Oil and Gas Leases Threaten Desolation
American Whitewater has joined the Outdoor Industry Association and Outward Bound in formally protesting oil and gas leases that threaten Desolation Canyon. Our protest letter is attached below. The development threatens potential wild and scenic designation, and the recreational experience of thousands of whitewater boaters.
August 20, 2004
Ms. Sally Wisely, State Director
Utah Bureau of Land Management
Attn: Utah State Office Business Information Center
324 South State Street, 4th floor
Salt Lake City, UT 84111
Dear Ms. Wisely,
The signers of this letter are interested recreation businesses and groups who wish to formally protest the inclusion of parcels UT 190/ 191/ 192/ 193/ 194/ 195/ 196/ 197/ 198/ 201/ 204/ 205/ 206/ 207 in the September 8, 2004 lease sale. These potential leases border the Green River in areas with current recreation use that has potential to grow. We ask that you suspend the sale of these leases until a decision on the merits of our protest can be made. We also wish to address UT 199, which was withdrawn from the September sale, and permitted outside of this protest process. This parcel, which straddles the Green River below the put-in point for most river use into Desolation Canyon, raises significant concern for us; it could impact thousands of users each year.
Outdoor Industry Association provides trade services for over 4,000 manufacturers, distributors, suppliers, sales representatives and retailers in the $18 billion active outdoor recreation industry. Members include recognized brands such as JanSport, Columbia, Nike, Eagle Creek, The North Face, Watermark, Mountain Hardwear, Timberland and many others. Black Diamond and Petzl America are OIA members based in Utah who also serve on the Utah Recreation Economic Ecosystem Task Force. Wasatch Touring is a Utah retailer providing equipment, clothing and rental gear for backcountry adventures. Wasatch Touring also serves on the Utah Recreation Economic Ecosystem Task Force. American Whitewater is a non-profit organization representing 80,000 kayakers through its 105 affiliate clubs. Its mission is to conserve and restore rivers so the American public can enjoy them. Outward Bound is one of the oldest and largest wilderness educators in the country. A non-profit organization with significant operations in the mountains, canyons and rivers of eastern Utah, Outward Bound is a permitee in Desolation Canyon; has significant operations and employees in Vernal and Moab; and introduces thousands of young people a year to the majesty of the Utah backcountry. Many of the customers, clients and members of these businesses and organizations are avid users of the Green River each year.
We object to the sale of the above leases for the following reasons:
- The parcels straddle the Green River above Desolation Canyon, a highly used and nationally recognized area for boating.
While the agency chose to defer many of the parcels along the rim of Desolation Canyon, the river above Sand Wash is also a recreationally rich area with a potential for growth. The major put-in for river use through Desolation Canyon is right between parcels 197 and 198; and 199 - a parcel leased ahead of the September 8th sale - is passed by nearly every river user entering Desolation Canyon. The stretch of river bordered by the parcels above is currently used by the National Outdoor Leadership School (NOLS). In addition, it is used by other river users seeking a longer trip leading into the Canyon. We anticipate that as use increases in the Canyon, the stretch of river above Desolation Canyon may become a more and more desirable location for recreational boating in Utah. Clearly, Desolation Canyon is a recreation gem that requires special attention. In addition, the parcel just leased by the BLM near the put-in (parcel 199) may impact both established and potential river running opportunities and business in the area.
- Impacts of existing oil and gas development have already affected the recreational experience in this area; more development may drive existing recreational users away.
We believe additional leasing will exceed the threshold the area can sustain if it is to retain recreational use. The wells now visible in the middle segment have already significantly changed the river experience, adding noise, limiting the sense of remoteness, and disturbing many natural characteristics of the corridor.
- The current and projected oil and gas wells in the area amount to an intensive land use that was not contemplated in the management plans for the area. The existing plans state a vision of recreational use of the Green River; we believe the proposed intensive lease activity flies in the face of that vision.
The parcels we protest are managed under Land Use Plans/ Environmental Impact Statements which were approved 10 to 20 years ago: Book Cliffs in 1985 and Diamond Mountain in 1994. Updated planning in this area is in progress, and is essential to dealing with new management challenges in the area. The recreational assets in the area are rich, and circumstances have changed considerably with regard to oil and gas exploration in the area. We understand that a draft Vernal Plan is expected in September. We look forward to working with the agency to ensure quality recreation opportunities are protected and maximized in that plan.
In the meantime, we believe the current and projected oil and gas wells in the area amount to an "intensive land use" that was not envisioned when the plans were written. The reasonable foreseeable development scenarios (RFDS) in the existing plans are so dated as to be obsolete. We believe the change in use contemplated by BLM requires supplemental environmental review before new land use authorizations can be made along the Lower Green.
- The Green has Wild and Scenic River qualities that may be affected by additional oil and gas activity. Assessments of these qualities are currently underway; additional leases should be suspended until plans for the results of these assessments are complete.
We expect the results of the upper, middle and lower segments' eligibility assessment by the Vernal office to be released in September with the new draft resource management plan for public participation. The draft Price RMP, which is currently out for comment, did assess portions of the river in its planning area to have wild, scenic, and recreation qualities. The creation of additional "valid and existing rights" through leasing along the Lower Green should be suspended until the Vernal and Price plans are complete. The impacts associated with explorative and drilling activities in the area, even with no surface occupancy stipulations and offsite mitigation, will weaken the river corridor's suitability for federal protection.
In conclusion, we believe that Desolation Canyon and the river stretching above and below it are outdoor recreation treasures that require special care. Outdoor recreation is a growing part of the economy of southern Utah. We believe the increased oil and gas leasing in the area must be balanced with the special recreation qualities of the area. We urge the BLM to defer leasing in the parcels listed above until the true impact of increased oil and gas activity can be addressed in the planning process.
Thank you for your consideration.
Frank Hugelmeyer Peter Metcalf
Outdoor Industry Association Black Diamond Equipment
Craig Mackey Mark "Roody" Rasmussen
Public Policy Liaison President
Outward Bound, USA Petzl America
Riley Cutler Jason Robertson
Wasatch Touring Acting Executive Director