Sunday, May 3, 2015

Study 3: The Adjacent Lands Study -- Final Report November 1981


From a vigorous, pro-Park System stance in 1976, the final report on potential park land five years later had declined to end up as a comfort to the hunters and ranchers who had been the only ones to make their opinions felt.* Of little interest or pride to the authoring agencies, a May draft was made known through the Federal Register and some local agencies. I.e., notice was not sent out to those who had shown interest during the process; I have nothing in my files to indicate I even knew about the draft. No surprise, then, that (page 6) "response to the Public Review Draft was negligible", though what there was "agreed with the study team's findings". A whimper, indeed.

Fifty pages long, the report's major topics were the story of the study itself, followed by descriptions of the Canyon and the Arizona Strip. The study area's environment, archeology, and land uses were covered, with the conclusions contained in Management Considerations, Options, and Recommendations. The report remains notable for a series of maps that present snapshots of conditions in the area as of 1980. Even more notable is its demonstration of how one agency, NPS, was hemmed in and forced to knuckle under to the combined pressure of two other agencies, USFS and BLM, protecting their turf.


The report's attenuated legislative history emphasized that the Secretary was to study certain areas, not included in the Park, "to determine if they or any part of them qualify for national park designation". However, once the Secretary selected NPS as lead, with the Forest Service and the Bureau of Management joining, the study area was re-defined to include lands "one mile back from the rims" of the canyon, along with that part of the Shivwits remaining in Lake Mead NRA.  Thus the legislation's 200+ kac was swelled up by the study to 400 kac. Given the actual legislative history, this expanded re-definition was guaranteed to bring out the same opposition as appeared during congressional consideration, with the focus shifted once again to above-rim uses.

No wonder that the issues "centered" on the multiple uses of BLM and the FS, those "historically" used for sport hunting and grazing. How different the study would have sounded had those "historic uses" as practiced on the above-rim lands, been excluded, leaving the study to concentrate on the below-rim Canyon lands where hunting & grazing were at best minor activities. Thus the report could say, "Written comments have also consistently echoed the desire of hunters, wildlife groups, and local ranchers to maintain multiple use designation on the lands IN THE STUDY AREA." (my emphasis) It thus confused and conflated canyons and prime Canyon view spots with lands Park advocates had years before given up on. 

Jumping in this historical review to its conclusions, the study team (p.5) "acknowledged that big game trophy hunting is an important recreational use of the STUDY AREA", and grazing in the STUDY AREA and the rights of grazing allottees are "very important factors" (my emphasis). No wonder that the study team decided to "broaden the scope of the study" -- as it had broadened the study area. Strictly speaking, the team admitted, it was ordered to study only certain lands for their park quality. However, it decided,  "A more equitable concept" would be to look at "their" (the lands') resource values and management needs -- thus shifting "their" from strictly defined lands of possible park quality to the multiple use lands they had added to their study. "Useful information" from the public included data on grazing, wildlife, and "land use" -- more multiple-use cards added to the already stacked deck. 

Data collection was described only in general terms, giving no way to evaluate the depth and breadth of their information. The team spent four days in the study area, including helicopter "reconnaissance". [Perhaps this is not relevant, but any lover of the Canyon knows that using air travel is perhaps the worst way to appreciate the size and complexity of the Canyon's values. I have to wonder if any of the team "put their feet on the ground and moved through the country".]

Evaluation of the resources was the "heart" of the study -- their national significance, management needs, and role in maintaining the Canyon's integrity; AND their "existing and potential land use primarily for commercial uses including grazing, timber harvesting, and timber, and for recreation, especially sport hunting". (Keep close watch as we get into the report, and see if you can spot any useful data for "especially sport hunting".) NPS criteria were used to judge the national significance of the resources, while each agency's own policy statements were used to determine management practices and agency capabilities. 

The report then asserts there was "public review" of the draft report because a "Notice of Availability" appeared in the Federal Register (every citizen's regular reading). Drafts also went to individuals and agencies indicating interest (my files do not indicate any of this). The general public in the region could go to a local government, Chamber of Commerce (sic!), or public libraries. After 45 days, there had been "negligible" response, all of which agreed with the findings of this report. The stacked deck had been used in a game played in a closed house.


The putative focus of the report, the "Grand Canyon Region", is described in half a page of broad strokes, accompanied by an equally informative map. This was followed by three pages of facts and figures on "The Arizona Strip". Five million acres, almost all federal land, with a sparse population almost all along the Arizona-Utah border. (Interestingly, there is no mention of the Kaibab Paiutes, whose reservation on the Strip's north ought to have brought some comment.) "Of little economic diversity", the area has "limited economic opportunities". (Interestingly again, these conditions, leading to "resulting out-migration" did not lead the study team to suggest how significant the Park was and could become.) Access was by dirt roads and trails.

The economy was in grazing and timber, and there is "potential for expansion in recreation and service sectors". Hunting provides the largest group of visitors. Unfortunately, there was no attempt made to distinguish between different parts of the Strip. Does this "group", for instance, include all hunters on the Kaibab, as opposed to those who actually travel into the "study area", or most relevantly, those who go into the canyons that were supposed to be the study subject?

Mining was quiet, though copper and uranium had seen some significant production. (They had their blinders on, here, for not learning more about the uranium and its potential for environmental damage as well as economic boom-and-bust cycles.) The dominant economy was grazing, with all operators living on the Strip's margins. The tourism magnet of the Strip, the Canyon's North Rim, is ignored.

A most significant map, in historical terms, follows on Land Ownership:

On the bottom is the Hualapai Reservation. Winding along above that is the dark gray Grand Canyon NP, and the area with diagonals is part of Lake Mead NRA. The large swath going up to the top is BLM lands. The rest, mostly scattered townships, are state and private (a little hard to tell apart, private lands have lines running east-west; state sections add north-south lines on top of those). The study area boundary is drawn free-form in two pieces, Kanab on the right, Whitmore to the Shivwits on the left. 

There are significant patches of mostly private checker-boarding just above the LMNRA boundary in two places. More significant is the near-total lack of private/state acreages in the prime areas for Park addition. Since there is no written commentary in the report, we cannot know what the study team made of this information. However, we know how Lake Mead and BLM thoughts about those lands turned out --  here is the BLM Arizona Strip map of 20 years later:

Gone. Almost all the private and state townships near the Canyon (the "study area") have been traded out by NPS and BLM. So at the same time that BLM and the LMNRA administrators were talking up their "multiple use" lands, they were continuing a program of consolidating federal lands near the Grand Canyon. There is no recognition of this thinking in the report, which too often sounds not just like a defense of grazing and hunting as "highest use", but those uses as they were practiced in previous years. I would argue that because this report was written to justify existing agency turfs, there was no incentive for examining on-going trends contrary to uses that were changing and even dying out. This is even more glaringly obvious focussing on the specific canyon and Shivwits lands that we wanted to add. 

A section on "History" follows, with this howler: "The early history of the Arizona Strip country as a whole began with the Church of Jesus Christ of Latter Day Saints (… last part of the 19th century)". Major Powell and other explorers of the Grand Canyon are barely treated. And definitely no Southern Paiutes, who only get a mention 15 pages later after the rocks and bushes are examined. The hundreds of thousands of sheep of the first half of the 20th century, with their "excessive and competitive grazing", get a fuller description. Which is not to say that the latter-day history of the Arizona Strip is not interesting, but why does its grazing element dominate in a report written to deal with Canyon country's Park qualities? Indeed, where is the more relevant story of the fight over the dams and the subsequent upsurge in public interest in the Canyon? Anyway, the History sketch, as with the rest of the report, takes little note of changes that were happening at the time and where they might lead.


Fourteen pages and two maps discuss the biology and the geology. Once again, the report's bias is indicated by the section's  opening phrase: "The Arizona Strip …"  The report listed the following vegetative associations and life zones: riparian (the rarest),  creosotebush, desert shrub, sagebrush, grasslands, pinyon-juniper, cliff rock outcroppings, and ponderosa pine. The importance of fire in p-j country is stressed. Strangely, the ponderosa pine receives no discussion, despite its importance for, e.g., the Shivwits viewing platform. Moreover, there is no shading for ponderosa on the map (only for p-j and some creosote), in spite of its presence on the main projections of the Shivwits into the Canyon, and the evidences of the logging that once took place. A pro-Park, or even a balanced presentation, would have dwelt on the fortuitous combination of ponderosa, distinctive volcanic cover, and the existence of a few, fragile springs on a long, thin peninsula with a variety of viewpoints over a Canyon very different from that seen from Mather Point or the North Rim, and reachable on a road that is its own backcountry experience, leading to a superb campsite. 

Soils receive cursory notice. Ah, but wildlife, especially mule deer, now there's an important subject. In general, though, wildlife is "not abundant", despite water development for cattle that has benefited other fauna. Reptiles, birds, and small mammals are listed, with emphasis given to turkey and partridge. So we learn that Merrimans turkey is a "successful transplant", though only "a small population" is found in a patch of the north Shivwits study area. Quite wonderfully for the Canyon, a partridge from India was introduced and now inhabits canyon drainages "throughout the Strip country". (In 1974, the Game Department clamored about these partridges in the bottoms of Kanab Canyon as another huge loss to the hunting community -- no mention that they were an exotic that had spread "throughout the Strip country".)

A list of other mammals included the pronghorn, which had disappeared (for some unmentioned reason) from the Strip, and then brought back. Desert bighorn "inhabit the study area in lower Kanab Canyon overlapping from the inner canyon". Funny, I thought the "lower" Kanab had been added to the Park in 1975, but now the sheep have gotten into the "study area", although their habitat "is in fair to poor condition" due, guess what, to grazing. (Just to be explicit, what we are hearing is that the reasons Kanab could not go into the Park was because grazing, a multiple use, had destroyed habitat for such as bighorn, which therefore could not be hunted even if not "wasted"  inside the Park.)

The section on mule deer (by far the most on any biology) repeats the usual tired claims: The Strip is a "consistent producer of trophy" animals and the hunt there "accounts for a large part of the visitation". Looking at the second map below, however shows just how huge Hunt Unit 13 is, particularly in comparison to the areas of interest to Park advocates. The report does note that "from the standpoint of mule deer production", the mature p-j areas are not as succulent as in the first stage after a fire. Following November 1, winter range becomes important, a range that is now "fair to poor" due to overgrazing, drought, and fire suppression. (The relationship is not examined of the hunting season dates to when the deer have tried to escape the cold & snow by moving "into the canyons of the various tributary drainages", much less the condition of their winter range inside the Park, where it may be overgrazed, etc.) Conflicts and complementariness between range work (water sources, reseeding, fencing & corrals) and the effect on deer are mentioned. 

Feral burros are cited as the "most conspicuous exotic" and a successful competitor with bighorn. The Park's efforts to affect the burro population are noted, but no mention is made of a feral burro hunting season. [And now, the introduced bison herd east of the Kaibab is migrating up onto the plateau and into the Park; another factor not foreseen by the writers of this report.]

The Grand Canyon National Game Preserve is mentioned for its recognition of the high value of the wildlife habitat in Kanab, although nothing is said of that fact that the Preserve is toothless. Nevertheless, Kanab is "key winter range" inside the Preserve. Moreover, the rims of Kanab and Sowats Canyons contain "The Points", which see a lot of wintering deer use, November through March. (To repeat, that is why we excluded these areas from our Park proposal as passed by the House, and that is why writing up this report to include these rejected areas for Park consideration was so misleading.)
The effort to be misleading is highlighted in the summary on biology: "The biological communities (complicated and evolving through time) of THE STUDY AREA are intrinsically associated with Grand Canyon itself. The plant and animal life of these communities cannot be separated or considered distinct from those of the surrounding lands which have similar environmental characteristics." That is, everything is so mixed up, there cannot be a Park because the values of the Canyon biota are so high as to warrant their being in a Park that would be much bigger than the area we were supposed to study.


Pages 20-27 deal with the very heart of the study, the "Physiography/Geology" of the "Kanab Creek/Andrus/Parashant/Whitmore" study areas that contrast so strongly with the Strip's "gently-rolling, dissected tableland". "These major tributaries … extremely rugged, precipitous terrain typical of the Grand Canyon… provide classic examples of landscape development in nearly horizontal sedimentary rock of varying resistance to erosion". The Grand Wash, Hurricane, and Toroweap fault systems and the Cenozoic lava flows provide significant and unusually good evidences of earth movement.

The accompanying map uses a strong black line for the Coconino Sandstone (pointed to by C) to delineate Canyon country at the study's heart, while at the same time highlighting the southern ends of the two major volcanic covers, the Shivwits Plateau (left V) and, upriver, the Whitmore Canyon (right V). The three big faults are shown as very thin lines running down through the Canyon. 

I paraphrase the detailed descriptions to bring out the report's major points:

The Shivwits is a "series of long, narrow, relatively inaccessible peninsulas", Kelly Point being "the southernmost extension of the north rim". The Canyon surrounds the plateau on three sides, marked by the tributary Surprise/Green Springs, Twin Springs, Burnt Springs, and Tincanebits Canyons. The plateau's basic Kaibab limestone is overlain by Quaternary basalts, marked by the lumps of Mt. Dellenbaugh and Blue Mountain. 

Next, the Andrus-Parashant-Whitmore Canyons are a "deeply incised … major tributary system" between the Shivwits, and on the east, the Uinkarets. The "sharp rise of the inner canyons is broken by the broad [orangey] bench of the Esplanade (with) the upper cliffs then rising sharply to the plateau's surface", three steps in elevation from the river at 1600', to the Esplanade, ~3300', to the plateau, 6000'. Scant vegetation and difficult access mark this area of predominate rock exposure. Spectacular flows remain from the cascades of lava that poured into Toroweap and Whitmore from the Uinkarets. That exposed in Whitmore is recently extruded and essentially unmodified. The area exposes the formations from the Kaibab to the Redwall, which forms the current boundary of the (in this stretch, very narrow) Park. Going upstream in Whitmore, it is filled to the Esplanade with interbedded alluvium.

The Kanab tributary system, the largest on the Canyon's north side, is deeply entrenched between the Kanab and Kaibab Plateaus. The canyons (Hack, Snake, Jumpup, Sowats, and the main stem) are a small and highly dissected -- "dramatic" --  part of a several-thousand-square-mile drainage system. They consist of steep to vertical canyon walls and cliffs dropping to gently sloping benchlands (the Esplanade) and confined canyon bottoms. "The impression is one of a series of canyons within a major canyon". The top six formations of the Canyon form the upper walls, with the Redwall, Supai, and Hermit showing up in the inner canyons.

Evaluating the geology overall, the geologic features of the study areas are their most significant, and "are valuable adjuncts to the geological features" in the current Park. The study areas are all linked to the Park by the generally well-defined uppermost rim of the Kaibab/Toroweap limestone cliffs (though marked on the map above by the Coconino line). The basalt on the Shivwits contains Cenozoic lava of the oldest type in the Canyon region. In contrast, the lava flows in Whitmore are the most recent of that era, and are linked (through the Uinkarets) to those at the mouth of Toroweap. The highly significant and dominant Supai & Hermit formations of the Esplanade are well-exposed throughout the study area and from an integral part of the Canyon's inner portions, continuing on into the Sanup platform above which the Shivwits rises to the west.

[Between the heights of the Shivwits and the Kaibab Plateaus, come the incised Kanab Canyon on the east and the Andrus-Parashant on the west, then the lava-drowned valleys of Toroweap and Whitmore, overlooked by the Uinkarets ridge. Well, the Kanab Plateau between Toroweap and Kanab doesnt fit this pretty symmetry, I suppose.]

The flat plateau of the Strip "contrasts sharply with the relatively barren, vertical landscape of the Grand Canyon and its tributaries at (the Strip's) southern extremity." The contrast is heightened by the viewer suddenly encountering the steep verticality of the Canyon after traveling through many miles of the horizontal land forming the approaches and hinterland of the Canyon.

Each of the three study areas offers "distinct scenic viewing experiences". The Shivwits "affords a variety of spectacular views of the western Canyon" from a series of mesas that provide "a unique viewing platform … not available elsewhere." The Esplanade is "dramatically present",  a "distinctive outer canyon formation consisting of great expanses of sandstone slickrock dotted with potholes and agave." It is not visible [in so spectacular a way] from the south rim. The Andrus/Parashant/Whitmore landscape is a colorful companion drainage into the mainstem canyon. The Esplanade is deeply incised as the first two meet to drain into the Colorado. Whitmore Point offers views of the cut-into broad expanse of the Esplanade dropping sharply into the inner Canyon with a dramatic backdrop provided by the spectacular lavas flows of Whitmore. "Kanab is a vast, rugged, and primitive system of colorful canyons and formations, spectacular vistas and natural beauty." On a smaller scale, their formations, erosional characteristics, and physiographic features are linked to and virtually identical with the Canyon they are part of. There are numerous viewing locations on the surrounding plateau lands. 

"There can be no doubt that the study area lands are physically and visually linked to the Grand Canyon of the Colorado River."

The rugged canyons drain directly into the Colorado; the surrounding plateaus form their rims as they do for the Canyon's north rim. "The scenic qualities … are integrated with and lend additional diversity to the (Park's) viewing experiences." The plateaus function as viewing platforms for the study areas and the Canyon itself. Most notably, there is "a spaciousness and a feeling of isolation derived from a lack of development, distance from urbanization, and the primitive nature of the access roads." The physiography and scenery, most outstanding features, intensify as the viewer gets closer to the River. Therefore, management and use must ensure these lands' visual integrity "in order to protect the integrity of the entire Grand Canyon".


There are no maps for the human history of the study area, and the first sentence of the archeological discussion says the "prehistory … is not well-known". Speaking then of the "Strip region", there was the period, 11 or more millennia ago, of the Paleo-Indian, followed by the Archaic, and after that a time marked by ceramics, a couple of millennia ago. Nothing from the first period has been found in the Strip, while groups of hunter-gatherers left artifacts that continue to puzzle archeologists. The Puebloans occupied the Strip from one to two millennia ago, comprising the Virgin-Kayenta branches. They were "followed" by the Southern Paiute. [I would have added they were the Strip's residents (the Kaibab, Uinkarets, Shivwits bands) until near wiped out by the Spaniards, Navajo, Ute, and Mormon & other whitefolk in the XIXth century; see below.]

The study undertaken for the Suitability Study in 1977 included a partial archeological  inventory. Past surveys were casual and sporadic, and the latest one covered 1% of the study area. A few transects were run, finding indications and isolated artifacts -- aboveground walls, lithic  & sherd scatters, chipping stations, camp sites, cliff granaries, rock art. There could, however, be thousands of sites. A bit of Archaic evidence of hunter-gatherers is known. The number of Virgin-Kayenta occupiers was small; many in the Shivwits area. So maybe the Puebloans came into this marginal section about 1600 b.p., followed by a spread east over several centuries, and then a withdrawal, from Kanab, then all the study area by a millennium ago. The Southern Paiute way of life better fit the Strip's conditions, and lasted until overrun in the XIXth century. 

The sites that were turned up were predominately on the plateau/uplands, not below on the esplanade or drainages. Proximity to reliable water did not seem to matter, the great majority were not within "a reasonable transport distance of water". Agriculture seems to have been of little importance. Instead there may have been a seasonal round of "procurement activities" by people who lived elsewhere. So far, "no permanent habitation sites have been found."

The evaluation concludes that archeology in the study area, sparse though it is, would further the integrity and completeness of study of the Canyon's cultural resources, which so far have concentrated on other evidence. All are part of the Grand Canyon story. 


The description of "Land Use of the Study Area" started with three pages on grazing, continued with two on hunting (titled "Recreation"), and ended with two more on energy, i.e., uranium. These details were followed by an evaluation. 

As i have repeatedly pointed out, by first doubling the study area by including plateau lands within a mile of the rim, and further blurring their focus by talking often about the entire Arizona Strip, the study team was able to present its materials as if any additional park-worthy lands were somehow integral, not to the Canyon, but to a much wider area, largely on the plateaus. This is made obvious in the map below of game management areas and grazing allotments. The game area, Unit 13, covers all of the non-Park Strip up to the Utah border, well past the Grand Wash Cliffs, and to the middle of Kanab Creek. 

The grazing allotments shown included some land already in the Park. Most of the rest were largely outside the study area, with even less, a few bits and pieces, within the prime Park lands, excepting the top of the Shivwits with its extraordinary viewing points.
To show how misleading the study team's wide-net approach was, here are two maps, with the desirable, Park-worthy areas roughly colored in green:

The major factor in understand grazing, the report said, was where the water was, and that was variable, so the operators had to chase forage where water fell or filled. Chaining the vegetation had had varied success, since follow-up was often lacking in reseeding and livestock rotation. Specifically, Kanab Creek was not suitable for grazing "if sound management principles are followed". The study area lands "do provide critical range for some of the local cattle operations", most valuable as winter rangeland. "Severe overgrazing" meant the majority of the range was "in fair or poor condition". "THE RIPARIAN CANYON BOTTOMS HAVE BEEN ESPECIALLY DEGRADED BY OVERGRAZING."(my emphasis), and the Forest Service has had Kanab Creek on "non-use status" for three years. Under BLM, management practices, which since the 1930's have shown mixed results, will set the future trend toward reducing grazing. BLM plans on a Strip-wide AUM reduction of about 25%.

In summary, the lack of dependable water sources and wide range in precipitation limit the study areas' capacity for grazing. So grazing is a "traditionally acceptable use" but "grazing practices have resulted in overgrazing and environmental degradation". Continued grazing … must recognize the areas' limitations. Grazing should be eliminated entirely in riparian locations. [And indeed in the years succeeding this report, the agencies have closed the allotments in the green areas above in LMNRA (now part of Grand Canyon - Parashant N. M.) and Kanab Creek.]

The "Recreation" component of the report was pre-occupied with mule deer hunting, though other values were mentioned. However, in spite of the supposed purpose of the report to look at prime Park areas, the numbers and commentary on the deer are for the huge expanses of Unit 13, and even data from hunt Unit 12A, for the eastern Strip is used to swell the numbers. The 7400 hunter days spent on Unit 13 harvested 300 deer (about 10% of the herd).

Competition with livestock is mentioned. The herd begins its migration from the higher summer range by the start of hunting season. So deer are already on the plateaus and rim lands, and even in the canyons, where hunting can be extremely difficult. Winter weather conditions "must be particularly severe" to force "large concentrations of deer" into "the relatively barren canyons".  In  spite of this descriptive picture, the game managers claimed one-third of the hunting permits would be cut if "Andrus, Parashant, Whitmore and Kanab Canyons proper were closed to hunting", 600-1200 of Unit 13's 1800 permits. However, the report admits, the permit numbers included the lands already moved from LMNRA to the Park in 1975, and in fact, the numbers have not been reduced by the Game Dep't in the five years since those lands were closed. The report admitted that the numbers do "not reflect the actual number of hunters that venture just into the study areas", much less the least accessible lands, i.e., the canyons within the study areas. [This is the gravest criticism of the report, for if there was one statistic that should have been obtained from the state game managers, it was just how many hunters in the late '70's actually went into and tried to hunt on the lands desired and desirable for the Park. In other words, the hunters will be able to continue using their phony statistics covering the whole Strip whenever the question came up of Park expansion that "might" include some of the marginal hunting land.]

In conclusion, recreation, in spite of the small visitation, is "among the highest and best use of these lands". "Recreational hunting in the STUDY AREAS, particularly in the CANYON AND RIMLANDS, is a unique, high-quality experience for a select group of hunters because of the wild and primitive nature of the natural environment. A relatively small number of hunters are willing to undergo the hardships inherent in hunting here such as rugged canyon terrain and limited access. … Minimum contact with other hunters and a true wilderness experience and the potential for a trophy-sized animal have given this area a high reputation among the hunting fraternity." (my emphasis) In short, the possibility for expanding the elitist National Park is to be scuttled to protect the elite hunters.

Speaking of the differences in wildlife philosophy between NPS and the hunter-friendly agencies, the report makes clear that its focus on the enlarged study areas and the Strip itself make the study team's effort useless as a guide to decision-making on the issues they were supposed to pursue. The report clearly favors maintaining the "wilderness qualities of elite hunting" given the increased hunting pressure (by humans) on a shrinking natural base. Permits in the future must be strictly regulated to protect wilderness hunting. 
[Which was not, after all, what the conference committee told the Secretary to worry about. A final sad collapse of any NPS effort to lobby for what Congress had done in trying to recognize, present, and protect the entire Grand Canyon.]


The final resource section dealt with "energy development". First, it wastes some words on oil & gas, totally irrelevant even to their over-blown study areas. Next, more waste to dismiss the idea of geothermal uses. Then, the historical failure of pre-1940's mineral exploitation. Finally, they get to the plethora of uranium-bearing breccia pipes, as shown on this map. [Most seem to already be in the Park; however …]

The pipes, averaging 300' deep by 300' wide, are, most of them, "barren of economic mineralization". Five ore-producing pipes exist in the Canyon region: Hack Canyon, the most focussed-on candidate. Two others, near Parashant & Andrus, are notable only for copper. Nevertheless, not all pipes have been explored, and mineral potential may exist. [And indeed, realization of that potential continues to trouble the Canyon.]


Vast Acreages and remoteness led the study team to ignore the Congressional request and blur their focus by taking the broad view of the area, its climatic conditions and geologic features, especially the erosional characteristics of the region. Going by landform type:

The Uplands (the Shivwits): They are pretty flat and get more rain, so they are low value scenically, but good for grazing [now gone], hunting, and primitive camping. [The Shivwits as a Canyon viewing platform second to none, and as an entry into the western Canyon's canyons, is ignored, although those were the very reasons we proposed adding it to the Park in the first place.]

The Rimlands/Upper Cliffs: Defining the upper rim, these areas have high scenic value. Their difficult terrain limits the biology to sheep and "migrating" mule deer. Hunting, hiking, and sightseeing are suitable.

Upper/tributary Canyons: There is enough riparian habitat for the biology to be valuable. There are archeological and historical remains. Of little interest scenically, they are relatively accessible, so good for hunting among the wintering deer herds. Grazing is not compatible in the riparian areas. 

Esplanade: It lends a high degree of scenic diversity to the cliff landscape. Not much good as wildlife habitat; little frequented by aborigines. [Little did they know what is there. Just as well, I guess.] There are several exposed breccia pipes. No grazing in the Kanab Canyon esplanade, but five allotments partly around the three western canyons "depended upon" the study areas for winter grazing. Mule deer hunting is significant [though they do not have the data to prove it], but mostly because it is a wilderness experience. (Too bad they did not choose to examine possible competition between hunters and non-hunters in these wild places.)

Inner Canyons: Extremely rugged, and susceptible to flash flooding, these canyons offer a high degree of geologic and scenic interest. There are some riparian areas [sic!], but little archeological interest. The number of breccia pipes is significant.

In conclusion, all areas "are suitable to varying degrees for 'nonpark' land uses". These lands are integrated with the Strip, each other, the Grand Canyon province, and the entire Colorado River watershed. Most significantly, their geology promotes the most important scenic values. So recreation including sport hunting is the best use. Also cattle ranching is "intrinsically" linked to the people of the region, and so is a historic & legitimate use. And improved practices could make it more viable. [Although it has disappeared from most of the desirable Park area.] 
[Notice that the pieces of the area are all tied together, so no matter what the park values are, nonpark uses prevent any discussion of even an acre being added to the Park.]


The report's wind-up starts off on a good foot, quoting the definition section of the 1975 Park Act. It presents the geological definition: that system of canyons eroded below the Kaibab limestone (that) exists as a continuous surface over all of the plateau lands of northwestern Arizona. It continues on this high ground, noting the "vast land area" reaching out along the Little Colorado, Havasu and Kanab Creek Canyons. It speaks of the "three Indian reservations", national forest, public lands, and non-federal patches, perhaps twice the enlarged Park. 

The writers note that Congress did not imply that the entire Canyon would be in the Park. OK. Congress intended to both recognize the Canyon phenomenon, and to protect "additional significant features closely associated with the (earlier) National Park and to consolidate their management by placing them within an enlarged park." Then, "Congress also suggested that there were other associated areas that should be studied and reported upon to some future Congress."

[Interestingly, the study team ignores section 6, in which the Secretary is authorized and encouraged to cooperate with the owners or managers of Grand Canyon lands NOT in the Park, in order to interpret and protect the "Canyon in its entirety".] That is, by concentrating right away on the Conference report, they missed the chance to show how Congress intended that its definition, ifs vision of the Canyon, was to be realized fully as a cooperative effort, not just by Park expansion. Instead, the report falls back on the idea of "its either Park or not." By missing their chance to promote the cooperation between agencies, they thwarted what the 1975 Act was intended to do, namely, recognize, present, and protect the Canyon in its entirety regardless of ownership or management status. 

Having shot that foot, they then ask the rhetorical question: Should lands, "similar to other Grand Canyon lands" (well, duh) be included within the Park? Of course, they should have answered they should be, but maybe there are countervailing arguments such that the lands could instead the subject of cooperative arrangements if they cannot, politically, be added to the Park. Not satisfied with this mis-step, they had expanded their study both in geographic extent and to determine all resource values, in order to decide on appropriate management. And by this step, they have tripped and fallen off the structure Congress set up, ending up committed, not to finding ways to move toward the protection and interpretation of the entire Canyon, but only to preserving existing agency arrangements. Splat! on their faces.

Hoping nobody will notice, they next consider Wilderness proposals as if they were a substitute for first determining lands of Park quality and what would be necessary to protect and interpret them. The Forest Service has recommended their part of Kanab for Wilderness. Lake Mead, too, scenting a good ploy, has pushed its Wilderness recommendation to a maximum of 141 kac. essentially all the Canyon land LMNRA administers. [Perhaps, the threat of Park status "encouraged" both these agencies to shake up their previous wilderness ideas and go for the maximum.] Struggling along somewhat in the rear, BLM has thrown an even wider net for its wilderness "study" areas. Now, what, they seem to be asking, could those Park lovers want that Wilderness status does not satisfy?

For grazing management, the report recalls BLM's pledge to reduce AUMs on the Strip.
Also, handily, the Forest Service has cleaned up its Act and closed riparian Kanab to grazing. BLM is mum on this aspect, and indeed, just a few years ago, validated grazing on the Esplanade of southern Kanab Canyon in spite of the "sparse" resource and the archeological values. 

A little section reminds the reader that the public -- the hunters and cattle operators -- came out in force to protest any change to Park status "in the STUDY AREA". Never mind asking this public to look hard at the actual lands and see the difference in the values in Park and non-Park areas. 

On a toot now, the writers ignore the over-grazing, the fudged non-data of the hunters, and their non-recognition of the Park values such as the Shivwits as viewing platform,  and claim the "major threat" is mining activity. They take half a page to wring their hands over the possible "significant environmental impacts"  and "serious degradation of natural wilderness character". They are even so far-sighted as to look to the coal gasification schemes in southern Utah, and their threat for additional air pollution and adverse effects on the "vast watershed" of the Colorado River and the National Park. Well, no one would deny such threats existed; but their tears and fears for the future would be more convincing had they done their job correctly.

There is a final stab from the gamesters, as the report says that the migration patterns of the "Kaibab mule deer herds" are such that similar land management polices across "the entire range" are desirable in order to arrive at the level of a healthy kill. Again, for them  everything is connected to everything else, so no gradation of care is possible. 

Seriously crippled, the report finishes by looking at two options: 1. Add portions of the study area lands to the Park, or 2. Maintain existing agency management responsibilities. [The option called for by the 1975 Act, that of cooperation for protection and interpretation, is not mentioned. Indeed, no compromise or impact on USFS & BLM prerogatives is to be entertained.]

1. There are significant features of park caliber, geologic and scenic resources especially, in the study areas. Lands below the upper cliffs in the four named canyons "logically" belong in the Park. However, sport hunting and grazing would no longer be possible unless specifically allowed by legislation. Those two uses are "an integral and traditional part of the environmental framework of these lands". [Overgrazing? Killing creatures for sport? And what about when the Mormon settlers swept the Southern Paiute off the lands they had lived on for a 1000 years in "an integral and traditional" blend of their cultural and environmental identity? Jesus wept.] If the lands were transferred, mining might be minimized, although coal gasification would still be a threat. [No greater threat than these befuddled bureaucrats. who failed to even mention the Shivwits.]

Option 2 gets twice the verbiage as 1. Good management is essential to the study area's environmental integrity. The three agencies can all do a good job. Also, they follow policies to allow long-term resource exploitation to continue. Multiple use is dandy; even LMNRA, an NPS area, uses it. Public opinion wants to preserve the wild qualities of the area while allowing "nonconsumptive" uses ( hunting and grazing) to continue. [Having won their fight, the user groups rub their victory in to the point of absurdity.]  In the future, there might be better range management. And state game managers might finally figure out how to reach "sustained yield" of their meat supply. 

Wandering into irrelevance, the report suggests mining could be mitigated by existing controls. It repeats the falsehood that the Game Preserve proclamation prohibited mining activity. Wilderness will also help mitigate the mining threat. All the agencies have policies to deal with damage from mining [Needless to say, none of this mattered when the miners came to push and shove.]


Having structured the report's framework, written its content to conform with their biases, and ignored even obvious considerations, the authors decided that proper management did not need the lands being transferred into the Park. So at the end, they reiterate their distortion of the task the conference report set. The study was all about resource protection, not about the Canyon's integrity. And "historic, compatible use of renewable resources such as well-managed grazing and sport hunting" have the highest priority.
The report ends with a call for wilderness designation of all qualifying lands if necessary criteria are met. 

*This entry is my summary of "Final, Adjacent Lands Study, November 1981, Grand Canyon National Park, Arizona" with the authors listed as National Park Service, Bureau of Land Management, and U.S. Forest Service. 
In the spirit of the report, I have woven my perspective in as an integral part of the summary. 

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