THE BLM WILDERNESS REVIEW

After 200 years of agricultural, industrial, and urban development, very little remains of the American wilderness. Today, less than eight percent of the land area of the lower 48 states remains wild. Most Americans understand how much has been lost. And as opinion polls show, most want to preserve what little remains of the American frontier.

Born of national pride in the natural splendor of America, the Wilderness Act of 1964 was an event of profound historic significance. Never before had a nation taken such deliberate measures to protect its wilderness heritage. The Act created a National Wilderness Preservation System and mandated a nationwide inventory of roadless national forest and national park lands which might qualify for inclusion.

In 1976 the Federal Land Policy and Management Act (FLPMA) directed the BLM to conduct a nationwide inventory of all BLM-managed roadless areas and assess their potential for wilderness designation. While the inventory was under way, the law required the BLM to prohibit new development on all lands under review. Once the inventory was complete, the moratorium on development would end for all lands which failed to meet the BLM's criteria for further study. Qualifying lands were to be identified as Wilderness Study Areas (WSAs) and would remain closed to new development until the Congress could determine their fate by means of wilderness legislation.

In Utah, where BLM lands comprise over 40 percent of the state, the BLM wilderness inventory was an opportunity to protect some of the largest remaining tracts of roadless land in the southwestern United States. Yet despite the superb character of Utah's roadless lands, the BLM's wilderness review went seriously astray from the policies established by Congress. Huge blocks of wild land were "inventoried" by helicopter without adequate field-checking on the ground. Remote and beautiful expanses of slickrock and sagebrush were excluded from wilderness study for the most spurious reasons. And in direct violation of its own policy, the BLM repeatedly dropped from its wilderness inventory those lands with potential -- real or imagined -- for mineral development.

The following explains what went wrong with the BLM wilderness review in Utah, focusing on Mancos Mesa, where only through the diligent efforts of conservationists was a wilderness study ever conducted at all.

The Case of Mancos Mesa

The helicopter dropped each of three inventory crew members at two different locations on Mancos Mesa. "We took pictures for five or ten minutes at each location," recalls Janet Ross. "That was the entire inventory."

To watch dawn unfold over Mancos Mesa is to experience the silence, the clarity, the sense of infinite distance that can be found in few other places in America. Rising to elevations of between 5,000 and 6,000 feet, Mancos Mesa is an island in the sky, cut off from the outside world by canyons and cliffs. The top of the mesa is a mosaic of bare rock, sand, and sage. Its surface is incised with more than 200 miles of winding canyons. Mancos Mesa is not easy to reach by foot. Once there, you want to linger.

For more than a decade, Mancos Mesa had been one of the BLM's top candidates for primitive area designation. "The intrigue and adventure of this totally isolated area, coupled with its history, offers an unusual opportunity for man to participate among the true essences of nature," concluded a 1970 BLM staff report. " . . . an `ecological island' such as Mancos is a rare find." In December, 1970, the BLM held public meetings in nearby Monticello, Utah, to unveil its primitive area proposal for Mancos Mesa. But when powerful mining and livestock interests attacked the proposal, the agency quietly abandoned it.

The One-Day Inventory

On the morning of June 12, 1979, the BLM wilderness inventory team arrived at remote Mancos Mesa -- in a Bell jet helicopter. "We wanted to backpack into the area, but upper management decided we couldn't do that," recalls team member Janet Ross. Instead, the team was given just one day to assess the wilderness character of the 110,000-acre Mancos Mesa roadless area from the air.

The helicopter dropped the three inventory crew members at two different locations on Mancos Mesa. "We took pictures for five or ten minutes at each location," recalls Ross. "That was the entire inventory." Almost. After making its first drops, the helicopter circled -- and circled again. Something had gone wrong. In the rugged vastness of Mancos Mesa, the helicopter pilot could not find two of the three inventory team members. "We couldn't get them on the radio, and we were running out of gas," recalls Ross. After refuelling, the pilot searched for another hour before finding his lost crew. Tormented by swarming gnats, they had pulled their flight jackets over their heads and zipped them shut, thus accomplishing nothing in the way of inventory.

Several weeks later, the inventory crew filed its report on the wilderness character of Mancos Mesa. To qualify for wilderness study, a roadless area must meet three basic criteria. First, it must be undeveloped -- in the words of the Wilderness Act, "primarily affected by the forces of nature, with the evidence of human activity substantially unnoticeable." Second, it must be at least 5,000 acres in size. Third, it must offer outstanding opportunities either for solitude or for primitive recreation.

In the unanimous opinion of the inventory field team, the Mancos Mesa roadless area met all three criteria. "As nearly as I could tell, from my ten minutes on the ground, there were quite outstanding opportunities for solitude," recalls Janet Ross. "Those canyons and mesas are just as spectacular as anything in southeastern Utah." Yet in November, 1980, when the BLM announced its final wilderness inventory decisions, Mancos Mesa was missing from the list of new wilderness study areas. While the mesa met size and naturalness requirements, the BLM ruled that it failed to provide "outstanding opportunities" for solitude or recreation. "The canyons have sparse vegetation, and are fairly open in character," the BLM explained. "Opportunities here for solitude are present, but not outstanding."

The recommendation of the BLM's field inventory team had been quietly reversed by the Utah BLM state director.

BLM Overrides Staff, Rewrites Documents

On Mancos Mesa, and throughout Utah, the BLM conducted its wilderness inventory with reckless haste. Though FLPMA had allowed 15 years for the BLM to complete its wilderness review, the Utah state BLM office had allocated just 2 years to evaluate nearly 900 individual roadless units and 22 million acres of land. Lack of time, inadequate resources and poor organization, recalls Janet Ross, made the inventory "heavily dependent upon vehicular and aerial reconnaissance which, given the very nature of wilderness, are extremely unreliable ways to assess wilderness characteristics."

The case of Mancos Mesa was far from unique. Throughout Utah, the BLM cut millions of acres of pristine mountain, desert, and canyon wilderness from the inventory.

In numerous cases, the final decision reversed a favorable recommendation from inventory field crews. "Most of the input came from the line management, not the wilderness staff," recalls former Moab district wilderness specialist Peter Viavant. "There were many times when a decision would be changed after a recommendation was written, and one would just go back and rewrite it again. I mean, you'd write, `The canyons are 500 feet deep, providing great solitude . . . ' And then they'd change their mind and decide it should be out of the wilderness inventory, and you'd come back and write "there's only 500 feet of relief and this does not provide very good solitude."

In the case of Mancos Mesa, managers instructed inventory team leader Paul Happel to alter the recommendation of his own field crew. The alteration was discovered by Interior Board of Land Appeals judge Bruce Harris. "Close inspection," he wrote in a 1983 court decision, "indicates that a mark in the "Yes" box is whited out . . . . An "X" is typewritten in front of the statement `Unit does not qualify for wilderness study.'"

Along with Mancos Mesa, the BLM had eliminated more than 90 percent of all lands originally under study. By November 1980, the BLM had cut from the inventory 89 roadless areas with outstanding wilderness character. An additional 32 roadless areas were arbitrarily cut up into smaller units or radically reduced in size. On the southern perimeter of the San Rafael Swell, for example, the BLM eliminated 80,000 acres of wild lands from the Muddy Creek wilderness inventory unit by adopting a BLM district line as the roadless area boundary. In Labyrinth Canyon, the BLM drew a roadless area boundary down the center of the Green River, identifying the west half of Labyrinth Canyon as a WSA while eliminating 57,000 acres along the east side of the canyon from wilderness study. In Arch Canyon, the BLM concluded that a 27,000-acre roadless area was "too small" to be wilderness because half of it lay on lands managed by the U.S. Forest Service.

Violations of Policy

Many inventory decisions directly violated the BLM's own wilderness inventory policy. That policy stated, for example, that roadless areas should not be eliminated from the inventory because of minor human impacts located around the periphery, where those impacts could be eliminated by means of a boundary adjustment. Yet the BLM dropped dozens of roadless areas because of impacts which could easily have been excluded by minor adjustments in the boundary. The Harts Point roadless area was a typical case. The unit featured an 800-foot-deep canyon system, at least three huge natural bridges, pools, waterfalls, and abundant wildlife. The BLM cut the entire unit from wilderness study, claiming that human impacts had ruined wilderness character throughout the unit. Yet simple boundary adjustments could have eliminated all significant human impacts, leaving a wild area of more than 68,000 acres.

"The boundary of a unit is to be determined based on evaluation of the imprints of man," read the policy, " . . . and should not be further constricted on the basis of opportunity for solitude and primitive and unconfined recreation." Yet more than 300,000 acres of lands were trimmed from a dozen WSAs when the Utah BLM state director determined that "portions of these units contain outstanding opportunities, while other parts clearly do not."

"What the BLM was trying to do was totally absurd," recalls Terry Sopher. Flying over Labyrinth Canyon, he remembers, "you were looking down on the ground, and one side of the river was said to have outstanding characteristics, and the other side was said not to have, and they both looked identical."

"It is erroneous," read the BLM's inventory guidelines, "to assume that simply because a unit or a portion of a unit is flat and/or unvegetated, it automatically lacks an outstanding opportunity for solitude." Yet in Utah the BLM cut millions of acres of wilderness from the inventory for the sole reason that portions of roadless areas were flat or sparsely vegetated. The entire 140,000-acre Wahweap roadless area, for example, was cut from the wilderness inventory after the BLM concluded that "on the flat upper bench areas . . . the opportunity for solitude is limited because of the flatness of the terrain."

Such procedural violations were so numerous that in August, 1980, just prior to the BLM's final inventory decision, the national director of the BLM wilderness program, Terry Sopher, came to Utah to investigate. A single overflight, recalls Sopher, convinced him that "what the BLM was trying to do was totally absurd." Flying over Labyrinth Canyon, he remembers, "you were looking down on the ground, and one side of the river was said to have outstanding characteristics, and the other side was said not to have, and they both looked identical . . . . Based on what we had seen, there was an egregious violation of the policies."

Sopher immediately returned to Washington, D.C., where he met with BLM national director Frank Gregg to report the problems in Utah. "I recommended," recalls Sopher, "that the director should intervene and take steps to stop the current direction of the inventory, and require it to be done over." But before Gregg could take action, all Interior Department appointees were swept out of office with the defeat of President Jimmy Carter.

Appeals Board Reverses State BLM Office

Meanwhile Utah conservation groups tried to reinstate lands cut from the inventory. After the BLM denied their formal protests, conservationists filed a series of appeals with the Interior Board of Land Appeals (IBLA). One such appeal was 2,000 pages long, containing 300 photographs and 120 affidavits. Covering 925,000 acres on 29 roadless areas, it was the largest appeal of its kind in the history of the IBLA. In 1983, the IBLA responded with a stunning indictment of the BLM inventory. Utah BLM inventory decisions had been in error, the Board ruled, on 90 percent of the lands under appeal.

But appeals could not correct the deficiencies of the Utah BLM wilderness inventory. Upon reconsideration, the BLM ultimately reinstated less than half of all lands under appeal. More important, many key inventory omissions were never appealed.

"Conservationists' resources were stretched to the breaking point in order to appeal more than 1.4 million acres," recalls Sierra Club activist Jim Catlin. "If we had more time, money, and people, we might have appealed up to 2.9 million acres in 122 inventory units."

"You only have 30 days to file an appeal," explains Terry Sopher. "It was damn near impossible for citizens to appeal every area that deserved an appeal."

Yet publicity surrounding the appeals had begun to expose the true magnitude of the BLM wilderness inventory omissions. "The work of the Bureau has been too hasty and too piecemeal . . . " editorialized the Deseret News in August, 1982. " . . . there was much Utah land that should have been considered for possible designation as wilderness, but the BLM did not study it."

In 1983, charges of mismanagement in the Utah BLM wilderness inventory brought House Public Lands Subcommittee chairman John Seiberling on a fact finding mission to Utah. Seiberling returned to Washington convinced that the BLM had indeed mismanaged the inventory. "They've left out areas that obviously qualify for wilderness -- and I've seen a lot of them," he told reporters. "I mean, their position is absolutely absurd, where they've said that they dropped a particular area because it didn't give opportunities for solitude."

Congressional Testimony Underscores Inventory Abuses

In 1984 and 1985, Seiberling held a series of oversight hearings to investigate the problems of the BLM wilderness inventory. As the hearings progressed, the story of the Utah wilderness inventory gradually unfolded. Key witnesses included former BLM wilderness inventory staff.

"The American public, you and I, have suffered a great tragedy in Utah," testified former BLM wilderness coordinator Clive Kincaid. "We have been the victims of ineptitude or deception, and the price has been a heavy one."

For Utah, the BLM wilderness inventory had been precisely the reverse of what Congress had requested. Congress had asked for a thorough inventory of the nation's last unprotected wild lands. What it got, instead, was commercial and industrial zoning.

Kincaid had earned two outstanding achievement citations for directing one of the Bureau's first complete district-wide wilderness inventories, in Arizona. After resigning his job with the Bureau, he spent a full year investigating BLM wilderness inventory violations in Utah. Kincaid summarized his findings for the subcommittee by presenting five case studies, including that of Mancos Mesa. In each case, Kincaid's research suggested that the BLM had cut land from the inventory because of its potential for mining, grazing, or industrial development.

"It's rather interesting," said Rep. Seiberling, "that in many cases those areas which they dropped happened to coincide with things like tar sands, or coal fields." In the Henry Mountains, for example, the BLM trimmed nearly 200,000 acres of rugged badlands from the Mt. Ellen and Mt. Pennell WSAs -- neatly excluding 100 percent of the known recoverable coal in the two roadless areas. North of Canyonlands National Park, the BLM omitted 57,000 acres of wild lands bordering the site of a proposed potash solution mining complex. Sixty-five thousand acres of spectacular slot canyons surrounding Natural Bridges National Monument were dropped from the inventory while under siege by oil and uranium exploration companies. Eighty-eight thousand acres of wilderness adjacent to Canyonlands Park vanished from the BLM wilderness inventory after the area was identified as a candidate site for a nuclear waste repository and its railroad. In the San Rafael Swell, the BLM cut 350,000 acres of wild lands surrounding the proposed Intermountain Power Project's transmission line, rail corridor, and power plant sites. And on the Kaiparowits Plateau the BLM cut nearly 400,000 acres underlain by coal.

For Utah, the BLM wilderness inventory had been precisely the reverse of what Congress had requested. Congress had asked for a thorough inventory of the nation's last unprotected wild lands. What it got, instead, was commercial and industrial zoning. Instead of letting Congress strike a balance between commercial uses and wilderness protection, the BLM quietly dropped any lands having mining claims or other mineral potential.

"Congress told us to identify every acre of land that had wilderness characteristics," said Terry Sopher. "BLM was directed simply to identify the areas that had wilderness qualities and let Congress decide which ones were outstanding. Yet it is now apparent that there was egregious violation of that mandate of the law."

"We tried to make the decision for somebody else, that we had no right to make," recalls a BLM inventory team member, who risked his career to protest mismanagement of the Utah BLM inventory. "We cut the pie the first time. If Congress never sees the whole pie, then they don't make decisions on it, do they? And that's exactly what happened."

In many cases the BLM altered WSA boundaries to promote industrial development which would never take place. The Intermountain Power Project was finally located on a different site 100 miles west of the San Rafael Swell. Between 1979 and 1983, worldwide uranium and oil prices plummeted, and energy exploration in Utah virtually ceased. A stagnant energy market killed the Kaiparowits Power Project, and Kaiparowits coal was never developed. The potash market slumped, and Buttes Oil and Gas abandoned its proposed solution mine north of Canyonlands National Park. And in 1984, the Department of Energy eliminated Davis Canyon as a candidate site for the nation's first nuclear waste dump.

Administration Lets Violations Stand

In a July, 1985, BLM oversight hearing Rep. Seiberling specifically requested Interior Secretary Donald Hodel to "take a final look at the inventory, especially in Utah . . . to assure that they have not overlooked deserving lands." In December 1985, Seiberling repeated the request in writing, identifying 18 Utah roadless areas where critical inventory omissions had occurred. The Department of the Interior responded in February, 1986. The reply was terse. The BLM flatly refused to add lands to the wilderness inventory. "We believe the inventory in Utah was as accurate and consistent as possible," explained deputy assistant secretary James Cason. "The time for initiating such an appeal has long since expired. Failure to raise these allegations at the appropriate time in the formal appeal period does not constitute sufficient reason to disrupt the systematic review process."

The Utah Wilderness Coalition

By the spring of 1985, it was clear that the Utah BLM wilderness review had been a failure. The BLM had arbitrarily cut more than 2 million acres of wild lands from its inventory, removing interim management protection and throwing the lands open for development. An additional 1.1 million acres would ultimately be omitted from the agency's draft wilderness recommendation to Congress, announced in February 1986. A final version of that proposal, due to be released in 1990, is expected to increase that recommendation by only some 80,000 acres -- adding some areas, dropping others.

On the Colorado Plateau -- the canyon country of southern Utah -- the BLM's piecemeal, development-oriented wilderness recommendations would transform one of the nation's last great blocks of high desert wilderness into islands of protected land in a sea of industrial development.

Utah conservationists were convinced that the BLM wilderness review had fallen short of its congressional mandate. To take their case to the public, they formed the Utah Wilderness Coalition, which has grown to include 35 local and national conservation groups.

In February 1985, coalition members convened the first of nine conferences to hammer out a citizen's BLM wilderness proposal for Utah. Where BLM inventory work was inadequate, the coalition sent volunteers into the field to map the true extent of Utah's BLM wild lands. "Our members have walked and flown extensively over the lands in our proposal," says Utah Wilderness Coalition spokesman Darrell Knuffke. "We know what's out there. It's wilderness. And we intend to do everything in our power to keep it that way."

Developing a Citizen Proposal

The Coalition's objective is to do what the BLM failed to do during the Utah wilderness inventory: to fully document the wilderness resources of some of the largest blocks of undeveloped land in the nation.

On July 16, 1985, the newly formed Utah Wilderness Coalition announced a 5.1-million-acre BLM wilderness proposal for Utah. During the five-year interval between that announcement and the publication of this book, UWC staff and volunteers have spent thousands of additional hours in the field, documenting wilderness character and accurately mapping the boundaries of proposed areas. We have added wild lands to our proposal where human impacts had previously been overestimated, or where erosion and vegetation growth had further obscured faint, unused vehicle tracks. These additions, along with more accurate, computer-generated acreage calculations, have increased the UWC proposal to 5.7 million acres.

This book presents the combined knowledge of hundreds of Utah conservation activists. Its goal is to do what the Bureau of Land Management failed to do during the Utah wilderness inventory: to fully document the wilderness resources of some of the largest blocks of undeveloped land in the nation.

The BLM took a piecemeal approach to the wilderness inventory, dividing huge roadless areas into numerous smaller units, and omitting large blocks of land. By contrast, the Coalition identified 42 integral wilderness areas, many of which are contiguous to national park or national forest wild lands. While each proposed wilderness area may contain separate individual roadless units that are separated by narrow road corridors, each should be viewed as one wilderness, with a physical, geological, and biological character all its own.

Our proposal will protect the visual integrity of the entire Canyonlands Basin -- the million-acre labyrinth at the heart of the Colorado Plateau. It will protect the viewsheds of Capitol Reef and Bryce Canyon national parks by precluding strip mining and chaining on adjacent BLM wild lands. It will protect the scenic and recreational resources of the entire San Rafael Swell, not just a narrow band around the Swell's perimeter. It will protect the biological integrity of the Book Cliffs, the Escalante canyon country, and the Henry and La Sal Mountains, by preserving habitat size and diversity, wildlife migratory routes, and numerous endangered species. It will preserve the inspiring solitude of the Kaiparowits Plateau, the cliffs and mesas of the Grand Staircase, and parts of the Great Basin desert. It will protect the archeological treasures of Cedar Mesa and the San Juan River Basin by prohibiting new road development and vehicle access to remote archeological sites. And it will preserve, for our children and their children, the opportunity to experience wilderness on a scale such as that of the original American frontier.

The silence, solitude, and sheer beauty of Utah's high desert wild lands are among America's scarcest and most valuable natural resources. It is a landscape so diverse, so intricate, that it requires much more than the cursory inventory given it by the BLM. The Utah Wilderness Coalition proposal is our effort to redress that inventory's failings and present a full picture of Utah's desert wild lands to the American public.

Ray Wheeler

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