Linda Colville

Acting State Director

Utah State Office

Bureau of Land Management

324 South State Street

P.O. Box 45155

Salt Lake City, UT 84145-0155
 

Re: 1999 Utah Wilderness Inventory

Scoping on Proposed Section 202 Plan Amendments

The State of Utah has begun its review of the 1999 Utah Wilderness Inventory and supporting data, pursuant to the Notice in the Federal Register dated March 18, 1999, page 13439. The state submits these comments to meet the deadline for submission of scoping comments, but would like to indicate that it will continue to submit more detailed statements as more review and field work is completed. We understand that these later comments will be given full consideration, as indicated in your June 8, 1999 Planning Notice.

Primarily, in addition to the attached comments, and the data given to you by the Division of Water Resources, the state is concerned that the scope and purpose of the review is too narrow. In addition to a review of the wilderness characteristics of an area, the BLM should carefully examine other uses of the area, and determine which is better for the good of all. The BLM must review all the possible mineral uses, recreational uses - motorized and nonmotorized - and historical use patterns. For example, many areas are now in very good shape, due to active management by the Division of Wildlife Resources, BLM and local ranchers. Water sources have been developed, which, in turn, has allowed many herds of animals and flocks of birds to thrive, where otherwise no wildlife would be present at all. None of this is apparent to the casual eye. The BLM must consider carefully the best management regime for an area, for, if the active management necessary to support wildlife is removed, and the animals and birds leave, what is the purpose of wilderness?

We must emphasize the comments attached about the school trust lands. Many of them have been reviewed by BLM, but, of course, BLM does not have the authority to make school lands into WSAs. The Trust Lands Administration may be willing to exchange lands in the event of Congressional wilderness legislation, but BLM should examine the manageability of proposed WSAs with the understanding that the trust lands will be managed for the benefit of the schoolchildren.

We also ask BLM to review these units in light of other BLM actions. For example, if BLM has leased lands for coal or other mineral production, subsequent WSA status should be precluded. This has apparently happened in the Turtle Canyon and Mussentuchit areas. Recent BLM plans have allowed for reasonable uses of the public lands. For example, the Dixie RMP allows for setbacks near powerline corridors, which should be honored in this study, and the Grand Staircase - Escalante Monument Plan provides for the management of that area. There appears to be no reason to amend the Monument plan, jointly worked upon by state and federal people, by this process.

We look forward to working with the BLM in order to focus the issues related to each and every proposed WSA. Thank you for your consideration. Please call myself (538-1558) or John Harja (538-1559) with any questions or concerns.

Sincerely,

Brad Barber

State Planning Coordinator

BTB/jah
 

Division of Wildlife Resources

The designation of 2.6 million acres of new Wilderness Study Areas (WSA) in Utah will greatly impact the Utah Division of Wildlife Resources' (UDWR) ability to fully manage Utah's fish and wildlife species. To reduce the severity of this impact, the UDWR requests that certain areas not be considered for WSA status, and that several provisions be included as management prescriptions for any areas considered for WSA status, as follows:

1) The use of fixed-wing aircraft and helicopters for wildlife management purposes.

Helicopters and fixed-wing aircraft are critical for purposes of estimating population sizes, maintaining water developments, determining species distributions, conducting trend counts, releasing animals into historic habitats, augmenting wildlife populations, and capturing animals for transplant to new areas.

A prime example of a species that cannot be managed without the use of helicopters and fixed-wing aircraft is the bighorn sheep. Due to the hard-to-access areas utilized by bighorn, the UDWR must use helicopters to monitor the conditions and trends of numerous herds. The UDWR also uses helicopters to thin existing herds through transplant projects (to prevent disease epidemics) and to release bighorns as part of restoration efforts. In addition to these uses, helicopters are also important for disease work and other research. A prohibition on using helicopters and fixed-wing aircraft in new WSAs for game management purposes will prevent the establishment of new herds in those areas, and may cause Utah to lose many existing bighorn sheep populations.

2) The ability to maintain existing guzzlers and other water developments, as well as the ability to construct new water developments.

Water developments are crucial to the survival of wildlife species in many areas of Utah. In many of these areas, natural water sources are no longer available to wildlife, and historic population levels cannot be maintained without the water supplied by man-made water developments. Guzzlers and other water developments have been established and maintained for years in many of the proposed WSAs. These developments provide water to native wildlife species as well as non-native game species such as the chukar. The UDWR must be able to maintain those water developments, as well as construct new water developments when needed, in order to properly manage Utah wildlife. The inaccessibility of many water developments necessitates that motorized vehicles and helicopters be used for installation and maintenance activities.

3) The ability to conduct large scale vegetation treatments on WSAs and nearby areas.

Vegetation treatments are often employed by the UDWR to improve habitat for wildlife and return areas to more pristine conditions. Under recent range management practices, a variety of factors have lead to habitat degradation. For example, fire suppression in many areas has lead to a proliferation of old growth pinyon-juniper stands, which have diminished value for wildlife. The UDWR would like the Bureau of Land Management (BLM) to establish and implement fire plans on all WSAs that would allow for natural fires to burn and also allow prescribed fires when necessary for wildlife management purposes. Other methods of removing undesirable vegetation, including chemical and mechanical treatments, should also be allowed on WSAs.

The UDWR is also concerned with habitat rehabilitation following fire. Under current, altered ecology, undesirable plants, such as cheat grass, can invade recently disturbed areas. To prevent cheat grass, disturbed areas must often be reseeded, and the seed must be covered. As native plant species are often slow growing, the best seed mix for reseeding efforts will often contain beneficial non-native species which can out compete invasive cheat grass and other undesirable species. The ability to seed / reseed disturbed areas is necessary for UDWR to properly manage range for wildlife species.

4) The ability to introduce and stock fish and wildlife.

The UDWR currently transplants native wildlife species, such as Bonneville cutthroat trout and bighorn sheep, to areas of the state where suitable habitat for those species exists. These transplants are conducted to restore species to historical range areas, to maintain populations of species, and to provide for increased recreational opportunities. Non-native species, such as chukar and rainbow trout, are also transplanted to provide for increased recreational opportunities. The UDWR requests that transplants of native species be allowed in WSAs. The UDWR also requests that non-native species transplanted after 1976 not be removed from WSAs.

5) Administrative access on existing roads for wildlife management purposes.

Due to the large size and remoteness of many proposed WSAs, the UDWR will require the use of motorized vehicles and administrative access to existing roads to conduct inventories, trapping, transplants, species counts, maintenance of water developments, research, and other legitimate wildlife management activities.

6) The ability to control predators.

Under current regulations, predator control activities of Wildlife Services personnel in WSAs are limited to a "single offending animal." Many of the proposed WSAs currently receive extensive predator control, and a limited level of predator control will not be adequate for many of those areas. Predator control efforts are especially important in areas where a species has recently been introduced / reintroduced. The UDWR often works with Wildlife Services to remove predators from these areas so that the new species can become established. The UDWR would like the ability to control predators in WSAs for legitimate wildlife management purposes.

7) The continuation of recreational activities.

The UDWR employs hunting, fishing, trapping, and other legal methods of take to manage Utah's fish and wildlife species. The BLM should allow these activities to continue in perpetuity on WSAs.

In addition to the general comments listed above, the UDWR currently has comments on two specific proposed Wilderness Study Areas, Pilot Range and Newfoundland Mountains. Comments specific to other proposed WSAs will be supplied after BLM produces a Draft Environmental Impact Statement for the proposed Wilderness Study Areas. The current comments are as follows:

1) The UDWR needs the ability to maintain all guzzlers on these mountains. We also anticipate that up to ten additional guzzlers may be needed on each mountain range to maintain populations of bighorn sheep, chukar, pronghorn, and other wildlife species.

2) The UDWR needs to maintain our ability to monitor big game and upland game on these mountains using helicopter and fixed-wing airplanes.

3) The UDWR may need to develop some springs in these mountains for wildlife management purposes and/or restore some springs in these mountains to re-establish riparian vegetation and amphibian habitats.

4) The UDWR will need to perform some vegetation manipulation on these mountains to enhance wildlife habitat.

5) The UDWR needs the ability to survey these mountains for populations of least chub and boreal toad, state listed sensitive species. UDWR also needs the ability to introduce / reintroduce these species into appropriate habitats in the Pilot Range and Newfoundland Mountains.

6) The UDWR plans to establish bighorn sheep in the Newfoundland Mountains later this year and to augment this new population of bighorn sheep in the future. The designation of the Newfoundland Mountains as a WSA should not interfere with these transplant efforts. Also, because bighorn sheep can contract lungworm, the BLM should allow UDWR to place "antibiotic blocks" near water sources so that sheep can medicate themselves.

7) The UDWR needs the ability to enhance and maintain sagebrush communities in the Pilot Range to support sage grouse populations. Sage grouse are a state listed sensitive species.

8) The Pilot Range contains two streams which support populations of Lahonton cutthroat trout, a federally and state listed threatened species. UDWR needs the ability to survey these populations and manage the species in perpetuity. Management activities for Lahonton cutthroat trout could include electroshocking, removal of fish, and addition of fish.

Division of Oil, Gas, and Mining

This BLM report was prepared to supplement the original Utah wilderness inventory conducted under the 1976 Federal Land Policy and Management Act (FLPMA) and reflects a second look at lands in the state of Utah which may have wilderness characteristics. The Division has no comments at this time on specific tracts which may or may not have wilderness characteristics, but reserves its right to comment at the time of a draft Environmental Impact Statement. The Division does however have an observation on the process used in identifying potential Wilderness Study Areas (WSAs).

At least two of the candidate 1999 tracts which have characteristics as WSAs include several comments describing evidence of prior exploration drilling efforts - Turtle Canyon and Desolation Canyon. Most notable about the comments in this regard are the descriptions of how the evidence of these intrusions are well on their way to becoming a part of the natural landscape of the areas. At page 127, the notation for the Desolation Canyon Tract reads in part:

***The imprints are in various stages of rehabilitation, with most being substantially unnoticeable in the area as a whole. The expansive landscape, diverse topography, and vegetation screens the scattered human intrusions within the units. Minor remnants of past oil and gas exploration, livestock grazing, and recreation pursuits remain, but most disturbance has been erased over time by the forces of wind, water and vegetation regrowth.***

Likewise, at page 129, the notation for the Turtle Canyon Tract reads:

***All of these intrusions are minor, have been reclaimed or are in various stages of natural rehabilitation, are well screened by vegetation and topography, and are substantially unnoticeable.***

Given these observations on tracts which obviously have some potential for mineral development, one must consider the utility of considering these areas for wilderness study at this time. If there is the "natural" capability for rehabilitation following man-caused disturbance, is there a need for protection of site characteristics at this time? When natural resources exist which can through civilization's exploitation be used to benefit our economy, should future development options be compromised through consideration as wilderness?

Utah Geological Survey

During the BLM's scoping process, and in crafting alternatives for its management plan, the UGS encourages the BLM to conduct or have conducted a thorough inventory and analysis, similar to that required by FLPMA in the original review, of the energy and mineral potential that exists on these lands.

The UGS has recently produced a Geological Resources Atlas of Utah that shows, in digital format, the locations of many past, current, and potential resource sites with associated exploration and production data. Also in this atlas are roads, land use, water rights, and other data. We encourage the BLM to use this atlas as a supplementary tool in identifying resource potential in the current and proposed WSAs. We note, however, that although the UGS has been collecting much of the data contained in this atlas during the past 50 years, the database is a compilation of existing data, not an inventory. A deliberate and systematic inventory of all the current mine sites and potential mineral and energy resources in the proposed WSAs is still needed. A query of the geologic resources atlas for the 142 new areas proposed for wilderness shows there are numerous locations within these proposed wilderness areas that may present a potential conflict to wilderness designation. These include: 6 dams, 87 water rights (existing wells or rights to drill wells), 1,643 coal sites, 13 geothermal sites, 300 oil and gas sites, 29 oil shale sites, 22 tar sand sites, and 331 mineral sites. These figures should be considered minimums, as not all data points have been entered into the database. In addition, up to 450 miles of roads are contained within the newly proposed wilderness lands according to U.S. Geological Survey data.

One aspect of the Utah Geological Survey's (UGS) mission is to promote mineral and energy resource development within Utah. We accomplish this mission by performing resource evaluations throughout the state, and disseminating this information to the public and to industry. Many prosperous mineral and energy developments in Utah have been realized through the work initially done by UGS geologists. The UGS is a strong advocate of responsible, prudent, and aggressive development of the state's energy and mineral resources. In its scoping, planning, and decision-making processes, we anticipate that the BLM will consider and recognize the value of allowing these resources to be developed now and in the future.

The UGS welcomes the opportunity to cooperate with the BLM to identify and characterize known and potential conflicts to wilderness designation, and to provide more information on a particular resource, site, or industry that is located within or near any of the current or proposed wilderness study areas.

Parks and Recreation

The staff of the Utah Division of Parks and Recreation appreciate the opportunity to reply regarding the Bureau of Land Managements (BLM) proposal on Wilderness Study Areas (WSA). The Division feels that precedence should be given to the Division on those areas that have been considered as potential state park sites. The Division still uses as a focal point for future State Park planning, a 1959 document prepared by the then Utah State Park and Recreation Commission.

The document identifies 118 potential state park sites. Although many of the sites have already become state, or even national, parks, it is still part of our planning process to look at others identified in the document, including areas such as the San Rafael Swell, Boulder Mountains, Book Cliffs, Fisher Towers and so forth. Further, since that time we have identified the canyons east of Kanarraville, expansion of Snow Canyon, Coral Pink Sand Dunes, Goblin Valley, and Kodachrome State Parks as sites for acquisition or development which could be affected by WSA designation.

We feel that a complete review of the 1959 document must be made to determine which sites should be given precedence as state park sites over WSA designation, and would be happy to work with BLM to focus those considerations.

Utah School and Institutional Trust Lands Administration

The Utah School and Institutional Trust Lands Administration (the "Trust Lands Administration") submits the following comments concerning the current wilderness study area ("WSA") planning project being undertaken by the U.S. Department of the Interior, Bureau of Land Management ("BLM") pursuant to Section 202 of the Federal Land Policy Management Act ("FLPMA"). The Trust Lands Administration's comments are submitted in response to BLM's request for scoping comments on the plan amendment process published in the Federal Register on March 18, 1999.

Introduction

The Trust Lands Administration is the state agency responsible for management of lands granted by Congress to the State of Utah in trust at statehood for the financial support of Utah's public schools, universities, and other state institutions. In managing these lands, the Trust Lands Administration has the fiduciary responsibilities of a trustee, and is required by law to seek maximum long-term financial gain from the lands for the benefit of the state's public schools and other beneficiary institutions.

The Trust Lands Administration does not oppose the designation of additional WSAs per se. Protection of outstanding lands as wilderness is a worthy goal for BLM to pursue, and the Trust Lands Administration supports a reasonable resolution of the public controversy over the designation of BLM wilderness in Utah. At the same time, the Trust Lands Administration is extremely concerned with the potential impact of the current WSA planning project upon its ability to manage and utilize trust lands. The Trust Lands Administration currently manages approximately 3.5 million acres of surface lands within Utah, plus an additional 1 million acres of severed mineral estate. A preliminary review the Trust Lands Administration's records indicates that there may be in excess of 466,000 acres of trust land that will be affected by BLM's current WSA planning. When this figure is added to approximately 134,000 acres of trust lands captured by existing WSAs, the total trust lands acreage potentially affected by BLM's wilderness management is approximately 600,000 acres - over one sixth, or fifteen percent, of the Trust Lands Administration's surface land base.

The Trust Lands Administration recognizes that any WSA designation will, as a legal matter, affect only BLM lands. Nonetheless, it has been the historic experience of the Trust Lands Administration that the creation of WSA boundaries that contain inheld state parcels markedly decreases the economic return from the state lands, whatever their legal status. The unavailability of surrounding federal lands due to WSA status discourages mineral leasing, exploration, and development on inheld trust lands, since many mineral development opportunities overlap ownership boundaries or require larger tracts to be economically feasible. Road and way closures associated with the creation of WSAs also has limited physical access to inheld trust lands, with additional impacts upon the lands suitability for mineral and surface development.

When exchanges of trust lands inholdings are considered after the passage of time from the WSA designation, the decline in mineral and surface leasing and development caused by the designation tends to influence valuation of trust land inholdings. Mineral appraisers point to the lack of mineral development as evidence that values are low, when in fact it is possible that such development might well have occurred had the WSA designation not been in place.

The Trust Lands Administration appreciates recognition by BLM during the reinventory process that it may be necessary to exchange trust lands out of designated wilderness areas for BLM lands elsewhere in the state. Trust Lands Administration staff have successfully worked with BLM to conclude the recent large land exchange of trust lands pursuant to the Utah School and Lands Exchange Act of 1998 (Public Law 105-335), and look forward to good faith negotiations on future exchanges associated with BLM wilderness. However, BLM's willingness to consider future exchanges is, in itself, insufficient to address the issue of inheld trust lands, since many problems complicate the exchange process.

If BLM does wish to include trust lands in additional WSAs, the planning process should address at least the following issues: (i) BLM has indicated in the past that it will not consider exchanges of trust lands until Congress acts to make WSAs actual wilderness, yet trust lands may be trapped in WSAs for decades in the interval; (ii) BLM's existing land use plans do not classify for disposal nearly enough BLM land to exchange for the almost 600,000 acres of trust lands in existing or proposed WSAs; (iii) as a practical matter, BLM does not have the staff or funding to complete administrative exchanges of this quantity of land within a reasonable period; and (iv) BLM appraisal standards do not adequately address the negative influence on the value of inheld trust lands caused by the WSA designation itself.

In addition to problems with exchanges, the Trust Lands Administration has concerns about procedural and substantive problems with both BLM's wilderness reinventory and the current WSA planning process. The hasty and non-public nature of BLM's reinventory of the subject lands, and the very brief period provided for public evaluation and comment during the current WSA planning process, have raised questions about the fairness and impartiality of BLM's decision-making process. The Trust Lands Administration recommends that BLM either: (i) stay the current planning process and re-open the reinventory for public comment and involvement; or (ii) significantly extend the current scoping period to permit adequate "ground-truthing" of the reinventory findings by all affected parties. Doing so would help ensure that any final decision to create new WSAs would have a better factual basis, and would be better supported by the public and affected governmental entities.

In addition to these general comments, the Trust Lands Administration also submits the following specific comments with respect to the WSA planning process. These comments are arranged in the following order: (1) comments with respect to flaws in the reinventory process; (2) comments with respect to the procedures being followed in the current WSA planning process; (3) general comments with respect to resource uses in proposed WSAs; (4) general comments with respect to manageability issues; (5) general comments with respect to the wilderness characteristics of proposed WSAs; (6) general comments with respect to other issues; and (7) specific comments concerning these issues, itemized by individual proposed WSA.

1. THE RE-INVENTORY PROCESS

A. Section 201 of FLPMA does not provide BLM with authority to conduct an inventory for the single resource value of wilderness. Authority for a single-purpose wilderness inventory was contained in Section 603 of FLPMA, which has now expired. Section 201 provides for an "inventory of all public lands and their resource and other values...", which implies a multi-purpose inventory. In Utah v. Babbitt, 137 F. 3d 1193, 1207, n. 18 (10^th Cir. 1998), the U.S. Court of Appeals for the Tenth Circuit expressly stated that it was making no finding that BLM had authority to conduct the Utah wilderness reinventory under § 201 of FLPMA.

B. BLM's wilderness reinventory specifically avoided any investigation of non-wilderness values, such as mineral resources or alternative surface uses. Section 202 of FLPMA requires that in the revision of any RMP, BLM must use and observe principles of multiple use, consider present and potential uses of the public lands, and consider the relative scarcity of the values involved (e.g., presence of scarce minerals/coal/oil & gas resources). 43 U.S.C. § 1712 (c). Since the wilderness reinventory contains no information on non-wilderness values and uses, it is arbitrary and unreasonable to rely upon it as the basis for RMP amendments creating new WSAs. Requests for public comment in the current scoping period concerning these additional values are not sufficient to cure this problem, since it is the obligation of BLM, not the public, to maintain the full inventory.

C. Section 202(c)(9) of FLPMA requires BLM to "coordinate the land use inventory" with the land use planning and management activities of the States within which the lands are located. BLM failed to do so, including particularly failure to consult or coordinate with the Trust Lands Administration, or the State of Utah generally, concerning the reinventory. Prior to reliance on the reinventory in the current planning process, BLM should reopen the reinventory and conduct the required consultation and coordination. Reliance on the reinventory in the current planning process without such coordination violates FLPMA and is arbitrary and unreasonable.

D. The Utah Wilderness Review Procedures (the "Utah Handbook") contains significant variations from the Wilderness Inventory Handbook (the "WIH") used in the previous wilderness inventory under §603 of FLPMA. There was no public participation in the creation of the Utah Handbook, as opposed to creation of the WIH, which was subjected to intensive public review. This reflects a change in the position of BLM from the WIH, which stated: "BLM agrees and believes that the best way to arrive at ... judgements is to provide the opportunity for the fullest possible public involvement in the process, including direct participation in the inventory and thorough public review." BLM should have allowed public involvement in the development of the Utah Handbook, including full opportunities for comment regarding deviations from the WIH.

E. The WIH acknowledged that even in applying the definition for road (it is the same in the Utah Handbook) that there will still be a wide range of opinions, in such cases, BLM will seek "[t]he widest possible range of public opinion from diverse points of view . . . Good judgement based on common sense and a balanced and objective analysis of what people say and how they feel is the best guide that can be given." This common sense rule was not followed in the current reinventory.

F. The definition for "road" in both the WIH and the Utah Handbook ignores case law which determined vehicle routes to be roads even if routine mechanical maintenance has not occurred because it is unnecessary due to the presence of stable soils. Ken Brower, 67 IBLA 124 (1982). The Utah Handbook therefore erroneously provides "[v]ehicle routes constructed by mechanical means but which are no longer being maintained by mechanical methods are not roads." Reinventory determinations based upon this statement should therefore be revisited.

G. Secretary Babbitt committed to the Utah Congressional delegation in his July 24, 1996 letter that he would direct the reinventory team "to consider each area on its own merits, solely to determine whether it has wilderness characteristics." The Utah Handbook provides, "[e]ach review unit must be assessed on its own merits as to whether an outstanding opportunity exists." Utah Handbook II.B.3.b. See also Sierra Club - Rocky Mtn Chap., 75 IBLA 220 (1983)(each inventory unit must be assessed on its own merits as to whether an outstanding opportunity exists). Contrary to the foregoing, the Utah Handbook provides that "[w]hen review units are contiguous to WSAs, they should be considered an extension of the WSA so that no additional evaluation of outstanding opportunities is required." On the ground, this can lead to areas that do not have such characteristics being bootstrapped into existing WSAs. For example, the western boundary of the current Desolation Canyon WSA is the cliff line of the Book Cliffs. The reinventory process identified unit 8, an extension of the Desolation Canyon WSA to the west, as having wilderness characteristics. Unit 8 is comprised entirely of unvegetated flatlands below the cliff line. Because of this natural boundary, any "outstanding opportunities" in the Desolation Canyon WSA cannot credibly be extended to unit 8, which is directly adjacent to two power lines, a major highway (U.S. 6), and a major railroad route. The cliff line may insulate visitors to the Desolation Canyon WSA from such human intrusions, but there is no escaping the impact of these human intrusions while within unit 8. The Utah Handbook provides that in assessing "outstanding opportunities" one must be able to avoid the sights, sounds, and evidence of other people in the inventory unit, which cannot be assumed on the basis of an adjacent WSA. The presumption that any lands adjacent to a WSA must also have "outstanding opportunities" is flawed, and the reinventory should be revisited on this basis.

2. THE CURRENT WSA PLANNING PROCESS

A. basic issue for consideration is whether § 202 of FLPMA authorizes wholesale designations of public lands as new WSAs after the expiration of § 603. There is substantial support in statute, legislative history, regulations, IBLA case law, and past policies and statements that suggest that the § 603 process was intended to be the final disposition of the WSA issue with respect to BLM lands, and that the current planning process is therefore not permissible.

B. In considering RMP amendments, BLM is required to provide public involvement and to consider the impact of the proposed amendments on local economies and uses of adjacent or nearby non-federal lands. 43 C.F.R. § 1601.08. In the current process, detailed analysis should be conducted on the impact that creation of new WSAs will have upon local economies by virtue of the withdrawal of any new WSAs from mineral leasing and entry. Similarly, withdrawal of surrounding BLM lands impacts the economic viability and ease of access for inheld trust lands, and a detailed impact analysis should be performed for each unit. As a practical matter, the required consideration of these impacts mandates a detailed mineral inventory and analysis of each proposed WSA, and a weighing of the impacts of WSA designation on local economies and adjacent non-federal lands. The mineral evaluations conducted during the FLPMA §603 process in Utah should be the minimum level of a mineral study. BLM should also consider that identification of all the resources within the units is also necessary to determine the suitability and manageability of the units as wilderness.

C. The Trust Lands Board of Trustees may consider adoption of particular policies regarding the management of trust lands affected by WSA designations. If any such policies are adopted, they will be provided to BLM for consideration in the plan development and consistency review stage. 43 C.F.R. § 1610.3-1(c).

D. The June 21 scoping deadline is too short to permit meaningful public involvement at this stage of the planning process. As described in the re-inventory report, BLM wilderness re-inventory team was composed of approximately 60 members who spent months doing intensive fieldwork, including substantial aircraft time, evaluating these issues, and spent months more preparing the inventory report. Accurate field-checking of this information and responses concerning the specifics of the wilderness characteristics of the subject lands in the time between the March 18 Notice of Intent and the June 21 deadline is not possible, given the large acreage involved. As a result, the Trust Lands Administration has been unable to submit specific information concerning the wilderness characteristics of individual units. Similarly, there is much outside information concerning resource uses of the subject lands that cannot be collected and compiled by June 21. BLM did not permit open public comment on the wilderness characteristics issue at the time it conducted the wilderness re-inventory. In light of the provisions in Section 202(c)(9) of FLPMA and associated regulations requiring BLM to provide meaningful public involvement for state government in all land use planning decisions, the scoping period should have been extended.

E. The Utah Handbook at I.B.4 indicates that the photographs that are taken during the reinventory process "will be important in illustrating how the wilderness characteristics determinations [were] made." All such photos are on slides. For all practicable purposes, interested parties have been unable to fully review these photographs without either spending thousands of dollars on duplication or bringing a slide projector into various BLM offices. BLM has also been unable to produce a full set of copies of the detailed field maps prepared by the inventory teams by the June 21 deadline, which also prevents accurate field-checks of the BLM teams' findings at this time. When coupled with the short time for making comments, these are tangible examples of BLM's current planning timetable rendering meaningful public comment impossible. In the best case, the reinventory should be reopened to permit full public and state government involvement prior to a final reinventory report as well as to allow BLM to reinventory all resources, or alternatively, the scoping period should be reopened or extended to permit full review of the materials described above.

3. RESOURCE USES IN PROPOSED WSAs

A. Prior to completion of draft plan amendments and a draft environmental impact statement ("DEIS"), BLM should complete a full and detailed study of all non-wilderness resource values in each of the proposed WSAs. This study should involve full consultation with, and opportunity to comment by, other land management agencies with knowledge of the resource base (including the Trust Lands Administration), and with United States Geologic Survey, the Utah Geologic Survey, county public land use advisory committees, industry, academia, and the public.

B. Trust Lands Administration records reflect multiple mineral and surface leases and permits, both active and inactive, on trust lands within proposed WSAs. These are indicative of resource values for which the public and industry has been willing to expend funds. This fact, and the impacts of WSA designation on future revenues, should be considered in the required socioeconomic impact analysis.

C. It is apparent from the Utah Wilderness Inventory (the "Wilderness Report") that the reinventory did not consider other resource issues at all. Under FLPMA, BLM has the duty to perform the inventory for all resources and provide full factual justification for its proposed action. While one of the purposes of public involvement is to identify specific information BLM may have missed, this does not mean that BLM may rely solely on the public comments for its primary information gathering activity on a particular issue. BLM has an obligation in the planning process to consider other resources thoroughly on a unit-by-unit basis.

D. The scoping comment period does not provide sufficient time for outside commenters to provide full information on other resources within the proposed WSAs, and should be reopened or extended. See comments above.

4. MANAGEABILITY ISSUES

A. The Trust Lands Administration manages multiple parcels of land within and on the boundaries of the proposed WSAs. BLM correctly notes that the Trust Lands Administration has expressed willingness to consider exchange of these lands for BLM lands elsewhere. As described elsewhere in these comments, there are substantial obstacles to completion of large-scale exchanges of this nature, including the lack of availability of BLM lands for exchange. If no such exchanges can be completed, the Trust Lands Administration has the legal obligation to manage its lands within WSAs to maximize long-term income, which may include mineral or surface development or sale. Possibilities of development on trust lands should be fully analyzed after consultation with the Trust Lands Administration.

B. Judicial authority supports BLM's obligations to provide reasonable access to inheld trust lands notwithstanding any obligation under the IMP or other authority to protect wilderness values on surrounding BLM lands. Utah v. Andrus, 486 F. Supp. 995, 1009 (D. Ut. 1979). This fact should be considered in the planning process, and existing roads or ways providing access to trust lands should be preserved and cherry-stemmed.

C. In many cases, the Wilderness Report proposes trust lands located on the boundaries of existing WSAs for WSA status without proposing any adjacent BLM lands. Since BLM does not have management authority with respect to trust lands, the Trust Lands Administration believes that BLM should not declare trust lands to form the boundary of existing WSAs, or as WSA additions. At the time Congress acts to declare wilderness, the Trust Lands Administration will gladly consider such lands for inclusion in wilderness if satisfactory exchange provisions are available, but until that time, they should not be deemed to have WSA status.

D. The reinventory did not collect factual information on the existence or scope of RS 2477 rights-of-way within the proposed WSAs. This is a factual determination that requires consideration of county road maps and dialogue with the affected counties, but was not done. Without some indication of which RS 2477 rights-of-way exist and their scope, any RMP amendment cannot adequately evaluate the manageability of proposed WSAs for wilderness. The reinventory should be reopened to address this issue, to ensure BLM and the public review and discuss RS 2477 right-of-way permits with affected counties.

E. The reinventory did not collect factual information contained in BLM's own files with respect to existing mineral leases and mining claims within the proposed WSAs, which represent valid existing rights that may affect manageability. The Trust Lands Administration has been able to compile information from BLM's mining claim indices and title plats as to some, but not all, of the individual proposed WSAs. In many instances, these indicate substantial and ongoing interest in mineral development in particular areas and valid existing rights for development of mineral resources. The reinventory should be re-opened so that BLM can identify and document these rights. These rights can be fully documented by BLM and analyzed in the DEIS.

F. For every unit <5,000 acres in size, BLM must provide, in detail, how it is "clearly and obviously" of sufficient size to make practicable its preservation and use in an unimpaired condition. Utah Handbook II.B.1.c.(2) ("It is demonstrated that the unit is clearly and obviously of sufficient size . . . ."); see also Save the Glades Committee, 54 IBLA 215 (1981) (Public support does not establish the practicability of an area's preservation in an unimpaired condition. The presumption must be that for an area <5,000 acres it would not be practicable.)

G. BLM's internet web page states: "[t]he wilderness protection mandate in Section 603 of FLPMA does not apply to WSAs created under the authority of Section 202 (43 USC 1712) of FLPMA. However, as a matter of policy and using the authority of Section 302 (43 USC 1732) of FLPMA, BLM applies a modified form of interim management to FLPMA Section 202 WSAs. The only modification involves mining operations. For FLPMA Section 603 WSAs, existing and new mining operations under the 1872 Mining Law are regulated according to the nonimpairment standard. However, for WSAs created under the authority of Section 202 of FLPMA, existing and new mining operations are regulated only to prevent unnecessary or undue degradation of the lands, not to prevent impairment of wilderness suitability. All other activities in both FLPMA Section 603 and Section 202 WSAs are managed under the nonimpairment standard of the IMP." Applying this nonimpairment standard to any new WSAs will be a violation of FLPMA § 302, which applies an unnecessary/undue degradation standard to WSAs created under § 202. 43 U.S.C. § 1732 ("In managing the public lands the Secretary shall, by regulation or otherwise, take any action necessary to prevent unnecessary or undue degradation of the lands").

H. In addition, the fact that existing and new mining operations in any new § 202 WSA will undisputedly not be regulated under the IMP requires full consideration on an area-by-area basis of the existence of unpatented mining claims.

5. WILDERNESS CHARACTERISTICS

A. As set forth above, accurate field-checking of this information and responses concerning the specifics of the wilderness characteristics of the subject lands in the time between the March 18 Notice of Intent and the June 21 deadline is not possible, given the large acreage involved. As a result, the Trust Lands Administration has generally been unable to submit specific information concerning the wilderness characteristics of individual units.

B. The Utah Handbook requires the inventory team to identify a "road' based upon the definition contained in the Utah Handbook, which requires improvement and maintenance of the route by mechanical means before it qualifies as a road. Annual maintenance is not required and weather can erase evidence of mechanized improvement. It appears from BLM's individual unit files that the inventory teams made in-the-field determinations as to whether a route was a way or road; no documentation whatsoever exists in the field files that county or even BLM maintenance records were consulted to determine if there had been past mechanical construction or improvement. The reinventory is greatly flawed in this respect, and should be reopened to permit research of county and BLM records. As noted above, BLM has the duty to perform the inventory and provide full factual justification for its proposed action. While one of the purposes of public involvement is to identify specific information BLM may have missed, this does not mean that BLM may rely solely on the public comments for its primary information gathering activity on a particular issue. BLM has an obligation in the planning process to conduct full and thorough research on the road issue on a unit-by-unit basis, and any planning decision reached without doing so will be flawed.

C. Multiple vehicle ways exist within the areas classified by the reinventory teams as having wilderness characteristics, yet the reinventory documents contain little discussion of the impact of these ways upon the wilderness characteristics of the particular area. The existence and likelihood of continued vehicular use of these ways (many of which may also have RS 2477 status) should be fully analyzed, which may require re-opening the reinventory.

D. The Wilderness Act specifically requires that for an area to qualify for wilderness it must contain an outstanding opportunity (either an "outstanding opportunity for solitude" or an outstanding opportunity for primitive and unconfined recreation). Each reinventory unit must contain "outstanding" opportunities to be considered for WSA designation. Consequently, to be considered outstanding, an area must either be unique or of greater quality than those of surrounding areas. The Wilderness Society, 66 IBLA 287 (1982). The Utah Handbook provides that an area "does not need to have outstanding opportunities on every acre. There must be outstanding opportunities somewhere in the unit . . . [and that this] is a subjective determination, and, should be made only after a careful assessment of a unit [sic]." Utah Handbook II.B.3.b. While BLM may have some discretion as to this determination, it is not unfettered. A reinventory unit must demonstrate some reasonable ratio of lands without wilderness characteristics (i.e., outstanding opportunities) to those land with such characteristics. The Utah Handbook is misleading in that it states that in determining whether outstanding opportunities exist within the reinventory unit "there must be no comparison among units." Utah Handbook II.B.3.b. This language is derived from Sierra Club - Rocky Mtn Chap., 75 IBLA 220 (1983). However, the intent of this requirement is to prevent any attempt to determine which units contain superior outstanding opportunities - it is sufficient that an unit have outstanding opportunities, it need not be superior to those outstanding opportunities of other units. Therefore, a comparison of the unit to surrounding lands and even other units is not prohibited in assessing whether an unit contains "outstanding" opportunities. Comparison prevents BLM from designating as a WSA every unit that simply has opportunities, whether it contains outstanding opportunities or not. There is little evidence in the Wilderness Report that BLM has truly evaluated whether the various units are actually outstanding.

E. Only units in which the impacts of man are substantially unnoticeable can be deemed to have wilderness characteristics. BLM's reinventory report does not make this finding with some units; for example, the descriptions contained in the Wilderness Report show the following units contain language other than "substantially unnoticeable":

1. Beaver Dam Wash - "relatively unnoticeable"

2. Red Mtn - "indiscernible to casual observers"

3. Deep Creek - "inconspicuous and well screened"

4. Canaan Mtn - "features are considered inconspicuous"

5. Parunuweap Canyon - "insignificant human imprints"

6. Desolation Canyon - "cumulative impact minor"

A reasonable observer might consider that an insignificant or well-screened human impact is still noticeable. The reinventory should be reopened and these units reviewed to determine if human impacts are in fact substantially unnoticeable.

6. OTHER ISSUES

A. Because BLM has chosen to include trust lands within the reinventory, and has justified doing so on the State's willingness to exchange trust lands out of designated wilderness, any plan should consider specific exchange issues, including but not limited to: (i) BLM has indicated in the past that it will not consider exchanges of trust lands until Congress acts to make WSAs actual wilderness, yet trust lands may be trapped in WSAs for decades in the interval; (ii) BLM's existing land use plans do not classify for disposal nearly enough BLM land to exchange for the almost 600,000 acres of trust lands in existing or proposed WSAs; (iii) as a practical matter, BLM does not have the staff or funding to complete administrative exchanges of this quantity of land within a reasonable period; and (iv) BLM appraisal standards do not adequately address the negative influence on the value of inheld trust lands caused by the WSA designation itself. Consideration of these issues is also justified based upon the requirement that BLM consider the impact of any plan amendment on adjacent non-federal lands.

B. Any plan amendments should specifically classify additional BLM lands within the relevant BLM planning area for disposal to the State of Utah, after consultation with the Trust Lands Administration, of a value approximately equivalent to those state trust lands contained in WSAs and not designated for retention by the Trust Lands Administration.

7. SPECIFIC COMMENTS

As set forth above, the Trust Lands Administration does not believe the June 21, 1999 comment deadline provides sufficient time to prepare adequate comments regarding the wilderness characteristics of each proposed unit identified in the Wilderness Report. The Trust Lands Administration must conduct additional field work to provide meaningful comments on this issue. However, the following information is being provided in an attempt to meet BLM's request for scoping comments on the plan amendment process. As such, the following information represents preliminary findings and is in no way exhaustive. The Trust Lands Administration will continue to submit additional comments to BLM for consideration in its plan amendment process.

As previously noted, the Trust Lands Administration is statutorily required to manage all trust lands for the exclusive benefit of the trust beneficiaries. Accordingly, BLM must consider in its plan amendment process that every section of trust lands affected by BLM's proposed action has the potential to be fully developed to realize its full surface and/or mineral potential. In the development of such trust lands, the Trust Lands Administration will actively seek our right to reasonable and economic access from BLM. Such right of ingress and egress to trust lands could reduce the wilderness characteristics of surrounding lands by diminishing the naturalness or solitude of a particular unit, or adversely impacting the manageability of the unit by BLM.

Newfoundland Mountains

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Northern end of the Newfoundland Mountains has high potential for important mineral deposits including gold, silver, and copper, as well as building stone and sand and gravel resources. The Trust Lands Administration currently has no active contracts within the Newfoundland Mountain Unit. Historic Trust Land Administration leases and permits include grazing permits, oil, gas and hydrocarbon and metalliferous mineral leases.

C. Other Relevant Information

The Wilderness Report indicates that 3,000 acres of trust lands are affected by the Newfoundland Mountains Unit. A preliminary review of our records indicates that 8 trust lands sections containing approximately 5,120 acres may be affected by the unit.

Silver Island Mountain

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Silver Island Mountains has high potential for mineral deposits including oil and gas, gold, silver, and copper, as well as known deposits of clay, building stone and sand and gravel resources. The Trust Lands Administration currently administers a special use lease for tracking military planes, grazing permits, metalliferous mineral leases and clay leases trust lands (within the unit). A large mine permit has been approved by the Utah Division of Oil, Gas and Mining in Section 2, Township 2 North, Range 17 West. Historically, the Trust Land Administration has issued a variety of leases and permits include grazing permits, oil, gas and hydrocarbon and metalliferous mineral leases.

C. Other Relevant Information

The Wilderness Report indicates that 4,700 acres of trust lands are affected by the Newfoundland Mountains Unit. A preliminary review of our records indicates that 9 trust sections containing approximately 5,760 acres may be affected by the unit.

Cedar Mountains

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other resources

The Cedar Mountains have moderate to high potential for mineral deposits including phosphate, oil and gas, and deposits of limestone, building stone and sand and gravel resources. The 1991 Utah Statewide Wilderness Study Report indicates that recoverable phosphate and low temperature geothermal resources may exist in the area. The report also indicates that aragonite, copper and gold and silver may occur in the area. The Trust Lands Administration currently administers active oil, gas and hydrocarbon leases within the unit. Historically, the Trust Land Administration has issued a number of oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report indicates that there are no trust lands affected by the Cedar Mountains Unit. A preliminary review of our records indicates that there are 4 trust land sections comprising approximately 2,540 acres of severed mineral interest that may be affected by the unit, but are not accounted for in the Wilderness Report. Mineral development of these trust lands could substantially affect the wilderness qualities and manageability of the unit.

North Stansbury Mountains

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1745-B indicates that the unit contains known limestone and sand and gravel deposits. Furthermore, the unit has a moderate potential for oil and gas resources, and deposits of lead, silver, zinc and copper, which are strategic and critical minerals. The Trust Lands Administration currently administers active grazing permits and metalliferous mineral leases within the unit. Historically, the Trust Land Administration has issued a number of grazing permits, metalliferous mineral leases and oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report indicates that there are 1,240 acres of trust lands affected by the North Stansbury Mountains Unit. A preliminary review of our records indicates that there are 2 sections consisting of approximately 1,280 acres of trust lands that may be affected by the unit. Surface or Mineral development of these trust lands could substantially affect the wilderness qualities and manageability of the unit.

Deep Creek Mountains

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1745-C indicates that the Deep Creek Mountains Unit contains indicated and inferred silver, lead, zinc copper and gold resources. The Trust Lands Administration currently administers an active special use lease in Section 36, Township 10 South, Range 18 West for a water well and storage tank supporting a small gold mining operation. Trust Lands Administration also administers active metalliferous mineral leases and grazing permits in the unit. Historically, the Trust Lands Administration has issued numerous oil, gas and hydrocarbon leases, grazing permits, metalliferous mineral leases and right-of-way and right-of-entry permits in the unit.

C. Other Relevant Information

The Wilderness Report indicates that there are 11,320 acres of trust lands with wilderness characteristics affected by the Deep Creek Mountains Unit. A preliminary review of our records indicates that there are approximately 20 trust sections containing approximately 12,800 acres that may be affected by the unit.

Fish Springs

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1745-A indicates that the unit has potential for high-purity quartizite, limestone and dolomite resources. The unit also has potential for low-temperature geothermal resources and oil and gas resources. The northern end of the Fish Springs Unit is within the Fish Springs Mining District and could contain valuable gold, silver, copper and zinc resources. The Trust Lands currently administers active grazing permits within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon leases within the unit.

In addition, a preliminary investigation of BLM records indicates that this unit contains 17 mining claims and 1 Free Use Permit (Section 25, Township 11 South, Range 15 West). The presence of the mining claims could greatly affect the wilderness characteristics and manageability of the unit if developed. Especially since mining activities associated with the development of the mining claims are not subject to the nonimpairment standard set forth in the Interim Management Policy (the "IMP").

C. Other Relevant Information

The Wilderness Report indicates that there are 2,980 acres of trust lands with wilderness characteristics affected by the Fish Springs Unit. A preliminary review of our records indicates that there are approximately 7 trust sections containing approximately 4,480 acres that may be affected by the unit.

Dugway Mountains

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

There is substantial mining activity on the northern end of the Dugway Mountains Unit. The unit has high potential for gold, silver, lead and zinc. Furthermore, the unit has potential for oil and gas resources. The Trust Lands Administration currently administers active grazing permits within the unit. Historically, the Trust Lands Administration has issued industrial sand, metalliferous and oil, gas and hydrocarbon leases within the unit.

In addition, a preliminary investigation of BLM records indicates that unit contains 1 mining claim. The presence this mining claim could greatly affect the wilderness characteristics and manageability of the unit if developed. Especially since mining activities associated with the development of the mining claims are not subject to the nonimpairment standard set forth in the Interim Management Policy (the "IMP").

C. Other Relevant Information

The Wilderness Report indicates that there are 2,600 acres of trust lands with wilderness characteristics affected by the Deep Creek Mountains Unit. A preliminary review of our records indicates that there are 5 trust sections containing approximately 3,200 acres may be affected the unit.

Rockwell

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The potential for mineral resources within the Rockwell Unit are generally considered low, however, the Trust Lands Administration has historically issued oil, gas and hydrocarbon leases within the unit. The Trust Lands Administration currently administers active grazing permits within the unit.

C. Other Relevant Information

The Wilderness Report indicates that there are 1,340 acres of trust lands with wilderness characteristics affected by the Rockwell Unit. A preliminary review of our records indicates that there are 3 trust sections containing approximately 1,920 acres that may be affected the unit.

Oquirrh Mountains

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Oquirrh Mountains Unit has the potential for valuable copper, gold and silver resources. The Trust Lands Administration currently administers active metalliferous mineral leases within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon and metalliferous mineral leases within the unit.

C. Other Relevant Information

The Wilderness Report indicates that no trust lands are affected by the Oquirrh Mountains Unit. A preliminary review of our records indicates that there are approximately 640 acres of severed trust land mineral interest in Section 32, Township 2 South, Range 4 West of which the Wilderness Report did not account for or considered.

Pilot Range

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Pilot Mountains Inventory Unit has potential for valuable building stone, sand and gravel, and oil and gas resources. Furthermore, the northern end has potential for valuable copper, gold and silver resources. The Trust Lands Administration currently administers active grazing permits and a right-of-way permit within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon and metalliferous mineral lease within the unit.

C. Other Relevant Information

The Wilderness Report indicates that 3,100 acres of trust lands with wilderness characteristics are affected by the Pilot Mountains Unit. A preliminary review of our records indicates that there are 5 sections comprising approximately 3,200 acres that may be affected by the unit. Furthermore, the Trust Lands Administration has identified some of these trust lands as having high value for the location of future telecommunications sites.

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1749-A indicates that the Swasey Mountain Inventory Unit has potential for limestone, quartzite, sand and gravel, and oil and gas resources. The Trust Lands Administration currently administers active grazing permits within the unit. Historically, the Trust Lands Administration has issued grazing permits and oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report lists 5,520 acres of trust lands with wilderness characteristics that are affected by the Swasey Mountain Unit. A preliminary review of our records indicates that there are 10 sections comprising approximately 6,400 acres that may be affected by the unit.

Notch Peak

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1749-C indicates that the Notch Peak Inventory Unit is within the Notch Peak mining district and has potential for valuable tungsten, molybdenum, gold, copper, uranium and thorium, limestone and sand and gravel resources. Furthermore, the unit may also contain valuable timber resources. The Trust Lands Administration currently has an active grazing permit and a metalliferous mineral lease within the unit. Historically, the Trust Lands Administration has issued metalliferous mineral leases, oil, gas and hydrocarbon leases, building stone leases, limestone leases, right-of-entry permits and timber permits within the unit.

C. Other Relevant Information

The Wilderness Report found that 2,060 acres of trust lands with wilderness characteristics are affected by the Notch Peak Unit. A preliminary review of our records indicates that there are 7 trust land sections containing approximately 4,480 acres that may be affected by the unit.

Howell Peak

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1749-A indicates the Howell Peak Unit has the potential for high-purity limestone, quartzite, sand and gravel, oil, gas and hydrocarbons, lead, zinc, copper, molybdenum, silver and gold resources. A preliminary review of our records indicates that the Trust Lands Administration currently has no active permits within the unit.

C. Other Relevant Information

The Wilderness Report found that 200 acres of trust lands had wilderness characteristics. A preliminary review of our records indicates that there are 2 sections comprising approximately 1,280 acres that may be affected by the unit.

Conger Mountain

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Conger Mountain Unit has the potential for beryllium, tungsten, lead and zinc, and oil, gas and hydrocarbon resources. The Trust Lands Administration currently administers active grazing permits within the unit. Historically, the Trust Lands Administration has issued grazing permits, oil, gas and hydrocarbon leases and metalliferous mineral leases within the unit.

C. Other Relevant Information

The Wilderness Report determined that 1,800 acres of trust lands within the Conger Mountain Unit had wilderness characteristics. A preliminary review of our records indicates that there are 4 sections comprising 2,560 acres that may be affected by the unit.

King Top

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The northern part of the King Top Inventory Unit has high potential to contain gold, silver, mercury, barium, copper, lead and zinc deposits. Numerous exploratory holes have been drilled in the unit delineating commercial grades of gold and silver. The unit also has high potential for oil and gas resource. Furthermore, the unit has the potential for beryllium and tungsten resources. The Trust Lands Administration currently administers active grazing permits and metalliferous mineral leases within the unit. Historically, The Trust Lands Administration has issued grazing permits, metalliferous mineral leases and oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report found 2,120 acres of trust lands with wilderness characteristics. A preliminary review of our records indicates that there are 8 trust land sections comprising approximately 5,120 acres that may be affected by the unit.

North Wah Wah Mountains

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1749-B reports that the North Wah Wah Mountains Unit has identified iron, limestone, dolomite, sandstone and quartzite, and volcanic rock resources within the unit. The Bulletin also reports the unit possesses moderate potential for oil and gas, and the potential for zinc, cadmium, antimony, molybdenum, lead, arsenic, bismuth, tungsten and gold deposits. The Trust Lands Administration currently administers active grazing permits, and oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report indicates that 4,200 acres of trust lands have wilderness characteristics within the North Wah Wah Mountains Unit. A preliminary review of our records indicates that there are 8 trust sections comprising approximately 5,120 acres that may be affected by the unit.

Central Wah Wah Mountains

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Pine Grove Molybdenum Complex bounds the Central Wah Wah Mountains Unit on the southern end. The unit has high potential for additional molybdenum resources. The unit also possesses moderate potential for oil and gas, and the potential for zinc, cadmium, antimony, lead, arsenic, bismuth, tungsten and gold deposits. The Trust Lands Administration currently administers active grazing permits, and oil, gas and hydrocarbon leases within the unit. Historically, the Trust Lands Administration has issued permits and leases for grazing, oil, gas and hydrocarbon, metalliferous minerals, and right-of-entry permit within the unit.

C. Other Relevant Information

The Wilderness Report indicates that 6,300 acres of trust lands have wilderness characteristics within the Central Wah Wah Mountains Unit. A preliminary review of our records indicates that there are 11 trust sections comprising approximately 7,040 acres that may be affected by the unit.

Granite Peak

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Granite Peak Unit has moderate to high potential for pumice, iron, gold, silver, copper, lead and zinc resources. The unit also possesses moderate potential for geothermal resources, and volcanic material and low potential for oil and gas resources. The unit has excellent potential for recreational cabin site developments. The Trust Lands Administration currently administers active grazing permits, volcanic material leases and a right-of-way permit within the unit. Historically, the Trust Lands Administration has issued permits and leases for geothermal resources, metalliferous minerals, oil, gas and hydrocarbons, and volcanic materials, as well as special use leases for recreational and industrial purposes within the unit.

C. Other Relevant Information

The Wilderness Report found that 2,400 acres of trust lands possessed wilderness characteristics. A preliminary review of our records indicates that there are 6 trust land sections consisting of within the unit approximately 3,800 that may be affected by the unit.

White Rock Range

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The trust lands within the unit have excellent potential for cabin site developments.

C. Other Relevant Information

The Wilderness Report found that 200 acres of trust lands possessed wilderness characteristics and no federal lands possessed wilderness characteristics within the White Rock Range Unit. BLM has no authority for planning activities on trust lands, therefore the White Rock Range Unit can not be designated as federal wilderness, consequently it should be eliminated as a proposed wilderness study area.

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Narrows Unit contains moderate potential for gold, silver, lead, zinc, copper and iron deposits and a low potential for oil and gas resources. The Trust Lands Administration has active grazing permits and a metalliferous minerals lease within the unit. Historically, the Trust Lands Administration has issued metalliferous mineral and oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report found that there are 1,100 acres of trust lands with wilderness characteristics within the unit. A preliminary review of our records indicates that there are 4 sections comprising approximately 1,360 acres that may be affected by the unit.

Joshua Tree

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Joshua Tree Unit contains moderate to high potential for metalliferous mineral resources and low to moderate potential for oil and gas resources. Furthermore, the unit has valuable timber resources. The Trust Lands Administration currently administers active grazing permits and a right-of-way permits on trust lands within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon leases on lands within the unit.

C. Other Relevant Information

The Wilderness Report found 900 acres of trust lands with wilderness characteristics within the Joshua Tree Unit. A preliminary review of our records indicates that there are 2 sections encompassing approximately 1,280 acres that may be affected by the unit.

Beaver Dam Wash

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Beaver Dam Wash Unit has low to moderate potential for mineral resources and low to moderate potential for oil and gas resources. Trust Lands Administration currently administers active grazing permits on trust lands within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon and metalliferous mineral leases within the unit.

C. Other Relevant Information

The Wilderness Report found 2,200 acres of trust lands with wilderness characteristics within the Beaver Dam Wash Unit. A preliminary review of our records indicates that there are 5 sections encompassing approximately 2,560 acres affected by the unit.

Red Mountain

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

Trust Lands within the Red Mountain Unit have high potential for surface development and sale. USGS Bulletin 1746-D reports common variety building stone and silica sand are present within the Unit. Furthermore, the unit has high potential for low-temperature geothermal resources, and low potential for metallic minerals and oil and gas resources.

C. Other Relevant Information

The Wilderness Report found 1,100 acres of trust lands with wilderness characteristics in the Red Mountain Unit. All trust lands within the Red Mountain Unit are considered suitable for surface sale. BLM has no planning authority on trust lands. Consequently, BLM should discontinue any further consideration of the wilderness characteristics of the trust lands and consider the effect of their sale and/or development upon the wilderness characteristics and manageability of the unit in its planning process.

Orderville Canyon

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1746-E reports that the Orderville Canyon Unit has moderate potential for oil and gas, and low potential for coal, metals and geothermal resources. The Bulletin also reports deposits of gypsum, common sandstone and limestone resources. Currently the Trust Lands Administration has an active grazing permit within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon lease, and coal leases within the unit.

C. Other Relevant Information

The Wilderness Report found 900 acres of trust lands with wilderness characteristics in the Orderville Canyon Unit. However, certain trust lands within unit 1 are for sale and others are considered excellent candidates for future land sales. Accordingly, all trust lands within the Orderville Canyon Unit are considered suitable for surface sale or other surface development activities. BLM has no planning authority on trust lands. Consequently, BLM should discontinue any further consideration of the wilderness characteristics of the trust lands and consider the effect of their sale and/or development upon the wilderness characteristics and manageability of the unit in its planning process.

Deep Creek

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Deep Creek Unit has low potential for oil and gas resources and metalliferous mineral resources. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon leases in the Deep Creek Unit.

C. Other Relevant Information

The Wilderness Report found 80 acres of trust lands with wilderness characteristics in the Deep Creek Unit. However, the trust lands within the Deep Creek Unit excellent potential for future land sale. BLM has no planning authority on trust lands. Consequently, BLM should discontinue any further consideration of the wilderness characteristics of the trust lands and consider the effect of their sale and/or development upon the wilderness characteristics and manageability of the unit in its planning process.

Spring Creek Canyon

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Spring Creek Canyon Unit is completely comprised of trust lands, which are considered suitable for surface sale or other surface development activities. The developed water source for the town of Kannarraville is within this unit.

C. Other Relevant Information

The Wilderness Report found 1,440 acres of trust lands with wilderness characteristics within the unit and no federal lands possess wilderness characteristics within the Spring Creek Canyon Unit. BLM has no planning authority on trust lands, therefore the SpringCreek Canyon Unit cannot be designated as a federal wilderness, consequently it should be eliminated as a proposed wilderness study area.

Black Ridge

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Black Ridge Unit has low potential for oil, gas and hydrocarbon resources; low to moderate potential for metalliferous resources; and high potential for sand and gravel resources. The Trust Lands Administration currently administers an active grazing permit and a metalliferous mineral lease within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon leases, metalliferous mineral leases, gemstone/fossil leases, and sand and gravel permits within the unit.

C. Other Relevant Information

The Wilderness Report found that 1,700 of trust lands within the Black Ridge Unit possessed wilderness characteristics. A preliminary review of our records indicates that there are 3 sections comprising approximately 1,920 acres that may be affected by the unit.

Canaan Mountain

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

Certain trust lands within the Canaan Mountain Unit have high potential for surface sale and/or development. The Trust Lands Administration currently administers an active grazing permit within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon leases, and a special use lease for surface activities.

C. Other Relevant Information

The Wilderness Report found 1,300 acres of trust lands with wilderness characteristics in the Canaan Mountain Unit. A preliminary review of our records indicates that there are 3 trust land sections comprising 1,920 acres may be affected by the unit. Furthermore, the Trust Lands Administration has received numerous inquiries regarding the sale of certain trust lands within this unit. Consequently, BLM should discontinue any further consideration of the wilderness characteristics of the trust lands and consider the effect of their sale and/or development upon the wilderness characteristics and manageability of the unit in its planning process.

Parunuweap Canyon

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1746-B reports that the Parunuweap Canyon Unit has moderate potential for oil and gas resources; low to moderate potential for metalliferous resources; and high potential for common varieties of limestone, sandstone and gravel deposits. The unit also has potential for valuable gypsum deposits. Currently the Trust Lands Administration administers active grazing permits on trust lands within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon leases and right-of-way permits within the unit.

C. Other Relevant Information

The Wilderness Report found 2,290 acres of trust lands with wilderness characteristics within the Parunuweap Canyon Unit. A preliminary review of our records indicates that there are 5 section comprising 3,200 acres that may be affected by the unit.

Moquith Mountain

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Moquith Mountain Unit may have low to moderate potential for oil and gas resources and low potential for metalliferous and other mineral resources. The Trust Lands Administration currently administers active grazing permits, right-of-way permit and a special use lease for a water well within the unit. Historically, the Trust Lands Administration has also issued oil, gas and hydrocarbon leases within the Moquith Mountain Unit.

C. Other Relevant Information

The Wilderness Report found 2,090 acres of trust lands with wilderness characteristics within the Moquith Mountain Unit. A preliminary review of our records indicates that there are 5 sections comprising 2,640 acres may be affected by the unit.

Upper Kanab Creek

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Upper Kanab Creek Unit has moderate potential for oil, gas and hydrocarbon resources; potential for coal and coalbed methane resources along the western boundary; and potential for valuable sand and gravel deposits. The Trust Lands Administration currently administers active grazing permits and right-of-way permits within the Upper Kanab Creek Unit.

C. Other Relevant Information

The Wilderness Report found 5,900 acres of trust lands with wilderness characteristics in the Upper Kanab Creek Unit. A preliminary review of our records indicates that there are 10 trust land sections consisting of approximately 6,400 acres of trust lands that may be affected by the unit. In its planning process BLM should consider the fact that the unit is immediately adjacent to the Grand Staircase Escalante National Monument however it was not found to possess qualities necessary to be included within the boundaries of the monument.

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

Trust lands located within Unit 3 have high potential for surface development and/or sale.

C. Other Relevant Information

Section 16 of Township 37 South, Range 1 East (Unit 3) of the Mud Spring Canyon Unit is owned by the Trust Lands Administration. These trust lands were not included in the Utah School and Land Exchange Act of 1998 (Public Law 105-335) and were retained specifically for their high potential for development and/or sale. Consequently, BLM should discontinue any further consideration of the wilderness characteristics of the such lands and consider the effect of their sale and/or development upon the wilderness characteristics and manageability of the unit in its planning process.

Wahweap-Death Ridge

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

Unit 13 contains lands that were recently acquired by the Trust Lands Administration as a result of Utah School and Land Exchange Act of 1998 (Public Law 105-335). These lands were specifically targeted for their high potential for development and/or sale.

C. Other Relevant Information

The Wilderness Report fails to acknowledge the Trust Lands Administration acquisition of lands within the unit as a result of Public Law 105-335. A preliminary review of our records indicates that there are 7 trust land sections consisting of approximately 4,480 acres of trust lands that may be affected by the unit. As previously noted, these land were specifically targeted for their high potential for development and/or sale. Consequently, BLM should discontinue any further consideration of the wilderness characteristics of the such trust lands and consider the effect of their sale and/or development upon the wilderness characteristics and manageability of the unit in its planning process.

Nipple Bench

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

This unit contains lands that were recently acquired by the Trust Lands Administration as a result of Utah School and Land Exchange Act of 1998 (Public Law 105-335). These lands were specifically targeted for their high potential for development and/or sale. The Trust Lands Administration currently administers an active grazing permit, easement, oil and gas lease, and a number of right-of-entry permits within the unit. Historically, this Trust Lands Administration has issued a coal lease within the unit.

C. Other Relevant Information

The Wilderness Report found 3,600 acres of trust lands with wilderness characteristics in the unit, however, the Wilderness Report fails to acknowledge the Trust Lands Administration acquisition of additional lands within the unit as a result of Public Law 105-335. A preliminary review of our records indicates that there are 7 trust land sections consisting of approximately 4,480 acres of trust lands that may be affected by the unit. As previously noted, these land were specifically targeted for their high potential for development and/or sale. Consequently, BLM should discontinue any further consideration of the wilderness characteristics of the trust lands and consider the effect of their sale and/or development upon the wilderness characteristics and manageability of the unit in its planning process.

Carcass Canyon

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The trust lands located within Unit 6 of the Carcass Canyon Inventory Unit have a high potential for surface development and/or sale.

C. Other Relevant Information

The West ½ of Section 32, Township 35 South, Range 3 East (part of Unit 6) of the Carcass Canyon Unit is owned by the Trust Lands Administration. These lands were not included in the Utah School and Lands Exchange Act of 1998 (Public Law 105-335) and were retained specifically for their high potential for development and/or sale. Consequently, BLM should discontinue any further consideration of the wilderness characteristics of the lands and consider the effect of their sale and/or development upon the wilderness characteristics and manageability of the unit in its planning process.

North Escalante Canyons

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

Certain trust lands within Unit 9 of the North Escalante Canyons Inventory Unit are currently planned for development, while the remaining trust lands parcels have high potential for surface development and/or sale.

C. Other Relevant Information

Part of Section 2, Township 33 South, Range 4 East (Unit 9) of the North Escalante Canyons Inventory Unit is owned by the Trust Lands Administration. These lands were not included in the Utah School and Lands Exchange Act of 1998 (Public Law 105-335) and were retained for their high potential for development and/or sale. Specifically, some of these lands are planned for low-density environmentally sensitive residential development. Consequently, BLM should discontinue any further consideration of the wilderness characteristics of the trust lands and consider the effect of their sale and/or development upon the wilderness characteristics and manageability of the unit in its planning process.

Fremont Gorge

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Fremont Gorge Unit has moderate potential for oil and gas resources and moderate to high potential for building stone and limestone resources. The Trust Lands Administration currently administers active grazing permits, oil, gas and hydrocarbon leases and building stone/limestone leases within the Fremont Gorge Unit. Certain trust lands within the Fremont Gorge Unit also have excellent potential for surface development and/or sale.

C. Other Relevant Information

The Wilderness Report found 1,400 acres of trust lands with wilderness characteristics within the Fremont Gorge Unit. A preliminary review of our records indicates that there are 4 trust land sections comprising approximately 2,000 acres that may be affected by the unit.

Notom Bench

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Notom Bench Unit has low to moderate potential for oil, gas and hydrocarbon resources, and metalliferous mineral resources. Furthermore, the trust lands within the unit have excellent potential for cabin site developments. The Trust Lands Administration currently administers active grazing permits and right-of-way permits within the unit. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report found 1,500 acres of trust lands with wilderness characteristics in the Notom Bench Unit. However, since these trust lands have excellent potential for cabin site developments BLM should discontinue any further consideration of the wilderness characteristics of the trust lands and consider the effect of their development upon the wilderness characteristics and manageability of the unit in its planning process.

Long Canyon

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Long Canyon Unit has moderate potential for oil, gas and hydrocarbon and low potential for metalliferous mineral resources. The Trust Lands Administration currently administers active oil, gas and hydrocarbon leases and grazing permits within the unit. Historically, the Trust Lands Administration has issued grazing permits and oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report found 1,250 acres of trust lands with wilderness characteristics within the Long Canyon Unit. A preliminary review of our records indicates that there are 2 trust land sections comprising approximately 1,200 acres that may be affected by the unit. BLM should note that approximately 80 acres of trust lands in the SW ¼ Section 36, Township 36 South, Range 9 East were transferred to the United States from the Trust Lands Administration pursuant to PL 105-335.

Mount Ellen-Blue Hills

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The western extent of the unit has moderate to high potential for coal and coalbed methane resources. The Trust Lands Administration currently administers active grazing permits, coal leases, right-of-entry permits, right-of-way permits and special use leases for surface activities. Part of the unit has irrigated pasture. Historically, the Trust Lands Administration has issued oil, gas and hydrocarbon leases, grazing permits, coal leases, metalliferous mineral leases, clay lease and a variety of special use leases for surface activities within the unit.

C. Other Relevant Information

The Wilderness Report found 7,840 acres of trust lands with wilderness characteristics in the Mount Ellen-Blue Hills Unit. A preliminary review of our records indicates that there are 16 sections comprising approximately 10,240 acres that may be affected by the unit.

Furthermore, a preliminary review of BLM records indicates the following within the unit:

- Right-of-Way for transmission line, Secs. 10, 15, 20, 21 22, T 29 S, R 8 E

- Henry Mountains known coal leasing area, Secs. 33 and 34, T 30 S, R 9 E

- Public Water Reservation Secs. 3, 7, 15, 17, T 31 S, R 9 E

- Henry Mountains known coal leasing area,

Secs. 4,5, 7, 18, 19, 20, T 31 S, R 9 E

- Public Water Reservation, Secs. 13, 20, 23, 24, T 30 S, R 10 E

- Henry Mountains known coal leasing area, Sec. 20, T 30 S, R 10 E

- Public Water Reservation, Secs. 29 and 30, T 31 S, R 10 E

- Public Water Reservation, Secs. 19, T 30 S, R 11 E

Bull Mountain

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

There is high potential for gypsum resources and low potential for copper, lead, zinc, molybdenum, silver, gold, uranium and vanadium, coal, oil and gas and geothermal resources. The Trust Lands Administration currently administers active grazing permits within the unit. Historically, the Trust Lands Administration has issued grazing permits, oil, gas and hydrocarbon leases and right-of-entry permits within the unit.

C. Other Relevant Information

The Wilderness Report found 1,400 acres of trust lands with wilderness characteristics within the Bull Mountain Unit. A preliminary review of our records indicates that there are 3 trust land sections comprising approximately 1,920 acres that may be affected by the unit.

Ragged Mountain

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Ragged Mountain Unit has high potential for uranium and vanadium resources; moderate potential for other metalliferous minerals and oil, gas and hydrocarbon resources; and low potential for coal resources. The Trust Lands Administration currently administers active grazing permits, a coal lease, and metalliferous mineral leases within the Ragged Mountain Unit. Historically, the Trust Lands Administration has issued grazing permits, metalliferous mineral leases, oil, gas and hydrocarbon leases, and special use leases for surface activities within the unit.

C. Other Relevant Information

The Wilderness Report found 3,400 acres of trust lands with wilderness characteristics. A preliminary review of our records indicates that there are 8 trust lands sections comprising 5,120 acres that may be affected by the unit.

Mount Pennell

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

Certain trust lands within the Mount Pennell Unit have a high potential for cabin site development or other surface sale or development purposes. The USGS Bulletin 1751-D indicates that the Mount Pennell Unit has high potential for uranium and vanadium resources, and moderate potential for copper, lead, tin, molybdenum, zinc, silver, gold, coal and coalbed methane resources. Furthermore, the unit has potential for conventional oil, gas and hydrocarbon resources. The Trust Lands Administration currently administers active grazing permits, and coal leases within the unit. Historically, the Trust Lands Administration has issued grazing permits, metalliferous mineral leases, oil, gas and hydrocarbon leases, and clay leases within the unit.

C. Other Relevant Information

The Wilderness Report found 10,600 acres of trust lands with wilderness characteristics. A preliminary review of our records indicates that there are 22 trust lands sections comprising approximately 14,080 acres that may be affected by the unit.

Furthermore, a preliminary review of BLM records indicates the following within the unit:

- 1 federal mining claim

- Henry Mountain Known Coal Leasing Area ,

Secs. 24, 25, 26, 35, 36, T 31 S, R 8 E

- Power Water Reservation, Sec. 21, T 31 S, R 8 E

- Henry Mountain Known Coal Leasing Area ,

Secs. 1, 2, 11, 12, 13, 14, 15, 21, 22, 23, 27,28, 29, 32-35, T 32 S, R 8 E

- Power Water Reservation, Secs. 30, 31, T 32 S, R 9 E,

- Power Water Reservation, Sec.12, T 33 S, R 9 E

- Power Water Reservation, Secs. 28, 33, T 32 S, R 10 E

- Henry Mountain Known Coal Leasing Area,

Secs. 20, 21, 28, 29, 36, T 34 S, R 10 E

- Power Water Reservation, Sec. 21, T 35 S, R 10 E

Bullfrog Creek

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Bullfrog Creek Unit has moderate potential for metalliferous mineral resources and low potential for coal, coalbed methane, and low to moderate potential for oil and gas resources. The Trust Lands Administration currently administers active grazing permits, and oil, gas and hydrocarbon leases within the unit. Historically, the Trust Lands Administration has issued grazing permits, oil, gas and hydrocarbon leases and metalliferous mineral leases in the Bullfrog Creek Unit.

C. Other Relevant Information

The Wilderness Report found 3,100 acres of trust lands with wilderness characteristics in the Bullfrog Creek Unit. A preliminary review of our records indicates that there are 7 trust land sections comprising approximately 4,480 acres that may be affected by the unit.

Mount Hillers

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

Certain trust land sections within the Mount Hillers Unit have high potential for cabin site development, telecommunications sites and other surface development purposes. USGS Bulletin 1751-C reports that the unit contains moderate to high potential for uranium and vanadium; moderate potential for copper, lead, zinc, gold, and coal resources; and low potential for conventional oil and gas and geothermal resources. The unit also has moderate to high potential for coalbed methane. The Trust Lands Administration currently administers active grazing permits, and special use leases for surface related activities within the unit. Historically, the Trust Lands Administration has issued grazing permits, metalliferous mineral leases, and oil, gas and hydrocarbon leases in the Mount Hillers Unit.

C. Other Relevant Information

The Wilderness Report found 2,590 acres of trust lands with wilderness characteristics in the Mount Hillers Unit. A preliminary review of our records indicates that there are 7 trust land sections comprising approximately 4,480 acres that may be affected by the unit.

Dirty Devil-French Spring

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Miscellaneous Field Studies Map MF 1754-A reports that the Dirty Devil-French Spring Unit has high potential for tar sands resources, the area is estimated to contain up to 1.6 billion barrels of oil. The unit also has moderate potential for conventional oil and gas uranium, vanadium, sand and gravel, and building stone. Furthermore, the unit has potential for other metalliferous mineral resources. The Trust Lands Administration currently administers active grazing permits, metalliferous mineral leases, oil, gas and hydrocarbon leases, and rights-of-entry permits within the Dirty Devil-French Spring Unit. Historically, the Trust Lands Administration has issued grazing permits, metalliferous mineral leases, and oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report found 18,700 acres of trust lands with wilderness characteristics in the Dirty Devil-French Spring Unit. A preliminary review of our records indicates that there are 32 trust land sections encompassing approximately 20,480 acres that may be affected by the unit.

Furthermore, a preliminary review of BLM records indicates the following within the unit:

- Federal Oil and Gas leases (2 in Unit 5, 2 in Unit 4, 5 in Unit 6)

- Public Water Reservation, Sec. 9, T 28 S, R 12 E

- Public Water Reservation, Sec. 9, T 31 S, R 13 E

- Public Water Reservation, Sec. 23, 34, T 28 S, R 14 E

- Tar Sand Triangle Designated Tar Sand Area, Sec. 36, T 30 S, R 14 E

- Tar Sand Triangle Designated Tar Sand Area, Secs.1-4, 5, 8-16, 21,22, 29, 32, 33, T 31 S, R 14 E

- Tar Sand Triangle Designated Tar Sand Area, Sec. 36, T 29 S, R 15 E

- Tar Sand Triangle Designated Tar Sand Area, Secs. 9, 16, 23-28, 31-36, T 30 S, R 15 E

- Tar Sand Triangle Designated Tar Sand Area, Secs. 1-16, 17, 18, 23-25, T 31 S, R 15 E

- Public Water Reservation Secs. 4, 9, T 31 S, R 15 E

- Tar Sand Triangle Designated Tar Sand Area, Sec. 32, T 29 S, R 16 E

- Tar Sand Triangle Designated Tar Sand Area, Secs. 16 and 32, T 30 S, R 16 E

Little Rockies

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

Certain trust lands within the Little Rockies Unit have high potential for cabin site development and or other surface sale or development activities. USGS Bulletin 1751-A reports that the Little Rockies Unit has moderate to high potential for uranium and vanadium resources and, low potential for metalliferous minerals and oil, gas and hydrocarbon resources. The Trust Lands Administration currently administers active grazing permits, right-of-way permit and a special use lease for surface activities within the unit. Historically, the Trust Lands Administration has issued grazing permits, oil, gas and hydrocarbon leases, metalliferous mineral leases, and an agricultural lease within the unit.

C. Other Relevant Information

The Wilderness Report found 7,800 acres of trust lands with wilderness characteristics in the Little Rockies Unit. A preliminary review of our records indicates that there are 13 trust land sections encompassing approximately 8,320 acres that may be affected by the unit.

Fiddler Butte

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Bulletin 1759-B reports that the Fiddler Butte Unit has high potential for tar sands, with in place resource estimates for the area exceeding 500 million barrels of oil. The report also found that industrial grade dolomite and common sand, gravel, stone and abundant petrified wood are present in the unit. Furthermore, the unit has moderate potential for uranium, vanadium, oil and gas, gold and silver; and low potential for geothermal resources. The Trust Lands Administration currently administers active grazing permits and oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report found 3,180 acres of trust lands with wilderness characteristics in the Fiddler Butte Unit. A preliminary review of our records indicates that there are 6 trust land sections containing approximately 3,840 acres that may be affected by the unit. The 1991 Utah Statewide Wilderness Study Report found that the tar sands potential for portions of the Fiddler Butte Wilderness Study Area outweighed the wilderness values of the area.

Furthermore, a preliminary review of BLM records indicates a Public Water Reservation in Sections 9 and 16, T. 31, R. 13.

Horseshoe Canyon South

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

USGS Miscellaneous Field Studies Map MF 1754-A reports that the Horseshoe Canyon South Unit has moderate potential for oil and gas, and uranium resources and low potential for other metalliferous minerals and construction materials including sand and gravel and building stone. The Trust Lands Administration currently administers active grazing permits within the unit. Historically, the Trust Lands Administration has issued grazing permits, oil, gas and hydrocarbon leases, metalliferous mineral leases and right-of-entry permits.

C. Other Relevant Information

The Wilderness Report found 5,300 acres of trust lands with wilderness characteristics in the Horseshoe Canyon South Unit. A preliminary review of our records indicates that there are 12 trust land sections encompassing approximately 7,680 acres that may be affected by the unit.

Labyrinth Canyon

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Labyrinth Canyon Unit has high potential for oil and gas resources and potash deposits, moderate potential for uranium resources; and low potential for other metalliferous mineral resources. The Trust Lands Administration currently administers active grazing permits, oil, gas and hydrocarbon leases, and potash leases within the unit. Historically, the Trust Lands Administration has issued grazing permits, oil, gas and hydrocarbon leases, metalliferous mineral leases, potash leases, right-of-entry permits and special use leases for surface activities.

C. Other Relevant Information

The Wilderness Report found 8,000 acres of trust lands with wilderness characteristics in the Labyrinth Canyon Unit. A preliminary review of our records indicates that there are 19 trust land sections encompassing approximately 12,160 acres that may be affected by the unit.

Cedar Mountain

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Cedar Mountain Unit has low to moderate potential for oil, gas and hydrocarbon resources, and low potential for metalliferous mineral resources. The Trust Lands Administration currently administers active grazing permits and oil, gas and hydrocarbon leases within the unit. Historically, the Trust Lands Administration has issued grazing permits, metalliferous mineral leases and oil, gas and hydrocarbon leases within the unit.

C. Other Relevant Information

The Wilderness Report found 2,200 acres of trust lands with wilderness characteristics in the Cedar Mountain Unit. A preliminary review of our records indicates that there are 4 trust land sections encompassing approximately 2,560 acres that may be affected by the unit.

Devils Canyon

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Devils Canyon Unit has low to moderate potential for oil, gas and hydrocarbon, and gypsum resources. Furthermore, the unit has potential for metalliferous minerals, tar sands, and geothermal resources. The Trust Lands Administration currently administers active grazing permits and gypsum leases within the unit. Historically, the Trust Lands Administration has issued grazing permits, and oil, gas and hydrocarbon leases.

C. Other Relevant Information

The Wilderness Report found 1,140 acres of trust lands with wilderness characteristics in the Devils Canyon Unit. A preliminary review of our records indicates that there are 3 trust land sections encompassing approximately 1,920 acres that may be affected by the unit.

Hondu Country

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Hondu Country Unit has low to moderate potential for sand and gravel and building stone resources, and low potential for oil, gas and hydrocarbon, and metalliferous mineral resources. The Trust Lands Administration currently administers active grazing permits within the unit. Historically, the Trust Lands Administration has issued grazing permits and oil, gas and hydrocarbon leases.

C. Other Relevant Information

The Wilderness Report found 2,200 acres of trust lands with wilderness characteristics in the Hondu Country Unit. A preliminary review of our records indicates that there are 5 trust land sections encompassing approximately 3,200 acres that may be affected by the unit.

Limestone Cliffs

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The Limestone Cliffs Unit has moderate to high potential for coal, and coalbed methane resources; moderate potential for clay and common varieties of building stone and limestone resources; and low potential for conventional oil, gas and hydrocarbons and metalliferous mineral resources is low. The Trust Lands Administration currently administers active grazing permits, coal leases and oil, gas and hydrocarbon leases within the unit. Historically, the Trust Lands Administration has issued right-of-way permits, coal leases, clay leases, and oil, gas and hydrocarbon leases.

C. Other Relevant Information

The Wilderness Report found 3,800 acres of trust lands with wilderness characteristics in the Limestone Cliffs Unit. A preliminary review of our records indicates that there are 8 trust land sections encompassing approximately 5,120 acres that may be affected by the unit.

Jones Bench

A. Wilderness Characteristics

Unknown at this time. See comments above.

B. Other Resources

The