As we begin to discuss the recently released BLM Draft Master Leasing Plan (MLP), it will be helpful to base discussions on information found in the actual document. The document can be found online at: http://www.blm.gov/ut/st/en/fo/moab/MLP/deis.html. I offer the following thoughts and information as personal remarks, and am not speaking formally for the Grand County Council.
I believe many Grand County residents are interested in opportunities for responsible economic diversity, and agree that in order to do that we need to assure close coordination of activities and development between our recreation and mineral resources. I endorse that concept. That being said, by definition this draft MLP does not provide, nor was it intended to provide balance, as has been indicated in the news media and from various interested parties.
From the Executive Summary, page ES-2, the Purpose and Need for the MLP is identified: “The MLP will enable the Moab and Monticello Field Offices to: 1) evaluate in-field considerations such as optimal parcel configurations and potential development scenarios; 2) identify and address potential resource conflicts and environmental impacts from development; 3) develop mitigation strategies; and 4) consider a range of new constraints, including prohibiting surface occupancy or closing areas to leasing.” This “Purpose” for the MLP is again identified in the Introduction section at page 1.2, Section 1.2.1.
So the MLP is not intended to seek a “balance” for resource use in the greater Big Flat area. Its focus is to more fully understand and project future mineral development, and then develop a “range of new constraints…” so that development has virtually no impact on other resources. Its purpose couldn’t be clearer, and the subsequent addition of new overlapping, confusing and questionable “constraints” fully complies with the purpose as stated.
The past five years have seen significant growth in the MLP area of Grand County in both recreational use and mineral development. The reason this growth has been possible is the BLM 2008 Resource Management Plan. Management in the RMP presents a balanced and multiple use approach. That is the legal direction of land use planning found in the Federal Land and Policy Management Act of 1976. Analysis and direction in that RMP clearly recognized the recreation resource, and focused significant and reasonable mitigation action toward its sustainable use.
Of additional concern to some county residents is information found in Chapter 2 – Alternatives, Table 2-21, Comparative Summary of Impacts, Socioeconomics, page 2-69. This seems quite significant to me. The socioeconomic difference to Grand and San Juan counties and the state, between that projected in the Alternative A – No Action alternative (the existing 2008 RMP), and Alternative D – BLM Preferred alternate, is the loss of $2.15 billion dollars in economic output, and the loss of 285 jobs in the oil and gas and potash industries, with no identified difference to recreation economics, which under both Alternatives A and D have a projected $761 million in economic output, $447 million in labor income, and 1,086 jobs.
In essence, the impact of all the newly developed constraints to mineral development identified in the preferred Alternative D, result in a $2.15 billion economic loss. And more noteworthy, according to the analysis, neither Alternative A nor Alternative D will have any socioeconomic impact to the economic value of the recreation industry.
The draft MLP is replete with layer upon layer of overlapping and conflicting constraints: Viewshed protection not just from national parks, but from cultural resource sites; sound-level management up to 6.1 miles from parks; the questionable application of potash diligence requirements taken from coal mining regulations; overlapping timing constraints from a dozen wildlife species; multiple new report and survey requirements for minimal activity; application of new constraints to existing leases, etc. The list goes on. These are found in Appendix A – Mineral Leasing Stipulations. The appendix is 68 pages long.
We all are welcome to our opinions on development in our area, and I’m sure there are those who would agree with this restrictive MLP approach. But I am not one to lightly consider foregoing $2.15 billion of economic development and 285 jobs in this region, when taking such a loss will have no apparent impact on our recreation industry.
As we move ahead with dialogue and debate, let’s base our discussions on accurate information derived from the actual draft MLP document. And based on the stated purpose of the MLP plan identified in the document, and the subsequent level of newly developed constraints, this is not a “balanced” approach to land management in the MLP area. The 2008 RMP is a balanced plan.
Lynn Jackson is a retired 32-year employee of the BLM, a public lands consultant and a member of the Grand County Council. The views presented are his alone and do not represent the formal position of the council.