November 9, 2015 82 East Dogwood fileNovember 9, 2015 Lance Porter District Manager, Canyon Country...

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November 9, 2015 Lance Porter District Manager, Canyon Country District Bureau of Land Management 82 East Dogwood Moab, Utah 84532 RE: Comments on the Moab MLP/DEIS Dear Mr. Porter: We commend the U.S. Bureau of Land Management for the hard work, smart thinking, and collaboration that has gone into the Moab Master Leasing Plan. The effort has clearly paid off, and the BLM is on the road to striking the right balance between the protection of outdoor recreation resources and responsible energy development on public lands in the Moab area. Based in Boulder, Colo., with offices in Washington, D.C., Outdoor Industry Association is the leading trade association for the outdoor industry and the title sponsor of Outdoor Retailer. OIA supports the growth and success of more than 4,000 employees of manufacturers, distributors, suppliers, sales representatives and retailers of outdoor recreation apparel, footwear, equipment and services. The BLM’s work on the draft Moab plan is critical given the importance that outdoor recreation plays in the economy for both Moab and the state of Utah. Every year, consumers in Utah spend upwards of $12 billion on outdoor recreation activities alone. This spending, in turn, provides more than $3.5 billion in annual wages and salaries and directly supports more than 120,000 jobs. Additionally, consumer spending on outdoor recreation in Utah generates more than $850 million in tax revenue for state and local governments. Further, the National Parks and other public lands in Utah, including those subject to this Plan, form the backbone of the state’s vibrant outdoor recreation economy. National Parks provide approximately $1 billion in economic output every year for Utah, and Arches and Canyonlands—the two Parks bordering the planning area— together generate nearly $150 million. Additionally, BLM lands in Utah provide another $70 million in annual economic output related to outdoor recreation activities. Utah Gov. Gary Herbert has called for increasing investment in the outdoor recreation and tourism economy as a way to boost state revenues from $1 billion to $1.2 billion by 2020. Given the strength and resilience of the outdoor recreation industry, that’s

Transcript of November 9, 2015 82 East Dogwood fileNovember 9, 2015 Lance Porter District Manager, Canyon Country...

Page 1: November 9, 2015 82 East Dogwood fileNovember 9, 2015 Lance Porter District Manager, Canyon Country District Bureau of Land Management 82 East Dogwood Moab, Utah 84532 RE: Comments

November 9, 2015 Lance Porter District Manager, Canyon Country District Bureau of Land Management 82 East Dogwood Moab, Utah 84532 RE: Comments on the Moab MLP/DEIS Dear Mr. Porter: We commend the U.S. Bureau of Land Management for the hard work, smart thinking, and collaboration that has gone into the Moab Master Leasing Plan. The effort has clearly paid off, and the BLM is on the road to striking the right balance between the protection of outdoor recreation resources and responsible energy development on public lands in the Moab area. Based in Boulder, Colo., with offices in Washington, D.C., Outdoor Industry Association is the leading trade association for the outdoor industry and the title sponsor of Outdoor Retailer. OIA supports the growth and success of more than 4,000 employees of manufacturers, distributors, suppliers, sales representatives and retailers of outdoor recreation apparel, footwear, equipment and services.

The BLM’s work on the draft Moab plan is critical given the importance that outdoor recreation plays in the economy for both Moab and the state of Utah. Every year, consumers in Utah spend upwards of $12 billion on outdoor recreation activities alone. This spending, in turn, provides more than $3.5 billion in annual wages and salaries and directly supports more than 120,000 jobs. Additionally, consumer spending on outdoor recreation in Utah generates more than $850 million in tax revenue for state and local governments. Further, the National Parks and other public lands in Utah, including those subject to this Plan, form the backbone of the state’s vibrant outdoor recreation economy. National Parks provide approximately $1 billion in economic output every year for Utah, and Arches and Canyonlands—the two Parks bordering the planning area—together generate nearly $150 million. Additionally, BLM lands in Utah provide another $70 million in annual economic output related to outdoor recreation activities. Utah Gov. Gary Herbert has called for increasing investment in the outdoor recreation and tourism economy as a way to boost state revenues from $1 billion to $1.2 billion by 2020. Given the strength and resilience of the outdoor recreation industry, that’s

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wise advice. However, to grow the recreation economy in Utah, business owners and manufacturers need to have certainty that these recreation opportunities will be there tomorrow in order to make investments today. The work that BLM is forging on the draft Moab plan can be a model for how different interests can work together to find win-win solutions and provide certainty to both outdoor recreation businesses and oil and gas companies. These economic figures and goals illustrate an important reason why the Moab plan must provide adequate protections for recreational resources: to protect Utah’s robust outdoor recreation economy. While we believe the Moab Master Leasing Plan is headed in the right direction, we would also like to offer-up support for a few important changes from the draft plan that would help ensure strong protections for Moab’s outdoor recreation resources, including:

o broadening or lengthening energy development setbacks around developed recreation sites such as overlooks, viewpoints, campgrounds, and trailheads.

o providing or applying setbacks to protect key recreation routes, including

hiking trails and climbing and canyoneering areas; and o strengthening protections along the Green River and Colorado Rivers, and

improve protections for their tributaries and connected water bodies, to ensure that water quality and scenic values will not be compromised by energy development.

Again, we applaud the BLM for the great work to date in development the Moab Master Leasing Plan. With a few changes, we are confident that the final plan can and should protect the most valuable outdoor recreation resources in the planning area, while still allowing for responsible energy development. Thank you for considering our comments. Sincerely,

Jessica Wahl Outdoor Recreation Advisor Outdoor Industry Association

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RECREATION STAKEHOLDERS

November 11, 2015

Lance Porter District Manager, Canyon Country District Bureau of Land Management 82 East Dogwood Moab, Utah 84532

RE: Moab Master Leasing Plan DEIS Recommendations

Dear Mr. Porter:

As representatives of the undersigned organizations and businesses, we ask you to accept our comments on the Moab Master Leasing Plan (MLP) and Draft Resource Management Plan (RMP) Amendments/Draft Environmental Impact Statements (EIS) for the Moab and Monticello Field Offices.

We commend the planning team for their efforts to preserve and protect motorized and non-motorized recreation opportunities in the course of managing oil, gas, and potash development in the project area.

We believe that Alternative D (the agency preferred alternative) provides a substantive foundation for managing both the destination/casual-use recreation and resource industry needs of the area.

However, we believe that Alternative D should be modified by enhancing the site-specific analysis component as it relates to energy/mineral project impacts to destination and/or important motorized and non-motorized recreation facilities.

ENHANCED RECREATION ANALYSIS Develop a decision matrix for the proposed "No Surface Occupancy" (NSO) stipulations for developed recreation sites, such as overlooks/viewpoints, campgrounds, and trailheads. Decisions should be made on a site-specific basis using criteria and mitigations to address; direct, sound, or visual impacts, conflicts between recreation traffic with industrial vehicles, conversion of recreation routes to “haul” roads, line-of-site vs. topographical based buffers, and post-project restoration of commercial routes back to recreation routes. NSO buffers could extend up to a 2-mile setback.

Apply up to a 1-mile NSO setback from key routes, trails, climbing, canyoneering, and filming location based on site specific analysis using aforementioned decision matrix criteria/mitigation.

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"Special recreation management areas" and related "focus areas" should have an additional layer of NSO-related analysis and setback parameters before permitting a resource industry project.

Clarify in the Record of Decision (ROD) that “NSO” does not apply to recreation projects so as to avoid confusion in subsequent site-specific planning efforts.

With the inclusion of our suggested Enhanced Recreation Analysis, recreational interests should be properly protected. Therefore, many of the more restrictive measures placed on locating resource development in Alternative D become unnecessary and the modification to Alternative D should lessen these restrictions.

We believe our recommendations will help the final plan protect both the recreation and extractive industry-based economy in the Greater Grand County Area.

We look forward to working with the agency on this project.

Sincerely, Don Amador Western Representative BlueRibbon Coalition, Inc.

Bob Humphreys, President Mike Kelso, Vice President Red Rock 4 Wheelers

Jeff Stevens, President Moab Friends For Wheelin'

Clif Koontz, Executive Director Ride with Respect

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November 13, 2015 Lance Porter District Manager, Canyon Country District Bureau of Land Management 82 East Dogwood Moab, Utah 84532 RE: Moab Master Leasing Plan DEIS Recommendations Dear Mr. Porter: We greatly appreciate all of the work that has gone into the creation of the Bureau of Land Management's (BLM) draft Master Leasing Plan (MLP) to manage oil, gas and potash development and to protect recreation resources on public lands in and around Moab. We support the draft MLP and view the plan as a critical tool for protecting the recreation economy of the Moab area while simultaneously allowing new oil, gas, and potash development in appropriate places. The Moab MLP will bring a new level of certainty to local and regional businesses that rely on the recreation economy as well as to oil, gas, and potash companies interested in resource extraction in the Moab area. We understand that the MLP will not affect valid and existing leases and that some 24 percent of the MLP area is already leased. Accordingly, we have the following requests to protect and further enhance recreation experiences in the MLP planning area that will not materially affecting existing or future mineral lease revenues:

• Broaden the proposed "No Surface Occupancy" (NSO) stipulations for developed recreation sites, such as overlooks/viewpoints, campgrounds, and trailheads, to a 2-mile setback (Please see attached list).

• Apply a 1-mile NSO setback from key routes, trails, climbing, canyoneering, and filming locations. (Please see specific routes below.)

• Apply an NSO stipulation to all "special recreation management areas" and re -lated "focus areas." (Listed below.)

• Increase Protection along the Green River for recreation opportunities, water quality, scenic values, and archeological resources by focusing development out-side Upper Ten Mile (east of the wash), Labyrinth Canyon and tributaries to the Green River at Red Wash, and Hatch Point.

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• Protect both the Green and the Colorado Rivers for water quality and recre -ation activities by requiring development companies to apply best management practices throughout the Moab MLP planning area and apply an NSO stipulation to preclude mineral activities within public water reserves, 100-year floodplains and within 660 feet of intermittent and perennial streams, rivers, riparian areas, wetlands, water wells, and springs.

A strong Moab MLP that protects recreation resources on public lands is critical to 45 percent of all jobs in Grand County and our more than $200 million local tourism and outdoor recreation economy. We support your work on this important detailed planning process. Our businesses de-pend on the recreation assets within the MLP area and we believe the MLP is the best way to enhance and maintain both resource extraction and the recreation economy of the region. Sincerely, Adventure Inn Jim Schwalen Moab, UT

AP Tech Services Ann Perri Moab, UT

Avid4 Adventure David Secunda Boulder, CO

Back of Beyond Books Andy Nettell Moab, UT

Black Diamond Peter Metcalf Salt Lake City, UT

Cali Cochitta Bed and Breakfast Kim Boger Moab, UT

Chile Pepper Bike Shop Tracy Reed Moab, UT

Canyon Voyages Don and Denise Oblak Moab, UT

Colorado River and Trail Expeditions Vicki Mackay Fredonia, AZ

Community Rebuilds Emily Niehaus Moab, UT

Deep Desert Expeditions Mike Coronella Moab, UT

Eklecticafe Julie Fox Moab, UT

The Edge Gallery Bret Edge Photography Moab, UT

Escape Adventures Jared Fisher Las Vegas, NV

Far Out Adventures Vaughn Hadenfelt Bluff, UT

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Gonzo Inn Michael Badger Moab, UT

Gouldings Lodge and Tours Ronnie Baird Monument Valley, UT

Grand Properties, LLC Jana Wilson Moab, UT

Hauer Ranch Sena Hauer Moab, UT

Hermosa Tours Matt Mc Fee Durango, CO

Holiday River Expeditions Tim Gaylord Green River, UT

Impermanent Sangha Wilderness Retreats Johann Robbins Estes Park, CO

Jackson Hole Mountain Guides -Moab Branch Phil Powers / Rob Hess Jackson, WY and Moab, UT

Jail House Cafe Will Petty Moab, UT

Lost River Trading Company, Inc. Dave Knowles Moab, UT

Love Muffin Café Wes Shannon Moab, UT

Matt Olding Consulting Matt Olding Moab, UT

Magpie Cycling Maggie Wilson Moab, UT

Mavic, USA Aaron Walker Ogden, UT

Miguel’s Baja Grill Dave Bodner Moab, UT

Milts Stop & Eat BC Laprade Moab, UT

Moab Barkery Kay Davis Moab, UT

Moab Adventure Center Jason Taylor Moab, Utah

Moab Cyclery Jacques Hadler Moab, UT

Moab Desert Adventures Nathaniel Sydnor Moab, UT

Moab Destination Man-agement Fiona Raison Moab, UT

Moab Half Marathon Ranna Bieschke Moab, UT

Moab Photo Tours, LLC Jon Fuller Moab, UT

Moab Photography Sym-posium Bruce Hucko Moab, UT

Moab Realty Judy Powers Moab, UT

Moab Springs Ranch McKay Edwards Moab, UT

Moab Yoga Angela Houghton Moab, UT

Moab Trail Marathon Danelle Ballengee Moab, UT

Nichols Expeditions Chuck and Juday Nichols Moab, UT

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North Idaho College Paul Chivvis CDA, ID

The O.A.R.S. Family of Companies Concessioner: Canyonlands National Park George Wendt Angels Camp, CA

Oneway Boatworks Herm Hoops PO Box 1234 Jensen, UT

Outerbike Mark Sevenoff Moab, UT

Petzl America Nazz Kurth Clearfield, UT

Poison Spider Bicycles Scott Newton Moab, UT

Quintstar JJ Wang Moab, UT

Recapture Lodge Jim and Luanne Hook Bluff, UT

Red Desert Adventures Springdale, UT

Red River Adventures Carl Dec Moab, UT

Red Rock Astronomy Alex Ludwig Moab, UT Resmark Systems Jamie Pearce Salt Lake City, UT

Rim Tours Matt Hebberd / Kirstin Pe-terson Moab, UT

Sabaku Sushi Alex Borichevesky Moab, UT

Salt Lake City Bicycle Company Brent Hulme Salt Lake City, UT

Skinny Tire Events LLC Beth Logan Moab, UT

Sloan Law Firm, PLLC Christina Sloan Moab, UT

Soar Communications Chip Smith Salt Lake City

Solfun Mike Holmes Moab, UT

Storm Cycles Todd Henneman Park City, UT

The Neighborhood Suites Helen Boyer, Drake Taylor, Brian Lugers, Jenna Wood-bury 543 Nichols Lane Moab, UT

Tom Till Photography Marcy Till 61 North Main Moab, UT

Treasure Mountain Inn Andy Beerman 255 Main Street Park City, UT

Trek Travel Tania Burke Madison, WI

TMI Gear Rock Thompson Salt Lake City, UT

ULA Equipment Chris McMaster Logan, UT

Up the Creek Campground Center Street Suites Kimberly Schappert Moab, Utah

Waterpocket Press Chad Niehaus Moab, UT

Western River Expeditions Brian Merrill Salt Lake City, UT

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Western Spirit Cycling Ashley Korenblat Moab, UT

Dr. Lionel E Weeks Director of Surgery Moab Regional Hospital Moab, Utah

White Horse Development, LLC Mark Griffith Moab, UT

Windgate Adventures Eric Odenthal Moab, UT

With Gaia Design Kalen Jones Moab, UT

World Wide River Expedi-tions Nicki Hazlett Moab, UT

CC: Governor Gary Herbert, Secretary of Interior Sally Jewell

Attachments: Developed Recreation Sites 2-mile NSO set-back from the following developed recreation sites: Amasa Back Trailhead Anticline Overlook Bartlett Campground Big Bend Campground Overflow Big Bend Recreation Site Blue Hill Trailhead Bridger Jack Mesa Camping Area Canyon Rims Entrance Area Canyonlands Overlook Cliffline Interpretive Site Copper Ridge Dinosaur Tracks Trailhead Corona Arch Trailhead Courthouse Rock CG & Mill Canyon Dinosaur Trackway Cowboy Camp Camping Area Creek Pasture Camping Area Dewey Bridge Recreation Site Donnelly Canyon Day Use Area Drinks Canyon Recreation Site Fisherman's Point Beach Access Gold Bar Campground Hal Canyon Campground Hamburger Rock Campground Hatch Point Campground Horsethief Campground Hunter's Canyon/Spring Camping Area Indian Creek Falls Group Campsite Jaycee Park Campground & Portal Trail Kane Creek Trailhead Kings Bottom Campground Ledge Campground Loop

Ledge Campground Loop Ledge Group Area Lone Mesa Group Sites, A, B, C, D, E Lone Mesa Viewpoint Looking Glass Rock Interp. Site Lower Gemini Bridges Trailhead (Private) Mill Canyon Dinosaur Trailhead Mineral Bottom River Access Minor Overlook Moab Brand Trails Mountain Bike Trailhead Moab Rim Trailhead Monitor and Merrimac Trailhead Monitor and Merrimac Viewpoint Moonflower Canyon Camping Area Needles Overlook Newspaper Rock Oak Grove Campground Plateau Viewpoint Poison Spider Mesa Trailhead Potash Boat Ramp Sandy Beach River Access Shay Mountain Vista Superbowl Campsite Takeout Beach River Access Trough Springs Canyon Trail Trailhead Upper Big Bend Camping Area White Wash Campground and Trailhead William's Bottom Camping Area Wilson Arch Windwhistle Campground

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Key Routes, Sites and Filming Locations 1-mile NSO set-back from the following motorized and non-motorized routes and trails, climbing, canyoneering sites, and filming locations:

Klondike Bluffs bicycle trails Bar M bicycle trails Porcupine Rim trail Magnificent Seven/7 Up bicycle trail systems Ahab bicycle trails Lower Monitor and Merrimac bike trail Kokopelli's Trail Hunter Canyon hiking trail Jeep Routes Metal Masher (Arth's Rim) jeep route Gold Bar Rim jeep route Golden Spike jeep route Poison Spider jeep route Cliffhanger jeep route Chicken Corners jeep route Top of the World jeep route Moab Rim jeep route Behind the Rocks jeep route Kane Creek jeep route Lockhart jeep route Seven Mile Rim jeep route Secret Spire jeep route Jug Rock Equestrian Trail System Jewel Tibbets hiking trail Trough Springs hiking trail Climbing & Canyoneering Indian Creek Wall Street

Ice Cream Parlor The Tombstones of Kane Creek Needle Rock (Tombtone) Long Canyon/Day Canyon/Culvert Canyon Cameltoe Canyon Granary Canyon Rock of Ages Repeat Junior Winter Camp Slot Filming Needles Overlook Colorado River corridor and Corona Arch Green River Canyon Kane Creek corridor Looking Glass Rock View from Dead Horse Point Potash Road/Shafer Basin (including Fossil Point) Long Canyon Highway 211 (including Newspaper Rock) Highway 313 Monitor and Merrimac/Determination Towers/Mill Canyon Gemini Bridges Jewell Tibbetts Arch White Wash

Special Recreation Management Areas NSO stipulation applied to all SRMA and Focus Areas:Canyon Rims SRMA Colorado Riverway SRMA Labyrinth Rims/Gemini Bridges SRMA South Moab SRMA Indian Creek SRMA Dolores River Canyons SRMA Hatch Wash Hiking and Backpacking Focus Area Needles and Anticline Roads Focus Area (Utah Scenic Backways) Bar M Mountain Biking Focus Area Bartlett Slickrock Freeride Mountain Bike Focus Area Gemini Bridges/Poison Spider Mesa

Focus Area Goldbar/Corona Arch Hiking Focus Areas Klondike Bluffs Mountain Biking Focus Area Labyrinth Canyon Canoe Focus Area Mill Canyon/Upper Courthouse Mountain Biking Focus Area Mineral Canyon/Horsethief Point Competitive BASE Jumping Focus Area Seven Mile Canyons Equestrian Focus Area Spring Canyon Hiking Focus Area Tusher Slickrock Mountain Biking Focus Area Behind the Rocks Hiking Focus Area 24 Hours of Moab Mountain Biking Focus Area

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November 12, 2015 Lance Porter District Manager, Canyon Country District Bureau of Land Management 82 East Dogwood Moab, Utah 84532 RE: Public Land Solutions Comments to Moab Master Leasing Plan Draft Environmental

Impact Statement Dear Mr. Porter: Public Land Solutions welcomes this opportunity to comment on the Moab Master Leasing Plan (MLP) Draft Environmental Assessment (DEIS). Public Land Solutions is a non-profit organization dedicated to providing comprehensive recreation planning and stakeholder coordination to support effective and sustainable public land solutions. We have been involved at the local, regional and national level during every step of this MLP planning process, including organizing stakeholder workshops, providing comments and proposed maps during the Bureau of Land Management’s (BLM) preliminary alternatives comment period, providing presentations to local and state government, and communicating with a wide range of stakeholders interested in this project. Through this entire project we have sought to find a balanced approach for multiple uses in the Moab MLP planning area while advocating for protecting and enhancing Moab’s world-class recreation assets that attract visitors from all over the world and support our thriving regional economy. Public Land Solutions greatly appreciates all of the work that has gone into the creation of the BLM’s draft MLP to manage oil, gas and potash development and to protect recreation resources on public lands in and around Moab. We support the draft MLP and view the plan as a critical tool for protecting the recreation economy of the Moab area while simultaneously allowing new oil, gas, and potash development in appropriate places. The Moab MLP will bring a new level of certainty to local and regional businesses that rely on the recreation economy as well as to oil, gas, and potash companies interested in resource extraction in the Moab area. Public Lands Fuel a Thriving Outdoor Recreation Economy in Moab Public lands are big business for Moab’s outdoor recreation economy. Two of the nation’s most iconic national parks—Arches and Canyonlands—are local to Moab and bring thousands of visitors each year into Utah. Moab’s main street is bustling with visitors that have come to enjoy a broad range of recreation opportunities on lands that surround the parks including jeeping, hiking, mountain biking, climbing, and river running. In order to maintain a healthy, thriving, and diverse local economy in Moab, the BLM must protect recreation assets on and access to public lands. By enacting this MLP we can protect our parks and public lands that drive our diverse outdoor recreation economy while ensuring oil and gas drilling occurs responsibly and in the right places.

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From visiting Arches and Canyonlands to biking the Slickrock Trail or rafting the Green River, opportunities abound to enjoy the Moab area’s great outdoors. By attracting hundreds of thousands of visitors, public lands pump money into the local economy, sustain businesses, and create jobs. Small businesses thrive in Moab because public lands present world-class recreation opportunities at places such as Castle Valley, the Colorado River Corridor, Gemini Bridges, and Indian Creek. The stunning landscapes of Arches and Canyonlands National Parks are critical economic drivers for the local economy: according to a National Park Service report (http://bit.ly/1hCdECx), in 2013 national parks in the Moab area saw more than 1.5 million visits and generated over $146.5 million in direct spending. The BLM can be a good neighbor and protect these parks through this MLP by ensuring that responsible oil and gas development and mining occurs in the right places. Tourists and travelers spent a record $7.5 billion in the Utah economy during 2013, generating a record $1.02 billion in total state and local tax revenues. Recreation activities on BLM’s public land in Utah generated at least $70.4 million in economic activity in 2011 and accounted for over 900 jobs. Travel, tourism, and recreation account for 47 percent of all private employment in Grand County. About two thirds of Grand County residents say public lands are “extremely important” to their business, and over a third of families have a family member who works in tourism or recreation related a business tied to public lands. Recreation and tourism creates permanent jobs for the Moab area. Tourism and recreation produce more revenue than drilling and mining in Grand County. In 2013, oil and gas drilling generated less than 10% of county revenues. Moreover, as we found out in the latest recession (and more recently with the price of oil below $50/barrel), the oil and gas and mining industry is subject to booms and busts and local communities can’t depend on those jobs over the long run. On the other hand, Grand County’s tourism and recreation economy held strong during the recession. The tourism and recreation industry creates permanent jobs—not jobs that can be eliminated or outsourced due to variation on commodity prices. Other economic sectors are also growing along with tourism and recreation as a result of Grand County’s public lands and high quality of life. From 2001 to 2013 Grand County employment grew significantly in several areas that include high paying jobs: finance and insurance (+61%), health care (+56%), and professional and technical services (+32%)—all grew faster than the overall increase in employment (+25%). Along with tourism and recreation, these economic sectors are thriving because of the proximity of high quality natural landscapes in the Moab area, many of which provide unsurpassed opportunities for outdoor recreation. The Moab Master Leasing Plan Strikes the Right Balance Between Providing Resource Extraction Opportunities and Protecting Important Recreation Assets This Moab MLP project represents a model effort for how local communities can work with land managers to strike the right balance between energy development and the protection of public lands and a robust outdoor recreation economy. For example, in 2014 the Moab community stepped-up to work with BLM and held several stakeholder meetings that included a wide array of stakeholders. This work helped BLM identify where there is conflict between uses and where there is agreement. The BLM and everyone from the state director to the head of BLM to Interior Secretary Sally Jewell herself have participated in theses stakeholder conversations. With this planning process the BLM has set the right course by fostering collaboration, recognizing the need to strike a balance, and creating a bottom-up approach to land management. The foundation has

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been built to create a plan that will benefit conservationists, the outdoor recreation and tourism industry, the oil and gas industry, and other local stakeholders. Public Land Solutions Recommendations to Improve Draft Moab Master Leasing Plan We understand that the Moab MLP will not affect valid and existing leases (nor state and private lands) and that existing mineral lease revenue to local government will continue; some 24 percent of the MLP area is already leased and only about 40 percent of those leases are actually developed. Accordingly, existing leases will continue to produce oil and gas via the extensive unit agreement on the Big Flat area north of Moab for decades to come. And those mineral lease revenues will continue as long as the resource holds out. However, a strong Moab MLP that protects recreation resources on public lands outside of these leases is critical to 45 percent of all jobs in Grand County and our more than $200 million local tourism and outdoor recreation economy. Accordingly, we have the following requests to protect and further enhance recreation experiences in the MLP planning area: • Broaden the proposed “No Surface Occupancy” (NSO) stipulations for developed recreation sites,

such as overlooks/viewpoints, campgrounds, and trailheads, to a 2-mile setback (Please see attached list).

• Apply a 1-mile NSO setback from key routes, trails, climbing, canyoneering, and filming locations. (specific routes listed below.)

• Apply an NSO stipulation to all special recreation management areas and related focus areas. (Listed

below.) • Increase protection along the Green River for recreation opportunities, water quality, scenic values,

and archeological resources by focusing development outside Upper Ten Mile (east of the wash), Labyrinth Canyon and tributaries to the Green River, and Hatch Point.

• Protect both the Green and the Colorado Rivers for water quality and recreation activities by

requiring development companies to apply best management practices throughout the Moab MLP planning area and apply an NSO stipulation to preclude mineral activities within public water reserves, 100-year floodplains and within 660 feet of intermittent and perennial streams, rivers, riparian areas, wetlands, water wells, and springs.

* * *

We support your work on this important planning process. Many Utahns depend on the recreation assets within the Moab MLP planning area and we believe this plan is an essential process to optimize and maintain both resource extraction and the recreation economy of the region. Sincerely,

Jason Keith Public Land Solutions

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2-mile NSO set-back from the following developed recreation sites:

Amasa Back Trailhead Anticline Overlook Bartlett Campground Big Bend Campground Overflow Big Bend Recreation Site Blue Hill Trailhead Bridger Jack Mesa Camping Area Canyon Rims Entrance Area Canyonlands Overlook Cliffline Interpretive Site Copper Ridge Dinosaur Tracks Trailhead Corona Arch Trailhead Courthouse Rock CG & Mill Canyon Dinosaur Trackway Cowboy Camp Camping Area Creek Pasture Camping Area Dewey Bridge Recreation Site Donnelly Canyon Day Use Area Drinks Canyon Recreation Site Fisherman’s Point Beach Access Gold Bar Campground Hal Canyon Campground Hamburger Rock Campground Hatch Point Campground Horsethief Campground Hunter’s Canyon/Spring Camping Area Indian Creek Falls Group Campsite Jaycee Park Campground & Portal Trail Kane Creek Trailhead Kings Bottom Campground Ledge Campground Loop

Ledge Campground Loop Ledge Group Area Lone Mesa Group Sites, A, B, C, D, E Lone Mesa Viewpoint Looking Glass Rock Interp. Site Lower Gemini Bridges Trailhead (Private) Mill Canyon Dinosaur Trailhead Mineral Bottom River Access Minor Overlook Moab Brand Trails Mountain Bike Trailhead Moab Rim Trailhead Monitor and Merrimac Trailhead Monitor and Merrimac Viewpoint Moonflower Canyon Camping Area Needles Overlook Newspaper Rock Oak Grove Campground Plateau Viewpoint Poison Spider Mesa Trailhead Potash Boat Ramp Sandy Beach River Access Shay Mountain Vista Superbowl Campsite Takeout Beach River Access Trough Springs Canyon Trail Trailhead Upper Big Bend Camping Area White Wash Campground and Trailhead William’s Bottom Camping Area Wilson Arch Windwhistle Campground

1-mile NSO set-back from the following routes and trails, climbing, canyoneering sites, and filming locations: Trails Klondike Bluffs bicycle trails Bar M bicycle trails Porcupine Rim trail Magnificent Seven/7 Up bicycle trail systems Ahab bicycle trails Lower Monitor and Merrimac bike trail

Kokopelli’s Trail Hunter Canyon hiking trail Jeep Routes Metal Masher (Arth’s Rim) jeep route Gold Bar Rim jeep route Golden Spike jeep route

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Poison Spider jeep route Cliffhanger jeep route Chicken Corners jeep route Top of the World jeep route Moab Rim jeep route Behind the Rocks jeep route Kane Creek jeep route Lockhart jeep route Seven Mile Rim jeep route Secret Spire jeep route Jug Rock Equestrian Trail System Jewel Tibbets hiking trail Trough Springs hiking trail Climbing & Canyoneering Indian Creek Wall Street Ice Cream Parlor The Tombstones of Kane Creek Needle Rock (Tombstone) Long Canyon/Day Canyon/Culvert Canyon Cameltoe Canyon

Granary Canyon Rock of Ages Repeat Junior Winter Camp Slot Filming Needles Overlook Colorado River corridor and Corona Arch Green River Canyon Kane Creek corridor Looking Glass Rock View from Dead Horse Point Potash Road/Shafer Basin (including Fossil Point) Long Canyon Highway 211 (including Newspaper Rock) Highway 313 Monitor and Merrimac/Determination Towers/Mill Canyon Gemini Bridges Jewell Tibbetts Arch White Wash

NSO stipulation applied to all Special Recreation Management Areas and Focus Areas: Canyon Rims SRMA Colorado Riverway SRMA Labyrinth Rims/Gemini Bridges SRMA South Moab SRMA Indian Creek SRMA Dolores River Canyons SRMA Hatch Wash Hiking and Backpacking Focus Area Needles and Anticline Roads Focus Area (Utah Scenic Backways) Bar M Mountain Biking Focus Area Bartlett Slickrock Freeride Mountain Bike Focus Area Gemini Bridges/Poison Spider Mesa Focus Area

Goldbar/Corona Arch Hiking Focus Areas Klondike Bluffs Mountain Biking Focus Area Labyrinth Canyon Canoe Focus Area Mill Canyon/Upper Courthouse Mountain Biking Focus Area Mineral Canyon/Horsethief Point Competitive BASE Jumping Focus Area Seven Mile Canyons Equestrian Focus Area Spring Canyon Hiking Focus Area Tusher Slickrock Mountain Biking Focus Area Behind the Rocks Hiking Focus Area 24 Hours of Moab Mountain Biking Focus Area