in Utah is growing. The EIS should recognize that the majority of Utahns use and enjoy wild lands. [National Parks and Conservation Association, et al.] Travel and tourism is a billion dollar industry in Utah. It is the State’s natural and scenic areas that have made Utah a destination point. Visitation of Utah's national parks in 1985 was 7 million people. That's a 55 percent increase over the last decade. Utah's State parks show a similar pattern of visita- tion. They had about 5 million visitors in 1985, an increase of 37 percent over the last decade. Utah's Division of Parks and Recreation has called it a recreation boom, and they report that, in 1983, 93 percent of Utahans went picnicking, 71 percent went fishing, and 68 percent went camping. This boom is not likely to bust. Utah's population grew 37 percent in the 1970s. It has grown another 15 per- cent in the last 5 years. These figures reflect a reality that Utah’s elected leaders and Federal land managers should recognize, one that the vast majority of Utahans use, enjoy, and value Utah's national parks and wild lands. 21.14 RESPONSE: Future demand for outdoor rec- reation in Utah, especially as it relates to wilderness use and ORV use, is discussed in the responses to Gen- eral Comments 21.5 and 21.7, and in the Recreation sections of the EIS. 21.15 COMMENT: The EIS analysis should show that wilderness will not stimulate tourism as much as recreational development. [Multiple Use Coalition, Utah Farm Bureau Federation, et al.] a. Wilderness advocates say increased tourism comes from wilderness designation. The opposite is 8 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION more likely true. Eliminating motorized vehicles and roadways reduces tourists and locks out the vast majority of the public. b. Tourism figures for southern Utah are very im- pressive. If the tourism associated with Lake Powell and the national parks is taken away, the figures would be much lower. Most visitors to the national parks use roads and developed areas exclusively. Developing more roads is the way to increase tour- ism. 21.15 RESPONSE: Little information is available re- garding the effect of wilderness designation on tour- ism. General Comment Response 21.17 provides infor- mation on the changes in use of wilderness areas sub- sequent to designation. That response indicates that studies of the so-called "designation effect" show that little change has been documented in use patterns prior to and after designation of wilderness areas in the past. BLM experience in Utah indicates that in- creased use has followed significant publicity about an area. Publicity may be a more important factor in increasing use patterns than designation. It is unlikely that wilderness designation of WSAs would reduce tourism. As indicated in General Com- ment Response 21.1, the significance of vehicle routes and ways in WSAs in the State is small. Major roads penetrating WSAs are cherry-stemmed to allow access. It is not likely that a significant amount of vehicular use by tourists would be displaced by wil- derness designation. In addition, the topography of most WSAs is not conducive to construction of scenic roads in the future. Tourism is a major economic factor in southern Utah and in the State as a whole. Although there are no studies available that describe the effect of wilder- ness type recreation on tourism, as compared to non- wilderness recreation, information exists that can give insight into the significance of wilderness recrea- tion. Dalton (1982) surveyed Utah residents about the recreational activities they had participated in, both inside and outside their local communities in 1981. Since wilderness recreation does not occur within communities, the use outside local communities will be considered here. Dalton also evaluated recreational use in Utah by nonresidents. Among Utah residents, the most popular recrea- tion activities, outside home communities, were, in ranked order; Family gatherings Sightseeing/driving for pleasure Camping Fishing Play (unstructured) Visiting Fairs/Amusement Parks Picnicking Hiking/Backpacking Spectator Sports Swimming Among recreational visitors from outside the State, the most popular activities were, in ranked order: Malar Vehicle Tourists View Scenery/Visit Attractions Hiking/Backpacking Picnicking Fishing Swimming Photography Golfing Rockhounding Boating/River Running Commercial Air Tourists (1979-1980 data) View Scenery/Driving for Pleasure Downhill Skiing Picnicking Photography Swimming Hiking Horseback Riding Hunting It is assumed that wilderness-type recreation is included in the hiking/backpacking activity. It is fur- ther assumed that only a portion of the hiking and backpacking activity was associated with BLM WSAs. The percentage of the activity associated with BLM lands is not known, but is probably a relatively small amount considering the popularity and high public knowledge of the State's national parks and forests. Further insight can be gained from examination of the quantitative data regarding visitation. There are no WSAs in the Bear River multi-county area. There are only four WSAs and a portion of the fifth WSA in the Wasatch Front and Uintah multi-county areas. Visi- tor use in these WSAs is very low and is considered an insignificant part of tourist activity in these areas. The following discussion will focus on the three multi-county districts containing the great majority of WSAs in the State. Because hiking/back- packing was not among the five most popular 9 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION activities for commercial air travelers, it is assumed that those visitors were not users of WSAs. The following recreation trips were made in 1981 to the three multi-county areas containing most of the WSAs: Area Resident Non-Resident Vehicle Central 634.100 2.077,500 Southwestern 947,700 2,496,500 Southeastern 717.900 1.613.100 Total 2,299,700 6,187,100 Unfortunately, the Dalton (1982) study does not list the number nor the percentage of those sampled who engaged in the recreational activities listed above. However, a nationwide survey conducted by the American Forest Institute in 1977 also lists, in ranked order, the activities favored by its respon- dents, and reports the percentages of the respondents who engaged in each activity. Although the survey was not identical to Dalton's, the rankings are very similar to Dalton's results. The survey indicated that about 10 percent of those questioned had engaged in hiking and backpack- ing on remote trails in the past year. It indicated that 19 percent had hiked on accessible trails. Assuming that these results are applicable to recreationists in Utah and assuming that hiking on remote trails is anal- ogous to wilderness use, an estimate of the portion of the recreational use associated with wilderness can be made by applying the results of the survey to Dal- ton's estimate of total recreation trips. The results are: Area Resident Non-Resident Total Central 63,400 207,800 271,200 Southwestern 94,800 249,700 344,500 Southeastern 71.800 161.300 233.100 Total 230,000 618,800 848,800 Assuming that BLM WSAs account for about 10 percent of all wilderness-type use in the three multi- county areas, about 84,900 persons trips would be attributable to WSAs. If each trip were about 3 visi- tor days in length, about 254,600 visitor days could be estimated as the level of use of WSAs. This is near to the BLM estimate of WSA use, about 250,300 visi- tor days. Based on these assumptions, the recreational use of BLM WSAs in the three multi-county areas can be estimated at about 3 percent of the total tourist visi- tation. This is not a significant part of tourist use in southern Utah. It is concluded that designation or non- designation of wilderness would not have a significant effect on tourism in southern Utah. 21.16 COMMENT: BLM should promote tourism. [Utah Wilderness Coalition] The following proposals are designed to protect wilderness resources, attract tourists in greater numbers, and increase the quality of tourist experi- ences in wilderness areas. State and Federal govern- ments do not have to spend millions of dollars develop- ing new towns and highway systems. Socioeconomic successes can be achieved by making what is already available work better. Specific recommendations for State and Federal projects to enhance the socioeconomic value of Utah wilderness areas are: Conduct more sophisticated surveys, designed in advance, with the direct assistance of conservation- ists and others who have a deep appreciation for the beauty and values of wilderness. Patterns of tourism in Utah should be compared and contrasted with those in other States to assist in learning how to best pro- mote Utah's wilderness areas. A University of Utah program should be established and funded to study the travel industry. More needs to be learned about the proportion of potential tourists who may view travel in Utah as less desirable than in other western States. Establish a Utah Travel Association to support Utah tourism by building and improving upon existing efforts to promote tourism. Some of the tasks of the association should include the development of a de- tailed Utah Travel Guide for sale in bookstores nation- ally, creation of a Statewide computer reservation system and informational service for the travel indus- try, a Utah Travel Association magazine for national distribution to travel agents, training programs to help local communities develop more attractive tra- vel services, and intern programs for college stu- dents seeking future travel industry related careers. Education programs to assist the travel industry need to be fostered covering areas such as restau- rants, retail trade, advertising, accommodations, and 1 0 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION guides/outfitters. Scholarships and intern programs should be made available for residents in communities located near wilderness areas to participate in these training programs. Produce a nationally shown public television pro- gram about wilderness areas in Utah. Present video- tapes of this program at regional and national travel agent association meetings. Develop high quality regional travel information describing wilderness areas. Improve the quality of existing facilities and tra- vel services located near wilderness areas rather than construct new ones. For example, couldn't the millions of dollars planned to be spent on paving parts of the Burr Trail be better utilized by improving the image and services in a small town like Hanksville? A Statewide travel industry plan keyed to wilderness resources should be developed. Some target commun- ities should be selected for improvements to attract wilderness users and the socioeconomic impacts eval- uated. A funding program similar to the Block Grant program for rural communities should be instituted to assist communities like Hanksville to enhance their tourism images. State land management policies should be insti- tuted to both promote tourism to build wilderness areas and, at the same time, protect these areas. Project BOLD should be used to select lands that benefit the travel industry and enhance the State's park system. Federal agencies such as BLM should be encour- aged to assist the Utah travel industry. Federal wil- derness designation should be coordinated to encour- age and aid local communities to take advantage of the socioeconomic potentials of such designation. Federal facilities for tourists, such as campgrounds, should not unfairly compete with local, private facilities that can maintain comparable cost and quality stan- dards. In general, State and Federal agencies should coor- dinate efforts to develop sustainable, small-scale communities near wilderness areas. Types of socio- economic growth incompatible with wilderness areas should be encouraged to locate elsewhere in the State to minimize unnecessary political conflicts. 21.16 RESPONSE: The proposals are very interes- ting and may have potential for a very positive effect on tourism in Utah. BLM cooperates fully with respon- sible agencies, informs the public about opportunities for recreational uses of public lands, effectively man- ages recreation on public lands, and provides quality visitor services. These actions carry out BLM's man- agement responsibilities and are compatible with en- couraging tourism in the State. This comment is in- cluded in this EIS to bring the proposals to the atten- tion of the appropriate State agencies and the public at large. Also, see the response to General Comment 2.1, which discusses BLM’s responsibility to educate the public on the wilderness program. It should be noted that recreation is not the primary purpose of wilder- ness. See the response to General Comment 1.1. 21.17 COMMENT: The EIS fails to adequately dis- cuss the effect of wilderness designation on visitor use and the economy. [Composite of comments and questions from many commentors.] Will visitor use significantly increase as a result of wilderness designation? Will recreation-related employment increase as a result of wilderness desig- nation? Will designation result in degradation of wil- derness areas as a result of increased visitor use? 21.17 RESPONSE: Volume I, Chapter 4, page 120 of the Draft EIS states: "that past studies have shown no permanent relationship between wilderness desig- nation and changes in level of recreation use." Sever- al authors were cited in reaching this conclusion, in- cluding Jungst (1978), Peterson (1981), and McCool (1985). The work of Johst (1982) also supports this conclusion. Experience in the Paria Wilderness Area, a recent- ly designated BLM wilderness area in Utah and Ari- zona, seems to indicate that publicity may have a greater influence on visitor use than designation. Use in Paria Canyon steadily increased for several years prior to designation and has continued to increase at about the same rate since designation. A use level much higher than the normal increase occurred during the hiking season subsequent to the publication of an article in the very popular Arizona Highways maga- zine. The following year, the use pattern returned to normal. There is some support among knowledgeable people for the concept that publicity associated with designation will increase use in WSAs selected for GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION designation. It seems likely, however, given the level of publicity associated with the Utah wilderness re- view process, that effects of publicity may be seen prior to designation. A considerable amount of publi- city about Utah WSAs has already occurred locally, region-ally, and nationally. This level of interest is likely to continue as the process continues. As stated in the EIS, recreation-related employ- ment is not likely to significantly increase in the State as a result of designation. Please refer to Gen- eral Comment Responses 21.15 and 21.19 for fur- ther explanations of this position. Whether or not wilderness areas are degraded as a result of increased use will depend on whether desig- nation tends to increase use. Based on available infor- mation, a great increase in use following designation is unlikely. It is more likely that a steady increase will occur during the review process, through designa- tion, and beyond as a result of areas becoming better known. The rate of increase will probably be greater in better known and higher use areas. 21.18 COMMENT: The EIS should state that designa- tion limits recreation use to a narrow range of recrea- tional activities and users. [Nora Worthen, Utah Wool- growers, off-road vehicle users, senior citizens, et al.] The irony of the debate over wilderness seems to be since these areas are so beautiful, we should ex- clude all but those with certain narrow recreational preferences from enjoying them. There are estimates that only 3 percent of the total public will ever see a wilderness area. This is largely due to the time in- vestment required to see areas without the benefit of motorized travel. Most of us do not have the days or weeks that would be required to see even a small por- tion of 70 or 80 thousand acres of rugged terrain on foot. Secondly, most of us are either not inclined or not physically able to traverse even a part of the areas being considered for wilderness. 21.18 RESPONSE: Refer to the response to General Comment 1.3. In short, visitor use is not the primary purpose of wilderness designation. 21.19 COMMENT: The EIS fails to adequately assess the economic value of wilderness recreation. [Utah Wilderness Coalition, Roger Jenkins, John Lockhart, et al.] a. The Draft EIS fails to adequately assess the economic benefits from primitive recreation. Speci- fically, the Statewide average expenditure of $4.10 per recreational visitor day does not accurately rep- resent the monies spent to recreate in those areas which are national calibre wilderness. The most out- standing areas, such as the canyon regions of south- ern Utah, represent truly unique wilderness experi- ences when compared with those elsewhere in the country. As a result, people do or will come to visit these areas. Seekers of solitude and primitive recrea- tion from Washington, New York, or Tennessee spend much more than $4.10 per visitor day to enjoy these places. Such trips may include the rental of a car or van for the trip from the Salt Lake City airport and back. Also to be considered are the ticket agents, grocers, baggage handlers, jet fuel sellers in Salt Lake City, the restaurant owners and grocers in Hanksville, or the Hite Marina personnel which were supported. Could it be that the figure is only an esti- mate of the cost of food while in a wilderness area, without consideration for travel or other associated expenses? b. A number of sources are available which indi- cate that the $4.10 figure is too low. For instance, the Cherokee National Forest estimates a vaiue of $12.60 per visitor day for wilderness recreation. A likely scenario, given the increasing demand for primi- tive recreation, would be that the Dark Canyon and Fish Creek/Road Canyon areas would experience in- creases to approximately 20,000 visitor days by the year 2000. At $12.60 per visitor day (for noncom- mercial use) this would result in revenues of over $500,000 for the State of Utah. To put this figure in perspective, it is more than six times the current annual revenue from grazing in the entire San Juan Resource Area. This is no insignificant figure. c. The Draft EIS also understated income gener- ated by wilderness-related employment. Grand Gulch, for example, currently supports six commercial out- fitters and guides. Based on commercial use of 2,000 visitor days (10 percent of the total 20,000 visitor days as stated on page 31 of the Grand Gulch analy- sis) and using the $4.10 Statewide average for the value of a wilderness visitor day, the total outfitter- based income of Grand Gulch is $8,200, hardly enough to support one outfitter. Clearly the proportion of wilderness visitor days attributable to commercial use should be valued much higher in the Draft EIS analysis. If, for example, such 1 2 GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION use were valued at $50 per day (a reasonable fig- ure), the increase in income generated by wilderness designation would be about $9,150, based on a pro- jected increased use of 1,838 x 10 percent x $50. By valuing all recreation at the Statewide noncom- mercial average of $4.10, the Draft EIS estimates recreation-related sales attributable to designation of Grand Gulch at only $7,535 at the end of the 20-year period. In fact, using more reasonable figures, the projected increase due to commercial use alone ex- ceeds that amount. Adding commercial use with non- commercial use for Grand Gulch (50 x 183) + ($4.10 x 1,655) gives a more realistic figure of $15,935. By ignoring the commercial component of wilder- ness recreation, the Draft EIS underestimates the economic impact of increased recreation by almost 50 percent. The Draft EIS should recalculate these figures for each WSA where commercial and noncom- mercial uses were not differentiated. The results may further demonstrate the economic advantages of wilderness designation, which should be considered in the summary comparison alternatives. To further illustrate this critical point, the Draft EIS should compare aggregate figures for projected employment and income in each WSA. Again consider- ing Grand Gulch, recreation-based increases compare favorably with grazing-related increases. The Draft EIS states that the current 1,930 AUMs involving seven permittees could be supplemented by an addi- tional 1,118 AUMs (Volume V, page 30, Grand Gulch analysis). Even using the inflated $20 per AUM sales/ output figure (Volume I, page 357, Table 9), this would result in an increase of only $22,360 and 0.58 of one, using the direct employment factor of 0.00053 x 1,118. The increased jobs in recreation resulting from designation would be (183 x 0.0012) + (1,655 x 0.0004), using the correct ratio based on WSA data. This gives 0.88 jobs, small, but more than from grazing. And it seems likely that the manage- ment costs incurred by BLM would be less for recrea- tion than for grazing, given the heavy capital costs associated with intensive grazing practices. This kind of analysis, if performed Statewide, would show that wilderness designation would likely create more jobs than grazing could. The Draft EIS summary analyses should reflect this. Recreational benefits to local and regional Utah economies are significant, and BLM must recognize that wilderness-related recreation plays an impor- tant role. The economy of Utah is tied closely to the recreation industry. Therefore, a more thorough anal- ysis of this issue is well justified. 21.19 RESPONSE: The assertion that the $4.10 fig- ure does not accurately represent the gross expendi- tures of wilderness recreational users is correct. The estimated $4.10 per day was intended to reflect the contribution of wilderness recreation to the econ- omies of communities near WSAs. The EIS has been revised to clarify this point. The average recreation expenditure estimate was derived almost entirely from a 1982 study by Dalton. The estimate was made by dividing estimated SF statewide expenditure figures by Statewide visitor use estimates for all activities. The result was a val- ue of approximately $4.10 per visitor day expressed in 1980 dollars. The gross expenditure of wilderness users are not representative of the effect on local economies since many expenses incurred in wilderness recrea- tion are made at the point of origin of the trip or at some other point outside the local area. As stated in the EIS, the figure of $4.10 per visi- tor day is an estimate. However, until better informa- tion is available, the Statewide figures are the most reasonable and accurate estimates available for use in the EIS. There are a number of studies that examine the value of a user day of wilderness recreation. Perhaps the most informative of these is a study by Sorg and Loomis (1987) in which comparisons of empirical esti- mates of the value of wilderness recreation were made using comparable methodologies and comparable units of measurement. These authors examined sever- al valuation studies after adjustments were made to allow comparison. Adjustments included conversion of values to a 1982 base year, corrections for omis- sion of travel time, and instate sampling. Values were estimated using either the Contingent Value Method, or Travel Cost Method, with one excep- tion which used a "Hedonic Travel Cost Method" (Brown and Mendelsohn, 1984). These methods do not reflect gross expenditures for recreation. In describ- ing the values of these studies in relationship to gross expenditures, the authors stated: GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION "The value of a recreation experience is alleged to equal the total amount of money spent by recrea- tionists while participating in the activity. While in- sight into local income effects is provided, gross ex- penditures do not give an estimate of additional value created by an increase in recreation opportunities. Management decisions should be based on this net val- ue in excess of the costs of taking advantage of the recreation opportunity, because this measures the real monetary value that would be lost if the opportu- nity were not available. What is needed is not a gross value, but the net contribution to recreationists added by the recreation opportunity." The studies included in the comparison and the ad- justed values/activity day are shown below. These studies, like gross expenditueres, are not intended to describe the effect of expenditures on the economies of communities near WSAs. However, the values indicate that wilderness recreation has signifi- cant value to users. For example, the Loomis (1979) study indicates a value of $19.45 per visitor day for a particular area of Utah. If this value were accurate for the entire State of Utah, the value of the total vis- itor use of WSAs in the State (estimated at about 250,300 visitor days) would have been over $4 million. Author/Study Location/ Date of Data Adjusted Values/ Activity Day Walsh and Gilliam (1982) Colorado 1979 $12.78-22.68 Walsh et al (1981) Colorado 1980 $18.32 Loomis (1979-1980) Utah 1979 $19.45 Smith and Kopp (1980) California 1972 $20.50 Brown and Plummer (1979) Oregon, Washington 1976 $73.93 The comment regarding commercial outfitters and guides in Grand Gulch is inaccurate. Grand Gulch does not support six outfitters. Six outfitters, none of which are locally based, make periodic use of Grand Gulch. Only a portion of the business of any of the six outfitters is conducted in Grand Gulch. Like noncommercial recreationists, many users of commercial recreation services incur considerable expense in the pursuit of their activities. Many of their expenses are incurred in other States or areas where little or no effect is generated on the econo- mies of areas from which WSAs are accessed. Some exceptions may exist in a few areas where sales of commercial services are relatively high. Volume V of the Draft EIS accurately characterized the effect of commercial use in Grand Gulch on the San Juan Coun- ty economy (page 27). Economic impacts or other areas where significant local effect may exist are included in the analyses of impacts for specific WSAs. For example, refer to the discussion of Desolation Canyon WSA, Volume VI. Valuing a user day at $4.10 for commercial recre- ation use is generally as accurate an estimate as pos- sible. In many cases, the benefits of commercial rec- reation do not contribute to local economies to a great- er degree than noncommercial recreation, since the outfitters and services provided are not located where more than the Statewide average estimate would apply. In some cases, outfitters, guides, or other businesses which use WSAs are located where a greater contribution to local economies may occur. These cases have been identified in the EIS. It is not possible, because of a lack of data, to more reliably estimate the additional expenditure that may result from commercial use. Economic impacts per dollar of tourist expendi- ture are lower than other kinds of spending in rural or less developed areas. These areas are frequently proposed for recreation development as a stimulus for economic growth. The reason for low impacts per dollar spent is that recreation expenditures are not all net personal income for area residents. This is gen- erally due to the high proportions of goods, services, and capital imported to these areas. Tourist dollars quickly leave the area as payment for imported goods and services. Another important source of leakage from the local area results when the earnings of sea- sonal workers is spent outside the area. Also, see the responses to General Comments 21.17 and 24.8. 21.20 COMMENT: BLM and the EIS are biased against ORV use. [Harry Melts, et al.] The Draft EIS fails to evaluate the effect that such selective information has on visitor use types and patterns, yet use types and patterns are used to justify wilderness areas. GENERAL COMMENTS AND RESPONSES SECTION 21: RECREATION BLM recreation specialists favor hiking. Most of the BLM public information emphasizes hiking trails in- stead of giving equal treatment to ORV use. For exam- ple, in Issues and Concerns (Volume I), the impact wil- derness designation will have on existing and future needs of nonwilderness recreation is not even listed as an issue. 21.20 RESPONSE: The major issues identified for analysis in the EIS resulted from a major public scop- ing effort. The principal issues are identified and dis- cussed in Volume I, Chapter 1, page 13. Impacts on motorized recreation were not analyzed on a State- wide basis because motorized recreation is not an im- portant recreational activity in most WSAs and does not have Statewide significance. Please refer to Vol- ume I, Chapter 1, Issue Identification, for a more de- tailed explanation. BLM public information efforts are aimed at pro- viding information about recreational opportunities available on public lands to the public in a balanced manner. 21.21 COMMENT: The EIS should point out that des- ignation of wilderness areas may lead to overuse of nonwilderness recreation areas. [Marvin Morris, et al.J There is a tradeoff between the lands designated as wilderness and lands not designated. As more lands are designated, fewer areas will be available for non- wilderness uses. Those who do not use wilderness areas will be funnelled into smaller nonwilderness rec- reational areas, possibly creating overuse of those areas. 21.21 RESPONSE: There are certainly tradeoffs be- tween designation and nondesignation of wilderness areas. An attempt has been made to accurately de- scribe these tradeoffs. Because of the current light nonwilderness use of WSAs, few impacts on adjacent lands are expected. Also, see the responses to Gen- eral Comment 21.1 and 21.11. GENERAL COMMENTS AND RESPONSES - SECTION 22 WILDERNESS VALUES INDEX 22.1 Impacts to wilderness values are too general, underestimated, or inconsistent in the Draft EIS. What impacts to wilderness values would result from non- designation? (p. 1) 22.2 The Draft EIS analysis should indicate that wil- derness designation will not completely protect wil- derness values, (p. 2) 22.3 The Draft EIS displays inconsistency in identi- fication and analysis of wilderness values, including special features, outstanding opportunities for soli- tude, and outstanding opportunities for primitive and unconfined recreation. There are no objective stan- dards used. (p. 3) 22.4 Plant and wildlife habitat in WSAs should be iden- tified as wilderness values in the Draft EIS. (p. 5) 22.5 The Draft EIS has incorrectly divided WSAs and portions of WSAs into areas having outstanding vs. ordinary wilderness values, (p. 5) 22.6 The Draft EIS has not identified all of the intru- sions in the WSAs. (p.6 ) 22.7 The impact of high-speed, low-level Air Force flights on solitude and, therefore, wilderness suita- bility as described in the Draft EIS is a concern, (p.6 ) 22.8 The Draft EIS fails to identify what is meant by "a day's driving time." (p.7 ) 22.9 The Draft EIS fails to indicate how much of the nation is wilderness and in what way designating all the BLM lands nationwide and in Utah would change that figure, (p.7 ) 22.10 The criteria used to define diversity in the Draft EIS are not reasonable, (p.8 ) 22.11 The Draft EIS fails to mention that some of the nation's most spectacular land is in Utah. (p. 8) 22.12 How can both outstanding solitude and primi- tive recreation values be found lacking on the same acreage? (p. 8) COMMENTS AND RESPONSES 22.1 COMMENT: Impacts to wilderness values are too general, underestimated, or inconsistent in the Draft EIS. What impacts to wilderness values would result from nondesignation? [Sierra Club, Cache Group; Utah Wilderness Coalition; Nina Dougherty; Randolph Jorgen; Scott Smith, et al.] a. The No Alternative Action states: "This alterna- tive would not designate any wilderness, thus reduc- ing protection for 3,201,507 acres of naturalness values contained in the 82 WSAs. Although unlikely, naturalness values could be lost in part or in total in any or all of the 82 WSAs. Although unlikely . . ." That is an absurd statement. It is a certainty that these values will diminish or be lost in most, if not all, of the areas sometime in the future. They are disappearing right now in some areas under the dubi- ous protection of BLM's IMP. It is revealing that, under the No Wilderness Alternative, no wilderness values are foregone. Maybe this seems just a matter of semantics, but I think it shows the mind set of BLM. They are only too willing to estimate a precise amount of oil that will disappear if an area is desig- nated wilderness, but show no inclination to make any sort of estimate at all on the amount of development that may occur in an area if it is not protected, dis- missing any development as being unlikely. b. Throughout Chapter 4, Environmental Conse- quences, and Chapter 2, Table 17, there is the recur- rent phrase: "Although unlikely . . ." used in refer- ence to possible degradations of wilderness values and developments, in virtually every topic of discus- sion for all alternatives. The use of this phrase is an attempt to give the false impression that there is no need to preserve these lands as wilderness; that, in effect, they will be just about as well off without des- ignation as with; that, although impacts may occur, they are more likely to be minimal or nonexistent. I submit that the course of development in this country clearly indicates that these impacts are not at all 1 GENERAL COMMENTS AND RESPONSES SECTION 22: WILDERNESS VALUES unlikely, but rather are virtually certain, at least in the long term (a view this Draft EIS generally has not taken). Hence, the recurrent use of this phrase "al- though unlikely" is indefensible, misleading, and must be deleted. c. In the beginning of Volume I (page iii), there is a short discussion of BLM's subjective efforts to account for future changes in demand and extractive technology with regard to resources contained in the WSAs. This same consideration should be applied to the value of wilderness qualities. The established facts that in America, population is expanding and be- coming increasingly urbanized and undeveloped land is becoming increasingly scarce, supports the argument that wilderness will become evermore sought after. BLM should protect far more than 1.9 million acres. d. What wilderness values will be threatened by failure to designate part of an area as wilderness? BLM should report the recreation days, wildlife habi- tat acres, archaeological site numbers, and other wil- derness values that would be damaged or lost if a roadless area is not protected as wilderness. In the EIS, BLM does not respond to this concern consistently. Partial wilderness recommendations still fail to describe wilderness values which would be lost in the unprotected areas. We formally request that BLM respond to this concern in the Final EIS. If we are to make sound decisions about the future man- agement of Utah's public lands, we must know what the costs of certain choices are; fully understanding the implications of various choices is the primary purpose of an EIS under NEPA. We ask that the agency be as scrupulous in pointing out the wilderness values that could be destroyed without designation as it is in pointing out the commodity values that might be fore- gone with wilderness designation. e. Unprotected wild lands near highly visited na- tional parks will not remain for long. There has been a noticeable difference in the landscape between St. George and Zion Park in the last 10 years, especially just the last few years as many more people move into the area and tame the wild areas. f. When BLM describes a No Action Alternative in the Draft EIS for a particular WSA, it is often stated that no wild land values will be lost. This is a difficult position to accept. BLM does not outline its long-range plans for a particular WSA, so one does not know how long any of the wild land values will remain. This should not be used as a rationale to not designate wil- derness. BLM does not have the capability to protect wild areas that are not under either WSA or designat- ed wilderness status. g. Wilderness values are assumed by BLM to be absent when not inventoried. BLM has failed to inven- tory current wilderness use. Monitoring of the num- ber of hunters and hikers and wildlife is absent. BLM doesn’t know the number of archaeological sites found in roadless lands. Even without this comprehensive in- ventory, what little is known irrefutably makes these lands some of the most remarkable in the country. 22.1 RESPONSE: The response to General Comment 9.4 addresses analysis assumptions and development scenarios for the alternatives. Refer to the responses to General Comments 8.3, 9.6, 13.1, 16.2, and 20.2 for information on the level of detail required for EIS analysis. Additional information and analysis of wil- derness special features has been added in the Final EIS. The phrase "although unlikely" is no longer used. Estimates are now given on wilderness values that would be lost based on reasonably foreseeable devel- opment under each alternative. It is not the purpose of this EIS to determine how much wilderness is enough but to determine tradeoffs and suitability of areas for wilderness designation. 22.2 COMMENT: The Draft EIS analysis should indi- cate that wilderness designation will not completely protect wilderness values. [Utah Public Lands Multi- ple Use Coalition] a. Wilderness designation may not preserve all areas so designated. There may be no protection from forest fires, pest infestation, floods, predators, nox- ious weeds, etc. In addition, overuse by backpackers can destroy the area. 22.2 RESPONSE: Within reasonable constraints, natural ecologic processes are by definition permitted to occur within wilderness areas such as wildfire, pest infestations, floods, etc. However, emergency control measures may be taken when there is a threat to wilderness values or resources outside the wilder- ness. Overuse by recreationists would be controlled through a wilderness management plan to prevent or restrict such use to appropriate levels for the protec- tion of wilderness values. Wilderness values may be lost due to development of valid existing rights. Like- 2 GENERAL COMMENTS AND RESPONSES SECTION 22: WILDERNESS VALUES ly disturbance resulting from valid existing rights is identified in the Final EIS. 22.3 COMMENT: The Draft EIS displays inconsis- tency in identification and analysis of wilderness val- ues, including special features, outstanding opportu- nities for solitude, and outstanding opportunities for primitive and unconfined recreation. There are no ob- jective standards used. [State of Utah; Sierra Club, Cache Group; Utah Wilderness Association; Frances Fericks; Michael Salamacha; Gary Thompson, et al.] a. The many units cannot be supported by the Gar- field County Commissioner for wilderness designation because the opportunities for primitive and unconfin- ed recreation are less than outstanding due to a lack of diversity of recreational opportunity. These areas are simply geological formations which are common to the region. They are limited by either a lack of curi- osity-arousing features or other unique or unusual features which would attract visitors, and their des- ignation as wilderness would seriously limit future development of our county's mineral and geological resources. b. In November of 1980, then State BLM Director Gary Wicks wrote about the question of determining outstanding opportunities for solitude and unconfined recreation: ". . . this criterion is the most subjective . . . Ultimately, however, the decision represents a judgment made without the benefit of objective stan- dards." This idea of subjectivity should clearly be stated in the Draft EIS as an admitted determining fac- tor in BLM's process of final proposed designation of WSAs for Congress. I could not find it mentioned any- where in the seven volumes of the Draft EIS. Yet, many WSAs have had much acreage deleted or not even been recommended due to the lack of outstanding solitude accorded it by BLM. The definition of solitude stated in Volume IV, Little Rockies WSA (UT-050- 247), page 11, ". . . i.e., a secluded spot away from others" seems to differ with many of the other WSAs in their unending claim that screening is essential (ei- ther vegetative or topographical) for solitude. Open areas, according to BLM, seem unable to proffer any kind of solitude, yet some of the loneliest places I have ever been in are wide open landscapes with vast vistas surrounding me with no screening but the brim of my hat. It should be noted that solitude is an argu- able facet of wilderness and able to occur in any con- figuration, with or without screening. That BLM is able to determine outstanding solitude to the nearest acre is a complete fallacy-timing has as much to do with it as does place, something not even mentioned. c. In some analyses (i.e., Volume II) recreational activities were identified and analyzed for outstand- ing qualities. This practice of actually listing and eval- uating each activity listed should be followed in every WSA analysis. d. It appears that different volumes use different criteria for determining special features. Some Dis- tricts include everything outstanding about a specific area, while other Districts reject outstanding fea- tures (i.e., see technical comments on Cougar Canyon and Fifty Mile Mountain). Criteria should be consis- tent throughout the Draft EIS. e. There seems to be a problem with consistent application of special feature determination. Some- times every feature is included. Other times, fea- tures are excluded for no particular reason. For exam- ple, Cougar Canyon scenery does not qualify as a spe- cial feature because it is not unique to southern Utah. However, a special feature identified in Red Mountain WSA is Navajo sandstone, very common to southern Utah. What is the standard? A question that arises from the Cougar Canyon example is this: If scenery must be totally unique to be outstanding or unusual, can there be any outstanding or unusual (Class A) scenery in southern Utah? I think there is. f. The Draft EIS, Volume I, identifies 29 WSAs as having high value cultural resources (page 85), but states there are opportunities for archaeological sightseeing in only 12 areas (page 88). Why the discrepancy? g. In the 3.2-million-acre All Wilderness Alterna- tive in the Draft EIS, BLM clearly says: ". . . outstand- ing opportunities for primitive and unconfined recrea- tion would be protected by wilderness designation (through the All Wilderness Alternative) on 100 per- cent of the acreage. (Volume I, page 128). However, it appears that the following WSAs received reduced or nonwilderness recommendations because of BLM's primitive recreation criteria: Daniels Canyon, Fre- mont Gorge, Cheesebox, King Top, and Conger Moun- tain. This seems contradictory to the above state- ment from the Draft EIS. Can BLM explain this? h. Table 53 (pages 91 and 92) is incomplete. Many areas contain special features that are not in- cluded on the chart. For instance, special ecological 3 GENERAL COMMENTS AND RESPONSES SECTION 22: WILDERNESS VALUES features are described in part as: . . the presence of animal species inhabiting only remote areas free from human disturbance. Such animals include elk, bear, cougar, bison, etc. (bighorn sheep)." Canaan Mountain and Parunuweap Canyon contain cougar, the San Rafael Reef is home to bighorn sheep, and Floy Canyon harbors elk, bear, cougar, and bighorn sheep. None of the four WSAs are shown on Table 53 as hav- ing special ecological features. Many minor errors such as these exist on the listings of special features. BLM clearly says, in regard to the 3.2 million acre All Wilderness Alternative, that "special features would be protected by wilderness designation on 100 percent of the acreage" (Volume I, page 129). Why then, are some areas listed in the Draft EIS as lacking in wilderness features? i. BLM points out that the 3.2 million acre All Wil- derness Alternative would "protect naturalness val- ues on 100 percent of the WSAs" (Volume I, page 127) . If this is true, how can BLM justify removing some Draft EIS areas from wilderness consideration be-cause they are lacking in naturalness? We do not understand how a BLM unit can be identified as a WSA and then not have at least minimal wilderness quali- ties. Does not a WSA require certain minimum outstan- ding attributes in the initial inventory? Concerning the 3.2 million acre All Wilderness Alternative in the Draft EIS, BLM states, "Outstanding opportunities for solitude would be protected by wilderness designa- tion on 100 percent of the acreage" (Volume I, page 128) . Given this statement, why then do some WSAs in the Draft EIS suddenly lose their solitude? We are con-cerned about BLM's overall analysis of solitude in wilderness areas. Often, it appears that one of two criteria are used to discount solitude in a WSA. They are: (1) vegetation and rock confinement are insuffi- cient; and (2) outside intrusions. Both of these meth- ods have been successfully challenged in the past. The IBLA said several years ago that the first method may not be used by BLM to reduce solitude ratings. The second method was questioned by U.S. House Re- port No., 95510 which, concerning the New Mexico FS wilderness bill, states: "The 'sights and sounds' of nearby Albuquerque, formerly considered a bar to wil- derness designation by the FS, should on the contrary heighten the public's awareness and appreciation of the area's outstanding wilderness values." This argu- ment also has been rejected by Congress as evident in Utah's FS wilderness bill. In the 1984 Utah Wilder- ness Act, Congress accepted the Wellsville Mountains into the NWPS even though one can see two major population centers, Logan and Brigham City, from most summits. Overall, it appears that BLM will only accept the following for solitude: (1) dense brush; (2) dense trees; or (3) high canyon walls. We find that BLM must put more emphasis on the following when solitude is evaluated: (1) the ability of a user to find solitude; and (2) the size and configuration of the unit itself. 22.3 RESPONSE: The standards for rating various wilderness values are outlined in BLM's Wilderness In- ventory and Wilderness Study guidelines. These publi- cations are available to the public and have been wide- ly circulated. Therefore, a full explanation of subjec- tivity or the methodology for evaluation of these fea- tures is not necessary in the EIS. There is no inconsistency in the description of high value cultural resource sites and opportunities for archaeological sightseeing. Many of the high value cultural resource sites are scattered or buried or are noticeable only to trained archaeologists. Only those WSAs where cultural resources are comprised of dwellings or other structures noticeable to the public are considered to offer opportunities for archaeologi- cal sightseeing. There is no inconsistency in statements that with the All Wilderness Alternative naturalness, outstan- ding opportunities for solitude and primitive recrea- tion, and special features would be protected on 100 percent of the areas. The intent was to indicate that the existing level of presence or absence of these val- ues would be protected by wilderness designation, not to indicate that these values are present on 100 per- cent of the areas. We agree that the statements are, however, misleading and they have been clarified in the Final EIS. Additional information on wilderness special fea- tures has been included in the Final EIS to correct in- consistencies. The Draft EIS identified the special fea- tures recognized during the BLM wilderness inven- tory. These and other resources that could be consid- ered special features have been described in the Final EIS. Also, see the responses to General Comments 2.12, 2.13, 3.1, 3.17, and 8.11, which discuss the identifi-cation and ranking of wilderness values as part of the wilderness review process, including the inventory, study, and reporting phases. 4 GENERAL COMMENTS AND RESPONSES SECTION 22: WILDERNESS VALUES 22.4 COMMENT: Plant and wildlife habitat in WSAs should be identified as wilderness values in the Draft EIS. [Utah Wilderness Coalition, et al.] BLM's study policy directs BLM to consider the need to broaden the protection of natural features. BLM produces a limited set of criteria which fails to adequately identify the diversity of natural values present. The Draft EIS does not assess the natural values that need to be considered in addressing this part of the first criterion. An example of its approach is this: BLM uses the dominant plant found on average in the whole unit to represent all plants, animals, and habitat areas. But, in an area dominated by, say, pin- yon trees, there is found a diversity of smaller plant and animal communities; they are lost in BLM’s approach. Similarly, the wildlife assessment consid- ers only game animals or major raptors. Even that has not been without its flaws: in the case of ante- lope, BLM has not even identified prime habitat, much less sought to preserve it. There are hundreds of ani- mals and plants living in Utah's canyon country and Great Basin desert. Most are ignored in the Draft EIS. We request that BLM list all identified plant and wild- life habitats of candidate areas, the percentage repre- sented in each WSA and in each alternative, the inven- tories performed, and, where applicable, the inven- tories that have not been done. 22.4 RESPONSE: Additional discussion of plants and animals has been added to the Wilderness Values sections in the Final EIS. Antelope is not a wilder- ness dependent species. Also see the responses to General Comments 13.7 and 13.8 for a discussion on plant diversity and the vegetation data base, and Gen- eral Comments 16.2, 16.3, and 16.4 for a discussion on the need for wildlife inventories. 22.5 COMMENT: The Draft EIS has incorrectly di- vided WSAs and portions of WSAs into areas having outstanding vs. ordinary wilderness values. [State of Utah, Bruce Chester, Rex and Judy Wells, et al.] a. I am highly skeptical of Table 53's listing of acreages detailing the wilderness values of WSAs. How does one deem 50 percent of Fifty Mile Mountain to offer solitude or outstanding primitive recreation? I would gather that I'd be the only one atop the plateau on a given date in January. Suffice it to say that each area, and many that are not found in Table 53, con- tains wilderness values; there is no need to quantify this. b. In using criteria such as solitude, naturalness, and opportunities for primitive recreation, I found the Draft EIS contradictory. These attributes, as found in the Wilderness Act and BLM's own policy guidelines, are not to be rigidly applied in selecting or ranking areas. The terms are highly subjective and open to as many interpretations as there are District personnel quantifying them. Is the opportunity for primitive rec- reation any less in King Top than in the Wah Wah? Is one denied solitude on sparsely vegetated benchlands of Wahweap? Are old roads and stock trails in Fidd- lers Butte significant impacts on that area's natural- ness? I feel the Draft EIS has gone steps beyond the mandate of Congress by quantifying these wilderness characteristics and by further using comparisons by year or adjacent WSAs. I would appreciate a descrip- tion of the efforts used in determining solitude, natur- alness, and primitive recreation for each recreational area. I maintain these three factors are adequately met while hiking old eroded trails and ways in the Red Desert and on North Caineville Mesa. c. We oppose the concept of identifying Partial Wil- derness Alternatives on the basis that only those por- tions of the WSA "with the most outstanding wilder- ness characteristics" would be recommended as suit- able. This approach is based upon the identification of distinct zones, which is in violation of the Wilderness Study Policy. The Wilderness Study Policy (page 5118) states: "There appears to be two general cases when it may be appropriate to consider recom- mending less than entire WSAs for wilderness: (1) resolution of conflicts and (2) manageability of wilder- ness." Furthermore, it is not clear how these areas with the "most outstanding wilderness characteris- tics" were identified. It appears that areas with the "most outstanding wilderness characteristics" are only those that possess naturalness and outstanding opportunities for both solitude and primitive recrea- tion. This implies that an area possessing only soli- tude or primitive recreation opportunities, but not both, is of lesser quality than an area possessing both characteristics. d. The lack of distinction between suitable and out- standing solitude and primitive recreation acreage is confusing. Sometimes qualitative distinctions are made in one analysis but combined in another. The problem is particularly apparent in Volumes lll-A and lll-B. 22.5 RESPONSE: The objective of several of the Partial Wilderness Alternatives is to analyze as 5 GENERAL COMMENTS AND RESPONSES SECTION 22: WILDERNESS VALUES wilderness those portions of WSAs that have the best wilderness values. BLM believes that wilderness val- ues are of a higher quality in areas where outstand- ing opportunities for solitude and/or primitive recrea- tion exist, preferably in combination with special fea- tures. In forming these alternatives, the portions of the WSAs with outstanding opportunities for solitude and/or primitive recreation and special features were included where possible within a manageable boundary. This approach to identification of Partial Wilder- ness Alternatives is not in violation of BLM's Wilder- ness Study Guidelines. BLM has been charged with the identification of areas with "outstanding" opportuni- ties for solitude and/or primitive recreation. The term "outstanding" indicates that there are different levels in opportunities for these features within a geo- graphic region such as a WSA. Although determina- tions of outstanding or best wilderness values are somewhat subjective, objective features of WSAs were considered in rating opportunities as either out- standing or less than outstanding. For example, the features included in determining whether or not oppor- tunities for solitude are outstanding include size and configuration of the area, topographic and vegetative screening, and the presence of outside sights and sounds. These features occur to greater or lesser de- grees in portions of the WSAs. The full text and context of the Wilderness Study Policy (page 5118) states that use of subalternatives is "especially appropriate" in light of resource con- flicts and manageability considerations. It also states that "other relevant factors" may be considered in development of alternatives that would recommend less than the entire area of the WSAs. This indicates that conflicts and manageability are not the only fac- tors that can be considered. The quality of the wilder- ness values present is also central to decisions on wilderness designations. Also, refer to the responses to General Com- ments 2.12, 2.13, 3.1, 3.17, 3.36, and 8.11 for a discussion on ranking, mapping, and identification of wilderness values. 22.6 COMMENT: The Draft EIS has not identified all of the intrusions in the WSAs. [Wayne County, Nora Worthen, et al.J Many miles of roads passable by both two-and four-wheel drive vehicles exist in WSAs. Airstrips necessary to cattle operations, corrals and cabins, reservoirs and fences, drill sites, mines, placers, and capped wells will all be eradicated or rendered unprofitable and useless by the wilderness status. 22.6 RESPONSE: To qualify as wilderness, an area may include some imprints of man's work provided they are substantially unnoticeable. "Only significant imprints that will influence the decision as to the area's degree of naturalness should be documented." (USDI, BLM, 1978, pages 12 and 13). BLM has attempted to identify and analyze those imprints of man which are "substantially noticeable," and take them into consideration (along with all other pertinent information) in formulating a recommendation to Con- gress on what lands should or should not be designat- ed wilderness. Also, see the responses to General Comments 2.6, 4.2 and 4.5. 22.7 COMMENT: The impact of high-speed, low- level Air Force flights on solitude and, therefore, wil- derness suitability as described in the Draft EIS is a concern. [Nina Dougherty, et al.] a. In the times I have been in the West Desert I have not noticed any extraordinary airplane noise or traffic any more so than in any other part of the coun- try. b. Aerial overflights in West Desert WSAs have been a point of contention between land managers, users, and military officials. Who should have the final say in whether these noises detract from the wilderness experience; the user, I'd gather. No harm is done to these ranges physically by jet bombers; I have been personally confronted with many more com- mercial and military overflights in designated wilder- ness and BLM WSAs in Utah, let alone Nevada, Mon- tana, Wyoming, and Colorado. The planes are simply not an issue in places like the Dugways, Newfound- lands, Simpsons, and Cedar Mountains. Please don't pretend this is an issue which downgrades wilder- ness. Planes are everywhere: West Desert solitude is yet a unique community on this continent. 22.7 RESPONSE: Low level overflights by military aircraft are analyzed as a temporary annoyance that would detract from opportunities for solitude. Over- flights of the BLM WSAs are not considered in the ra- tionale for the BLM Proposed Action Alternative (re- fer to Appendix 11). Overflights would not change with or without wilderness designation. Also, see the responses to General Comments 3.1 and 3.42. 6 GENERAL COMMENTS AND RESPONSES SECTION 22: WILDERNESS VALUES 22.8 COMMENT: The Draft EIS fails to identify what is meant by "a day's driving time." [State of Utah, Frances Fericks, et al.] a. Page 95, Proximity to Population Centers: An explanation of how it was determined that the defi- nition of "a day's driving time" equals 5 hours would be helpful. b. One criterion for recommending designation of WSAs is proximity to population centers. BLM used one day's driving time, translated to 5 hours, as the measurement. How did BLM determine that one day's driving time is 5 hours? Were studies used which established 5 hours as the time people travel during a day on the road? Did BLM measure the driving time from major population centers to individual WSAs? How were major population centers determined? To what point in a WSA is the measurement taken? 22.8 RESPONSE: "A day's driving time" was deter- mined by the BLM Washington Office to be 5 hours. This time period is used throughout BLM to maintain consistency. This standard was published for public review and is discussed in the BLM Wilderness Study Guidelines, published on February 3, 1982 l Federal Register Volume 47, No. 23, page 5107). 22.9 COMMENT: The Draft EIS fails to indicate how much of the nation is wilderness and in what way des- ignating all the BLM lands nationwide and in Utah would change that figure. [Earth First!, Marathon Oil, et al.] a. The BLM EIS states that this designated wilder- ness represents 1.38 percent of the total land hold- ings in the lower 48 States. This is disputed on the grounds that wilderness lands are only on public Fed- eral lands. The total acreage administered by Federal agencies is 725 million acres in the nation, with the percentage of wilderness of all Federal lands standing at 1 1 percent of this total. Additionally, it states that 87 percent of designated wilderness is in the 11 west- ern states. To further amplify on this figure, my calc- ulations, from the American Petroleum Institute infor- mation that showed that, in the six western states of Arizona, Colorado, Idaho, Nevada, Utah, and Wyom- ing, currently amount to 75 percent of the designated wilderness lands in the continental United States. Turning to more specifics in the State of Utah, the EIS states that there are 5.8 million acres of existing or potential wilderness in Utah. This figure is then relat- ed to a percentage that is total land mass and not a percentage of the Federal lands in the State of Utah. The calculation comes out to 17.3 percent of the Fed- eral public lands in Utah are or could be designated wilderness. And, in a State where 63.6 percent of the land is Federally administered, this is a large propor- tion. To be conservative I've only used the Proposed Action. So the total for potential wilderness designa- tion is 4.5 million acres in Utah. Even with this con- servative figure, the State of Utah will have 12.9 per- cent of the total designated wilderness area in the con- tinental United States. b. The total amount of protected lands (i.e. , nation- al parks, wildlife refuges, and wilderness) in the low- er 48 United States is much less than 5 percent of the total area. And that figure wouldn't change much even if all of BLM's WSAs nationwide were to become desig- nated wilderness. 22.9 RESPONSE: Most of the public land in the U. S. is in the west, primarily within 1 1 western States; therefore, it is natural that most of the designated wilderness is also in those 11 western States. To be sure, the wilderness question is a local issue, but more importantly, it is a national issue, which pro- vides both benefits and costs to all Americans. Know- ing this, Congress reserved unto itself the decision on how much wilderness will be preserved, not only in Utah but throughout the United States. They will take many factors into consideration when deciding how much wilderness will be preserved, including the de- sires of the public. The Introduction to Volume I of this Final EIS explains the size and location of the lands of the NWPS. Also, see the response to General Comment 8.9. 22.10 COMMENT: The criteria used to define diver- sity in the Draft EIS are not reasonable. [Utah Wilder- ness Coalition, Tim Graham, et al.] I take exception to the criterion used in defining diversity in the Draft EIS (pages 94-95). Granted, the NWPS should include the gamut of ecosystems and landforms of this continent; though as far as BLM in Utah is concerned, there are only so many physio- graphic divisions of wilderness values. Furthermore, geography and relation to population centers of WSAs are not reasonable means of assessing an area's suita- bility. The EAWA of 1978 cited (page 95) is in refer- ence to wilderness lands in the Eastern U.S. where population and wildland relations differ vastly from the Great Basin. In my estimation, the Canyonlands section of the Colorado Plateau Province qualifies not 7 GENERAL COMMENTS AND RESPONSES SECTION 22: WILDERNESS VALUES only nationwide, but planetwide, as a landscape wor- thy of preservation. Wilderness values found here and in no other region must be compared with the present roster of NWPS units, not unto another unit within San Juan County, if diversity as criteria is properly applied. 22.10 RESPONSE: The information in the EIS deal- ing with geology and topography and existing vegeta- tion types and sensitive plant and animal species pro- vides additional information and diversity. The eco- system and PNV types found in WSAs are compared to existing and other potential NWPS units in the Affect- ed Environment (Chapter 3) Wilderness Values section of Volume I. Also, see the response to General Com- ment 8.22. 22.11 COMMENT: The Draft EIS fails to mention that some of the nation's most spectacular land is in Utah. [The Wilderness Society, et al.] The Draft EIS does not address the fact that some of the most spectacular county in the nation exists in southern Utah and that larger wilderness recommenda- tions need to be proposed in Utah in order to balance the NWPS. (That is to say we can't have a wilderness area in Cleveland, Ohio.) The BLM lands contain our last wilderness fron- tier. Of all the Federal agencies, BLM provides more habitat for wildlife, contains more diversity of eco- systems, and has more potential for archaeological discovery than any other systems. In Utah, we have opportunity to preserve for ourselves and future gen- erations a sample of these diverse wild lands. 22.11 RESPONSE: The spectacular nature of the lands in Utah is self evident because of the number of WSAs identified in Southern Utah and in the number of acres being recommended. Lands in Southern Utah are spectacular in their own setting just as many other lands in the U.S. are also spectacular in their setting. 22.12 COMMENT: How can both outstanding soli- tude and primitive recreation values be found lacking on the same acreage? [Owen Severance] I am always suspicious when the same acreage is claimed to lack both solitude and primitive recreation values, as is the case for the Deep Creek Mountains WSA, Swasey Mountain WSA, Notch Peak WSA, and the Wah Wah Mountains WSA. These areas should be rechecked to see if they have been properly evalu- ated. I have the feeling that the wilderness recommen- dation was arrived at first, and then the data were made to conform to that decision. The more I read the Draft EIS, the more pessimistic I become about the objectivity of the BLM personnel involved in the wil- derness study. 22.12 RESPONSE: Each of the WSAs was evaluated for solitude and primitive recreation values. Fifteen primitive recreation activities were analyzed by a team to see if opportunities for these activities were present in the WSA. Opportunities for activities were found in varying degrees throughout the various WSAs. Few, if any, of these activities were found of outstanding quality on the lower benchlands and other areas lacking outstanding solitude. It is entirely logical that acreages having or lack- ing outstanding opportunities for solitude would often be the same as those having or lacking outstanding opportunities for primitive-type recreation because both depend on similar terrain and geographic loca- tion. Vegetative and topographic screening, which pro- vide solitude opportunities also provide landscape var- iation, visual interest, and isolation, which enhance primitive recreation opportunities. 8 GENERAL COMMENTS AND RESPONSES - SECTION 23 LAND USE PLANS AND CONTROLS INDEX 23.1 Future power and communication lines are block- ed or curtailed by WSAs. Specifically, no considera- tion is given to long-range utility planning in the All Wilderness Alternative, (p. 1) 23.2 Coal transportation plans from the Kaiparowits coal field are no longer under consideration. There- fore, this should not be considered in BLM land use planning or the EIS. (p. 2) 23.3 Transmission pipelines and gathering facilities are adversely affected by WSAs. (p. 2) 23.4 Certain counties have ordinances, zoning, or master plans which oppose wilderness or conflict with it. (p. 3) 23.5 Wilderness is not totally opposed in county land use plans, (p. 3) 23.6 To agree to wilderness recommendations, Gar- field County residents must be guaranteed that min- erals can be developed in WSAs through the use of ex- isting old roads for access and powerline corridors in the Boulder-Bullfrog and Harris Wash areas, (p. 4) 23.7 BLM has failed to analyze possible negative eco- nomic effects resulting from restrictions occurring in zones adjacent to wilderness, (p. 4) 23.8 County opposition to wilderness should be of little consequence in BLM's studies, (p. 4) 23.9 The use of State lands is not static; there will be more changes over time. (p. 5) 23.10 The State of Utah's position on exchange of in- held lands should be clarified, (p. 5) 23.11 Plans for development in WSAs should not be further considered until questions are resolved con- cerning proposals on adjacent lands. Such proposals are not an adequate reason to dismiss areas from wilderness consideration, (p. 5) 23.12 Efforts to balance needs for energy and wilder- ness result in irregular boundaries and create manage- ment problems, (p. 6) 23.13 The EIS should consider project proposals on lands adjacent to proposed WSAs in alternatives other than the All Wilderness Alternative, (p. 6) 23.14 BLM's recommendations should be consistent with the NPS management, (p. 6) 23.15 BLM lands adjacent to national parks should be designated as wilderness to enhance management, (p. 7) 23.16 Which Ute tribe is listed? The Uintah and Ouray Utes or the White Mountain Utes? (p. 9) 23.17 The effect of wilderness designation on the mili- tary's use of low-altitude air space should be ana- lyzed. (p. 9) 23.18 If the BLM-FS interchange occurs, WSAs adja- cent to FS land (e.g., Mule Canyon and Arch Canyon) should be reevaluated to determine possible enlarge- ment. (p. 9) 23.19 BLM can only find ONAs and ACECs in areas supported for wilderness designation. Surely other areas deserve such status, (p. 10) 23.20 BLM should discuss six national natural land- marks as special management areas, (p. 10) 23.21 The EIS should provide more information and analysis on presently withdrawn lands and other areas already set aside for special management, (p. 10) COMMENTS AND RESPONSES 23.1 COMMENT: Future power and communication lines are blocked or curtailed by WSAs. Specifically, no consideration is given to long-range utility plan- ning in the All Wilderness Alternative. [Utah Power and Light] 1 GENERAL COMMENTS AND RESPONSES SECTION 23: LAND USE PLANS AND CONTROLS a. Powerlines don't just go from this little area to this little area. They start over here and then run a straight line all the way through. Somewhere they are going to be blocked by a wilderness area. Power rates are already to a point where we won- der why we're doing some of the things we're doing. I represent about 5,000 consumers in Garfield County, Kane County, Coconino and Mohave County in Arizona (the northern part) plus some in Washington County, and they serve Wayne County as well. We’re really impacted. I didn't hear very much or anything at all in the preliminary reading that addressed the power situa- tion (the possibility of putting in powerlines). You know, all powerlines become overloaded pretty soon. Pretty soon you have to build a new one. You're not going to build them in exactly the same place the other one is. You can't do it. You've got to have ano- ther corridor. You've got to put it in something- someplace. Almost every one of these places in this corner of Utah are blocked by wilderness areas. That means you've got to go around it. b. While we support a concept of preserving some wilderness areas for the recreation benefits they pro- vide to those persons in the service territory, the Final EIS should balance those interests with the fu- ture needs for electricity and development in Utah. No consideration is given to long-range plans to generate and supply electricity in the All Wilderness Alterna- tive, and we strongly oppose it. 23.1 RESPONSE: To the extent that they are known, the Draft EIS addresses planned or potential transportation corridors in specific WSAs analyses in Volumes II through VI. It is recognized that the effects of wilderness on transportation corridor planning would vary according to the alternatives, but trans- portation routes would not be completely foreclosed by any alternative. The All Wilderness Alternative would, of course, be the most restrictive; however, the Western Utility Group corridor map indicates that few, if any, WSAs would be affected by or would con- strain transportation routing (Volume I, Draft EIS, page 99). BLM planning subsequent to the Draft EIS bears this out. Many plans for power/communication lines have not yet been developed or are only concep- tual, as noted in the Volume I, Chapter 3 discussion of Land Use Plans and Controls and, therefore, could not be analyzed in detail in the EIS. 23.2 COMMENT: Coal transportation plans from the Kaiparowits coal field are no longer under considera- tion. Therefore, this should not be included in BLM land use planning or the EIS. [Environmental Protec- tion Agency] 23.2 RESPONSE: Coal mining in the Kaiparowits Pla- teau has been proposed for at least 15 years and has been the subject of several Federal and private stu- dies. Valid coal leases are held in the area, and coal reserves are documented and considerable in size. Therefore, the possibility of the future of coal mining and transportation cannot be ignored in BLM planning. Consideration of energy and mineral resources is also mandated by law and the Wilderness Study Policy (USDI, BLM, 1982a). Also, see General Comment Response 8.18 which responds to questions on the need for Kaiparowits coal transportation corridors. 23.3 COMMENT: Transmission pipelines and gather- ing facilities are adversely affected by WSAs. [Har- vey Mervil, Rocky Mountain Oil and Gas Association, et al.] Lost Spring Canyon, Flume Canyon, Spruce Can- yon, and Coal Canyon WSAs border on or contain transmission pipelines and gathering facilities. Clo- sure of public lands to mineral resource development will forego maximum use of existing transportation systems and preclude recovery of substantial quanti- ties of oil and natural gas. 23.3 RESPONSE: It is recognized in the Draft EIS that the oil and gas potential of Flume, Spruce, and Coal Canyons is relatively high. Pipelines in the Win- ter Ridge WSA and bordering Lost Spring Canyon would not be affected. No other pipelines have been identified and noted in the EIS. Analysis in the EIS indi- cated that foregoing recovery of oil and gas in the Lost Spring Canyon WSA would not have significant adverse impacts (Volume V, Lost Spring Canyon WSA); however, if the recommendation is made for wilderness, mineral importance of the WSA will be further reviewed by the Bureau of Mines/USGS, and these findings will be considered by the Director of the BLM and the Secretary of the Interior before final wilderness recommendations are made. 23.4 COMMENT: Certain counties have ordinances, zoning, or master plans which oppose wilderness or conflict with it. [Utah Counties, Mr. Keogh, et al.] 2 GENERAL COMMENTS AND RESPONSES SECTION 23: LAND USE PLANS AND CONTROLS a. BLM has not taken into account the master plans of local governments for use of these areas. Right now Emery County is in the midst of writing master use plans for the entire county, and I feel BLM should wait and consider these plans (as they are required to do by law) and incorporate them into the Draft EIS proposal for presentation to Congress. b. The concept of the wilderness areas is in direct conflict with the Kane County Master Plan. The Kane County Master Plan supports a total concept of multi- ple use of public lands. At present, there are 15 WSAs in Kane County. These areas cover an area of 639,558 acres of Federal land, 27,197 acres of State land, and 80 acres of private land. There is an area of about 19,000 acres already designated as a wilderness area in the Paria River area. About 25 percent of Kane County is tied up in either wilderness or in a WSA. c. The Grand County Planning Commission unani- mously recommended to the County Commissioners that they oppose any wilderness designation in Grand County because restrictions on mining, oil and gas development, grazing, or organizing recreational uses will adversely affect the county's economy. The pro- hibition or restriction of expressly permitted uses in our zoning ordinance for various areas would be a vio- lation of a legally adopted county ordinance. d. The Utah Association of Counties supports S.C.R. No. 1 passed in Special Session by the Utah State Legislature, with the Governor concurring therein. A copy of the resolution is attached. This resolution accurately reflects the concerns of this State and especially those who must live with the wilderness decisions on a daily basis. 23.4 RESPONSE: The fact that possible wilderness designation by Congress would be contrary to the in- tention of certain county commissions has been addressed in the Affected Environment, Land Use Plans and Controls section. As noted in the EIS (Vol- ume I, Introduction), BLM is required to study, report on, and make recommendations regarding possible wilderness areas; however, only Congress can desig- nate wilderness areas. See the responses to General Comments 4.1 and 4.2 concerning State and local road definitions. Also refer to the complete text of the local government position in Volume VII, Part A. 23.5 COMMENT: Wilderness is not totally opposed in county land use plans. [Utah Wilderness Associa- tion] Despite political rhetoric to the contrary, wilder- ness is not totally opposed in county plans. Table 59 in the Draft EIS points this out very clearly. It shows that Garfield County, Utah, and the Six County Com- mission Organization (including Juab, Millard, and Wayne Counties, Utah) have agreed that wilderness is not incompatible with their overall plans. From these counties we present the following: Wayne County's ". . . outstanding natural land- marks should be preserved as much as possible." Garfield County possesses ". . . some of the most spectacular scenery in the United States . . . The Coun- ty is sparsely populated and most of it in its original pristine condition." Likewise, Emery County submitted a paper to Utah Congressman Howard C. Nielson last year which, based on the March 1983 Site Specific Analysis (SSA), stated: "We come to an even more complete concurrence with the recommended findings of the BLM which propose setting aside 366,345 acres (13 percent of the County) in eight of nine proposed wil- derness study areas . . . Due to the geographic nature of the land that has been designated as wilderness, it has to be considered as wilderness. Accordingly, we would be acting irresponsibly if we were to discour- age or oppose some wilderness designation in Emery County. There is a certain portion of our County that is deserving preservation and protection." We are concerned that many politicians are twist- ing the wilderness issue in Utah without a complete understanding of the facts. BLM must, as the manager of many large county areas, correct inaccurate state- ments as soon as possible. For example, in a recently released report from a number of county governments in Utah, numerous in- accurate references are made to water rights, buffer zones, grazing, land transfers, and air quality, among other issues. BLM should correct these misunderstand- ings by whatever means possible. This should include public education campaigns and news media rebuttals. These same county governments keep asking for multiple-use management of the public lands. 3 GENERAL COMMENTS AND RESPONSES SECTION 23: LAND USE PLANS AND CONTROLS Wilderness designation of 5 million acres of BLM lands will add to multiple use of the land. BLM should work with the various county governments to explain that wilderness is an important part of multiple-use management practices. 23.5 RESPONSE: The Affected Environment, Land Use Plans and Controls sections of the EIS state that wilderness designation is generally consistent with multiple-use management since most resource uses would continue. However, the BLM Wilderness Study Policy (USDI, BLM, 1982a) requires BLM to consider not only the "plans," but the "policies" of local gov- ernments. Wilderness designation is not generally con- sistent with local government policy, as expressed to BLM. Also, see the response to General Comment 2.1, which discusses BLM's responsibilities to inform the public of the wilderness review process. 23.6 COMMENT: To agree to wilderness recommen- dations, Garfield County residents must be guaran- teed that minerals can be developed in WSAs through the use of existing roads for access and powerline corridors in the Boulder-Bullfrog and Harris Wash areas. [Guy Thompson] To agree to wilderness, the people of Garfield County would have to be guaranteed that the right of developers to drill and test for the oil in The Dome, which is in the lower reaches of a WSA, would be pro- tected, and that they would be allowed to develop and export the resource when found, including refining in the area if it should be economically needful. We must also be guaranteed that the tar sand, uranium, and other resources in the area will be allowed to be de- veloped as the market for those materials becomes economically viable, and that corridors shall be left into the areas where these deposits exist for ade- quate roads, powerlines, processing, and export. These shall include the Boulder to Bullfrog road and all other existing roads in the area; if needed, roads which existed in the past but which are presently not usable, such as the Harris Wash and Silver Falls roads; and, if it is necessary, the reconstruction of the road down The Gulch to get a crossing on the low- er Escalante River, which would not be necessary if the Harris Wash-Spring Falls road was reopened as an access corridor. In making this statement, I realize that some of this is beyond your power of agreement, and that the Harris Wash and Silver Falls roads are now in the NRA, and Congress may have to give their permission for their use. However, you could recom- mend that option as a compromise for the recovery of those natural resources on your lands and preserve wilderness integrity of the section of The Gulch and Escalante River, which to me appears to be more suit- ed as wilderness than the lower section which would be a much better river crossing and has been used as an access corridor in the past. 23.6 RESPONSE: The Garfield County Master Plan (1984) recommends wilderness designation for 111,053 acres of public lands, including 53,447 acres in the North Escalante Canyons/The Gulch ISA (Volume III, Part B). BLM's proposed alternative for the ISA is the Partial Wilderness Alternative of 96,361 acres, which would have the fewest conflicts with mineral development and transportation (Volume III, Part B). The area in question has low oil and gas potential and contains a relatively small amount of tar sand (Volume III, Part B). 23.7 COMMENT: BLM has failed to analyze possible negative economic effects of restrictions occurring in zones adjacent to wilderness. [Carvel Magelby] 23.7 RESPONSE: See the responses to General Comments 7.1, 10.3, and 24. 23.8 COMMENT: County opposition to wilderness should be of little consequence in BLM's studies. [Kevin O'Brien, et al.] a. In all the alternatives, there should not be em- phasis on conflicts with county multiple-use plans. Wilderness is a recognized part of multiple-use man- agement of Federal lands whether or not the counties recognize it as such. The issue of wilderness designa- tion/nondesignation is of overwhelming national con- cern, not just local concern. b. Throughout the EIS, local land use plans are mentioned, as though they are an important considera- tion. Have the sentiments of individuals, organiza- tions, etc., from outside neighboring communities been considered in this manner? I am concerned that BLM is placing undue emphasis on the wishes of a handful of political leaders from southeastern Utah. c. The fact that most local governments in Utah oppose wilderness designation on Federal lands within their boundaries should be of little consequence in BLM's treatment of the review of wilderness on the public domain. An unjust prejudice against wilderness 4 GENERAL COMMENTS AND RESPONSES SECTION 23: LAND USE PLANS AND CONTROLS and misunderstanding of its implications pervades throughout rural communities in Utah, and I feel this document is lacking in its service to dispel these fears. 23.8 RESPONSE: BLM is required by policy and regulation to consider other land use plans, policies, and programs, including those of local government (43 CFR 1610.3-2). Also, see the responses to General Comments 4.1 and 4.2 which explain State and local government defi- nitions of roads, and General Comment 2.20, which addresses local, regional, and national perspectives in the EIS. 23.9 COMMENT: The use of State lands is not static; there will be more changes over time. [State of Utah] 23.9 RESPONSE: See the responses to General Com- ments 6.1, 6.2, and 6.3 covering in-holdings. 23.10 COMMENT: The State of Utah’s position on exchange of in-held lands should be clarified. [State of Utah and Utah Counties] The Draft EIS anticipates that in-held State trust lands will be traded out. The policy of the State on exchange of in-held lands has changed since the Draft EIS was prepared. 23.10 RESPONSE: The Descriptions of the Alterna- tives and the Affected Environment, Land Use Plans and Controls sections of the EIS have been revised to note that the State of Utah may retain ownership of in- held lands. Access must be granted to in-held sec- tions, as demonstrated in the Cotter Corporation deci- sion. Therefore, provision of access to State lands may affect wilderness values, but wilderness designa- tion would generally not affect the use of State lands. Also, see General Comment Responses 3.34, 6.1, and 6.3. 23.11 COMMENT: Plans for development in WSAs should not be further considered until questions are resolved concerning proposals on adjacent lands. Such proposals are not an adequate reason to dismiss areas from wilderness consideration. [Bruce Chesler, et al. ] a. Appreciated are the mention of proposed devel- opments in WSAs (page 99). I do not think such pro- posals or plans can be given further consideration un- til wilderness questions are resolved on adjacent or contiguous BLM holdings. Such developments as the widening and paving of the Burr Trail would not only impact the WSAs mentioned, but repercussions of the upgraded road and transportation would be felt in sou- thern Utah in general. Mention of the possibilities for cloud seeding and communication sites (page 100) on summits or plateaus in WSAs seems to me trifling ex- cuses to dismiss an area from wilderness recommen- dation. Certainly, commercial communications net- works have satellite capabilities at their disposal. As per "radio show" instances among two-way radio users, I suggest either improving facilities already in use, drive-up summits, or alternately get out of the machine and hike up to relay the message. That's the way its done on certain public lands in this coun-try. b. I feel too much emphasis is made on the com- munications and relay station potentially locatable on West Desert summits. There are certainly other com- munication opportunities available (i.e., satellite). To make this issue moot, why not leave the few un- scathed high places in this desert intact as one place one can avoid other communications and listen to the immediate surroundings. We spend inordinate amounts of our lives listening and talking with others afar- let's keep a few places open so that more important communications can prevail with the earth, sky, and heavens. 23.11 RESPONSE: The interrelationship between proposed and actual uses in adjacent areas must be addressed in planning, analyzed as to consequences, and considered in decisionmaking (BLM Manual 1601.08). Certainly, there are alternative means of accomplishing many projects, and the EIS has consid- ered many. Nevertheless, the Wilderness Study Poli- cy (USDI, BLM, 1982a) requires BLM to identify po- tential land use conflicts with wilderness designation. Such problems as radio shadows can be important in emergency situations and in administration of land uses. Such affects are not expected to be significant on a Statewide basis, but are analyzed in the individ- ual WSA analyses. Also, see the response to General Comment 23.19. Rationale for BLM's Proposed Action are included in Appendix 11. 23.12 COMMENT: Efforts to balance needs for ener- gy development and wilderness result in irregular boundaries and create management problems. [Patricia Thompson, et al.] 5 GENERAL COMMENTS AND RESPONSES SECTION 23: LAND USE PLANS AND CONTROLS This will create management problems and re- sult in wilderness surrounded by well rigs and roads. Energy developments should not be planned adjacent to national parks and FS lands, for instance. These areas should be preserved for wilderness. 23.12 RESPONSE: WSA boundaries were identified in an inventory process guided by criteria and direc- tives, as discussed in the Introduction in Volume I. Manageability has been considered. BLM does not de- velop proposals for energy development; however, mineral resources must be considered, as mandated by the Wilderness Act of 1964 and FLPMA of 1976. WSA boundaries are not intentionally irregular. The commentor's recommendation for protecting areas adjacent to NPS and FS lands is noted; however, the present body of law and precedent indicate that public lands must be managed under multiple-use principles if released from wilderness study. There are no for- mally established buffer zones surrounding national parks in Utah. Also, see General Comment Response 2.1 1. 23.13 COMMENT: The EIS should consider project proposals on lands adjacent to WSAs in alternatives other than the All Wilderness Alternative. [National Park Service] We suggest that better management decisions re- garding wilderness on the public lands would be en- hanced if the EIS had more discussion about project developments on lands adjacent to proposed wilder- ness in alternatives other than the All Wilderness Alternative. Since uses on adjacent lands affect qual- ity of wilderness, we feel that more analysis of land use proposals on these adjacent lands is in order for each of the alternatives. The proposed activities for adjacent lands include mining exploration, mining pro- duction, livestock/wildlife habitat, development, etc. These sorts of activities will affect the wilderness air quality, disrupt views, create noise, and other- wise adversely impact the wilderness experience. Road construction, use of water resources, and watershed impacts should also be discussed. 23.13 RESPONSE: The EIS addresses foreseeable potential uses and proposals for areas adjacent to WSAs for each alternative analyzed in detail. The effects of possible activities both within and adjacent to WSAs are discussed under all alternatives in Vol- umes II through VI (e.g., see Volume III, Part B, Wah- weap WSA, for an analysis of effects of the No Action/No Wilderness Alternative). Also, see the gen- eral discussion on proposed development projects in Volume I, Chapter 3, Land Use Plans and Controls sec- tion, where proposed development projects in WSAs are identified. Foreseeable projects are also identi- fied in the Descriptions of the Alternatives. 23.14 COMMENT: BLM's recommendations should be consistent with NPS management. [National Park Service] In general, the NPS would recommend wilderness designation for WSAs adjoining NPS units and would like to see the Final EIS provide more discussion of compatible management of contiguous resources and values. 23.14 RESPONSE: BLM recognizes the importance of compatible management for contiguous similar or complementary lands. This was discussed in the EIS where appropriate (e.g., WSAs adjacent to Zion Na- tional Park, Volume III, Part B). In cases where WSAs are not designated as wilderness, management will be in accordance with BLM land use planning, which is guided by different laws and mandates than for NPS lands. BLM coordinates with the NPS as part of the normal planning process. That planning process re- quires consultation with the public and all affected and interested persons, groups, and government enti- ties, as well as compliance with NEPA. Also, see the response to General Comment 8.7, which addresses the EIS analysis of compatible BLM- NPS management. The Cluster and Interagency Area Alter-native has been added to the Final EIS to fur- ther identify opportunities for cooperative wilder- ness management. 23.15 COMMENT: BLM lands adjacent to national parks should be designated as wilderness to enhance management. [Sierra Club, Cache Group] A number of BLM lands in Utah that possess wil- derness qualities are located adjacent to NPS lands. These BLM lands complement, protect, and enhance the NPS boundaries. In most cases, they complete the true natural boundary of the NPS tract since NPS boundaries are usually drawn along imaginary but convenient section and township lines. Throughout the Draft EIS, BLM has stated that some lands simply cannot be managed as wilderness even if they do qualify. If BLM wilderness quality lands adjacent to NPS lands fall into this situation, then action should be taken to transfer their admini- 6 GENERAL COMMENTS AND RESPONSES SECTION 23: LAND USE PLANS AND CONTROLS stration from the BLM to NPS as soon as possible. Wilderness should be protected on its own merit, not based on which agency has the deed. The following subsections identify BLM lands that should be designated as wilderness and also critically border a national park, a national monument, or an NRA. The listed areas represent minimum additions that will protect the future of NPS lands. Arches National Park: One of Utah's most popular Fed- eral parks, Arches includes several pristine areas that suddenly convert from NPS protection to ques- tionable BLM ownership. Wilderness designation on the following units would extend the natural bounda- ries of Arches National Park and, therefore, protect the park's spectacular and unique roadless backcoun- try for future visitors. (a) Lost Spring Canyon (b) Hunter Canyon Brvce Canvon National Park: The following BLM tracts, though relatively small, would greatly en- hance the natural, scenic, and recreational values of Bryce Canyon National Park. These units are natural extensions of existing NPS land. (a) Squaw Creek (b) Willis Creek (c) East of Bryce (d) Box Canyon Canvonlands National Park: When Congress was debat- ing the boundaries of Canyonlands National Park in the 1960s, most of the serious proposals included the fol- lowing BLM units. It was unwarranted political pres- sure that removed most of these units from the final park bill. They are all natural extensions of the vari- ous geological formations and biological communities found within the park. (a) Six Shooter Peaks (b) Indian Creek (c) Shaffer Canyon (d) Goosenecks (e) Butler Wash Capitol Reef National Park: Capitol Reef National Park was primarily established to protect the famous Waterpocket Fold, but it also includes many outstand- ing backcountry areas which NPS is proposing for wil- derness. If the following areas were designated as wil- derness, the wild and unique roadless backcountry of Capitol Reef National Park would receive much needed protection. These areas would enhance many park val- ues by protecting scenic views and adjacent water- sheds. Most of these BLM units are natural remain- ders of canyon and plateau systems already present in the park. (a) Mt. Pennell (b) Fremont Gorge (c) Colt Mesa (d) Red Desert (e) Jones Bench (f) Dog Water Creek (g) Notom Bench (h) Long Canyon Dinosaur National Monument: Though the following two areas are very small, they are natural exten- sions of wild roadless backcountry in Dinosaur Nation- al Monument. Several early proposals for this monu- ment included these BLM units. Since they are so close to several monument boundaries, it is very un- likely that they could be used for any nonwilderness- type activity. (a) Daniels Canyon (b) Moonshine Draw Glen Canvon NRA: Even though the Glen Canyon NRA was established to administer and promote recreation at Lake Powell, its peripheral boundaries include many remote and pristine wilderness areas. These areas overlap the "Congressional boundary" and ex- tend deep into many BLM tracts. (a) Northern Boundary: On the northern bounda- ry, wilderness protection is critical for the fragile and popular upper canyons which drain into Glen Can- yon. These BLM tracts include: (1) North Escalante Canyons/The Gulch (2) Little Egypt (3) Scorpion (4) Dance Hall Rock (5) Sooner Bench (6) Escalante Tract No. 5 (b) Western Boundary: The western boundary of Glen Canyon contains large portions of the scenic and pristine Orange Cliffs. Wilderness protection of the following areas will protect the natural vistas that many Lake Powell users already accept as part of the NRA. (1) French Springs-Happy Canyon (2) Dirty Devil (3) Fiddler Butte (4) Little Rockies (c) San Juan Boundary: On this southeastern boun- dary of the NRA, several BLM lands need wilderness 7 GENERAL COMMENTS AND RESPONSES SECTION 23: LAND USE PLANS AND CONTROLS designation for the protection of numerous incised and narrow canyons which drain the Cedar Mesa’s pinyon- covered plateau highlands. The following BLM units would create an outstand- ing river and canyon wilderness complex, with many opportunities for solitude and primitive recreation. (1) Nokai Dome (2) Castle Creek (3) Grand Gulch Complex (4) Mike's Canyon Natural Bridges National Monument: These are impor- tant canyon areas because of their relationship to Natural Bridges National Monument, the Utah Wilder- ness Coalition has proposed a White Canyon Complex wilderness grouping for this location. We urge BLM to consider this well developed proposal; it has the full support of the Cache Group (Sierra Club). Zion National Park: With the exception of Parunuweap Canyon and Canaan Mountain, the following BLM tracts are among the smallest in Utah still possessing the wilderness qualities. These lands are natural ex- tensions of Zion National Park's backcountry. Wilder- ness designation of these areas will protect this national park's boundaries from potentially destruc- tive water and mineral development projects. The nearby city of St. George, Utah, has plans for water development in several of these following tracts. (a) Parunuweap Canyon (b) Canaan Mountain (c) The Watchman (d) Orderville Canyon (e) Shunesburg (I) North Fork Virgin River (g) Deep Creek (h) Goose Creek (i) Beartrap Canyon (j) LaVerkin Creek Canyon (k) Taylor Creek Canyon (l) Spring Creek Canyon (m) Lost Spring Canyon (n) Black Ridge (o) Red Butte 23.15 RESPONSE: See the responses to General Comments 3.1 and 3.7, which discussed the BLM wil- derness inventory in Utah and the need to analyze citi- zen alternatives. Many of the areas listed in the com- ment were dropped from further wilderness consider- ation during BLM's intensive inventory phase. The re- mainder are included in the Statewide EIS, and their relationships to NPS lands are discussed in the EIS. When developing the Proposed Action, BLM con- sidered management of adjacent areas. Rationale for the Proposed Action are summarized in Appendix 11. 23.16 COMMENT: Which Ute tribe is listed in con- sultation coordination? The Uintah and Ouray Utes or the White Mountain Utes? [Unidentified] 23.16 RESPONSE: The list was meant to indicate the "Uintah-Ouray Ute Indian Tribe." 23.17 COMMENT: The effect of wilderness designa- tion on the military's use of low-altitude air space should be analyzed. [United States Air Force] a. Currently, several Air Force operations, includ- ing instrument flight training routes, traverse por- tions of the WSAs, specially in the western half of the State. Although flight training areas, routes, and airspace requirements of the military are subject to change and do change frequently, it is not anticipated that new routes will be established in the immediate future. Mission requirements, fuel costs, and environ- mental constraints determine the decision to locate military training activities. Because of general avia- tion and population pressures, low-level high-speed flights are relegated to areas which are least acces- sible and sparsely inhabited. Therefore, we request that you give full consideration to how planning and management decisions made by your agency may adversely affect or restrict use of low-altitude air- space by the military. The Air Force's position on this matter is based on the high training and readiness values rendered by use of this low-altitude airspace. b. Communication sites, as referred to in Volume I, Chapter 3, page 100 of the Draft EIS, are not identi- fied in Volume II. The Air Force has a requirement to strategically locate microwave radio and other data collection and transmission devices in proximity to the airspace within the Utah Test and Training Range. At present, there are in excess of 100 of these sites located both on Department of Defense and non- Department of Defense land. Many of these sites are located on BLM-controlled land, and some are located in proposed wilderness areas (see attached map). These sites, in their current location and other loca- tions in the future, are critical to the success of ad- vanced defense testing at the Utah Test and Training Range. It is imperative that the Air Force be allowed to retain these sites and/or construct future sites 8 GENERAL COMMENTS AND RESPONSES SECTION 23: LAND USE PLANS AND CONTROLS within the proposed wilderness areas in the West Desert. The Air Force recommends that authority for use in these sites be included in the Final EIS, and that existing agreements between the Salt Lake BLM Area Office, and the Richfield BLM Area Office be upgraded immediately to reflect and protect the interests of both agencies. Where no official agreement exists, preparation and discussion should proceed as soon as possible. BLM can be assured that the Air Force will construct or maintain sites that cause no damage to soil or alter plant life. Where necessary, sites will be serviced from helicopter, eliminating the need for road construction. VRM rules, as they apply to color schemes and continuity, will be followed. 23.17 RESPONSE: See the response to General Comment 3.42. The EIS analysis assumes that mili- tary overflights of wilderness areas will continue and there will not be restrictions on military use of low- altitude airspace as a result of wilderness designa- tion. Information on the location and use of micro- wave radio and other transmission devices in West Desert WSAs has been included in the WSA analyses in the Final EIS. Following designation, military com- munication sites and low level tracking devices would not be allowed in wilderness areas. This would re- quire the Air Force to redesign and relocate their pre- sent tracking system. 23.18 COMMENT: If the BLM-FS interchange occurs, WSAs adjacent to FS land (e.g., Mule Canyon and Arch Canyon) should be reevaluated to determine possible enlargement. [Owen Severance] 23.18 RESPONSE: Potential and existing wilder- ness areas on adjacent lands were considered in ana- lyzing WSAs. Some boundary adjustments between BLM and FS have been made over the years, and any interchange of land would undoubtedly consider wilder- ness management. The FS areas referred to in the comment were dropped by Congress and were not held for further study. This indicates that Congress specifically rejected these areas, and BLM does not have authority to further study their wilderness char- acteristics at this time. Also, see the responses to General Comments 3.1 and 3.18. 23.19 COMMENT: BLM can only find ONAS and ACECs in WSAs. Surely other areas deserve such status. [Kevin O’Brien] 23.19 RESPONSE: The EIS recognizes current and proposed special designation areas in the Land Use Plans and Controls sections. The focus of the EIS is on the areas within WSA boundaries. 23.20 COMMENT: BLM should discuss six National Natural Landmarks as special management areas. [National Park Service] The NPS recommends that six proposed National Natural Landmarks be identified as special manage- ment areas (visual and/or geologic) in the section on Affected Environment. These are Deep Creek Moun- tains, Swasey Mountain, Red Mountain, and Jewel Box-Cockscomb in the Wahweap WSA, Beckwith Can- yon in Desolation Canyon WSA, and San Rafael Reef. Wilderness designation would afford greater protec- tion. 23.20 RESPONSE: Because suggested additions are not national natural landmarks, but are identified only in these studies, such reference is not made in the Final EIS. 23.21 COMMENT: The EIS should provide more information and analysis on presently withdrawn lands and other areas already set aside for special management. [Utah Counties, et al.] 23.21 RESPONSE: Additional information and analy- sis of withdrawn lands and their management have been added to the Land Use Plans sections of the Final EIS. Special management areas, such as power site classifications, national natural landmarks, ACECs, etc., are included. Also, see the responses to General Comments 23.19 and 23.20. 9 GENERAL COMMENTS AND RESPONSES - SECTION 24 SOCIOECONOMICS INDEX 24.1 More analysis of public sentiment and the value placed on wilderness by the public is needed in the EIS. (p. 1) 24.2 The EIS fails to analyze and compare manage- ment costs of wilderness vs. nonwilderness, (p. 2) 24.3 The EIS underestimates the negative effect of wilderness designation on the economics of livestock operations, (p. 3) 24.4 The EIS places too much (or too little) economic value on livestock and agriculture, (p. 4) 24.5 The EIS should analyze the costs and benefits of proposed land treatments, (p. 5) 24.6 The EIS should analyze the economic impact of denying access to trappers, (p. 5) 24.7 The EIS should recognize the livestock/wildlife tradeoffs, (p. 6) 24.8 The Draft EIS fails to adequately assess the eco- nomic benefits from recreation, (p. 6) 24.9 The Draft EIS does not adequately consider the feasibility of mineral development, (p. 8) 24.10 The EIS should put mineral revenues in per- spective. The economic returns from mineral devel- opment have been over [or under] rated, (p. 9) 24.11 Wilderness designation makes the small min- eral operations uneconomical, (p. 11) 24.12 The EIS should indicate that the value of graz- ing and minerals outside WSA boundaries would in- crease if development inside were foregone, (p. 10) 24.13 The Draft EIS failed to analyze the economic effect of Federal reserved water rights for wilder- ness. (p. 10) 24.14 The EIS analysis of impacts of wilderness designation on local economies is incorrect, (p. 12) 24.15 The effect of wilderness on funding of public education should be analyzed, (p. 13) 24.16 The analysis of the values produced or lost with each alternative is inadequate, (p. 14) 24.17 The EIS places incorrect emphasis on the value of tourism in Utah. (p. 14) 24.18 The value of motorized vs. nonmotorized recre- ation should be compared in the EIS. (p. 16) 24.19 The EIS analysis incorrectly estimates the val- ue of mineral leasing revenues, (p. 17) 24.20 The analysis of the effects of wilderness on local employment and income is inadequate, contra- dictory, and undocumented, (p. 17) 24.21 The EIS does not adequately address secondary impacts to natural resources and their effect on eco- nomics. (p. 21) COMMENTS AND RESPONSES 24.1 COMMENT: More analysis of public sentiment and the value placed on wilderness by the public is needed in the EIS. [Brian Williams, Dennis Willigan, Randolph Jorgen, Utah Wilderness Coalition, et al.] a. The public comment period is an important ele- ment of the EIS process; however, without scientific and systematic study of public opinion through state- of-the-art social science research methods (compu- ter assisted telephone interviewing and time-series panel studies), BLM cannot accurately state current levels of public sentiment and awareness. In short, what people think is as important an element of the social analysis as what they earn, where they live, and how they live. This type of research needs to be conducted for the EIS project. 1 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS b. The Utah Division of Parks and Recreation re- cently (April 1986) completed a Statewide telephone survey for the President's Commission on Americans Outdoors. This study found that 84 percent of Utah respondents agree that "additional efforts should be made to acquire and protect historic sites and natural areas." c. The Draft EIS ignores important social, spiri- tual, and philosophical concerns which were the princi- pal impetus for the establishment of wilderness areas in the first place. BLM cannot and should not attempt to answer the question of how much wilderness is enough. d. Planning, analysis, and evaluation of environ- mental issues has been done haphazardly or one- sidedly in Utah. Utah has never conducted a valid assessment of the residents' goals and desires. The wilderness study only reflects the goals and desires of those doing the study and is not representative of what the people of Utah want. 24.1 RESPONSE: The Federal government discour- ages the conducting of opinion polls and surveys by BLM and other Federal agencies. The Office of Manage- ment and Budget (OMB) must approve all formal ques- tionnaires or surveys any time 10 or more members of the public are involved, and quotas are established for each Federal department in terms of the number of public contacts allowed (BLM Guide to Social Asses- sment, 1982). Utah BLM believes that sufficient pub- lic input has been obtained and will continue to be ob- tained without the need for a Federally sponsored opin- ion survey. Further, the utility of such a survey would be of limited value due to survey constraints in reaching a true representation of local, State, and national publics. The Final EIS reflects public views and opinions re- sulting from a combination of inputs, including direct correspondence from those interested, written and verbal comments received during review of the Draft EIS, information from secondary sources (surveys by others and various media reports), and numerous con- tacts with individuals, groups, elected officials, advi- sory councils, and special interest organizations. A public comment analysis will be included in Wilder- ness Study Reports that will contain BLM's final rec- ommendation and rationale. Volume I, Chapter 1, recognizes the social, spiri- tual, and philosophical concerns on which the Wilder- ness Act is predicated: however, a detailed analysis of these concerns is of little use in defining environ- mental impacts of various alternatives. As a Federal agency, BLM is to provide recommen- dations which reflect its best interpretation of the national interest. This includes, but is not limited to, the views of people in Utah. Also, see General Comment Response 8.9, which deals with the question of "How much wilderness is enough?" 24.2 COMMENT: The EIS fails to analyze and com- pare management costs of wilderness vs. nonwilder- ness. [Rosemary White, Utah Wilderness Coalition, Paul Foreman, et al.] a. Wilderness designation would not incur any high- er tax locally. The management of wilderness acres is less expensive than the management of developed land. b. We request that, in the Final EIS, BLM prepare a detailed analysis to compare the management cost of a WSA based on wilderness and nonwilderness des- ignation. Wilderness manages itself in most situa- tions. Wilderness management consists of not issuing development permits, not performing reclamation, and not monitoring developments. BLM offers no rea- sons, examples, case histories, or legal restraints that support their opinion of management problems. Wilderness management is the least expensive approach. Manageability is a minor concern which ignores the spiritual values of wilderness for Ameri- cans. c. Enforcing wilderness stipulations would be cost- ly, tedious, and often very difficult. A large number of out-of-state deer hunters come to Utah each year who are not savvy to wilderness stipulations. They come with trucks, campers, jeeps, motorcycles, and they go into every part of the country without regard to maps or proper information. They leave their mark behind, especially in wilderness areas. The existence of wilderness will be a major factor in managing activities on adjacent lands and will be quite costly. Management costs should include compensating coun- ties affected by wilderness designation for the right to lock up their revenues with a yearly fee of $100 or more per acre. Does BLM have the budget? It would probably take more BLM employees to manage wilderness areas than are now in service. In times of 2 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS budget cuts, this would appear to take more Federal tax money. d. Why can't Federal costs be estimated for Table 65 (page 104)? Such data are already in Appendix K of the San Juan RMP. Plus, each BLM employee codes his time to a particular activity. 24.2 RESPONSE: Time and expense would be in- curred for preparation of a Wilderness Management Plan that will be required for each area designated. Also, there will be costs for maps and brochures for each area to guide visitors and others in wilderness use procedures. The cost of wilderness management in the field would vary for each area depending on the size, terrain, amount of boundary marking needed, manageability with respect to existing use rights or conflicts, amounts or concentrations of visitor use, and visitor use features. These costs would be in mod- erate amounts and not substantially different than costs for other land management activities. Also, see the responses to General Comments 3.11, 8.23, and 9.14. Wilderness management costs would ool "include compensating counties for the right to lock up their revenues with a yearly fee of $100 or more per acre." The resources and associated revenues on Fed- eral lands do not belong to counties. Revenues receiv- ed for resource development and use on Federal lands generally are (and would continue to be) placed in the U.S. Treasury. Some of the revenues (such as impact funds) may be returned to the States under specific Federal programs, and States may elect to distribute some of these shared funds to counties and cities. Cur- rently, there are no set or guaranteed amounts of Fed- eral revenues that are, or may be, returned to the States or the local governments. Any such returns may vary according to the applicable program, with or without wilderness designation of lands in a parti- cular State or county. Further, counties currently are and would continue to receive payments in lieu of taxes due to Federal lands within their borders. Wil- derness designation would not affect this compensa- tion. 24.3 COMMENT: The EIS underestimates the nega- tive effect of wilderness designation on the econom- ics of livestock operations. [Utah Woolgrowers, Utah Cattleman's Association, Utah Farm Bureau Federa- tion, Utah Counties, et al.] a. The establishment of wilderness areas, even though they are used in a minimal way by one class or another of productive livestock, interferes with these livestock operations. In many instances, it inter- feres in a very substantial way, so that it will so harass these operations to the point that it will bring them to termination. In many instances, there will be no livestock when members of the public come into or travel through such areas. To establish wilderness areas greatly depreciates the value of this substantial and valuable industry- livestock grazing-in the State of Utah. It reduces the value of the privately owned lands which depend upon the use of these public lands and which are vested with the attribute of priority or right to graze these lands. There is no justifiable reason to destroy or to interfere with this livestock industry use of these public lands which are located throughout our State. b. The 1984 BLM Draft Wilderness EIS for the pro- posed Bitter Creek WSA in northeastern Montana rec- ognizes that wilderness designation would negatively affect values of livestock operations. The findings were documented by a survey conducted by Agricul- tural Management and Economic Consulting. The Utah Wilderness Draft EIS totally ignores this issue. The Final EIS should recognize this negative value. c. If increased carrying capacity is on lands which straddle a wilderness area boundary, then the permit- tee will be faced with maintaining one number of stock on one part of his allotment and another number of stock on the balance of the same allotment. Several approaches are available to address such a conflict. BLM may require that the permittee fence the improv- ed allotment. The cost of this approach is not consid- ered in the Draft EIS. BLM may disregard the tres- pass of additional animals onto the wilderness range which would risk adverse legal action. BLM could pre- vent range manipulations on adjacent Federal lands to preclude the possibility of having separate carrying capacities on the same allotment. The cost of this approach to permittees is not considered in the Draft EIS. 24.3 RESPONSE: See the response to General Com- ment 18.1. Previous experiences in the National For- est Intermountain Region wilderness areas conclude that no negative effects to existing (prewilderness) livestock operations have resulted due to wilderness 3 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS designation. Consequently, no significant negative eco- nomic effects are expected to existing livestock oper- ations from wilderness designation on BLM admini- stered land in Utah. It is recognized in the EIS analy- sis that any feasible opportunities to increase forage through chaining projects (and any associated econom- ic gains) would be foregone with wilderness designa- tion. BLM does not foresee increased problems in man- aging allotments which may be partially within and partially outside of wilderness areas. Development of the nonwilderness portion of an allotment would tend to draw cattle out of the wilderness into the more favorable areas, and fencing or special management likely would not be required. 24.4 COMMENT: The EIS places too much (or too little) economic value on livestock and agriculture. [Utah Wilderness Coalition, Utah Woolgrowers, et al.] a. There is a vast oversupply of agricultural pro- ducts in our nation. Little land in Utah is useful for agriculture. Agriculture is a dying industry in Utah. Utah really has little land that is useful for grazing, so not much is lost through a wilderness designation. The Draft EIS overestimates benefits from grazing by overestimating the livestock use of WSAs. Actual use levels in WSAs are probably 40- to 60-percent lower than the preferred use level used by BLM. Most WSA allotments have large components outside the WSA, where access, water, and vegetation are typically more favorable. It is not realistic to assume even distribution throughout the allotment. b. Wilderness designation will cause a loss of in- dustry in Utah. Industries will leave the State and other industries will stay away. We have a strong livestock operation as a great part of the agricultural economics in our State. When a strong rural commun- ity exists, it attracts other light industries into these areas. Rural communities depend on these agricultural industries and do well. An example is found by looking at the agricultural industry in Morgan, Utah. The ranching industry has a vital interest in the designa- tion of BLM wilderness areas. Currently, many cattle and sheep operations are undergoing serious financial stress. Imposition of wilderness restrictions will mean greatly diminished ability to improve the range through chaining, seeding, and water development. Also, access for the movement of livestock will be more difficult. Although livestock interests now in place are supposed to be permitted to continue opera- tions, change or improvements may not be permitted. The Wilderness Act provides for continued livestock grazing where it is already established; however, the Wilderness Management Policy (BLM Manual 8560) goes on to state that "grazing shall be permitted to continue subject to such reasonable regulations as are deemed necessary by the Secretary of Agriculture." The Draft EIS has not considered adequately the eco- nomic loss that may occur as a consequence of the Secretary exercising his statutory prerogative to promulgate increasingly restrictive grazing guide- lines in order to preserve and enhance the wilderness character and limit the activities of nonconforming users. Besides, livestock is a growing industry in Utah, and wilderness designation would slow or cur- tail that growth. A study conducted by a Colorado researcher revealed the economic value of an AUM to be $108. This figure has likely risen, due to inflation, but it has an even more profound effect on the alrea- dy depressed rural communities that depend so heavi- ly on the livestock industry for their livelihood. On the 82 WSAs being considered for wilderness desig- nation, we understand that the All Wilderness Alter- native of 3.2 million acres will affect 423 livestock permittees, which constitutes a whopping 34 percent of all the BLM permittees in Utah and takes in some 96,521 AUMs of forage. According to the Draft EIS, the preferred alternative of 1.9 million acres will affect approximately 21 percent of the State's BLM livestock permittees. Either one of these proposals will have a serious long-term impact on Utah's billion dollar red meat industry. This concern is particularly amplified in the already depressed rural communities that depend so heavily on the range livestock for their livelihoods. The employment estimates used in the EIS seem to be based upon the assumption that if, for example, 10 percent of the livestock operations year-round grazing capability is lost, then 10 percent of his income for the year is also lost. Reality is that, if a cattleman has no grazing capability for 10 per- cent of the year, then his entire operation ceases to function, and he loses 100 percent of his income, not 10 per-cent. 24.4 RESPONSE: Although livestock grazing on pub- lic lands in Utah contributes a small percentage of meat produced in the nation, cattle and sheep ranching is an important local and regional business. This is recognized in the EIS. However, as noted in the re- sponses to General Comments 18.1 and 24.3, no sub- stantial economic impact to existing operations is ex- pected to occur with wilderness designation. The EIS recognizes that changes in access practices may occur and future options for increasing forage by chaining may be foregone in certain WSAs. The EIS 4 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS identifies the value of an AUM on public land using the 1987 figure of $1.54. The narrative in Volume I of the Final EIS has been expanded to further explain the local economic contribution of forage on public land. It is important to note that no existing AUMs would be lost due to wil-derness designation. Any reductions would be based on vegetative conditions, just as may occur without wilderness designation. The EIS clearly states that the Wilderness Act provides for the continuation of livestock grazing in wilderness areas. Available data and FS experience indicate that such grazing does, in fact, continue with- out significant effects to permittees. Consequently, BLM does not agree that proposed wilderness designa- tion would have a serious impact on the existing Utah livestock industry. The Final EIS reports that 339 per- mittees have a portion of their operations in WSAs, these portions are generally small for any one WSA. On a Statewide basis only 3 percent of the livestock operators in Utah are now involved with BLM WSAs. Also, see the response to General Comment 18.4, which discusses actual livestock vs. permitted live- stock use. 24.5 COMMENT: The EIS should analyze the costs and benefits of proposed land treatments. [Clay Johnson, Utah Wilderness Association, et al.] a. Throughout the Draft EIS you mention foregone AUMs and loss of revenues and income from those AUMs as impacts. Examples may be found in Volume I, Table 17, page 121, Impacts on Government Reve- nues, paragraph 3, on through to Volume VI, Winter Ridge WSA, page 34, Socioeconomics, paragraph 3. This ignores the fact that most areas are not using the AUMs currently allotted. Further, if you are going to list imaginary AUM revenues as foregone, then you should list the saved expense of not building 44 small reservoirs, 40,493 acres of land treatment (live- stock), 57,250 acres of land treatment (wildlife), and 18,000 acres of watershed treatment as a gain. How can BLM determine that the foregone potential of increased AUMs from land treatment would result in a loss of revenue if the cost of the treatments is not considered? b. The economics of proposed range improve- ments are not analyzed in the EIS. There is no indica- tion of the economic likelihood that certain range im- provements will, in fact, be developed. For example, the Draft EIS notes that 24,479 acres (4,317 AUMs) of proposed range improvements would be foregone in the Proposed Action. Yet, there is no indication if these 24,479 acres are, in fact, capable of being treated. Also, the economic analysis is confusing when looking at range improvements and AUMs. The appendix in Volume I lists two separate figures for AUM values: $1.66 and $1.40 (see page 358). Why is there this difference? c. Also, there is no economic analysis of the reve- nues to the Federal government vs. the costs. Range treatments run about $35 per acre. BLM could con- ceivably treat 40,493 acres and gain 7,373 AUMs. This amounts to 5.5 acres treated per AUM increase. Given a life expectancy of 20 years, the net return to the government is neqative. This needs to be shown in the EIS. 24.5 RESPONSE: The acreage of potential land treatments for livestock grazing has been revised to include only those areas likely to be treated in the foreseeable future. The estimated acreage of land and vegetation treatments has been reduced in this Final EIS to account for more realistic levels of range im- provement funding expected in the foreseeable future. Also, AUM values have been revised for consistent use of the 1987 figure of $1.54. The figure changes annually, but the $1.54 figure indicates the relative importance of the fee. Benefit-cost analyses for speci- fic range projects are not calculated until a detailed plan for each project is prepared; therefore, such in- formation is not available for these activities which now are identified only in the more generalized land use plans. Generally, range projects are not imple- mented unless they would have a positive economic or resource management value (such as watershed im- provement, erosion control, etc.). 24.6 COMMENT: The EIS should analyze the econom- ic impact of denying access to trappers. [Utah Farm Bureau Federation] a. There are many people in San Juan County who trap wild predators for a livelihood. In the winter, these predators heavily populate areas within the WSAs which are currently utilized by trappers. If these areas are locked up for single use, then the trap- pers will have to go elsewhere. These areas within the WSAs are some of the very best trapping areas in the country. 24.6 RESPONSE: Commercial trapping (i.e., where trapping is the sole source of the trapper's income) 5 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS would not be allowed in wilderness areas. In Utah, trapping is rarely the "sole source of income," and there would be few, if any, conflicts between trap- ping and wilderness management. Therefore, access in wilderness areas would not be denied to trappers. Trappers may enter wilderness areas by nonmotor- ized methods the same as other wilderness visitors. Incidental trapping, bounty hunting, and sport hunting would be allowed in BLM wilderness areas in accord- ance with applicable State and Federal wildlife regula- tions; therefore, little change, if any, in economics would occur as a result of wilderness designation. Also, see the response to General Comment 1.10. 24.7 COMMENT: The EIS should recognize the live- stock/wildlife tradeoffs. [Martin Bray, Roger Jenkins, et al.] a. It should be recognized that hunters are a reli- able source of revenue year after year. BLM has failed to realize the economic impact of continued overgrazing on wildlife resources in a wilderness set- ting. Cattle compete with wildlife and big game for water and forage. If there were less cattle, there would be more wildlife and big game; therefore, there would be more hunting license revenues generated. No assessment was made concerning the economic im- pact of a reduction in grazing on wildlife and big game hunting opportunities and increased revenues which would result. b. The cost of $1.40 to run one cow and one calf per month on public land considerably understates the cost of the impact of grazing on the biological re- source. Grazing fees should be raised to be compar- able to those fees charged for grazing on private land. c. The benefits of a reduction of overgrazing on all public lands is ignored by BLM. Wildlife would bene- fit greatly from wilderness designation since cattle and wildlife compete for water and forage. More cat- tle equals less wildlife. BLM ignored the increase in big game hunting revenues which could bring addition- al revenues to local communities. Also, water would not be polluted by cattle manure and quicksand- trapped cattle carcasses. Overgrazing is a serious problem on many BLM lands in Utah. This conflicts with the Taylor Grazing Act. Wilderness is ruined by line camps, fences, grass chewed down to the nubbin, contaminated surface water, benches crisscrossed with stock trails, and many places so littered with cattle droppings that it is impossible to sit down. This is largely due to the artificially low grazing fees. d. There is no analysis of the costs and benefits associated with grazing in the Draft EIS. There appar- ently is the operating assumption that grazing will continue at existing levels on all lands whether or not wilderness is designated. Alternatives should be pre- sented in which grazing on all BLM lands would be re- duced in a stepwise fashion over the next 5 years. Cattle grazing in wilderness areas needs to be greatly reduced. 24.7 RESPONSE: Hunting revenue, the cost of live- stock grazing fees, and the relationship between wild- life and livestock are matters applicable to many places on the public lands, not just in WSAs. Hunting revenues attributed to areas which may be designated as wilderness would be expected to continue. Since the Wilderness Act specifically provides for livestock use, no changes in the wildlife/livestock relationships are expected as a result of wilderness designation. The alternatives and impacts of wilderness designa- tion would not affect or be affected by grazing fees. It is not the purpose of the wilderness EIS to present alternatives for reduction of grazing or analysis of costs and benefits of grazing. Also, see the responses to General Comments 16.11, 18.1, and 18.2. 24.8 COMMENT: The Draft EIS fails to adequately assess the economic benefits from recreation. [Utah Wilderness Coalition, Sierra Club, John Lockhart, Roger Jenkins, et al.] a. The Draft EIS fails to adequately assess the eco- nomic benefits from primitive recreation. The State- wide average expenditures of $4.10 per recreational visitor day does not accurately represent the monies spent for recreation in wilderness areas. People buy gas, rent cars and vans, buy groceries, patronize res- taurants and hotels, as well as outfitters, and buy local items. This figure should be higher. For exam- ple, the Cherokee National Forest (Tennessee) uses a value of $12.60 per visitor day for assessing the val- ue of wilderness recreation. One likely scenario would be that Dark Canyon Complex and the Fish Creek/Road Canyon areas would experience increases to approximately 20,000 visitor days per year by the year 2000. At $12.60 per visitor day, this would result in revenues of over $500,000 for the State of Utah. That would be more than six times the current annual revenues from grazing in the entire San Juan Resource Area. In reaching the $4.10 visitor day fig- ure, the Draft EIS cites no reference to other studies 6 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS on recreation economies, nor is there any indication of how BLM computed the figure. Was consideration given to travel expenses? Other studies indicate that about $14 per person per visitor day is a more rea- listic figure. The $4.10 figure is far too low for Wa- satch Front visitors who must travel to southern Utah and especially for out-of-state visitors who fly to Utah. The FS refers to "destination skiers" who travel more than 100 miles to a ski area. BLM should likewise consider the expenditures of "destination backpackers." I personally expect to spend $30 to $40 directly on a 2-day trip to southern Utah. I attempt to spend as much as possible in towns close to the destination. No one can live on $4.10 per day just for food. Primitive recreationists burn a lot of calories so they eat even more. The costs of equip- ment and transportation raise the figure even higher. It costs $7.50 per person per day just for a river permit. Our informal survey shows an average expen- diture of $14.10 per person per day. b. The Draft EIS understated income generated by wilderness-related employment. Grand Gulch, for ex- ample, currently supports six commercial outfitters and guides, based on commercial use of 2,000 visitor days (10 percent of the total 20,000 visitor days as stated on page 31 of the area analysis.) Using the $4.10 Statewide average visitor day gives a total out- fitter-based income of $8,200 ($4.10 X 2,000), hard- ly enough to support one outfitter, let alone 20. The visitor day should be $50 per day. The Draft EIS does not take into account its own data. Adding commercial use to noncommercial use for Grand Gulch ($50 X 183) + ($4.10 X 1,655) gives a more realistic figure of $15,935. The Draft EIS underestimates the econom- ic impact of increased recreation by almost 50 per- cent. BLM should recalculate these figures for each WSA where commercial and noncommercial uses were not differentiated. c. Although the Draft EIS does not estimate in- creased recreation use for most WSAs, it does for Grand Gulch: 58 percent over the 1984 level, com- pared to a projected 48-percent increase without des- ignation (Volume V, pages 35 and 32). But this in- crease is dismissed as insignificant on page 38 owing to the existing popularity of the area. On the other hand, the Draft EIS states that recreation use of Man- cos Mesa would increase from 402 to 5,144 visitor days/year, assuming a 2 percent annual growth in- crease. According to the Draft EIS, the increase in outfitting jobs in this area alone would be equivalent to 25 percent of the loss in potential jobs Statewide in grazing. On a recent Desolation Canyon WSA float trip, 12 of us spent $1 7/visitor day for 6 days. Fur- ther, commercial trips through wilderness areas gen- erally cost three to four times as much as do-it- yourself trips. d. The Draft EIS fails to accurately assess the eco- nomic benefits from recreational usage of the most outstanding areas. Recreational benefits to local and regional Utah economies are significant, and BLM must recognize that wilderness-related recreation plays an important role. We feel wilderness recrea- tion has a significant economic impact on southeas- tern Utah. When we come to southern Utah, we spend, on the average, $25 per person per day in local towns. Furthermore, we pay land use fees to BLM for each of the 11 courses, 12 to 16 students per course, that we send to southeastern Utah annually. Every year approximately 175 of our students spend about $4,500. While the negative impacts of wilder- ness designation are inflated, the benefits are down- played. A figure of $1/user day is used in determin- ing revenues from recreation while the use day fee schedule shows the figure to be between $1.90 and $3.40 (Volume I, page 359). Why the discrepancy? Derived values such as option value, existence value, and bequest value should be added to recrea- tion use values in order to find the total economic value of wilderness to society. The term preserva- tion value is actually a combination of these compon- ents: annual option value, $5; annual existence value, $5; annual bequest value, $4; annual preservation value, $14. Option value is the benefit that accrues to the individual for the option to visit wilderness areas in the future. Existence value is the benefit that re- sults from the satisfaction derived by knowing that such natural areas exist, regardless of the respon- dent’s intention to visit the area. Bequest value is de- rived from the knowledge that these areas will be available for future genera-tions for use as a wil- derness area. e. Wilderness designation would generally in- crease recreation-based employment. Although the Draft EIS acknowledges that "wilderness publicity could increase nonmotorized recreation use and re- lated local expenditures and employment" (Volume I, page 134), the factor used in the Draft EIS to esti- mate such growth is too small. We surmise that BLM derived the direct employ- ment/output ratios in Appendix I, Volume I, page 357 7 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS by a simple ratio of labor to output, using the data in Table 64 (Volume I, page 105). For example, the ratio for grazing is 0.00053/AUM (Appendix 9), which is identical to the ratio given in Table 64 under columns 3 and 4 (Statewide data), 5 and 6 (public lands), and 7 and 8 (WSAs). This is hardly the sophisticated in- put/output model implied in Appendix 9 but, if used consistently, it suffices. However, the employ- ment/output ratio used for recreation (0.0009) is evidently based on Statewide data instead of the more appropriate ratio derived from WSA data (0.0004). Why the Draft EIS uses a less appropriate figure that happens to be 25 percent as large is a mystery. Rec- reation-based employment and the resulting income figures should be recalculated through the Draft EIS to reflect the larger, more appropriate figure. Recalc- ulation could well show that gains in wilderness based recreation employment offset any likely foregone po- tential for mining- or grazing-related employment in- creases. This question should be specifically address- ed in the comparison of alternatives. 24.8 RESPONSE: The discussion of recreation eco- nomics in the Final EIS has been reviewed, revised, clarified, and expanded. The overall conclusion, how- ever, does not change significantly from the Draft EIS. Economic tourism benefits to local areas from wilderness recreation are expected to occur, but not to the extent presented by the comments. Generally, purchase of backpacking equipment, food, and supplies would occur in the larger cities where most visitors reside. Recreation-related expenditures in the local (southern Utah) communities generally would be lim- ited to vehicle fuel and a food stop while enroute to and from wilderness areas. Commercial tours may occur in a few areas, as noted in the EIS analysis. Also, see the responses to General Comments 21.7, 21.15, 21.17, and 21.19. The "option value, existence value, and bequest value" are interesting economic theories, but do not provide any tangible financial support to local employ- ment, income, or tax revenues; consequently, they are not included in the impact assessment (Chapter 4). The intrinsic and theoretical economic value of wilderness has been mentioned in Volume I. 24.9 COMMENT: The Draft EIS does not adequately consider the feasibility of mineral development. [EPA, Utah Wilderness Coalition, Utah Wilderness Association, Utah Counties, Utah Mining Association, Exxon Corporation, Rocky Mountain Oil and Gas Asso- ciation, et al.] a. In today's market, only some of the coal and none of the tar sand in the WSAs is economically ex- tractable. We request you to develop a factor to eval- uate the reasonable economics and feasibility of the likelihood of extracting these resources. This would eliminate the current faulty reasoning of high OIRs which ignore development probabilities. Take into account such factors as remoteness, accessibility, high mining and transportation costs, water supply, rugged terrain, and the need or oversupply for this resource in the context of a national perspective. The Final EIS needs a section titled "The potential feasibil- ity and probability of resource development in the in- dividual WSAs." At what price would oil and gas have to reach to make development in unproven resources in such isolated, rugged terrain such as the southern Book Cliffs feasible? Also, considering the current conditions of the oil and gas industries, what exactly is the development potential for the WSAs? Also, mar- ket conditions are extremely dynamic for oil, gas, and mineral prices in today's world, which seems to make it impossible to develop adequate developmental projections. There are a lot of resource analyses in the EIS (coal, oil, gas, etc.) which are used as the basis for future action, but a lot of these actions are premised upon unleased lands, unproposed develop- ments, and a number of proposed conflicts have very limited credibility. For example, wilderness designa- tion of these areas is evaluated as conflicting with future coal when the entire future of coal mining in these areas is skeptical at best. b. The mineral development probabilities automa- tically drop to zero if a rich reserve is designated as wilderness. Our mining industries and local economies cannot afford to let this happen. It is crucial to know what mineral reserves exist where and to keep open the probability of their development in light of nation- al interests in security, freedom, and in avoiding a dangerous overdependence on foreign sources. Future and/or newly developed technologies could make min- eral extraction feasible in many areas now deemed unfeasible. If these areas under consideration are de- clared wilderness, then important mineral resources will be lost to us forever due to our short sightedness in locking up billions of dollars worth of resources. 24.9 RESPONSE: The feasibility of mineral develop- ment has been reviewed in detail. See the responses to General Comments 2.33, 3.37, 8.3, 15.1, 15.6, 8 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS 15.11, 15.20, 15.21, 15.22, 15.53, and Appendix 6 (Volume I). Both potential for mineral occurrence and feasibility of development were carefully reevaluat- ed. Economic considerations (including terrain, trans- portation, markets, prices, etc.) were a factor in estimating short-term feasibility; however, potential long-term opportunities were also acknowledged. BLM believes that the potential of mineral development and related economic considerations have been adequately presented in the Final EIS. 24.10 COMMENT: The EIS should put mineral reve- nues in perspective. The economic returns from min- eral development have been over [or under] rated. [Tim and Audry Graham, D.C. Kennell, Dennis Willi- gan, Rex and Judy Wells, Utah Counties, Utah Power and Light, Exxon Corporation, Paul McMullin, et al.] a. There is misleading information in Table 1, Summary of Significant Environmental Consequences, for each WSA. Under the Socioeconomics section it is stated that $10,722,000 dollars in Federal revenues from mineral leasing would be foregone. The majority of people skimming the document do not understand the meaning of the huge sum of money. They will think those dollars would come into the local economy di- rectly. As pointed out in the fine print, only half of this money is ever seen in the State of Utah again. The money is often used to mitigate effects of min- eral development, which wouldn't be a problem any- more in wilderness areas. We request the addition of a sentence in the summary table to point this out, which would read "Only a small, undetermined portion of this amount normally gets returned to the local area." Also, BLM tells how much money will be lost through shrinking Federal gas leases, but fails to show the economic gains of a wilderness area. The Draft EIS fails to place mineral and energy resources in a regional or national perspective, which does not provide the reader the opportunity to evaluate his/ her own preferences. BLM uses, in the Draft EIS, what appear to be highly speculative mineral values. Mineral values supposedly found within the WSAs at your projected levels would certainly make Utah seem to be a very rich mineral State, far beyond what it is in real life. It is unfair to disqualify an area because of the existence of a mineral lease when there are, in fact, little or no mineral values present. b. Is it possible to assign a dollar figure to visual, watershed, and wilderness resources? If so, will these figures be used in the Final EIS when oil, gas, and mineral dollar figures are used? BLM should re- evaluate the mineral economic analysis using current market conditions and should recognize that noncom- modity resources such as wildlife, recreation, water- shed, fisheries, cultural, visual, and wilderness have high values where dollar figures cannot be assigned. Will the Final EIS use current market prices for min- eral and energy products in the economic analysis? c. Which is more valuable, the beauty of the wil- derness by leaving the minerals in the ground, or the mineral value developed? Consider which resource lasts longer, the one taken out of the ground or the one left in? To say that the WSAs contain a signifi- cant portion of the nation's resources and that the eco- nomy depends on the extraction of these resources is false and is merely a scare tactic. The simple extrac- tion of natural resources is not sufficient for a health- y economy. Remember that the American Revolution came about partially due to the colonies being forced to ship their raw materials to England and then buy them back as manufactured goods. Today, many Third World countries remain in poverty despite an abund- ance of easily extracted natural resources. Extrac- tion of resources is unnecessary for a successful economy. Look at Japan, which must import almost all of its raw materials but, is very competitive. d. The discussion of mineral leasing fees is irrele- vant since the analyses fail to document if the State's share of these funds would be spent in these local areas. The loss of Federal revenue figures shown in the summary tables for each WSA and in the State- wide analysis are misleading. In the tables, the total dollar amounts of taxes assessed against mineral ex- tractions are presented as loss in Federal revenues. In the text, if one ploughs diligently through it far enough, it is explained that only half of that money is returned to the State. Of the returned money, a small, undetermined amount is returned to the local area of extraction, and much or all of this is used in mitigation of the impacts of the mineral extraction in the first place. Thus, what little money does come back into the local area usually does not play a signifi- cant role in the local economy. Since many people look only at the tables, without going through all of the text, the quantity of money apparently lost due to wil- derness designations is represented as being much larger than it really is from a local perspective. This should be clarified in the tables. I would like to see the economic analysis used in the Draft EIS include the secondary impacts of presumed increases of oil production that would be obtained by foregoing wilder- ness management on Hercules Inc., and Thiokol Inc., 9 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS the State's largest employers. These firms produce lightweight materials targeted in part towards the transportation industry and do not benefit from low oil prices that might be maintained for a few years by sacrificing Utah’s wilderness. e. Has BLM or anyone else evaluated the lands that they manage? Have you developed a reasonable assessment and value for that land if the mineral sur- vey has not yet been received? The natural resources that have not yet been valued by BLM, USGS, or USBM have values in the billions of dollars. Yet they are in danger of being isolated from productive use for mankind. This hurts local and national economies. We have heard the comments that we have enough coal mines and oil and gas wells; therefore, compan- ies supposedly do not need any more leases to explore or develop, so it won't hurt to remove a few million acres. But can we afford to lock up billions of dollars worth of resources that will be needed in the future? I don't want to depend upon OPEC and other nations for the natural resources that we need. Wilderness designation will prevent us from ever knowing the true value of the minerals locked away in these areas. Wilderness prevents even simple exploration, leaving us ignorant of what resources could actually be available to us within these lands. Wilderness goes against national interest and security. It is a liability in times of emergency to our nation. It restricts an individual's right of freedom to develop resources to protect and perpetuate this great nation. Minerals are locked up, dead, and done for permanently with a wil- derness designation. f. Economic benefits are gone forever. The Draft EIS has not properly addressed the area of revenue that will be brought in by mineral resources which are estimated to be in these wilderness areas. Pre- sent coal mining royalties average in excess of $2.40 a ton, based on 8 percent of royalties lost to the U.S. Government and the State of Utah for 1 billion ton of minable reserves is approximately $2.4 billion dol- lars, a substantial sum in these days of budget defi- cits. Revenues for the entire plateau, including Death Ridge WSA, would generate funds for the Federal Treasury far in excess of any other monetary gain from recreation, grazing, or other mineral royalty. g. Mineral resource revenues support education for our children; recreational revenues do not. In 1984 and 1985, Exxon accounted for 42 of the total 182 seismic crew months in Utah. Total expenditures for this effort were almost $23 million. A significant portion of this effort was aimed at evaluating the po- tential of some of the WSAs. h. It is a great mistake to embrace the illusion of economic development as presented by the oil and gas interests, thereby endangering the proven value of tourism. There is some reaction in Utah against wilder- ness. But many of its opponents haven't seen what is happening in the rest of the country. When we lived in southeast Texas, we had to deal with high rates of leu- kemia, contaminated water supplies, fumes so corro- sive that the seats of the local football stadium had to be replaced every 4 years. The oil companies were extremely gracious in footing the bill, but somehow I didn’t feel very grateful when I considered the effect on my lungs. The continual wretched taste in your throat became normal and only noticed when you re- turned from vacation. Children seemed to be continu- ally sick with ear infections, chronic coughs, sinus drainage, and respiratory allergies. Such situations are not unique to Texas; they are common throughout the land. It is to escape from these horrors that more people will visit Utah. 24.10 RESPONSE: The mineral leasing information has been updated and revised in the Final EIS. It is not practical to include detailed explanations in the sum- mary tables due to size and content limitations. The summary tables are intended to highlight only major conclusions. As noted in the comments, the EIS does explain that only a portion of the mineral lease reve- nues are returned to the State. The EIS puts mineral and energy resources in a State and national perspective in Volume I. The min- eral development feasibility and economic analysis have been reevaluated. Also, see the responses to General Comments 2.20, 15.16, and 24.9. The relative values of wilderness (with in-place minerals) compared to minerals extracted may vary, depending on the qualities of each WSA, the nature and amount of other wilderness opportunities, size and type of each mineral deposit, the available supply of each mineral, and the world market conditions at any point in time. Given these variables, the determin- ation of which is more valuable can only be a subjec- tive judgment, based on perceptions and interpreta- tions of available information. Ultimately, Congress GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS will make that judgment in designating or not desig- nating each WSA (see the responses to General Com- ments 2.23 and 8.9.) The relationships of raw materials and labor in the various nations, such as Japan and Third World countries, reflect many different circumstances and are not necessarily applicable to the western United States. There would not be an effect on nationwide oil prices from wilderness designation or nondesignation in Utah, consequently, the suggested economic analy- sis of impacts on Hercules and Thiokol has not been added to the Final EIS. The mineral development potential is based on the best information available, including USGS/USBM min- eral reports for some of the WSAs (see Appendix 6, Volume I). As noted in Volume I, the mineral reports for other WSAs preliminarily recommended for wil- derness will be added (and recommendations revised, if appropriate) prior to submission of the wilderness review package to Congress. The economic values of any minerals in the WSAs depends on extraction costs, transportation costs, and market conditions at any particular point in time; therefore, these values are subject to fluctuations which are difficult to pre- dict, especially in the long term. Based on the best data available, the EIS identifies which minerals and WSAs are most likely to have mineral development in the absence of wilderness, and the economic anal- ysis of the No Action/No Wilderness Alternative reflects such future development. Currently, most minerals in WSAs are not economically feasible to extract, transport, and market, as evidenced by the fact that generally mining is not occurring in WSAs. Coal mining royalties are only associated with active mines when coal production occurs. No royalties can be attributed to reserves in wilderness areas if the coal mining otherwise would not be produced (i.e., not economically feasible). Economic impacts from mineral and energy devel- opment are noted in the analyses. There would be little or no impact or human health because the types of developments anticipated in WSAs are not major point sources of air emissions or would be located away from population centers. 24.11 COMMENT: Wilderness designation makes the small mineral operations uneconomical. [Rocky Mountain Federation of Mineralogical Societies] Wilderness designation effectively excludes the small mineral prospector and operator since only large companies with substantial financial reserves can afford the cost of permitting in special use areas. 24.11 RESPONSE: WSAs are not currently closed to prospecting and staking of mining claims as a result of the wilderness review process. If an area is designated wilderness, it then would become closed to all new prospecting and mining claims. Regardless of economics, both small and large operators would be subject to the same closure provisions. Likewise, both small and large operators could continue to hold and carry out mining operations on valid claims locat- ed prior to the time of wilderness designation subject to unnecessary and undue degradation guidelines. These guidelines require that the rights of the opera- tor be protected while environmental impacts are minimized. 24.12 COMMENT: The EIS should indicate that the value of grazing and minerals outside WSA boundaries would increase if development inside WSAs were fore- gone. [Utah Wilderness Coalition] The Draft EIS does not take into account the in- creased value of mineral and grazing leases outside of WSAs if the intensive development of WSA leases were foregone. This compensating factor should be taken into account in the economic analysis. 24.12 RESPONSE: S ince existing livestock grazing would continue in wilderness areas, grazing permits outside wilderness areas would not increase in value. The value of mineral leases outside of wilderness areas could increase as a result of wilderness designa- tion only if such designation created a pronounced and known scarcity of certain mineral resources. Given the relatively small Statewide and nationwide percent- ages of leasable minerals in BLM's Proposed Action, it is highly unlikely that wilderness designation would result in increases in mineral values outside WSAs. Mineral values are and would continue to be determin- ed by national and international variables much more than the influence of BLM's Proposed Action. Conse- quently, the economic analysis does not consider the concept suggested by the comment. 24.13 COMMENT: The Draft EIS failed to analyze the economic effect of Federal reserved water rights for wilderness. [Utah Counties, Farm Bureau Federa- tion, et al.] GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS The Utah BLM Statewide Wilderness Draft EIS has not considered the potential economic implications of our wilderness water right reservation on affected area economies. According to Dr. Ferris P. Allgood, USDA State Soil Scientist, only 3 percent of the State, or 2 million acres, are currently under cultiva- tion. If more water were made available, as much as 8.5 million acres or more could be used for farming and pasture. However, approximately 34 of southern Utah's major perennial water sources will be affected or potentially affected by wilderness water reserva- tions. The Draft EIS does not consider this. Many areas of the southwest have been developed and all have a dependable source of water. No water exists in many areas proposed for wilderness designation. Multiple use has failed to do any major damage to these areas. Water resources are enhanced by devel- opment, not harmed by it. With the growth rate of approximately 12 percent experienced in the past 3 years in Washington County, the county's population could reach 100,000 people by the year 2000, and 200,000 people by the year 2020. There will be in- creased demands, by the population, for water-not only for culinary purposes, but industrial and recrea- tional purposes. Based on growth projections, it will be necessary to divert and treat 10,000 acre-feet of water from the Virgin River by the year 1988 to 1990; 30,000 acre-feet by 1995; and up to 90,000 acre-feet by the year 2020. 24.13 RESPONSE: The discussion of water re- sources has been expanded in the Final EIS. Specific reservoir or water development proposals are ana- lyzed in the WSA analyses. See General Comment Responses 14.5 and 14.8. Also, the economic implica- tions related to water resources are addressed in Volume I, Chapters 3 and 4. The comment that "Water resources are enhanced by development, not harmed by it" is a matter of opin- ion. It may be true in certain situations, but untrue in other situations. Water resource management in- cludes concern for protection of wetlands, water- sheds, ground water recharge zones, water quality, and water quantity. It concerns both maintenance of adequate minimum stream flows and prevention of flood damage. It may include storage in natural lakes and reservoirs. Water provides essential life support for natural environments, agricultural production, and developed human communities. Often water is a limiting factor for all three of these important aspects; consequent- ly, a balanced view is needed for proper considera- tion and use of the water resource. Culinary, indus- trial, and community recreation are not the only con- siderations to be given to the Virgin River and its tributaries. Also, see the responses to General Comments 14.13, 14.19, and 14.21, which discuss water qual- ity. 24.14 COMMENT: The EIS analysis of impacts of wilderness designation on local economies is incor- rect. [Thomas Noll, Utah Wilderness Coalition, Ray- mond Wheeler, Warner Linton, et al.] a. Towns that have diversified their economies (e.g., Salt Lake City, Steamboat Springs, Carson City, Moab, Jackson Hole, St. George, Evanston, etc.) face a more certain future. We need economic diver- sity in our State, and wilderness plays a very impor- tant role by attracting diverse industries and talents to Utah. Wilderness would be an asset to every local community. By providing a variety of easily acces- sible wilderness trips, people would be attracted to these communities for retirement homes. One of the very important criteria when I was looking for em- ployment was natural resources and the ability to ex- plore wilderness areas. Utah is very high on the list of States in the nation with the ability to do that. Wil- derness plays a very important role in the State as far as attracting success-oriented people and keeping them within the State. Many people who come from large cities are attracted to Utah for the open spaces and the wilderness opportunities. Also, wilderness serves as a magnet for Utah residents to stay here or return here after they become educated to contribute their talents and energy to our economy. Wilderness attracts people to Utah who become economically con- tributing residents. Wilderness creates jobs for outfit- ters, film makers, photographers, botanists, biolog- ists, archaeologists, explorers, sporting goods and grocery stores, and gas stations bordering the wilder- ness areas. When the minerals are extracted, the jobs are gone; wilderness jobs are more steady and stable. The total jobs created by wilderness designa- tion would more than compensate for the loss of jobs in minerals, grazing, and energy production. b. The WSAs considered in this Draft EIS repre- sent such a small fraction of the total land area to the State that we are convinced that wilderness designa- tion can proceed without fear of jeopardizing exploita- tive economic interests. On the other hand, a 1 2 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS degradation of these wilderness values would remove one of the reasons for our remaining in Utah. We are sure that our sentiments are shared by the majority of our professional colleagues in Utah, both present and future. The diminishing of this community of edu- cators and professionals would have serious conse- quences for the economic development of the State. The high technology companies that are coming to Utah can't sell their people on the low pay, entertain- ment, culture, or major metropolitan areas. What they can sell is the style and quality of life that is unique to Utah. This is why an investment in protec- ting these lands is an investment in local industry along the Wasatch Front. Wilderness and outdoor rec- reation are a great attraction for Utah's economy in bringing in growing high-tech businesses with clean industry. Let's preserve the quality of life in Utah. c. Cities and towns around national parks, wilder- ness areas, and forest preserves do not grow. Exam- ples include Bryce, Zion, and Canyonland National Parks, as well as Lake Powell. One might argue that St. George is only a 1/2-hour drive from Zion. How- ever, St. George can only credit a very small amount of its growth to Zion National Park. None of the towns east of Zion seem to be prospering, let alone booming. How will a home ever be sold if property values drop any further? We have the right to choose to earn our living in southern Utah. Wilderness is an infringement of this basic right. Every American citizen has the freedom to live and work in the area and business we choose. EIS has not addressed this fundamental Ameri- can value. d. The Draft EIS should address the costs associ- ated with large mining and energy projects in rural areas. Development places a heavy burden on local governments to provide needed services to incoming construction work forces, where long-term opera- tional work forces typically are not large enough to sustain the frontend capital costs of building schools, roads, sewers, and other facilities. Mineral and oil development are essential for the prosperity of the United States. However, they have created over 100 years of "boom-and-bust" economies in the American West. These industries usually bring a transient popu- lation to an area for several years and leave behind an unstable economy and much tragedy. An examina- tion of western U.S. boomtowns such as Butte, Lead- ville, Blanding, Monticello, McGill, Morenci, Rock Springs, and others reveal very depressed economies facing very dismal futures. Some who live in these towns would have us believe that only wilderness blocks their opportunities for the future. However, only towns with diversified economies can survive. Depression and despair are the rewards of reliance upon mineral extraction for financial opportunity. The only prosperous economy in southern Utah is St. George. St. George doesn’t rely on mineral extraction for its survival. Keep in mind that, once the soil and minerals are extracted, the jobs are gone and so is the wilderness. Reclamation is a worthy goal but is not realized many times. Today, many Third World countries remain in poverty despite an abundance of easily extracted natural resources. Local economies ship the extractions out and fail to reap the benefits. Wilderness designation offers stability to local econo- mies, while looking to mineral extraction offers the usual boom-and-bust followed by a depressed econo- my. We should look to tourism and recreational reve- nues and opportunities for our future. Utah's extraord- inarily high birth rate will continue to result in signifi- cant out-migration to other States possessing more attractive job opportunities. Out-migration will con- tinue independently of whether or not wilderness is designated as such. Wilderness is not the cause of out- migration for employment opportunities. During public hearings, many public officials were afraid that wil- derness designation will reduce revenues. This is a valid concern in light of Utah's financial problems, but with regard to wilderness designation it is overstat- ed. As the Draft EIS states: "Relative to the total rev- enues collected by the State (of Utah) and local gov- ernments, these allocation changes (from wilderness designation) would be less than 1 percent" (Volumel, page 135). This point should be emphasized in the Final EIS. 24.14 RESPONSE: While it is true that economic di- versity is a desirable feature, none of the communi- ties mentioned as examples in the comment rely spe- cifically on wilderness as a major factor. They do, however, rely substantially on nearby outdoor oppor- tunities, such as snow skiing, use of lakes and rivers, enjoyment of climate, and scenic attractions. Such features will continue to be available throughout much of the West, regardless of whether or not any particu- lar area is designated as wilderness. Since the EIS an- alysis demonstrates that the local economic benefits from wilderness would be rather limited, it is expect- ed that wilderness designation would not greatly con- tribute to economic diversity in Utah. Rather, it would help to maintain outdoor lifestyle opportunities related to the natural environment. GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS Wilderness would not necessarily "create" the jobs listed in the comment, although people in such jobs may use (or related to) wilderness areas for part of their work. Generally, these people do not (or would not) depend on any specific wilderness area for the full amount of their economic activity. The few public land management jobs that may be created for wilderness management likely would be offset by development-oriented management jobs not used in the wilderness areas. There are no data available to support the comment that the "total jobs created by wilderness designation would more than compensate for the loss of jobs in minerals, grazing, and energy production." It would be possible to compare exam- ples of these latter activities to examples of devel- oped resorts and tourist attractions, but the parallel of developed recreation to wilderness would be dis- similar and, therefore, not applicable. As noted above, outdoor recreation amenities in general (including, but not limited to, wilderness) do contribute to the lifestyle opportunities for educat- ors, professionals, and others who work in Utah. While these amenities are important to many individ- uals, the work positions they hold usually are com- pletely independent from public land management, and those positions would not be abolished due to changes in the outdoor recreation (i.e., wild land) resources on the public lands. Rather, the positions would be filled by people who have other lifestyle interests. Similarly, most large new businesses relocating to a new area do so on the basis of factors, such as avail- able work force, source of materials and space, trans- portation, markets, and other primary economic fac- tors. Lifestyle amenities for workers usually are only one of several secondary considerations. Life- style may be more significant for owners of small businesses. According to a 1987 survey sponsored by the Utah State Department of Community and Economic Development, only 3 percent of Utah companies ini- tially selected Utah as a place to do business primar- ily for "quality of life" reasons. The same survey identified "outdoor recreation opportunities" as a major intangible advantage, particularly to "high- tech" companies. Wilderness designation (or any other uses of the public lands) is not an infringement of the basic Ameri- can freedom to choose an occupation or select a place to live. The subject is not pertinent for analysis in the EIS and has not been included. It is not the purpose of the public lands to accommodate a variety of occu- pations and provide residential choices. It is the pur- pose of the public lands to provide for wise manage- ment of the inherent natural resource values for the overall enjoyment and/or benefit of the American people (collectively). Congress has established cer- tain basic parameters which guide this land manage- ment. These parameters are completely separate from and not directly related to the fundamental free- doms enjoyed by American citizens. Individual citi- zens do have occupational and residential freedoms, but realistically these must be practiced within the framework of the accepted socioeconomic system. In other words, it may not be possible for a person to select their ideal job and their ideal location simultan- eously, whether it be in Utah or in any other part of the United States. Wilderness designation of any par- ticular area would not alter this situation. 24.15 COMMENT: The effect of wilderness on fund- ing of public education should be analyzed. [Utah Coun- ties, Gail Johnson, State of Utah, State Representa- tive, David Adams, AMCA Coal Leasing Inc., et al.] a. On the one hand, what we pay in Utah for edu- cation is the lowest in the nation; on the other hand, our taxpayers are greatly overburdened already and are making a great effort to provide for education. Any attempt or anything that we do not now or potentially in the future would limit the tax base by which education and other programs could be funded and is a serious mistake. There is no way for us to know what the potential is from the loss of school sections that might be lost from this proposal, even if school sections are trans- ferred to some other place. The potential is what we can't measure. Over a period of years to come, there might be great value from both the school sections and the revenue which goes into the State funds sup- porting education. To lock that up and say that it can- not be used for education now or 20 years from now is a great mistake. b. It is a constant battle to keep the schools in Utah properly funded, and we feel that the wilderness proposal would place an additional burden on our schools. It is Utah’s children who will suffer. The present economic slump makes it hard for us to pay for our schools, especially if property values de- crease any further. We look to mineral extraction and fees from these minerals to help fund education. If GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS there is designated wilderness, who pays the price? Our children do. The State of Utah owns 1 1 percent of Utah's 84,916 square miles of land. This land was giv- en to Utah as school sections and is to provide reve- nue to support the school system. Wilderness designa- tion takes directly from the coffers of education and from the education of our children. Wilderness desig- nation removes private, taxable holdings from local tax rolls, making already difficult operations of local government in sparsely populated areas even more difficult. In a cost-benefit prospective, there will be many unrealized benefits lost forever to local govern- ments and communities as a direct result of wilder- ness designation. The school districts are responsible to take all of the vocational kids that we graduate and place them in jobs. If you understand vocational educa- tion in the State of Utah, if you can place these kids, they give you bonus money. If you lock up this area, cut down the jobs that we don't have already and cut down more jobs, this continues to limit the money we receive in the school district. Our young people must leave the area to locate jobs. The value of minerals is tied to education. Education will suffer due to the loss of mineral extraction revenues, which will result in lower taxes, and our children will pay the cost of wil- derness designation. The State of Utah is in a serious financial crunch, and edu-cation in Utah is in a serious financial position. We spend less per pupil for educa- tion than any State in the nation. We're absolutely last. The educational system for our children cannot afford in any way to lose revenue for education. It’s essential that these areas be left open for mineral exploration. What does the potential loss of revenue mean to Utah and southeastern Utah in particular? Well, the great majority of these services provided here (i.e., school, government services, health, and social services) comes from our property tax and production tax on gas and oil. The State receives 50 percent of the royalty from coal mined from Federal leases, and this money is distributed to various gov- ernmental, community, and educational bodies for pub- lic purposes. Locking this up will have the sweeping effect of crippling the State’s ability to aid commu- nities all over the State. 24.15 RESPONSE: The Federal lands within WSAs that may be designated as wilderness do not provide significant revenues used to support the public school in Utah. The State sections within WSAs do provide a very small percentage of the State school fund (but may not represent a net gain to the total State bud- get, as noted below). This is further explained in Vol- ume I, Chapters 1, 3, and 4, of the Final EIS. Since the State sections would either (1) remain under State management with reasonable access allowed; or (2) be exchanged for public lands of equal value else- where in the region, there would be no loss to the school fund as a result of wilderness designation. In fact, the school fund may be enhanced in the long term by wilderness designation if State manage- ment efficiencies can be attained by trading scattered in-held State sections for tracts in larger blocks. For example, with the scattered State land sections, "lease revenues have rarely, if ever, exceeded the costs incurred by the State to manage the school lands. In 1986, the lands produced between 0.8 and 1.2 million in lease revenue. Management costs were $1.2 million. Incredibly, the citizens of Utah received no monetary return from the 3.7 million acres of sur- face (State school) lands" (Davis County Clipper, 1987). Development of mineral resources can provide for increased revenues, some of which may be returned to local communities and schools. It is recognized that increased costs to local communities and schools can also occur with such development. The analysis of the No Action/No Wilderness Alternative in Volume I, Chapter 4, has been expanded to reflect such poten- tial economic impact for those WSAs with projected mineral development. Also, see the responses to General Comments 6.1, 6.2, 24.8, and 24.10. 24.16 COMMENT: The analysis of the values pro- duced or lost with each alternative is inadequate. [J.R. Hinds, Marc Hoshovsky, Dennis Willigan, et al.] a. The Final EIS should compare the differences between the total values produced or lost in all of the alternatives. It is important, for instance, to see an evaluation of the commodity production values that are lost by adding the extra acreage in partial (large and small) WSAs in the Proposed Action in order to determine if, indeed, these alternatives are the same in terms of protection of commodity production inter- ests as was stated in the Draft EIS (Volume I, page 25). b. A cost-benefit analysis of wilderness designa- tion always tends to sell wilderness short because the economic theories used do not adequately address the benefits of nonconsumptive uses. GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS c. Is it possible to assign a dollar figure to wilder- ness resources? How can you put a price on natural arches and bridges, deep canyons, desert springs, and multi-colored rock formations? If so, how can they be compared with more tangible mineral and energy resource dollar figures? Can views and values be reduced to a strict cost-benefit analysis? Surely this makes for a shaky comparison of "apples and oranges." 24.16 RESPONSE: See the responses to General Comments 3.3, 24.10, and 24.14. 24.17 COMMENT: The EIS places incorrect empha- sis on the value of tourism in Utah. [Utah Wilderness Coalition, Utah Farm Bureau Federation, Utah Coun- ties, et al.] a. The Draft EIS should be substantially revised. In particular, BLM needs to pay much greater atten- tion to the socioeconomic value of wilderness desig- nation and the substantial damage that may result to the State's image and its number one industry, tour- ism, if areas possessing outstanding wilderness val- ues are sacrificed for short-term profits. b. BLM listed loss of revenue for grazing, oil, gas, and mining. However, BLM did not consider the additional revenue which can be raised by having wil- derness areas. Revenue can be raised through sport- ing goods, tourism, outfitters, etc. Why was this not addressed? c. No county is expected to suffer a significant loss of revenue or be caused any hardship by wilder- ness designation. Therefore, local governments should be improving existing facilities and travel ser- vices to facilitate growth resulting from wilderness, not fighting against it. d. There is a misconception that tourism is the number one industry in Utah. Agriculture is the num- ber one industry in Utah and is still, economically, the number one industry in this State. The outlook for agriculture is much brighter and more feasible than is the outlook for tourism or increasing tourism under wilderness scenarios. The so-called economic bene- fits that would come about because of the wilderness proposal by bringing tourists and economic dollars into the county are false tales. If you observe the indi- viduals who backpack and use our parks and rivers now, you can see that they spend very little money and do very little business with our stores and mo- tels. Following comments made by Dr. Thayne Robson, wherein he indicated the prime opportunities for eco- nomic development were in natural resource develop- ment and tourism, we began looking at these options. Concerning tourism, even if the physical resources are present, the infrastructure to attract tourism dollars is not. Special designation of county geograph- ic resources away from multiple-use management would be counterproductive. We conclude that our best chance for economic growth is to protect those assets currently providing the jobs and paying the bills. Agriculture and mining, not tourism, are the number one industries in Utah. Wilderness advocates say increased tourism comes from wilderness desig- nation. The opposite is more likely true. Eliminating motorized vehicles and roadways reduces tourists and locks out the vast majority of the public. Eliminat- ing relatively high paying jobs our mineral industries provide and substituting tourism-related jobs in their place usually cuts wages by at least half. Lower wages mean less taxes paid and continue to lower our standard of living and depress our economy. It is very important that we broaden the tax base as much as possible. Anything that can be done to help the tax- payer in this State ought to be considered. We need to develop-build up a reserve for those things. If there is one single acre taken from a county as a result of this wilderness proposal, then there should be a law passed that would justly compensate the tax base of the local governments for that one single acre. e. BLM should talk with the local tourist-related industries and ask how much of their business is relat- ed to wilderness visitors. Local county commission- ers do not see corporations begging them for building permits to build motels and restaurants to service these people in anticipation of wilderness designation. Because people visiting do not patronize our busi- nesses, our towns do not grow. Examples are Bryce, Zion, Canyonland, and Lake Powell areas. Businesses located near national parks receive very little eco- nomic benefit from this. Managers of these lands have frequently opposed actions that would help economic activity in the county. More wilderness area will only add to our economic problems. Throughout the Draft EIS it is stated that certain monies will be developed over a period of years by increased recreational use of wilderness areas. The EIS is totally inaccurate in this area. Wilderness will result in no significant in- creases in recreational revenues for local businesses and communities. Tourism is speculative, and we do not have the infrastructure to attract tourist dollars. Therefore, we conclude that our best chances for 1 6 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS economic growth are to protect those mineral and energy resources currently providing the jobs and paying the bills. f. More wilderness designation will result in in- creased tourism, which would bring a more stable economy to much of southern Utah. One quarter of Utah's economy, $1.3 billion in 1985, depends on the travel industry. Tourists seeking solitude and primi- tive recreation come from all over America to Utah. They rent vans, small cars, and buy gas just in the drive down and back from the Salt Lake City airport. Also to be considered are the ticket agents, grocers, baggage handlers, jet fuel sellers, restaurant own- ers, and marina personnel. These have been left out of the Draft EIS. Tourism also supports local outfit- ters. Local communities located near wilderness areas would receive promotion through literature available for tourists and commercial outfitter opera- tions. This increased tourism will result in the genera- tion of more jobs for Utah residents, which will help stabilize and improve the existing depressed econo- mies which rely on mineral extraction. g. Tourism is the State's most important indus- try. Wilderness is a sound financial investment for the State. The Draft EIS downplays the importance of tourism to the health of the economy in the State of Utah. The poorest counties stand to benefit the most from wilderness through trade and services. The Draft EIS lacks monetary values of projections of in- creased tourism gains in the State. On the other hand, the Draft EIS ignores the damage that may result to the State's image and its number one industry of tour- ism, if areas possessing outstanding wilderness val- ues are sacrificed for short-term profits. Studies and research on patterns of tourism in Utah should be com- pared and contrasted with those in other States to assist in learning how to best promote Utah's wilder- ness areas. More can be learned about potential tour- ists and their views of Utah. Mass marketing needs to be undertaken to promote tourism in Utah. People who live in wilderness areas should try to be more crea- tive in thinking of new ways to make a living in har- mony with wilderness. We cannot afford to gain a reputation as a State that is anti environment. We cannot afford to gain a reputation as the State with the greatest wilderness potential, in the lower 48 States, that let itself become the State with the least protected wilderness. The greatest potential for growth is found in tourism. The visitation of Utah's national parks alone in 1985 was 7 million people. That’s a 55-percent increase over the last decade. Utah's State parks show similar patterns of visita- tion. They had about 5 million visitors in 1985, an increase of 37 percent over the last decade. Tour- ism value of wilderness areas in Utah will likely in- crease over time in proportion to the negative im- pacts of U.S. population growth on land elsewhere. Recreational benefits to local and regional Utah econo- mies are significant. Wilderness visitors will spend monies in local communities that will be increasingly substantial. Existing small communities located near large clusters of wilderness areas should clearly be designated in available promotional literature and on highway signs. Local economies should be developed around what may be or eventually may become their principal socioeconomic resource, wilderness. Many people spend up to an average of $50 a day in towns close to their final wilderness destination. Increased wildlife will benefit the local economy through a re- sulting increase in hunters to the area. Local busi- nesses should try to be more creative in thinking of ways to increase their benefits from wilderness visi- tors. In summary, wilderness can result in substan- tial increased revenues to local businesses and com- munities. h. Tourism, the one important local industry that is growing, would be positively served by wilderness designation. There is no doubt that a wilderness area encompassing a large part of the Book Cliffs roadless country could become a major tourist attraction, con- tributing significantly to the tourism-dependent local economy. Under the worst-case scenario, the Draft EIS states the All Wilderness Alternative could result in a loss of 20 future jobs being available. This assumes there are not areas of similar or better ener- gy potential outside of the proposed wilderness where the jobs could be provided, and that is simply not the case. 24.17 RESPONSE: The comments typify the widely differing views regarding the role of wilderness in the economy. In response to numerous conflicting com- ments, BLM has studied the subject further, obtained additional input, reviewed available new data, and ex- panded the narrative in the economics analysis in Vol- ume I of the Final EIS. In general, data indicate that there is not a permanent link between wilderness and increase in visitation. Therefore, wilderness designa- tion would not result in appreciable gains in local em- ployment or income. See the responses to General Comments 8.10, 21.15, 21.17, 21.19, and 24.8, which discuss the GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS effect of wilderness designation on recreational use and economics. Concerning comment h, the estimate of 20 jobs foregone in the Book Cliffs area was based on the assumption that certain new oil and gas drilling and recovery activities would occur without wilderness designation, and that these activities would not occur with wilderness designation. It had no relation to any oil and gas production that may occur outside WSAs, since such activity could occur regardless of actions within WSAs. 24.18 COMMENT: The value of motorized vs. non- motorized recreation should be compared in the EIS. [Utah Four-Wheel Drive Association, et al.] Four-wheel drive vehicle sales in the past 7 years have exceeded $5 million and have increased 96 percent from 1975 to 1979. Sales have tripled from 1981 to 1984. In 1984 alone, the sales of four- wheel drive vehicles exceeded $1.1 million. Closing roads is outright discrimination against the legitimate recreation of four-wheel drive users. Four-wheel drive use continues to grow in spite of the cost of vehicles and the dollars that are spent annually from this recreational activity. Millions of fees are col- lected from recreational special fees by BLM and other government institutions. BLM collected over $75 million alone in 1983 from ORV usage. These collections came from special permits, taxes, and fees for use of lands. The recreational vehicle market estimated it to amount to more than $2.4 million annu- ally spent in equipment sales alone, in addition to the estimated $10 million of annual four-wheel drive vehicle sales. The potential $12 billion total recrea- tional four-wheeling income amounts to nearly 5 per- cent of the total $244 billion in the recreational indus- try. Today, millions of recreational vehicles are gen- erating billions of dollars for the economy. One BLM District in Arizona in 1983 accounted for 655,000 visitor hours of recreational usage. The income of this exceeded $620 million. Approximately 33 per- cent of America is owned by the Federal government, and 30 percent of that is already closed to motorized vehicle travel. In Appendix 9, page 357, the value of "noncommercial recreation use" is grossly under- stated. 24.18 RESPONSE: See the responses to General Comments 21.1 and 21.4. Wilderness designation is not expected to significantly reduce opportunities for ORV use and related economy in Utah because lack of access and rough terrain presently preclude ORV use in much of the WSA acreage and because there are ample ORV use areas outside WSAs. 24.19 COMMENT: The EIS analysis incorrectly esti- mates the value of mineral leasing revenues. [Utah Wilderness Association, Utah Counties, et al.] a. BLM notes the lease figure as $3 per acre, which skews the socioeconomic figures because non- competitive leases are only $1 per acre. Volumes II through VI use a figure of $3/acre for oil and gas leases when the actual amount is $1. 52/acre. Thus, the mineral revenue lost through wilderness designa- tion is indicated to be twice as high as it actually should be. Volume I uses the correct figure. Why is there a discrepancy? b. Wilderness designation will result in a loss of millions of dollars per year in oil and gas lease mon- ey, of which the State receives 50 percent. In this day and age when the nation is concerned about defi- cits and balanced budgets, how can the Federal govern- ment consider the loss of revenue generated by min- eral leases in these wilderness areas alone? It is estimated that the Federal government will lose $2,238,466 in monies generated through mineral and grazing leases in Utah. This figure does not reflect undetermined amounts related to royalties, bonus bids, taxes, community contributions, etc. 24.19 RESPONSE: Lease revenue figures vary. Early in the wilderness study (early 1980s) the aver- age lease figure was about $3 per acre; however, the recent figure is about half that amount. Volumes II through VI were based on the earlier amount, while Volume I was prepared later and reflected the more recent figure. An upda.ed figure of $2 per acre has been used consistently throughout the Final EIS; how- ever, it should be recognized that this figure probably will change in the future. The number of leases and related revenue figures also have been updated for the Final EIS. These updat- ed figures show a decline from those shown in the Draft EIS. This has occurred because many existing leases were cancelled by the lessees or were allowed to expire due to poor market conditions. In most cases, no exploration was done on these leases to de- termine the presence or absence of oil and/or gas in producible quantities. Under current law, new oil and gas leases are not issued in WSAs. The comment is correct in stating that lease revenues do not include GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS royalties, bonus bids, taxes, community contribu- tions, etc. Such aspects occur with only a small por- tion of leases and are significant to local economic conditions only where leases are brought into produc- tion. Less than 3 percent of oil and gas leases in Utah ever reach commercial production (Lopez, 1987). 24.20 COMMENT: The analysis of the effects of wilderness on local employment and income is inade- quate, contradictory, and undocumented. [Nora Worthen, Utah Counties, J.R. Hindes, Utah Wilder- ness Coalition, Dennis Willigan, Randolph Jorgen, Howard Garber, Dennis Slifer, et al.] a. In Volume VI, Page 27, we read that with wil- derness there would be "no significant changes in the current trends and population, employment and local income distribution." Yet, Volume I, Page 55, flatly contradicts that statement. Volume I, Page 55, docu- ments the negative economic impact on both employ- ment and income levels amounting to 5 percent. b. The Draft EIS did not include a comprehensive analysis and assessment of local and State economies by evaluating the loss of jobs, loss of industry poten- tial, and loss of revenues. Suppression of employment opportunities and earning levels is a reality that is ig- nored by the Draft EIS. Wilderness employment oppor- tunities will lower the standard of living by forcing a switch from higher paying industry jobs to lower pay- ing service sector jobs in tourism-related industries. I do not want to see my family be forced to give up their livelihood and move away just to accommodate some student from Pennsylvania to come here and smell our sagebrush. He can go to Canyonlands where there is plenty of sagebrush already set aside. c. Many statements in the Draft EIS are totally false, including: "Overall there would be no signifi- cant changes in current trends of population, employ- ment, and total income distribution," and "Livestock use and ranchers income would remain and continue as present." To maintain that the locking away of a large number of acres would have so little effect on local residents and our economy is preposterous. The Draft EIS indicates "Utah's mining industry now accounts for less than 3 percent of the State’s total employment." In Emery County, well over 50 percent of the work force is either engaged in mining or a utility-related position. The Draft EIS indicates that Emery County is one of six counties that has ". . . the greatest potential for significant impacts resulting from designation." These six counties are those which would experience a possible decrease in future eco- nomic development and employment of at least 5 per- cent, yet the BLM Proposed Action ignores this. The economic figures used in the Draft EIS appear to be arbitrary and are not documented in any way. Have there been no studies in other parts of the country of the impacts of wilderness on employment opportuni- ties? d. In Volume I, Chapter 2, Table 17, "Impact Sum- mary," it is indicated that with any wilderness combi- nation there would be at least 5 percent less employ- ment and income. Wayne County has an unemployment rate close to 20 percent, which qualifies us in nation- al studies as one of the poorest counties in the entire nation. Wilderness will only aggravate this existing critical condition. e. In the Draft EIS, the statement is made, refer- ring to the economic status of growth in Wayne Coun- ty that: "... if current trends continue, then the econ- omy and employment will not be severely impacted by wilderness status." The current trends in Wayne County are toward poverty and unemployment for the majority of the residents. These trends are exactly what we wish to change, and the developments that will facilitate these necessary changes will be prohib- ited by wilderness designation. In a county that is already 80-percent government controlled, the loss of the resources of some 426,956 acres of public lands will be a blow that will prove hard to recover from, if not impossible. The future of Wayne County lies in the development of its water on behalf of farmers with projects like the Cainville Dam, which will open hundreds of acres to the families there, and in its mineral resources. f. A minimum of 75 well paid jobs would be re- quired for a start-up mine, and the benefits on the surrounding communities would be substantial. The Draft EIS estimates that there will be a 5-percent reduction in employment in Carbon, Emery, Garfield, Kane, Tooele, Uintah, Washington, and Wayne Coun- ties. Five percent is significant, even disastrous, but there is no mention of unemployment in Grand and San Juan Counties. Yet, approximately 80 percent of the preceding wilderness areas are located in these two Counties. Can we assume 5 percent to 10 percent, or even 20 percent? I can find no attempt to address the financial impact that this rate of unemployment will have. When this study is done, it must also include the multiplier effect, only this time done in reverse. GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS g. The entire Draft EIS overstates the potential losses of jobs in mineral and energy development by estimating losses as if the full potential development would someday be forthcoming in spite of stating that most of the "potential" development would never be- come economically feasible. The predicted 5 percent reduction of jobs in grazing due to wilderness would occur anyway since both grazing and mineral produc- tion are predicted to fall anyway. h. Draft EIS data are flawed. For example, there is a discrepancy in Volume I, page 105, Table 64, which is the source of the employment impacts des- cribed in Appendix 9, Table 1 (Volume I, page 357). To determine where the direct employment/output ratio of 0.00053 AUM for livestock forage derives, we look at the third and fourth columns in Table 64. Correctly recognizing that operators' employment is only partially accounted for by the additional grazing available on WSAs, one takes the hired labor employ- ment estimate of 3,200 and calculates it as a ratio of total AUMs generated throughout the State: 3,200/ 6,003,372 = 0.00053/AUM. The problem is that we are not interested in how many sheep and cattle graz- ing on other public lands and total lands in the State (public and private) will be affected by the alterna- tives, since the impact that is to be studied is precise- ly that associated with the WSAs as the Draft EIS states in Volume I, page 104, "The WSA's importance to Utah's economy is determined by the activities occurring within them." The figure 0.00053 is unreal- istic since the employment of hired labor associated with sheep and cattle is most likely independent of where the livestock are grazing. However, when this same process is applied to employment/output ratios for recreation, the two calculations do not come out the same. Again, in Table 64, columns 3 and 4, the ratio is 13,100/142,138,000 = 0.00009. But the same logic as before applies here. What sense does it make to take the Statewide average employment ratio, when what we are really interested in is the employment impact in the WSAs? Redoing the calcula- tion using the last two columns in the table gives us 77,213,361 = 0.0004, a figure some four times greater than that found for Statewide recreation. In- creased recreation could be expected to more than make up for the lost employment due to reduction of grazing and mineral production. i. BLM derived the direct employment/output ratios in Appendix 9 (Volume I, page 357) by a simple ratio of labor to output, using the data in Table 64 (Volume I, page 105). For example, the ratio of graz- ing is 0.00053/AUM (Appendix 9), which is identical to the ratio given in Table 64 under columns 3 and 4 (Statewide data), 5 and 6 (public lands), and 7 and 8 (WSAs). This is hardly the sophisticated input/ output model implied in Appendix 9, but, if used consistent- ly, it suffices. In describing the potential impacts of the Proposed Action, the Draft EIS states: ". . . em- ployment opportunities in Washington, Kane, Garfield, Wayne, Emery, and Carbon Counties have the great- est potential significant impacts resulting from desig- nation" (page 120). This claim is made without any supporting evidence or documentation. Under the Pro- posed Action, how can Carbon County be significantly impacted? The only recoverable resource within the Carbon County portion of Desolation Canyon is oil and gas, and the area with potential (Jack Creek/Peter's Point) is excluded from BLM's recommendation. Even under the All Wilderness Alternative, there would be very little impact. It would not be significant if every person employed in oil and gas in Carbon County were laid off right now. If the Draft EIS is going to make outrageous claims about loss of employment, it is in- cumbent upon BLM to clearly indicate what potential jobs could be lost, and from what projects. j. The State of Utah's Resource Development Coor- dinating Committee Wilderness Subcommittee (July 1986) report determines that wilderness designation will have little or no impact on employment. In every instance-oil and gas, coal mining, powerplant devel- opment, and uranium mining-the report con-cludes that the baseline projection for employment can be reached in the next 25 years regardless of wilder- ness. Only agriculture and government revenues are negatively impacted. k. Regarding employment and income in general, we are told on page 55, Table 17 (on pages 121, 126, and 134-5) that, under the All Wilderness Alterna- tive, income and employment in some areas ". . . would be at least 5 percent less than with no wilder- ness areas." Where are the figures to support this? Where are the data? How was this conclusion arrived at? l. What proportion of total income and employment is presently recreation oriented in the communities nearest the wild lands? What will happen to that in- come if the wild lands are lost? How stable is that in- come in contrast to the boom-and-bust economies of mineral and energy incomes? 20 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS m. It seems logical to combine "impacts on employ- ment" and "impacts on income." What is the differ- ence between "income-producing opportunities" and "opportunities for employment"? n. The Draft EIS lacks a proper baseline against which to compare impacts. Impacts of wilderness des- ignation should be determined in comparison to proba- ble future conditions in the absence of designation. A modeling analysis should be performed that accur- ately projects economic and social conditions in sev- eral scenarios involving more and less wilderness. The Draft EIS states that wilderness designation might forego some future employment opportunities in mineral industries. The reduced employment, how- ever, is only against future levels, not current em- ployment. The Draft EIS identifies six counties that could suffer significant impacts from wilderness des- ignation. Yet, those counties have suffered substan- tial employment losses in mineral industries not relat- ed to wilderness since 1984. A meaningful analysis would project economic conditions with wilderness designation against existing trends without designa- tion. With those trends being unfavorable in the im- pacted counties, it is not accurate to ascribe job and income losses to wilderness designation. o. On pages 120, 126, and 234, we are told, "Foregone annual mineral production and resulting changes in local economic conditions cannot be speci- fically quantified due to uncertainties regarding the presence of mineral resources and future economic and technological conditions." So, how does BLM then quantify projections, such as the 5-percent employ- ment and income reductions due to wilderness? p. Utah contains six national parks and numerous designated wilderness areas. These current wilder- ness areas contain hundreds of thousands of acres, acres that guarantee the limited use for the limited few. The national parks are designed to provide many of the same values and protections of the single-use wilderness designation. What is being created through wilderness designations is a series of "supernational parks," super parks that are generally enjoyed only by the super hearty. The few benefit, while the many, and their opportunities for multiple-use enjoy- ment, are hindered. Areas designated as wilderness already burden the citizens of Utah. The burden is evident in higher costs to consumers and lost jobs in industries that can no longer be provided with the raw resources lying within the confines of these limited single-use areas. Careful review should begin again so as to correctly and adequately identify the mineral resources and their value lying within the WSAs. Such a review will facilitate the necessary cost-benefit analysis as regards further wilderness designations within the State of Utah. 24.20 RESPONSE: The Volume VI statement refer- enced in the comment pertains only to a specific WSA, whereas the statement on page 55 of Volume I applies to a Statewide alternative comprised of many WSAs; therefore, no contradiction exists. The Final EIS has updated information and analysis on the potential impacts of wilderness on the local and State economies. BLM's overall conclusion is that wil- derness designation would not substantially affect the economy of rural Utah one way or the other. Contra- ry to some opinions, BLM believes that wilderness would not result in a large influx of tourist dollars (see the responses to General Comments 21.7, 21.15, 21.17, 21.19, and 24.8). Contrary to other opinions, BLM believes that wilderness designation would not result in significant loss of jobs and loss of local income. There are uncertainties in the analysis, but BLM believes that statements made in the Socio- economics sections of the EIS are based on the best available information and are not "totally false." The economic problems of Utah counties are com- pletely unrelated to the matter of wilderness designa- tion. A recent study by the Western Governors Asso- ciation (1987) indicates that many rural counties throughout the western United States are experienc- ing economic difficulties. Most of the distressed rural counties have a high degree of economic dependency on a single sector of the economy, and the decline is part of a long-term trend dating back to the turn of the century. The trend was only temporarily halted by the high commodity prices of the 1970s. Resour- ces on lands within WSAs have been available for economic-oriented uses over this extended period of rural economic concern and have made little differ- ence to the declining trend. With the exception of a few specific WSAs, as identified in the analysis, there is little realistic potential for use of WSAs in the future due to the substantial and permanent in- fluence of the long-term declining economic trend in the identified central and southern Utah counties. The Final EIS includes a revised, updated, and expanded socioeconomic narrative, particularly in Volume I, Chapters 3 and 4, and Appendix 9. Most of 21 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS the numbers referenced in the comments have been changed and/or further explained. The State of Utah's Resource Development Coordi- nating Committee report mentioned in the comment, which determined that wilderness designation would have little or no impact on employment, is consistent with BLM findings. The 5 percent estimation represents a summary conclusion, based on the consideration of all of the various economic data and conditions described in the EIS. It was derived based on the judgment of those preparing the EIS and represents a low level of signi- ficance in the amount of change expected. The antici- pated developments analyzed in the Draft EIS have been reduced in number and size for the Final EIS as a result of further information regarding feasibility. Therefore, projected effects on local economics are lower than in those reported in the Draft EIS. The recreation-related income and employment is included for each WSA, and aggregated in Volume I, Chapter 3. The figures are estimates for those types of activities directly associated with primitive recre- ation (i.e., hiking, backpacking, nature appreciation, photography, etc.). Income and employment attributed to developed recreational facilities, sightseeing from roads, tourist attractions with vehicle access, ORV and four-wheel drive recreation, hunting, and fishing are noted separately. Recreation-oriented local econo- mies may vary with changes in the overall national economic situation; however, in most cases, such changes tend to be less dramatic to local economies than the typical examples of growth and recession (boomtown) changes related to energy and minerals. Impacts on employment and income are related, but are explained under separate paragraph headings in the EIS because the former focuses on jobs and the latter on earnings. Income-producing opportunities may or may not include employment, whereas oppor- tunities for employment generally denote jobs (hiring of employees). The best baseline data available are used in the Final EIS. Information on existing trends is included. Also, see the response to General Comment 9.16. The analysis of socioeconomic impacts to the vari- ous counties has been substantially revised. Carbon County was identified among the locations impacted by the Proposed Action due to its geographic relation- ship to the San Rafael Swell and Desolation Canyon regions. The EIS is correct in stating that foregone min- eral production and related local economic conditions cannot be specifically quantified due to future vari- ables and the basic limitations in making long-term economic predictions. This does not mean that a gen- eral estimate cannot be made. As noted above, 5 per- cent is intended to represent a summarized judgment indicating approximate magnitudes of impact. It is used along with such qualifying words as "up to," "more than," and "at least." This is not the same order of detail or precision as reflected in the terms "specifically quantified." A careful review of mineral resources, potential for their development, and related local economic con- siderations has been conducted in preparation of this Final EIS. This information is reflected in the docu- ment; however, a cost-benefit analysis has not been included. Also, see the responses to General Comments 1.3, 3.3, 9.4, 9.12, and 9.16. 24.21 COMMENT: The EIS does not adequately address secondary impacts to natural resources and their effect on economics. [Utah Wilderness Coalition, et al.] We find that BLM's impact analysis has been in- adequate and too general in nature. A more discerning impact analysis should be completed in the Final EIS. For example, BLM fails to adequately discuss sec- ondary impacts of development allowed through non- wilderness recommendLtions. BLM has not addressed the quantity of archaeological sites that will be van- dalized if lands are designated unsuitable and opened to use by ORVs. BLM fails to quantify the impacts on wildlife populations, of both game and nongame spe- cies, from development on roadless lands not desig- nated wilderness. Such secondary impacts affect the entire Utah travel industry. BLM has not discretely identified that industry. In developing gross cate- gories of transportation, services, and utilities, BLM fails to identify the portion of each category that relies upon and benefits from the travel industry. Tourists come to Utah to see its natural resources, and a majority of these are on BLM lands. BLM has not considered the discrete components of the 22 GENERAL COMMENTS AND RESPONSES SECTION 24: SOCIOECONOMICS economy that are affected by wilderness designa- tion. 24.21 RESPONSE: The analyses addresses secon- dary effects to resource values and related socioeco- nomic aspects. The EIS analysis concludes that im- pacts on wildlife and cultural resources from nondes- ignation (No Action/No Wilderness Alternative) would not be significant on a Statewide basis, (see Chapter 1, Issue Identification section in Volume I.) Also, see the responses to General Comments 16.1, 16.2, 20.1, 20.2, and 20.5. 23 * GENERAL COMMENTS AND RESPONSES - SECTION 25 EDITORIAL INDEX 25.1 The titles given to Utah's regional areas down- play their wilderness qualities, (p. 1) 25.2 The photographs of the WSAs in the Draft EIS are inadequate, (p.2 ) 25.3 The coloring of maps to identify designated lands is misleading, (p. 2) 25.4 Lists of preparers should note that the years of experience are not necessarily in the assigned topic. (P- 2) 25.5 On page 194 (Volume I of the Draft EIS), Mr. Wood's degree should be listed as a MS rather than a BS. (p. 2) 25.6 Many acronyms are not identified in the Draft EIS. (p. 2) 25.7 The Draft EIS definition for cubic feet per sec- ond is incorrect, (p. 2) 25.8 The term "nondesignated lands" is misused in the Draft EIS. (p. 3) 25.9 Grand Gulch Complex is incorrectly worded on page 88. (p. 3) 25.10 Fish Creek Canyon is erroneously labeled Fish Spring Canyon on page 23. (p. 3) 25.11 The word "proposed" should be added before wilderness area on page 140. (p. 3) 25.12 The Draft EIS contains unnecessary duplica- tion, repetition, and a confusing page numbering system, (p. 3) 25.13 Volume I contains two copies of page 19. (p. 3) 25.14 "Response To Comment 31" on page 231 is in- correct. (p. 3) 25.15 There is a discrepancy in figures for acres of disturbance due to mineral activity, (p. 4) 25.16 The Draft EIS contains incorrect acreage fig- ures for Arches and Canyonlands, and erroneously excludes Mt. Pennell adjoining a national park. (p. 4) 25.17 There are contradictory BLM proposals for Mt. Pennell WSA. (p. 4) 25.18 There are contradictions concerning WSA Nos. 19, 40, and 42 between alternative descriptions and other references, (p. 4) 25.19 All the descriptions involving comparisons of WSAs adjoining Zion National Park should be in one volume, (p. 4) 25.20 The Draft EIS needs to include more tables on each alternative and by specific WSA. (p. 4) 25.21 On Pocket Map 1 #59, "Rafael" is misspelled. (P- 5) COMMENTS AND RESPONSES 25.1 COMMENT: The titles given to Utah's regional areas downplay their wilderness qualities. [Earth First!] I object to BLM's choice of the great titles by which to call Utah's regional areas. Utah's lands have the power to capture the nation's imagination. Utah's landscape is revered in Europe. But could anything be more deadening to enthusiasm than to refer to parts of incredible Utah as merely the West-Central Region, East-Central Region, South-East Region, et cetera? It is not the South-Central Region. It is the Book Cliffs and San Rafael Swell. It is not the South-East Region, but it is the Greater Canyonlands. The South-West Region is the Mohave. Again, BLM is doing precisely what it can to play down the subject here. 25.1 RESPONSE: The titles "West-Central Region, East-Central Region," etc., were used as a logical means to identify and geographically group WSAs. This identification is simpler and easier to remember, 1 GENERAL COMMENTS AND RESPONSES SECTION 25: EDITORIAL especially for those not familiar with the geography of Utah. In addition, the titles suggested in the com- ment do not refer to the contents of the volumes. For example, the South-West Region WSAs are not the Mohave Desert region, but are part of the Colorado Plateau physiographic region. It was not intended to downplay the WSAs qualities. Reference to such areas as the Book Cliffs, San Rafael Swell, etc., are often used throughout the Draft EIS, where appropriate. 25.2 COMMENT: The photographs of the WSAs in the Draft EIS are inadequate. [Earth First!] I am concerned about the scenic color photos at the front of Volume I of the EIS. These photos are only of areas being recommended by the agency. The decep- tion intended I suppose, is that what BLM is recom- mending is beautiful enough and that the public need not be alarmed or concerned or investigate further. Again, BLM in Utah is engaging in a conspiracy of cal- culated deception against the American public. We feel BLM should have photographs of some of the areas they did not choose to recommend for wilderness. Many of these areas are just as beautiful as the ones represented in the photos and have similar qualities, yet they were not chosen. We think they should re- ceive some recognition as well. 25.2 RESPONSE: The color photos appearing in Vol- ume I of the Draft EIS are, in BLM's judgment, among those areas best suited for wilderness designation. Because of the length of the document and the high cost of printing color photographs, BLM could not in- clude additional pictures. However, a black and white photograph of each WSA appears on the title page of each individual WSA analysis (Volumes II through VI). 25.3 COMMENT: The coloring of maps to identify designated lands is misleading. [Tim and Audry Graham] We feel that the coloration of Pocket Map No. 2 is misleading. It is not right to color all the NPS and In- dian Tribe proposed wilderness areas, especially in such bright colors. If these lands are to be shown (which does make it easy to see how some of the BLM areas will round out the proposed wilderness areas of other agencies), there should also be a notation about the fact that all the proposed lands would only equal 1 1 percent of the State. Put it right on the map. Other- wise, the wilderness opponents who don't bother to read the EIS just see vast areas of land "locked up" whether that is true or not. We suggest that Pocket Map No. 2 be colored more like Pocket Map No. 1, or maybe with outlines of other agency wilderness lands, existing or proposed. This would eliminate some of the unfair bias against BLM's All Wilderness Alternative. 25.3 RESPONSE: See the response to General Com- ment 26.2. 25.4 COMMENT: List of preparers (pages 192 to 195) should note that the years of experience are not necessarily in the assigned topic. [Brian Wood] 25.4 RESPONSE: The list of preparers (pages 192 to 195 of the Draft EIS) has been amended in the Final EIS by inclusion of a footnote that indicates that years of experience do not always reflect experience in the topic assigned for the EIS. 25.5 COMMENT: On page 194 (Volume I of the Draft EIS), Mr. Wood's degree should be listed as a MS rather than a BS. [Brian Wood] 25.5 RESPONSE: Comment noted. The list of pre- parers for the Final EIS includes only those who pre- pared the Final EIS. 25.6 COMMENT: Many acronyms are not identified in the Draft EIS. [National Park Service] Certain acronyms used in the document are not defined in the "List of Abbreviations" section. These include UCA, ISA, SCORP, and ATV. In Volume I, pages 389 and 391 are out of place and should be in reversed order. 25.6 RESPONSE: The acronyms ISA, SCORP, and ATV are included in the List of Abbreviations for the Final EIS. The use of the acronym "UCA" could not be found in the Draft EIS. Pages 389, 390, and 391 of the Draft EIS were out of order and have been reor- dered in the Final EIS. 25.7 COMMENT: The Draft EIS definition for cubic feet per second is incorrect. [Brian Wood] Page 376: One cfs flowing for 24 hours will not yield 1,983 acre-feet of water; rather, it will yield 0.2 acre-feet. 25.7 RESPONSE: The definition for cubic feet per second on page 376 of the Draft EIS should have read, "One cfs flowing for 24 hours will yield 0.1983 acre- 2 GENERAL COMMENTS AND RESPONSES SECTION 25: EDITORIAL feet of water." This error has been corrected in the Final EIS. 25.8 COMMENT: The term "nondesignated lands" is misused in the Draft EIS. [Composite Comment] The language "nondesignated lands" in WSAs is a misstatement. Congress designates land as wilder- ness. Land that Congress does not designate as wil- derness remains open to the public land laws unless formally withdrawn. Once Congress has made the deci- sion on which lands are designated wilderness there is no WSA anymore. 25.8 RESPONSE: When using the term "nondesig- nated lands," BLM is referring to lands that are cur- rently WSAs. In the future these areas will either be designated wilderness areas or nondesignated, depend- ing on Congress' decision. 25.9 COMMENT: Grand Gulch Complex is incorrect- ly worded on page 88. [Brian Wood] Page 88: "Grand Complex" should be "Grand Gulch Complex." 25.9 RESPONSE: Page 88 of the Draft EIS should have read ". . . Grand Gulch Complex . . ." This error has been corrected in the Final EIS. 25.10 COMMENT: Fish Creek Canyon is erroneous- ly labeled Fish Spring Canyon on page 23. [Robert Hassell] I find little about which to complain in Volume I. There is one misprint I located. In Table 4, page 23, Area 48 has been incorrectly identified as Fish Spring Canyon, while everywhere else in the EIS it is called Fish Creek Canyon. This would be of little import, ex- cept that Area 4 is named Fish Springs, and the two areas are at opposite ends of the state. 25.10 RESPONSE: Area 43 on Table 4 has been changed to "Fish Creek Canyon." 25.11 COMMENT: The word "proposed" should be added before wilderness area on page 1406. [Unidenti- fied] Page 140, Impacts on Locatable Mineral Produc- tion: The word "proposed" should be added before wil- derness areas in the last sentence of this section. 25.11 RESPONSE: The last sentence of the section entitled "Impacts on Locatable Mineral Production" (page 140 of the Draft EIS) should have read as fol- lows: "Some of the most likely deposits are not inclu- ded in proposed wilderness areas with this alterna- tive." The Manageability Alternative has been elimi- nated from the Final EIS. 25.12 COMMENT: The Draft EIS contains unneces- sary duplication, repetition, and a confusing page num- bering system. [Brian Wood and Dennis Silfer] It would have been helpful if the pages had been numbered consecutively throughout the EIS, as oppos- ed to starting over with each WSA. Chapter 3, Affect- ed Environment, provides great quantities of concise background data and information. A problem with it, however, is that much of this information is duplicat- ed in the descriptions of individual WSAs in the subse- quent volumes. There must be a way to reduce this repetition of facts (how about-refer to . . .?). 25.12 RESPONSE: The objective of the EIS is to analyze each individual WSA analysis as a separate unit, thus enabling study and consideration of each WSA on its own merits. Therefore, BLM numbered each WSA analysis separately. Pages can easily be referenced by stating the name of the WSA analysis along with the page number. 25.13 COMMENT: Volume I contains two copies of page 19. [Clay Johnson] 25.13 RESPONSE: This error does not appear to be widespread, and is evidently a random mistake that occurred during binding of the document. 25.14 COMMENT: "Response To Comment 31" on page 231 is incorrect. [State of Utah] Page 231, Response to Comment 31: Text should read, "Refer to the response to Comment 30." 25.14 RESPONSE: The response to Comment 31 (page 231 of the Draft EIS) should have read: "Refer to the response to Comment 30." 25.15 COMMENT: There is a discrepancy in figures for acres of disturbance due to mineral activity. [National Park Service] The discrepancy in acres of disturbance due to mineral activity between the "Impact Statement," 3 GENERAL COMMENTS AND RESPONSES SECTION 25: EDITORIAL Table 17, page 49, and the "Environmental Conse- quences," Chapter 4, page 110, should be corrected. The former (under Impacts on Naturalness) lists 3,004 acres, while the latter lists 2,934 acres. 25.15 RESPONSE: Table 17 (page 49) and Chapter 4, Impacts on Naturalness section (page 110) of the Draft EIS both indicate a total of 3,004 acres of min- eral-related surface disturbance for the No Action/ No Wilderness Alternative. The disturbance estimates have been changed in the Final EIS to correspond with new development scenarios. 25.16 COMMENT: The Draft EIS contains incorrect acreage figures for Arches and Canyonlands, and erro- neously excludes Mt. Pennell adjoining a national park. [National Park Service] Page 93: Canyonlands proposed wilderness is now 287,133 acres with 120 acres pending as potential wilderness. Arches wilderness recommendation is 62,947 acres. Page 101, paragraph 4: the Mt. Pen- nell WSA should be included in the list of WSAs that adjoin NPS areas (Mt. Pennell adjoins Capitol Reef National Park). 25.16 RESPONSE: Table 54 of the Draft EIS has been changed to indicate the correct acreages of Arches and Canyonlands potential and proposed wil- derness. The WSAs listed on page 101, fourth para- graph of the Draft EIS, did not include Mt. Pennell as a WSA adjoining NPS lands because the WSA and Nation- al Park Service lands are separated by the Notom or Boulder to Bullfrog road. 25.17 COMMENT: There are contradictory BLM proposals for Mt. Pennell WSA. [Owen Severance, et al.] Mt. Pennell WSA-A major problem with the BLM treatment of this WSA is just what is the Proposed Action? In Volume I, both the maps and all tables show that zero acres of the Mt. Pennell WSA are rec- ommended for wilderness. In Volume IV, the Partial Wilderness Alternative recommending 25,800 acres is supposedly the Proposed Action. Since Volume I is pushed by BLM as the document most necessary to analyze the Draft EIS, a very false picture is given concerning the Mt. Pennell WSA, or the false picture is given in Volume IV. This error should be publicly corrected-a corrected version of Mt. Pennell treat- ments should be mailed to everyone that received Volume I. 25.17 RESPONSE: BLM's Proposed Action for Mt. Pennell WSA was the No Action/No Wilderness Alter- native in the Draft EIS, but it now has been changed to the Partial Wilderness Alternative in the Final EIS. The apparent contradictory proposals in the Draft EIS were the result of typesetting mockup problems. An errata sheet mailed to recipients of the Draft EIS, and published in the Federal Register on April 2, 1986 (FR Volume 51, No. 63), made further explanation of the discrepancies. 25.18 COMMENT: There are contradictions con- cerning WSA Nos. 19, 40, and 42 between Alterna- tive Descriptions and other references. [Tod Young] Volume I, Chapter 2, Table 4 and Pocket Map 1 conflict with the Alternative Descriptions of WSA Nos. 19, 40, and 42 in subsequent volumes. I assume that the descriptions are correct and the other refer- ences require editorial correction. Please advise. 25.18 RESPONSE: BLM's Proposed Action in the Final EIS for WSA Nos. 19, 40, and 42 are as follows: Parunuweap Canyon, Large Partial Wilderness Alter- native; French Spring-Happy Canyon, Partial Wilder- ness Alternative; and Mt. Pennell, Partial Wilderness Alternative. This Final EIS reflects the correct infor- mation. 25.19 COMMENT: All the descriptions involving comparisons of WSAs adjoining Zion National Park should be in one volume. [Brian Wood] Comparisons of the WSAs adjoining Zion National Park would have been easier had all their descriptions been in one volume. 25.19 RESPONSE: Volume III (South-West Region) of the Draft EIS was divided into two parts because of its large size. WSAs were ordered sequentially by map number (refer to Pocket Map 1) in all volumes of the Draft EIS. 25.20 COMMENT: The Draft EIS needs to include more tables on each alternative and by specific WSA. [State of Utah, et al.] a. The emphasis on Statewide alternatives in the Draft EIS has led to a lack of composite information on the individual WSAs. I realize that this is the focus BLM requires in order to make its recommendation to the Secretary, but the public’s analysis would be greatly assisted by the inclusion of more tables which 4 GENERAL COMMENTS AND RESPONSES SECTION 25: EDITORIAL would be useful for ascertaining the impacts of new alternatives. Perhaps BLM would consider including such tables as a public service. A typical example would be: a table listing each type and amount of energy and mineral resource in each WSA could be provided in Volume I (perhaps near the Impact Sum- mary Table on page 50, or combined with the totals in Table 29, page 69). Many other opportunities for in- cluding this type of breakdown exist. b. Page XXV, Tables: Many tables (such as those in Chapter 2) focused on the totals (acreages, AUMs, management actions, etc.) for the various Statewide alternatives. Few tables were included which show a comparison of the effects of site-specific alterna- tives on each WSA (such as were included in the Ore- gon WSA Statewide EIS, i.e., Summary Environmental Consequences, Volume I, page V; Summary of Propos- ed Management under Each Alternative, Volume I, page 24, Tables 2 and 3; Comparison of Impacts, Vol- ume I, page 26, Tables 2, 3, and 4). Similar tables would be very useful in the Final Utah EIS. Tables 25 (U.S. Production of Fuel and Nonfuel Minerals) and 26 (Utah Mineral and Energy Production) were very help- ful, as were many tables listing the quantity of a spe- cific item in each WSA (i.e., Table 24, Major Surface Water Supplies Within or Bordering WSAs; Table 27, Past or Existing Mineral and Energy Production from Utah WSAs; and Table 53, Wilderness Values of WSAs). Table 29, Total Estimated In-Place Resources in WSAs, is a typical example of a table which would have been more useful had it listed the data for each WSA. In general, it would be very helpful to indicate the information for individual WSAs in each table which gives Statewide totals. c. The Draft EIS is inadequate in that the tabular information given in Volume I does not contain an indi- vidual listing of data for each WSA. Without WSA spe- cific information, independent review of the totals for each of the Statewide alternatives is extremely time consuming or impossible. 25.20 RESPONSE: Data tables that array re- sources by WSA were compiled from the WSA anal- yses for preparation of Volume I of the EIS. They are extremely large and, therefore, have not been inclu- ded in the printed document. 25.21 COMMENT: On Pocket Map 1, #59, "Rafael" is misspelled. [National Park Service] 25.21 RESPONSE: The error has been corrected. 5 . GENERAL COMMENTS AND RESPONSES - SECTION 26 MAPS INDEX 26.1 Data presented in the text should be mapped, (p. 1) 26.2 All the Volume I alternative maps should be pre- sented in the same manner, (p. 2) 26.3 State sections to be acquired should be identified as such on WSA maps. (p. 3) 26.4 Adjacent WSAs or wilderness areas should be shown on individual WSA maps to give a complete picture, (p. 3) 26.5 There are many inconsistencies in the Draft EIS maps. Volume I pocket maps do not agree with WSA maps in Volumes II through VI. WSA maps do not match "official" maps located in each District Office. (P- 3) 26.6 The Draft EIS maps are of poor quality and are unreadable, (p. 4) 26.7 BLM maps should present WSAs analyzed on their own merits, rather than pitted against other agency lands, (p. 4) 26.8 The name of the Fremont River was missing from maps used to indicate the location of the Fre- mont River Gorge WSA. (p. 4) COMMENTS AND RESPONSES 26.1 COMMENT: Data presented in the text should be mapped. [State of Utah; Sierra Club, Cache Group; Utah Wilderness Coalition; Frances Fericks; Kim Jennyson; Owen Severance; et al.] a. Data identified in the text should be mapped (i.e., geographic features, scenic quality, VRM, wil- derness characteristics, wilderness special features, major vegetative zones, cultural sites, historical sites, major wildlife zones, existing mineral lease and mining claim boundaries, bristlecone pine, can- yons, mesas, roads, ways, potential and existing con- flict sites, etc.). b. Data identified in the text should be mapped. The data in the EIS cannot be independently analyzed nor reviewed for the Partial Wilderness Alternatives because maps are not included for each of the re- sources. In addition, many geographic and other fea- tures discussed in the text are not included on the maps that do appear in the EIS. c. Very often features in the text could not be found on the maps. Roads were not clearly delineated and ways were absent. These need to be clearly mark- ed. d. Maps are a problem throughout the Draft EIS. Geographic and other features named and discussed in the text are often not shown or named on the maps. For example, it would have been helpful if range im- provements, both existing and proposed, were identi- fied on the maps along with allotment boundaries. This would have given the reviewers an opportunity to more thoroughly analyze the impact wilderness desig- nation may or may not have on livestock operations. Also, a map with the locations of mineral and energy potential should be included in each WSA analysis (such as was done in the Oregon Wilderness EIS). e. BLM fails to provide key information pertain- ing to conflicts and recommendations. BLM fails to provide maps that show the location of minerals with- in lands under wilderness study, of mining claims, mineral leases, range projects, and other issues. This information does exist and is critical in determining the geographic scope of the conflict. Some of this in- formation was found in the SSA reports; additional information is found in BLM's land use plans (e.g., range projects), and in other BLM files and docu- ments. BLM also knows which of the mining claims are valid and which are not. This information should be provided to the public, and we request that map information on the location of conflicts be included in the Final EIS. f. Charts and maps in the Draft EIS were gener- ally very helpful. However, special features identi- fied in the text were sometimes not identified on the maps. This made it very difficult to determine how 1 GENERAL COMMENTS AND RESPONSES SECTION 26: MAPS partial boundaries affect special features, canyons, mesas, bristlecone pine stands, etc. g. In the Draft EIS, BLM should have included maps which showed specific acreage boundaries for solitude, recreation potential, and similar traits as identified in the individual WSA analysis. For exam- ple, when BLM reports that 14,000 acres of a 125,000-acre WSA possesses solitude qualities, then this area should have been identified on a correspon- ding map. h. The Draft EIS does not include enough informa- tion for the reviewer to determine whether the WSAs' wilderness values have been accurately stat- ed. Since either outstanding solitude or primitive rec- reation values in addition to naturalness are required for wilderness designation, maps showing the areas of each WSA having outstanding opportunities and maps showing areas with naturalness should have been included along with maps showing scenic quality and VRM classifications. These maps cover the pri- mary issues concerning wilderness values in the WSAs, and persons reviewing the Draft EIS could more easily use personal knowledge to agree with or disagree with BLM's findings. Without these maps, the reviewer has to look at the SSAs and earlier docu- ments to try to find the reasons for the decisions made in the Draft EIS. However, most of the Draft SSAs do not have adequate maps, so the reviewer has to guess at the meanings of BLM statements. 26.1 RESPONSE: BLM did not map data areas un- less their location could not be adequately discussed in the text. Data that could not be adequately narrat- ed, that were important to the analysis, and that could be accurately mapped, have been mapped in the Final EIS. This approach was generally taken because map- ping data that could be narrated results in unneces- sary duplication and expense. Other reasons include: (1) some data, such as mining claims and mineral leases, are subject to change; (2) some data, such as wildlife and vegetative zones, are generally not issues for analysis; (3) conflict areas are shown in many cases by location of Partial Wilderness Alterna- tives; and (4) some data cannot be accurately map- ped. An example of Item 4 is wilderness character- istics. In many cases when WSAs were established, it was acknowledged that, although all portions of the unit did not contain wilderness values, the unit as a whole did. It would be difficult to accurately map por- tions of the unit that do not possess some of the wil- derness characteristics. We have recognized in the text that naturalness or outstanding opportunities for solitude or primitive and unconfined recreation do not exist throughout each WSA. Percentages of WSAs lacking these values have been estimated and the gen- eral location of these areas have been narrated. Loca- tions of some wilderness special features, such as threatened and endangered animal and plant species, is not specifically known and can be identified only in a general manner which is easily narrated. Other wil- derness special features, such as rivers or geograph- ic features, generally are identified on the maps. 26.2 COMMENT: All the Volume I alternative maps should be presented in the same manner. [National Park Service, et al.] a. Volume I, Pocket Map No. 2, which displays the All Wilderness Alternative, shows all existing and po- tential wilderness in the State, not just lands under review by BLM. All other Volume I alternative maps show only BLM wilderness that would be designated under that alternative. The All Wilderness Alterna- tive map creates a biased impression that there is plenty of wilderness without BLM wilderness. b. The maps included in Volume I indicate the vari- ous wilderness proposals. Only the All Wilderness Alternative map indicates all the other wilderness areas in the State (i.e., FS and proposed wilderness by the NPS). To avoid a perception of attempting to judge "how much wilderness is enough" and to achieve consistency, we recommend that all the maps either include or exclude other agency wilderness areas or proposed wilderness areas. 26.2 RESPONSE: The Volume I pocket map showing the All Wilderness Alternative has been redesigned. Only lands under review by BLM are colored, although all lands currently designated, proposed, or managed as wilderness are still shown in order to display how BLM WSAs complement proposed wilderness or wil- derness type areas in the State. A new Volume I map is now included which dis- plays the new Cluster and Interagency Areas Alterna- tive. This map colors not only BLM WSAs but other lands designated, proposed, or managed as wilderness because the proximity of other wilderness-type lands to BLM WSAs was a factor in defining the alternative. 2 GENERAL COMMENTS AND RESPONSES SECTION 26: MAPS 26.3 COMMENT: State sections to be acquired should be identified as such on WSA maps. [Kim Jennyson, Michael Salamacha, Ginny Taylor, et al.] When a WSA had State sections, the maps should have clearly shown which State sections would be acquired if the area became wilderness. Instead, it is a guessing game on the part of the reader, especially concerning the transfer of adjacent State sections. 26.3 RESPONSE: The State has changed its policy regarding exchange of State sections in BLM-managed wilderness areas since the Draft EIS was published. The State no longer wishes to exchange all State sec- tions, but may consider them on a case-by-case bas- is. Because the State has not yet identified which of these sections it would like to exchange, BLM cannot identify these on the maps. Also, see the responses to General Comments 6.3 and 23.10. 26.4 COMMENT: Adjacent WSAs or wilderness areas should be shown on individual WSA maps to give a complete picture. [Utah Woolgrowers, Michael Salamacha, et al.] a. The maps that are included should include all of the wilderness areas in national parks, in national rec- reation areas, and in national forests to give a full picture. b. Adjacent WSAs or wilderness areas of other agencies should be clearly shown on the individual WSA maps-they are not. 26.4 RESPONSE: The adjacent WSAs and existing and potential wilderness areas of other agencies are identified in Volume I Pocket Map No. 7, Cluster and Interagency Acres Alternative. Refer to the response to General Comment 26.2. On WSA-specific maps, contiguous, designated wilderness acres are identi- fied. 26.5 COMMENT: There are many inconsistencies in the Draft EIS maps. Volume I pocket maps do not agree with WSA Maps in Volumes II through VI. WSA maps do not match "official" maps located in each District Office. [Owen Severance] a. There are many inconsistencies in the EIS maps. Pocket Map No. 1 does not agree with the maps in Volumes II through VI, and there are discrepancies between those maps and the "official" maps in the Dis- trict Offices. On Pocket Map No. 1, WSAs 40 and 41 are shown as the No Action Alternative. In the text they are proposed as partial wilderness. WSA Nos. 3, 19, and 66 have less proposed wilderness than is shown on the map in the text. Obviously changes were being made in the Proposed Action during the time the EIS was being printed. How many more changes would have been included if more time had been available? An example of an incorrect map in the text is the Grand Gulch ISA Complex map. It does not agree with the "official" map in the District Office-two cherry- stemmed roads in the Polly's Mesa area have been left off the map in Volume V. How many other maps in the EIS are incorrect? b. One of the more interesting "official" maps in the Moab District Office is the Mexican Mountain WSA map. An area along the San Rafael River just north of Mexican Mountain is shown to be excluded from the WSA. This deletion does not appear on the SSA map or the WSA map in the EIS. It is shown only as part of the Partial Wilderness Alternative. Why? c. Last Tuesday I journeyed to Moab to check the accuracy of the WSA maps in Volumes V and VI at the District Office. The results were appalling: 16 out of 31 "official" WSA maps disagree with the maps in Vol- umes V and VI. In addition, the "official" maps do not show the boundaries for BLM's Partial Wilderness Alternatives (BLM has recommended partial wilder- ness for 31 of the 82 WSAs). Accurate Partial Wilder- ness Alternative maps are available only in the Re- source Area Offices! It is totally unreasonable for BLM to expect the public to go to every Resource Area Office to inspect the maps. BLM should have pro- vided accurate maps of all of the WSAs including accu- rate designations of the Partial Wilderness Alterna- tives. The WSA maps in Volumes V and VI that do not agree with the "official" maps in the Moab District include: 45 (partial), 46, 51, 55, 56, 57, 58, H, 60, 63, 64, 65, 68, 71, 59, and 70. Some of the differ- ences are major, while others are not as significant; however, all of them should have been corrected before the Draft EIS was printed. d. Pocket Map No. 1 is not correct in showing the BLM wilderness proposal. So far, I have found seven WSAs that have the wilderness proposal shown incor- rectly (3, 19, 20, 40, 42, 66, and 72). However, that is a fairly minor problem compared to the maps in the text of Volumes II through VI. Two of the three WSAs that I have checked so far have the boundaries 3 GENERAL COMMENTS AND RESPONSES SECTION 26: MAPS shown wrong on the map in the text— I visited the San Juan Resource Area Office to see the correct maps. In Volume V, the Grand Gulch map leaves out two cherry-stemmed ways in the Polly’s Island area and the Dark Canyon map incorrectly shows the WSA boundary running down the bottom of Fable Valley instead of along the rim. At the San Juan Resource Area Office I was told that the "official" maps are located in each District Office. This creates a major problem for me: how can I find out the correct WSA boundary proposals without driving all over the State? I need accurate maps in order to be able to make intelligent comments on the EIS. Most of the maps in the SSAs were unreadable, so they aren't any help. How are you going to help me (and other interested people) get accurate maps? Also, the WSA maps in the Draft EIS do not agree with the "official" maps in the Moab District Office (although the official maps are changed periodically so that may not be the case today-or next month). 26.5 RESPONSE: All maps in the Draft EIS have been reviewed and compared to maps in the BLM pub- lication "Intensive Wilderness Inventory, Final Deci- sion on Wilderness Study Areas," November, 1980, or against other maps published when WSAs were officially designated. Maps in the Final EIS have been revised, where necessary, to better reflect the above-named maps. Official maps in the Districts are much larger in scale and are, therefore, more pre- cise. However, as with the Final EIS maps, they re- flect the same boundaries identified when each WSA was officially designated. 26.6 COMMENT: The Draft EIS maps are of poor quality and are unreadable. [Michael Salamacha, Owen Severance, Ginny Taylor, et al.] a. Most of the maps in the SSAs were unreadable, so they aren’t any help. How are you going to help me (and other interested people) get accurate maps? b. Most maps are poorly reproduced and barely readable. c. Discrepancies and errors were the rule in the Draft EIS. Clarity never seemed to figure in much of the study, especially when trying to make heads or tails of the maps printed in the Draft EIS. than that they were poorly reproduced and contained discrepancies. As discussed in the response to Gener- al Comment 26.5, map discrepancies have been cor- rected in the Final EIS. All maps were also reviewed for clarity, and improvements were made when speci- fic maps were difficult to read. 26.7 COMMENT: BLM maps should present WSAs analyzed on their own merits, rather than pitted against other agency lands. [Utah Woolgrowers] None of the maps in Volume I show other agency lands, except the map of the All Wilderness Alterna- tive. This appears to be an attempt by BLM to create an impression that there is plenty of wilderness with- out BLM wilderness. The BLM WSAs should be ana- lyzed on their own merits, not pitted against other agency lands. All the maps should show only BLM wil- derness to be designed under that alternative. Those WSAs adjacent to other wilderness areas can be iden- tified verbally, but the maps present a biased picture as they were provided. 26.7 RESPONSE: Analyses of WSAs are based only on their particular wilderness qualities, resource values, and conflicts with other resources. The Clu- ster and Interagency Areas Alternative maps in Vol- ume I now include other agency proposed, designat- ed, or managed wilderness areas to inform the reader of BLM WSA locations relative to other agencies' proposals or management areas. Refer to the re- sponse to General Comment 26.2. 26.8 COMMENT: The name of the Fremont River was missing from maps showing the location of the Fremont River Gorge WSA. [National Park Service] 26.8 RESPONSE: The location of several streams and other bodies of water were inadvertently left off of several WSA maps. These errors have been cor- rected in the Final EIS. 26.6 RESPONSE: The comments do not identify why the Draft EIS maps were of poor quality other 4 BIBLIOGRAPHY - VOLUMES Vll-B AND Vll-C Bangerter, Governor Norman H. 1986. "Land Ex- changes" (personal communication). 1986. Office of the Governor, Salt Lake City, Utah. Beckman, R.T. and Kerns, W.H. 1965. Mercury in Utah. Information Circular 8252, U.S. Department of the Interior, Bureau Mines. Pages 352-357. Brown, G. Jr., and Mendelsohn, R. 1984. "Hedonic Travel Lost Method." Washington University. Caughley, C. 1979. "What is This Thing Called Carry- ing Capacity?" In North American Elk: Ecology Be- havior and Management. University of Wyoming, Laramie, Wyoming, pp. 2-8. Clyde, C.; Israelsen, E.; and Liu, W-K. 1979. A Resource Survey of Hydroelectric Power Potential in Utah and Southeast Idaho. UWRL/H-79/04, Utah Water Research Laboratory, Utah State University, Logan, Utah. Cordell, H. Ken and Hendee, John C. 1982. Renewable Resources Recreation in the United States; Supply. Demand, and Critical Policy Issues. August 1982. American Forestry Association, Washington, D.C. Council on Environmental Quality. 1986. "Regulations for Implementing the Procedural Provisions of the National Environmental Policy Act." July 1, 1986. Washington, D.C. Dalton, Michael J. 1982. Outdoor Recreation in Utah: The Economic Significance. Prepared for the Utah Division of Parks and Recreation. Department of Natural Resources, Salt Lake City, Utah. Dasmann, W.P. 1971. If Deer Are to Survive. Wildlife Management Institute, Washington, D.C. 128 pp. Davis Countv Clipper. 1987. "Sell State Land, Invest Money and Pay Off Debts?" (Editorial), April 30, 1987. Bountiful, Utah. Davis, B. L. 1959. "Petrology and Petrography of the Igneous Rocks of the Stansbury Mountains, Tooele County, Utah" in Brigham Young University Research Studies. Geology Series. Volume 6, No. 2. Brigham Young University, Provo, Utah. 56 pp. Davis, George D. 1987. Ecosystem Representation As Criterion For World Wilderness Designation. Wild Wings Foundation. (Document written for and present- ed at Fourth World Wilderness Congress). September 1987. Estes Park, Colorado. Eighty-Eighth Congress of the United States. 1964. Wilderness Act. Public Law 88-577. September 3, 1964. U.S. Government Printing Office, Washington, D.C. Environmental Research and Technology, Inc. (ERT) 1980. Kaiparowits Coal Development and Transpor- tation Study. August 1980. Prepared for the U.S. Department of the Interior, Bureau of Land Manage- ment, Salt Lake City, Utah. Harper, Kimball T. 1986. "Cryptogamic Plants and Ecology of Arid Wildlands." July 1986. (Unpublished Report). Brigham Young University. Jungst, Steven. 1978. Projecting Future Use of the National Forest Wilderness System. Cooperative Agreement 13-522 prepared for the U.S. Department of Agriculture, Forest Service, Rocky Mountain Experiment Station, Ft. Collins, Colorado. Lucas, Robert C. 1971. "Hikers and Other Trail Users" in Recreation Symposium Proceedings October 12-14, 1971, U.S. Department of Agriculture, Forest Service, Northeastern Forest Experiment Station. Lucas, Robert C. 1980. "Use Patterns and Visitor Characterstics, Attitudes and Preferences in Nine Wilderness and Other Roadless Areas." Research Paper INT-253. U.S. Department of Agriculture, Forest Service, Intermountain Forest and Range Experiment Station. Lucas, Robert C. 1985. The Management of Recrea- tional Visitors in Wilderness Areas in the United States. In: Bayfield, N.G.; Barrow, G.C., eds. The Ecological Impacts of Outdoor Recreation on Mountain Areas in Europe and North America. R.E.R.G. Report No. 9. Wye, England: Recreation Ecology Research Group: 122-136. 1 BIBLIOGRAPHY: VOLUMES Vll-B AND Vll-C Lucas, Robert C.; Schrauder, Hans T.; James, George A. 1971. Wilderness Use Estimation: A Pilot Test of Sampling Procedures on the Mission Mountains Primi- tive Area. Research Paper INT-109. Ogden, UT: U.S. Department of Agriculture, Forest Service, Inter- mountain Forest and Range Experiment Station. Lucas, Robert C.; Kovalicky, Thomas J. 1981. Self- issued wilderness permits as a use measurement system. Research Paper INT-270. Ogden, UT: U.S. Department of Agriculture, Forest Service, Inter- mountain Forest and Range Experiment Station, 18 p. Maser, Chris and Thomas Jack W. 1983, Wildlife Habitats in Managed Ranoelands-The Great Basin of Southeastern Oregon. Introduction. General Technical Report PNW-160, U.S. Department of Agriculture, Forest Service, Pacific Northwest Forest and Range Experiment Station, 15 pp. McCool, Stephen F. 1985, "Does Wilderness Designa- tion Lead to Increased Recreational Use?" in Journal of Forestry. January 1985. Meese, Edwin III. 1988. "Solicitor's Opinion Regarding Implied Reserved Wilderness Water Rights." July 28, 1988. Office of the Attorney General, Washington, D.C. Nickens, Paul R.; Larralde, Signa L.; Tucker, Gordon C. Jr. 1981 A Survey of Vandalism to Archaeological Resources in Southwestern Colorado. BLM Culture Resources Series 11, Denver, Colorado. Ninety-Third Congress of the United States. 1974. Colorado River Basin Salinity Control Act. Public Law 93- 320 (88 STAT.121 9). June 24, 1974, U.S. Government Printing Office, Washington, D.C. Ninety-Fourth Congress of the United States. 1976. Federal Land Policy and Management Act. Public Law 94- 579. U.S. Government Printing Office, Washington, D.C. Ninety-Eighth Congress of the United States. 1983. House Resolution 1214. February 2, 1983. U.S. Government Printing Office, Washington, D.C. Payne, John F. 1980. A Multi-Site Evaluation of Pinyon-Juniper Chaining in Utah. Master of Science Thesis, Utah State University. Peterson, Margaret. 1981. "Trends in Recreational Use of National Forest Wilderness." Research Note INT-319. August 1981. U.S. Department of Agricul- ture, Forest Service, Intermountain Forest and Range Experiment Station, Ogden, Utah. Rigby, E.K., (editor), 1958, "Geology of the Stans- bury Mountains, Tooele County, Utah" in Guidebook to the Geoloov of Utah. No. 13, Utah Geological Society, Salt Lake City, Utah. Russo, J. P. 1984, The Kaibab North Deer Herd. Game and Fish Department, Wildlife Bulletin 7. Phoenix, Arizona. 195 pp. Sorg, C.F.; and Loomis, J.B. 1987. Empirical Esti- mates of Amenity Forest Values; A Comparative View. U.S. Department of Agriculture, Forest Service, Ft. Collins, Colorado. Thomas, Jack Ward and Bell, Evelyn L. 1987, "Wild- life Habitat in Managed Forests: What To Think About While Chopping." In Western Wildlands. Spring. 7 pp. Tooker, E.W. and Roberts, R.E. 1971 "Structures Related to Thrust Faults in the Stansbury Moountains, Utah." Professional Paper 750-B, U.S. Department of the Interior, Geological Survey, pp. B1-B12. U.S. Department of Energy. 1987. Uranium Industry Annual. Washington, D.C. U.S. Department of the Interior, Bureau of Land Management. 1978. Wilderness Inventory Handbook: Policy. Direction. Procedures, and Guidance for Con- ducting Wilderness Inventory on the Public Lands. September 27, 1978. U.S. Government Printing Office, Washington, D.C. U.S. Department of the Interior, Bureau of Land Management. 1979. Interim Management Policy and Guidelines of Lands Under Wilderness Review. December 12, 1979. U.S. Government Printing Office, Washington, D.C. U.S. Department of the Interior, Bureau of Land Management. 1980a. Kanab-Escalante Grazing Management Environmental Impact Statement. U.S. Government Printing Office, Denver, Colorado. 2 BIBLIOGRAPHY: VOLUMES Vll-B AND Vll-C U.S. Department of the Interior, Bureau of Land Management. 1980b. BLM Intensive Wilderness Inventory: Final Decision. November 1980. U.S. Government Printing Office, Denver, Colorado. 404pp. U.S. Department of the Interior, Bureau of Land Management. 1981a. "Wilderness Management Policy." Federal Register Notice. September 24, 1981. U.S. Government Printing Office, Washington, D.C. and BLM Manual 8560. U.S. Department of the Interior, Bureau of Land Management. 1981b. "Escalante Planning Unit Management Framework Plan" (unpublished document). Escalante Resource Area, Escalante, Utah. U.S. Department of the Interior, Bureau of Land Management. 1982a. "Wilderness Study Policy: Policies, Criteria, and Guidelines for Conducting Wilderness Studies on Public Lands." Federal Register Notice. Vol. 47, No. 23. February 3, 1982. U.S. Government Printing Office, Washington, D.C. U.S. Department ot the Interior, Bureau of Land Management. 1982b. "Henry Mountain Management Framework Plan" (unpublished document), Henry Mountain Resource Area, Hanksville, Utah. U.S. Department of the Interior, Bureau of Land Management. 1982c. "Guide to Social Assessment" (unpublished). July 1982. U.S. Department of the Interior, Bureau of Land Management. 1983a. Grand Resource Management Plan. Grand Resource Area, Moab, Utah. U.S. Department of the Interior, Bureau of Land Management. 1983b. Final Henrv Mountain Grazing Management Environmental Impact Statement. May 1983, U.S. Government Printing Office, Denver, Colorado. U.S. Department of the Interior, Bureau of Land Management. 1984b. Utah Combined Hydrocarbon Leasing Regional Final Environmental Impact Statement. June 1984. U.S. Government Printing Office, Denver, Colorado. U.S. Department of the Interior, Bureau of Land Management. 1985. "Congressionally Required Wilderness Maps and Boundary Descripitions" (unpublished document). April 12, 1985. Washington Office, Washington, D.C. U.S. Department of the Interior, Bureau of Land Management. 1985c. Bureau of Land Management Utah Facts and Figures 1984, May 1 985. Utah State Office, Salt Lake City, Utah. U.S. Department of the Interior, Bureau of Land Management. 1985d. 1984 Public Land Statistics. Volume 169. August 1985. U.S. Government Printing Office, Washington, D.C. U.S. Department of the Interior, Bureau of Land Management. 1987a. Final Resource Management Plan and Environmental Impact Statement for the House Range Resource Area. October 1987. U.S. Government Printing Office, Denver, Colorado. U.S. Department of the Interior, Bureau of Land Management. 1987b. Final Resource Management Plan Environmental Impact Statement for the Warm Springs Resource Area. U.S. Government Printing Office, Denver, Colorado. U.S. Department of the Interior, Bureau of Land Management. 1988b. Environmental Assessment - Henrv Mountain Coordinated Resource Management Plan. August 1988. BLM Richfield District, Richfield, Utah. U.S. Department of the Interior, Fish and Wildlife Service, 1985. Federal Reoister/Volume 50, No. 188/Friday, September 27, 1985/Proposed Rules. Department of the Interior, Fish and Wildlife Service, 50 CFR Part 17 Endangered and Threatened Wildlife and Plants; Review of Plant Taxa for Listing as Endan- gered or Threatened Species. U.S. Department of the Interior, Fish and Wildlife Service, 1987. Federal Register/Volume 52, No. 208/Wednesday, October 28, 1987/Rules and Regula- tions. Department of the Interior, Fish and Wildlife Service, 50 CFR Part 17 Endangered and Threatened Wildlife and Plants; Final Rule Determining Asclepias welshii (Welsh's Milkweed) To Be a Threatened Species with Critical Habitat. U.S. Department of the Interior, Fish and Wildlife Service, 1989. Endangered and Threatened Wildlife and Plants. January 1, 1989 50 CFR 17.11 and 17.12 (special reprint). Publication Unit, U.S. Fish and Wildlife Service, Washington, D.C. U.S. Department of the Interior, U.S. Geological Survey. 1978. Ecosystems of the United States (Bailey-Kuchler Ecosystem Map). Reston, Virginia. 3 BIBLIOGRAPHY: VOLUMES Vll-B AND Vll-C U.S. Department of the Interior, U.S. Geological Survey. 1983. Geology-related Scenic Features, Kaiparowits Plateau, Utah. U.S. Geological Survey Miscellaneous Investigation Series. Map 1-033-K. U.S. Department of the Interior, U.S. Geological Survey. 1987. Mineral Resources of the Littlle Rockies Wilderness Study Area. Garfield Countv. Utah. U.S. Geological Survey Bulletin 1751-A, Denver, Colorado, U.S. Government Printing Office 1987. U.S. Department of the Interior, National Park Service. 1982. The Nationwide Rivers Inventory. Washington, D.C. U.S. Department ot the Interior, National Park Service. 1984a. Preliminary Assessment for Wilderness Study Areas Contained in H.R. 1214. Arches National Park. Capitol Reef National Park- Dinosaur National Monument. Great Sand Dunes National Monument. Zion National Park: Colorado and Utah. July 1984. Rocky Mountain Regional Office, Denver, Colorado. U.S. Department of the Interior, National Park Service and Bureau of Land Management. 1984b. Tar Sand Triangle Environmental Impact Statement. July 1984. U.S. Department of the Interior, National Park Service and Bureau of Land Management, 1985. Boulder-Bullfrog Road Environmental Assessment. May 1985. Utah Department of National Resources and Energy, Outdoor Recreation Agency. 1980. Utah Outdoor Recreation Plan. 1980 SCORP. Salt Lake City, Utah. Utah Office of Planning and Budget, 1987. 1 987 Baseline Projections. April 1987, Salt Lake City, Utah. Welsh, Stanley L.; Atwood, N. Duane; Goodrich, Sherel; and Higgins, Larry C. 1987. A Utah Flora Great Basin Naturalist Memoirs No. 9, 1987, Brigham Young University, Provo, Utah. Williams, G.; Gifford, G.F.; and Colthorp, G.B. 1972. Factors Influencing Infiltration and Erosion on Chained Pinyon-Juniper Sites in Utah. J. Range Management. 25:201-205. 4