I am a member of the Boulder Outdoor Survival School (BOSS) community. BOSS is a nonprofit in southern Utah which has been operating educational courses in wilderness survival in and around Grand Staircase Escalante National Monument since 1968.

I urge the BLM to adopt the preferred alternative (Alternative C) of the draft Resource Management Plan, with significant attention toward the preservation of ecosystems, while also preserving opportunities for responsible visitation.

Three particular details in the implementation of the plan have a potential to impact BOSS's operations:

1. Responsible use of fire: BOSS teaches the responsible use of fire, including minimizing any impact from fuel collection, as well as disposal and erasure of ashes and coals.  It is appropriate to restrict the usage of fire and fuel collection in high-use areas such as road corridors; but in backcountry areas, it is imperative that BOSS continue to be able to practice and teach responsible fire use.

2. Responsible disposal of human waste: BOSS teaches appropriate ways to manage human waste in the backcountry. This includes careful choice of where and how to bury waste, minimizing impacts, and preventing overuse of any area.  It is appropriate to restrict human waste disposal in heavily visited areas where the impact cannot be adequately dispersed.  But in areas with lighter visitation, it is imperative that BOSS continue to be able to teach appropriate natural waste disposal, without requiring "wag bags" or similar.

3. Group sizes: BOSS emphasizes ways of travel and camping which avoid harmful impacts to ecosystems, including biological soil crusts and sensitive desert plants. To survive financially, BOSS needs to be able to continue to operate with group sizes from 12-15 people, as it has for decades.

I urge you to adopt a plan that emphasizes the protection of natural ecosystems. Responsible use of fire, responsible natural disposal of human waste, and responsible backcountry foot travel with group sizes up to 15 are all compatible with these goals.

Restrictions that would materially alter the manner in which BOSS has conducted itself for decades would deny future generations the opportunity to learn the skills and values that BOSS teaches, which align with the BLM’s mission of preserving and protecting this unique wilderness.