To the editor:

As reported in the Deseret News on March 28 and 29, the Environmental Protection Agency has criticized several fundamental inadequacies in the Utah Bureau of Land Management's final wilderness environmental impact statement.I was discouraged to read in the Deseret News and in other Utah newspapers that Gregory Thayn, who led the BLM's 10-year, $7 million study, fails to satisfactorily acknowledge the EPA's concerns. Instead, he hides behind the weakest of excuses: He stated that the EPA is concerned with issues that are not "pertinent" to the topic of wilderness. He stresses the notion that the BLM must meet the October 1991 deadline for its wilderness review, and infers that the deadline will be met regardless of the quality of the review. Finally, Thayn goes as far as to charge, in a March 30 Cedar City Spectrum article, that the EPA did not even read the final impact statement before presenting its review.

I had looked forward to a reasoned and informed response to the EPA's critique from Thayn. Unfortunately, his statements only characterize what has been agency business-as-usual during the wilderness review process - that decisionmaking will press forward no matter what procedural failures occur. For instance, when asked about the EPA's suggestion that the BLM re-evaluate its finding of only minimal wilderness on the Kaiparowits Plateau, Thayn stated, "We think we are right. . . . Our position is that the inventory is over and BLM is not in the stance of reopening the inventory."

Thayn also suggests that the problems surrounding the determination of mineral values in proposed wilderness areas are put to rest in the final impact statement. This is untrue. The draft EIS wrongly concentrated only upon the potential of locating a particular mineral resource; a high rating of resource certainty was enough in many cases to eventually disqualify an area from wilderness status. As Thayn mentions, the BLM did revise this measure in its final statement by adopting a process that would also evaluate the economic feasibility of mineral development in each area.

However, the EPA notes that the BLM "tends to assume resources will have long-term potential if there is a favorable geologic environment." In other words, BLM accepts the notion that the development of a resource is economically feasible as long as geological conditions are favorable for that particular resource. To hold that this "improvement" solves the problems of the draft EIS is ridiculous. Thayn's response regarding the agency's adherence to Interior Board of Land Appeals decisions is equally unconvincing.

The EPA report deserves Thayn's full attention. It has uncovered fundamental flaws that call the integrity and reliability of the entire document into question. As Joseph Bauman of the Deseret News notes, the Utah legislature and Rep. Jim Hansen have both suggested that only 1.4 million acres of Utah's BLM land be designated wilderness. These conclusions are in large part based upon a hugely flawed environmental impact statement. Before legislative action on either of these proposals goes forward, the BLM owes an explanation as well as a plan to repair the damage done. If the BLM continues to ignore the obvious shortcomings of the final impact statement - and it has given every indication that it will - then Congress must review the product of BLM's work before it makes its determination regarding Utah wilderness.

Mark MacAllister

Southern Utah Wilderness Alliance

Salt Lake City