The Honorable Ryan Zinke
Secretary of the Interior
U.S. Department of the Interior
1849 C Street, N.W.
Washington DC 20240
RE: Review of the Bears Ears National Monument, Utah
Dear Secretary Zinke:
Please accept this correspondence as comments from the Trails Preservation Alliance (TPA) with regard to the review of the National Monument designation for the Bears Ears National Monument in Utah.
The TPA is a volunteer organization whose mission is to be a viable partner, working with the United States Forest Service (USFS) and the Bureau of Land Management (BLM) to preserve the sport of multiple-use trail riding. The TPA acts as an advocate of the sport and takes the necessary action to insure that the USFS and BLM allocate for trail riding to receive a fair and equitable percentage of access to public lands. The TPA stands in unity with our partner organization, Ride with Respect in Utah and fully and completely supports their comments regarding the inappropriate designation of the Bears Ears National Monument.
From its inception, the Bears Ears monument proposal has been a lose-lose for all stakeholders. The Antiquities Act states that monuments “shall be confined to the smallest area compatible with proper care and management of the objects to be protected.” Nationwide, the acreage not already proclaimed as a monument or other protective designation is shrinking; yet the acreage added to the national-monument system has grown in recent administrations.
Hoping to capitalize on this trend, wilderness expansion groups seeking to greatly expand wilderness and de facto designations sabotaged a precious opportunity to resolve public-land disputes more collaboratively. Unfortunately the wilderness-expansion groups’ gamble paid off, as the Obama administration adopted most of the Bears Ears proposed acreage. However, it didn’t pay off for our Native Americans, as the Bears Ears proclamation offers the tribes no more substantive influence than they already had. We are now left with a monument that goes far beyond the antiquities surrounding Cedar Mesa to cover most of the Abajo Mountains with its talus slopes, and most of western San Juan County all the way up to the outskirts of Moab. Monument proponents praise Bears Ears NM for being merely 70,000 acres larger than the Utah Public Lands Initiative’s (UPLI) Bears Ears and Indian Creek National Conservation Areas (NCA’s). However, 70,000 acres equates to over a hundred square miles, and it includes the upper Indian Creek motorized singletrack, Shay Mountain, and Gooseberry ATV trail, all of which have been cared for by our partner organization, Ride with Respect. Further, the UPLI proposed NCA’s with more inclusive management than a monument. For OHV trail riders, the NCA’s would have effectively provided no net loss of recreational opportunity by limiting travel planning to temporarily close or permanently relocate routes on an as-needed basis. Above all, the UPLI proposed many other benefits beyond these NCA’s to provide balance. Rather than legitimizing the Bears Ears National Monument, the fact that the UPLI offered millions of acres of additional protections (with modest gains for recreation and development in other areas) only makes this latest monument all the more offensive.
Instead of assuming the motives of wilderness-expansion groups, we’ll share with you our view and that of our partner Ride with Respect. Bears Ears NM has actually steamrolled conservationists who prefer a diplomatic approach, it has discouraged multiple-use advocates from future collaboration, it has damaged relationships within Native American and other communities, and it has alienated the people who live closest to the land. We can’t blame San Juan County for recommending that Bears Ears NM be rescinded altogether. For one thing, rescinding monuments may be the only way to get wilderness-expansion groups to meaningfully negotiate. For another thing, since passage of the Antiquities Act, subsequent laws have already bolstered the protection of cultural resources. Western San Juan County had faced no overwhelming, imminent threats. Cultural sites can be effectively preserved by the BLM with its cooperating agencies such as tribes and counties, provided adequate support. It simply takes proactive management, as Ride with Respect has managed to do with a meager budget on OHV trails.
Despite that no monument is needed to protect the Bears Ears area; both the TPA and Ride with Respect have a bias toward resolving controversy. We recognize that areas surrounding Cedar Mesa contain many cultural sites of significance. Therefore, while we recommend releasing most of the current acreage from Bears Ears National Monument, the TPA and Ride with Respect supports monument status for those areas that the Antiquities Act was truly designed to preserve. Upon releasing acreage from monument status, we hope you will implore Congress to pass a bill with more appropriate designations for the many other areas like Indian Creek that deserve additional protections in San Juan County and preferably the entire state of Utah. Like the UPLI, the bill should also benefit recreation and development interests in terms of providing longevity. Just as preservation advocates deserve to know that their gains won’t be stripped by a future president, recreation and development interests would need to know that their gains won’t be jeopardized by another monument proclamation. So long as the threat of unilateral mega-monuments looms, public-land disputes will worsen, and our nation will suffer.
Whether people are of Native American or other heritage, we respect the wide range of opinions about Bears Ears National Monument so long as they are grounded by truth. Unfortunately, the majority of pro-monument comments are based on profound misunderstandings about how the land is managed. Even more unfortunate is the fact that wilderness-expansion groups deliberately propagate this misinformation along with their proxies, which include masquerading sportsman groups. For example, the Southern Utah Wilderness Alliance insists that “Bears Ears rectifies a history of racism towards the tribes” even though its lack of co-management actually repeats a history of false promises made to Native Americans. Just today, a Facebook post sponsored by The Wilderness Society claims “URGENT: The Trump administration is threatening to shrink more than 20 national monuments including Bears Ears and Grand Staircase-Escalante National Monuments. Speak now! Once they’re lost, they’re gone forever.” As a result, the well-meaning public writes letters opposing the loss of these places as if they’ll be privatized, strip mined, developed, or somehow dropped off the face of the earth. Although such letters are based on sincere concern, they are undermined by a false premise. Therefore it is key for you to prioritize comments that are in touch with reality, whether they support or oppose the Bears Ears National Monument.
In reality, responsible OHV access is frequently under attack, and monument designations have historically added another “hammer” for preservationists to wield. Even in BLM-managed monuments like Grand Staircase and Canyons of the Ancients, OHV riders have had to fight for the existing roads, let alone trails. If those who peddled for Bears Ears are any indication, this monument would be more of the same. The National Parks Conservation Association urged closing Lockhart Basin 4WD road to all vehicles that are not registered for highway use, which would exclude all ATV’s. Utah Dine Bikeyah endorsed designating the majority of western San Juan County as wilderness, which excludes all motorized and even mechanized use. The Bears Ears Inter-Tribal Coalition recommended the monument proclamation to limit all motorized use to roads, only.
More importantly, the Bears Ears campaign was intended to be a short cut, but it wound up causing deep wounds in southeast Utah. Spending over twenty million dollars, the campaign certainly won over some people. Backed by the same people who orchestrated Grand Staircase-Escalante National Monument, the Conservation Lands Foundation created Utah Dine Bikeyah and funded the Bears Ears Inter-Tribal Coalition. The Grand Canyon Trust alone has spent millions of dollars on its “Native America education” project. While aspects of it may be commendable, the thrust appears to be pushing Bears Ears upon San Juan County with an utter disregard for its residents. This cannot provide a foundation for healing among cultures, as the Bears Ears campaign purports. We sincerely hope that some of these aspirations can be realized through a more inclusive process.
To promote a more thorough process for Congress, the new administration could help by tempering some of the quick fixes that got us into this mess in the first place. When formulating the Bears Ears campaign, wilderness-expansion groups stated, “The more land the better.” In response, many other stakeholders are now calling to rescind Bears Ears National Monument, and to take further steps. To deescalate the situation, scaling the monument back to reflect its outstanding objects of antiquity is the right thing to do for this land and its people.
Director of Operations
Trails Preservation Alliance