How to Comment
The main channel for submitting noticing comments to the BLM is through the agency e-planning website here. From here, you can review all of the associated documents, maps, and contact information for BLM in the left menu. When you are ready to submit, you can use the button below to take you directly to the form where you can enter your comments and attach any separate files you want to include with your electronic submission.
Resource Management Plan Comments: Summary of Goals
In accordance with Proclamation 10286 issued by President Biden in 2021, the Bureau of Land Management (BLM) must manage the monument for the protection and preservation of its historic, prehistoric, and scientific values, and only allow uses other than those needed for protection of monument objects when those uses do not conflict with the directives of the proclamation. “The Secretary of the Interior (Secretary) shall manage the monument through the Bureau of Land Management (BLM), as a unit of the National Landscape Conservation System, and in accordance with the terms, conditions, and management direction provided by this proclamation.” Proclamation No. 10286.
Accordingly, the standard approach of multiple-use management does not apply, and any effort to adopt such a management approach to the detriment of the monument’s natural, cultural, historic, and scientific values violates the proclamation. The Antiquities Act mandates prioritizing the protection of monument objects and values over discretionary uses. Monument proclamations have the force of law and the relevant agencies must manage these lands for the protection of monument objects.
Please see this list of Objects of Historic and Scientific Interest identified in the 2021 proclamation and consider how your comments may help protect these objects.
National Landscape Conservation System
The monument is part of the National Landscape Conservation System (NLCS), which was established by Congress in the Omnibus Public Land Management Act of 2009. 16 U.S.C. § 7202(b). The Proclamation specifically provides that the Monument is to be managed as a unit of the National Landscape Conservation System. The NLCS was established “to conserve, protect, and restore nationally significant landscapes that have outstanding cultural, ecological, and scientific values for the benefit of current and future generations.” 16 U.S.C . § 7202. National Landscape Conservation System Management Manual (BLM Manual 6100) and National Monuments, National Conservation Areas, and Similar Designations (BLM Manual 6220) further reaffirm that the BLM shall ensure that the components of the NLCS are managed to protect the values for which they were designated, including, where appropriate, prohibiting uses that are in conflict with those values.
Terrestrial Habitat and Vegetation Resilience and Conservation
- Maintain or increase populations of rare plants in the monument.
- Consult with Tribes about management of culturally relevant plants, and manage vegetation to support medicinal plants and other culturally important vegetative resources.
- Vegetation treatments will prioritize the restoration of native ecosystem processes.
- Vegetation treatments will be managed for long-term resistance and resilience.
- All vegetation treatments will include an estimate of the amount of carbon release caused by the action.
Noxious and Invasive Nonnative Plants
Goal: The BLM will place a priority on control of noxious and invasive non-native plants to achieve overall vegetation objectives.
Soils and Biological Soil Crusts
- Prevent damage to and degradation of soil resources and ensure that soil health is maintained or improved.
- Ensure soils exhibit infiltration, permeability, and erosion rates appropriate for the soil type, climate, and landform. Avoid activities that impact function, health, and distribution of soil resources.
- Maintain, improve, and restore areas of biological soil crust appropriate for the soil type, climate, and landform.
- Provide opportunities for tribal use of minerals for traditional and ceremonial purposes.
- Increase and improve understanding of biological soil crust management
Rangeland Health and Livestock Grazing Management
- Restore and maintain soils, hydrology, and native vegetation to promote long-term ecosystem sustainability.
- Grazing management will be based on objective, justifiable, scientific principles and will protect culturally significant resources to Tribes including archaeological resources, springs, and culturally significant plants.
Recreational Use and Visitor Services
Goal: Recreation will be managed to facilitate specific recreational experiences while ensuring continuing and future protection of monument objects and values.
Travel, Transportation, and Access Management
- Manage the transportation system so it provides safe and reasonable access for public travel, recreation uses, traditional and cultural uses, and land management and resource protection activities while protecting and preserving monument objects and values.
- Encourage a sense of stewardship and conservation of the landscape during travel.
Cultural Resource Management, Native American Religious Concerns, and Tribal Use
Resources to review and consider:
- Tribal comments received during Council on Environmental Quality consultations on the President’s America the Beautiful Initiative September 27th – November 23rd, 2021, at www.whitehouse.gov/wp-content/uploads/2022/03/Atb-tribal-Consultation-Summary.pdf
- Direction for implementing provisions of Joint Secretary’s Order 3403 (SO 3403), Fulfilling the Trust Responsibility to Indian Tribes in the Stewardship of Federal Lands and Waters. BLM guidance (Permanent Instruction Memorandum 2022-011)
- National Cultural Resources Procedures Handbook
- Bears Ears Inter-tribal Coalition Collaborative Land Management Plan for Bears Ears National Monument, at https://www.bearsearscoalition.org/wp-content/uploads/2022/08/FINAL_BENM_LMP_08252022.pdf
- Manage and protect cultural resources in collaboration with Tribes.
- Minimize damage to cultural resources from visitor use.
- Ensure tribal access and use for traditional and cultural purposes.
- Address data gaps about cultural resources within the monument.
- Support an inter-Tribal group to collaborate on management planning.
Forestry and Woodland Products
Goal: Sustain and improve forest health, including forest-associated monument objects and special status species.
Fire and Fuels Management
Goal: Allow fire to play its historic role in the ecosystem, where appropriate.
Wildlife and Fisheries
- Maintain, protect, enhance, and recover habitats and populations of federally listed threatened, endangered, or candidate animal or fish species, and actively promote recovery to the point that provisions of the ESA are no longer required. Maintain, protect, enhance, and recover habitats of the latest Utah BLM State Directors sensitive animal species list to ensure that BLM-authorized or approved actions are consistent with the conservation needs of the species and do not contribute to the need to list any species under the ESA.
- Promote and restore healthy riparian habitat throughout the monument. Maintain and preserve aquatic connectivity through land acquisition and maintenance of instream flows and by removal of barriers where practicable.
- Protect eagle and other raptor habitats. Maintain healthy vegetation to support raptor prey base.
- Manage the biological integrity and resiliency of terrestrial and aquatic ecosystems to maintain and/or improve habitat and fish and wildlife populations, with emphasis on climate change resiliency and overall biodiversity.
Hydrology (Groundwater, Surface Water, Wetlands, Riparian Areas, Floodplains, and Water Quality)
- Ensure that groundwater pumping is not damaging monument objects including aquatic, wetland and terrestrial organisms.
- Ensure that surface water ecosystems, including springs, streams and wetlands, are functioning and supporting the native flora and fauna of the region.
Manage riparian areas so as to maintain or restore them to properly functioning conditions and to ensure that stream channel morphology and functions are appropriate to the local soil type, climate, and landform
Assess the condition of all springs on the monument at least every five years, and for any springs in areas where NEPA is being done.
Manage spring health for cultural significance in addition to ecological significance.
Maintain good water quality or remedy conditions that are creating impaired water quality.
Conduct assessments to identify places where water quality is impaired.
Ensure that uses of water rights are not degrading monument objects.
Study the impacts of water uses on monument objects including springs, riparian ecosystems and streams.
Goal: BLM will manage resources to ensure landscape resistance and resilience to disturbances due to climate change and drought, including the development and implementation of a climate change adaptation plan.
Visual Resource Management
- Manage monument lands as VRM I and II with mandatory prescriptions to protect scenic values, especially areas with high conservation values such as lands with wilderness characteristics, backcountry recreation areas, scenic byway and backway corridors, eligible and suitable WSR segments, WSAs and ACECs.
- Explicitly include management direction in the VRM portion of the RMP provisions to protect and improve night skies to ensure that only natural sources of light are visible to the human eye throughout the monument.
- Protect viewsheds and visual resources in a manner consistent with Tribal values.
Dark Night Skies
Goal: Include mandatory management direction to protect and improve night skies to ensure that only natural sources of light are visible to the human eye throughout the monument.
- Manage uses to protect and maintain the natural soundscape.
- Protect wildlife species known to be sensitive to the effects of human caused noise.
- Protect visitor experience of natural quiet and solitude.
Lands with Wilderness Characteristics
- Manage all BLM-identified lands with wilderness characteristics to protect those characteristics.
- Designate new Wilderness Study Areas within existing BLM-identified lands with wilderness characteristics.