Want to know what 30 of Trout Unlimited’s state councils had to say about national monuments? Here’s the full text of their official comments, submitted July 10.
July 10, 2017
Monument Review, MS-1530
U.S. Department of the Interior
1849 C Street NW
Washington, DC 20240
Comments of Trout Unlimited on DOI-2017-0002, Review of Certain National Monuments Established Since 1996
Dear Secretary Zinke:
Thank you for the opportunity to provide comments on the Review of Certain National Monuments Established since 1996. Trout Unlimited is a national sportsmen’s conservation organization with more than 300,000 members and supporters organized into over 400 chapters from Maine to Alaska. Our mission is to conserve, protect and restore North America’s coldwater fisheries and their watersheds. Trout Unlimited chapters invest hundreds of thousands of volunteer hours annually on their local streams and rivers to restore habitat for trout and salmon, as well as in conducting youth conservation and fly fishing camps, veterans’ service programs, community events and taking kids fishing.
Public lands are vitally important for fishing and hunting in America because they contain the vast majority of good aquatic and terrestrial habitat left in this country and are accessible for sporting opportunities. Forest Service and Bureau of Land Management managed lands, in particular, are immensely important to Trout Unlimited members, as approximately 50 percent of the nation’s blue-ribbon fisheries flow from or through these lands, and in many cases these lands are the last and best remaining habitats for prized native trout and salmon. Healthy public lands are thus integral to Trout Unlimited’s mission. Our conservation work on public lands focuses on engaging with local, state and federal partners to develop and implement pragmatic solutions that balance multiple interests and uses while protecting and restoring trout and salmon habitat.
General Comments
National monuments are an important part of our public land heritage. They also contain some of our country’s most unique and undeveloped ecological zones – consequently, they also conserve some of our best fish and game habitat and sporting opportunities. For this reason, anglers and hunters have strongly supported monument designation for places such as California’s Giant Sequoia and Berryessa Snow Mountain, Colorado’s Browns Canyon, New Mexico’s Organ Mountains and Maine’s Katahdin Woods and Waters national monuments.
We understand that, in some instances, national monuments have been controversial, starting with President Theodore Roosevelt’s use of the 1906 Antiquities Act to set aside 808,120 acres of public land as Grand Canyon National Monument. From a habitat perspective, however, national monument designation via presidential use of the Antiquities Act has been widely supported as one of our most effective conservation tools, and has directly helped to sustain our fishing and hunting traditions. The Antiquities Act is a critical law that has allowed for the preservation of our national heritage and the public lands that belong to all Americans.
While on occasion past presidents have diminished the size of national monuments, none have done so since the passage of the Federal Land Policy and Management Act of 1976, which reserved for Congress the authority to modify or revoke national monuments. Moreover, no president has attempted to rescind a national monument, and doing so would be both legally questionable and a bad precedent which could jeopardize some of our nation’s best habitat and sporting values.
For these reasons, we are concerned by the Interim Report Pursuant to Executive Order 13793 and the recommendation to modify the boundaries of Bears Ears National Monument. While there are no coldwater fish or fishing values in this monument, we are nonetheless troubled by such action, which would be unprecedented in the modern era and call into question the durability of protections afforded to other national monuments. Of what good is a conservation designation for public land that can be modified or eliminated at the whim of a future administration?
Trout Unlimited urges you to reconsider the interim recommendation to modify Bears Ears National Monument. Doing so will help to ensure that the final report and recommendations chart a more balanced and responsible course for the management of America’s public lands. Rescinding or diminishing a national monument is heavy-handed and unnecessary, especially when the Department has other means to resolve dissatisfactions among stakeholders, such as through transparent and collaborative processes for revising management plans.
Comments Specific to Individual National Monuments
The following are comments specific to individual national monuments that support important coldwater fisheries.
Browns Canyon, CO: While this monument was not specifically identified for review, the request for public comments asks for information related to national monuments that may have been established “without adequate public outreach and coordination with relevant stakeholders.” Without question, extensive public outreach was part of the locally-driven conservation initiative that led to Browns Canyon being designated as a national monument and the proposal enjoyed broad support.
Browns Canyon National Monument protects exceptional fishing and recreation resources. The popularity and productivity of the Arkansas River for fishing has earned 102 miles of the river Gold Medal status, a class bestowed to only a handful of waters in Colorado. Browns Canyon not only conserves an important stretch of this river, but it provides ample public access for recreation, including fishing, rafting and hiking. The size of Browns Canyon National Monument is the minimum to support these resources of significant value to local communities, hunters and anglers, and businesses. In fact, legislation to permanently protect Browns Canyon offered a higher level of protection, for a much larger area, compared to the national monument designation.
Rio Grande del Norte, NM: Rio Grande del Norte National Monument protects more than 60 miles of the Rio Grande River, as well as important wildlife habitat. This section of the Rio Grande River is one of New Mexico’s most iconic wild trout fisheries. Moreover, the hunting and angling opportunities of the Rio Grande del Norte contribute tens of millions of dollars to New Mexico’s economy annually. The size of Rio Grande del Norte National Monument is the minimum necessary to support these values.
This national monument designation received broad-scale bipartisan support. Local and statewide support came from local elected officials (Taos County Commissioners and Mayor), state and national sportsmen’s groups (New Mexico Trout Unlimited, New Mexico Wildlife Federation, New Mexico Backcountry Hunters & Anglers, United Bowhunters of New Mexico, and Theodore Roosevelt Conservation Partnership), tribes (Taos Pueblo), grazing permittees, and the New Mexico congressional delegation representing the area.
Katahdin Woods and Waters, ME: Katahdin Woods and Waters National Monument protects important habitat for brook trout and Atlantic salmon, including the East Branch of the Penobscot River, 10 miles of Wassataquoik Stream, seven miles of the Seboeis River, many miles of smaller tributary streams, and four ponds designated as “Heritage Brook Trout” waters by the state of Maine. The size of Katahdin Woods and Waters National Monument is the minimum to support these natural resources of scientific and cultural significance. This national monument designation was unanimously supported by Maine Council of Trout Unlimited, representing 1500 members in the state.
Cascade-Siskiyou, OR: Cascade-Siskiyou National Monument protects a unique, isolated population of native redband trout in Jenny Creek, as well as headwaters tributaries to the salmon and steelhead fisheries of the Rogue and Klamath Rivers. In addition, the Cascades-Siskiyou region hosts one of the most significant concentrations of biodiversity in North America. The monument was originally established in 2000 with significant local support, and was expanded in 2017 by 48,000 acres (also with strong local support and virtually all of Oregon’s congressional delegation) to better conserve the remarkable ecological and scientific values of this region. The size of Cascade-Siskiyou National Monument is the minimum necessary to protect the unique population of redband trout in Jenny Creek as well as the exceptional biodiversity of this geographic area.
Sand to Snow National Monument, CA: This monument conserves unique geologic, ecological, and scenic values at the juncture of the Mojave Desert and the San Bernardino Mountain range. It also protects the headwaters of the Santa Ana River, the longest river in the region and a popular recreational fishery, and sanctuary for a remnant population of the endangered southern steelhead trout. This monument is no larger than necessary to conserve these distinctive values.
San Gabriel Mountains National Monument, CA: This monument protects the famous northern skyline of the greater Los Angeles area, numerous Native American cultural sites, and the headwaters of the East Fork San Gabriel River – a State designated Wild Trout Water – which provides a rare trout fishing experience in Southern California. Remnant populations of endangered southern steelhead are also found in headwater streams within the monument. Local sportsmen and women strongly supported designation of the San Gabriel Mountains National Monument, which conserves the unique scientific, recreational and cultural values of this rugged mountain range.
Berryessa Snow Mountain National Monument, CA: This monument protects the headwaters of the famed Eel River, one of California’s most productive watersheds for salmon and steelhead, as well as tributary streams to the Sacramento River such as Putah Creek, home to blue ribbon trout water and spawning grounds for Central Valley Chinook salmon. This area’s unique serpentine soils have created an unusual biodiversity hotspot which is of considerable scientific interest. National monument designation was strongly supported by local sportsmen and women, business interests and communities.
Giant Sequoia National Monument, CA: Located in the southern Sierra Nevada, this monument protects the southern-most groves of giant sequoias, the largest living thing on earth, as well as the headwaters of the Tule River, South Fork Kings River, and North Fork Kern River and a portion of the mainstem Kern River, which contain popular wild trout fisheries and are vital sources of water supply for downstream agricultural and metropolitan use. The designated area is the minimum size necessary to protect the unique scientific, habitat, and recreational values of this remarkable landscape.
Hanford Reach National Monument, WA: This monument helps to protect the last free-flowing stretch of the Columbia River, as well as spawning areas for eighty percent of the fall-fun Chinook salmon remaining in the upper Columbia Basin. Additionally, spring Chinook, a threatened species, and both middle and upper Columbia River steelhead migrate through the Hanford Reach to reach spawning grounds upstream. The Hanford Reach National Monument helps to protect these fisheries of great cultural, scientific and economic importance.
There is no sporting opportunity without good habitat, and some of our nation’s best habitat for trout, salmon and steelhead is conserved in national monuments. Therefore Trout Unlimited opposes reducing or modifying the boundaries of any national monument, not just those being considered under this review. National monuments are an important part of America’s public land heritage that helps to sustain our hunting and fishing traditions.
Thank you for the consideration of our comments and recommendations. We encourage you to build on the bipartisan tradition embraced by sixteen presidents of ensuring that our nation’s most important historic, scientific, and geological and ecologically remarkable landscapes are conserved as national monuments for ours and future generations. We look forward to the final report and recommendations and hope that they will reflect the importance of national monuments for habitat conservation and for fishing and hunting in this country.
Sincerely,
Chris Wood, President and CEO of Trout Unlimited
This letter is co-signed by the following volunteer Trout Unlimited state councils:
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Steve La Falce, Chair Arizona State Council |
Tom Quail, Chair Michigan State Council |
Terry Turner, Chair Oregon State Council |
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John Sturgis, Chair Arkansas State Council |
Don Hayes, Chair Mid-Atlantic Council |
Charlie Charlesworth, Chair Pennsylvania State Council |
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Cindy Noble, Chair California State Council |
Steve Carlton, Chair Minnesota State Council |
Paul McKee, Chair South Carolina State Council |
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Cam Chandler, Chair Colorado State Council |
Jeff Witten, Chair Missouri State Council |
Phil Dopson, Chair Texas State Council |
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Carl Riggs, Chair Georgia State Council |
Chris Schustrom, Chair Montana State Council |
Jeff Taniguchi, Chair Utah State Council |
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Ed Northen, Chair Idaho State Council |
Tom Ives, Chair New Hampshire State Council |
Clark Amadon, Chair Vermont State Council |
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Darwin Adams, Chair Illinois State Council |
Rich Thomas, Chair New Jersey State Council |
Kevin Daniels, Chair Virginia State Council |
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Jim Kelehan, Chair Iowa State Council |
Art Vollmer, Chair New Mexico State Council |
Rosendo Guerrero, Chair Washington State Council |
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Ron Urban, Chair New York State Council |
Linn Beck, Chair Wisconsin State Council |
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Kathy Scott, Chair Maine State Council |
John Kies, Chair North Carolina State Council |
Cole Sherard, Chair Wyoming State Council |