John Day Fossil Beds
Administrative History
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Chapter Three:

Planning for a new park in an era of expansion

Almost nothing had transpired since the NPS issued its directive for the John Day Fossil Beds master plan in May 1970, so Regional Director John Rutter called a meeting in his office on October 16 to develop the project further. [81] John Sage, of the Office of Environmental Planning and Design in the Western Service Center (WSC), joined Rutter at this meeting, as did Dan Burroughs from the Portland Field Office. [82] From it came some guidelines to direct the planning team's preparation of master plan documents. [83]

One of the key directives involved giving strong consideration to the town of Day as administrative headquarters. This is because the group envisioned a unit operation with Sheep Rock providing visitors with primary interpretation, Painted Hills accommodating campers, and Clarno serving as a day-use area. Rutter, Sage, and Burroughs also wanted the NPS to manage "the scattered and numerous regional features" which they thought should be considered for less-than-fee acquisition. [84] In most cases this meant scenic easements, whereby the property owner agreed to perpetuate agricultural uses on their land. This involved the purchase of development rights by the NPS, but on a willing seller basis.

The meeting's one reference to staffing concerned on-site employee housing which, in somewhat obvious terms, they saw as being determined by the extent of park development and a need for resource protection. By December 2, however, Rutter planned to place a ranger and a maintenance employee at each of the three units while stationing a superintendent, secretary, naturalist and/or protection specialist at John Day. At this time he also gave "general administration and housekeeping" responsibility for the proposed monument to the NPS group office in Klamath Falls. [85]

WSC's John Sage gave Rutter tentative boundaries for the proposed national monument on December 11, 1970. In wanting to consolidate features in each of the three units, Sage intended to simplify boundaries to the degree possible for management while providing enough area for development and protection of the visual scene. [86] This took the form of an oblong and contiguous unit of 16,300 acres at Sheep Rock. It included the 4,340 acres of state park land, public domain already in federal ownership and administered by the Bureau of Land Management, along with private parcels to be acquired in fee or through easements. He found the Painted Hills more problematic, as a need to acquire enough of Bridge Creek to permit overnight camping flew in the face of anticipated antagonism arising from the state prevailing in condemnation proceedings. In this unit Sage wanted to incorporate the state park with 1,400 acres of other lands for a total of 4,220 acres. In proposing 2,040 acres for the Clarno Unit, Sage omitted most of its geological features except for the Palisades. He admitted that perhaps this needed restudy, but his sentiments had more to do with bringing river recreation into the master plan, than paleontology. [87]

NPS proposed campground along Bridge Creek
The NPS proposed a campground for an area along the west bank of Bridge Creek, just south of the state picnic area,
in all three drafts of its master plan for the prospective national monument. Planners eventually settled for
improvements to the picnic area due to doubts about the need for camping at the monument.
(photo by the author)

Sage's ideas about boundaries carried into a management statement drafted at year end as part of the master plan. This document saw the region's geology and its interpretation as compatible with visitor use of the John Day River. Both of these might be better facilitated, it stated, by an opportunity to camp. [88]

Much of what had been outlined earlier appeared in January 1971 as a working draft of the master plan promised to Ullman a year earlier. [89] Although it had only nine pages of text and some maps showing boundaries of proposed units, Ullman wanted the draft so that he could introduce a new bill early in the 92nd Congress. The bill, HR 488, did not specify park size nor did it supply direction for how the prospective national monument should be administered. This is because such things as management objectives, it appeared, could be developed in the master plan. Proposals in this draft, as the planners put it, followed from three goals: to protect existing paleontological features, provide related comprehensive interpretation, and develop indigenous recreational assets. [90]

Ullman introduced his bill on January 22, 1971. A month later one of his staff members inquired about the next step in this master plan process. One of Rutter's subordinates replied that a finalized plan could serve as a basis for preparing the Department of the Interior's report on Ullman's bill, if the House Committee on Interior and Insular Affairs requested such a report. [91] During the next few months, little more than a restudy of the Sheep Rock Unit's boundaries took place until four NPS planners visited Grant and Wheeler counties in May 1971. [92]

Probably the most significant change to the park proposal arising from this visit involved excluding Camp Hancock from the Clarno Unit. Operated as a summer facility by the Oregon Museum of Science and Industry (OMSI) since 1951, the camp attracts science students who range from elementary to graduate school. [93] NPS plans called for a ten acre exclusion from the monument, even though OMSI originally had a 40 acre lease from the Bureau of Land Management. [94] This stemmed, however, from a BLM determination in 1969 that OMSI's plans for development were inconsistent with its lease policy and therefore limited camp facilities to ten acres. [95]

Meanwhile, one state representative began preparing a bill that granted the highway commission authority to donate state parks for the purpose of establishing a national monument. [96] Despite a previous state attorney general's opinion that authority for such a transfer already existed, this bill made its way through the legislature partly because of concern that Ullman's bill in Congress had languished once again. [97] With three state parks in the upper John Day Basin specifically in mind, the state legislature passed HB 1223 in May and the governor signed it in June of 1971.

Previous indication of the state's willingness to donate these parks resulted in the Secretary of the Interior's Advisory Board endorsement of the proposed national monument in April. [98] The park proposal had solidified enough at this point for the NPS to present it as three noncontiguous units totaling 22,560 acres with a headquarters in John Day. Described as independent but complementary parts of a single entity, the NPS likened each of the three units to separately developed areas of a large national park. [99]

Tentative boundaries for the proposed national monument
Tentative boundaries for the proposed national monument encompassed 22,560 acres according to the NPS master plan dated January 1971.

Ullman's scheduled visit to Oregon in August 1971 pushed the master plan draft closer to completion. [100] Work on cost estimates for land acquisition, staffing, and development began three weeks after a short field visit to the proposed monument by NPS planners in May. [101] These aspects dominated the master plan draft of August 1971, so much so that statements about the scope of resource management and the monument's purpose appeared vague by comparison.

Nevertheless, planners cited protection of fossil resources as being partly responsible for the master plan study. [102] In responding to threats previously outlined by Shotwell, such as the increased trade in fossils, planners stuck to broad generalities concerning the emphasis of resource management. Primary objectives centered on preservation and protection, along with interpretation of geological and paleontological features, though use of the John Day River also became a focus. [103] Since they knew that relatively small and widely separated units could not function as wildlife management areas, secondary resource management objectives focused on cooperating with other land managers to retain "a naturalistic landscape that complements the fossil story." [104] Planners pointed to NPS administrative policies for the natural area category for more specific management direction. [105]

NPS land acquisition plans reduced the proposed monument to 15,680 acres, as compared with 22,560 acres of a few months earlier. This is largely because the 9,922 acre Sheep Rock Unit now had three components: a contiguous tract from the Mascall Overlook to Blue Basin, a considerably smaller holding at Foree, and a 40 acre parcel at Cathedral Rock. Planners suggested a mix of existing state park land, fee acquisition (from private landowners and the Bureau of Land Management), and scenic easements at all three units. At the 4,093 acre Painted Hills Unit, for example, they proposed fee acquisition to buffer existing state park land (especially where bottomland along Bridge Creek bordered state holdings) whereas a scenic easement appeared sufficient for 800 acres east of the county access road. Curiously, however, the nut beds and mammal quarry were missing from the 1,665 acre Clarno Unit. The planners wanted little more than the Palisades, located in the 100 acre state park, which they described as the "primary Clarno formation." They proposed that 800 acres be acquired through scenic easement, but this largely constituted a buffer around existing state park land. In contrast to the plan for Painted Hills, the NPS aimed at public domain land for proposed fee acquisition at Clarno. Planners thought a small private tract south of State Highway 218, however, might have to be acquired in fee because it could provide visitors with river access.

This access point might then be developed into a primitive campground, like one the NPS planned for further upstream near Service Creek. [106] Nonetheless, most development at Clarno centered on day-use facilities at the Palisades, where the plan called for a picnic area and interpretive trail. The NPS had a more ambitious scheme for Painted Hills, where a visitor contact station, campground, amphitheatre, and trail system had been proposed. Plans for developing the Sheep Rock Unit bore a marked similarity to those previously formulated by the state, but the team justified a choice to make it the primary interpretive site for a number of reasons. Among them included its size relative to the other units, the variety of geological resources represented, this unit's land ownership pattern and relationship to the John Day River, as well as its location relative to highways in the region and to the town of John Day. [107] As a result, development of a visitor center, support facilities, river access, and trailheads all centered on the Sheep Rock Overlook. The planners recommended that other development in this unit be less intensive, in proposing only a picnic area and trail at Foree, tables and toilets at Johnny Kirk Spring, a trail at Blue Basin, and a vehicular trail" on the south side of Picture Gorge to provide safer access to viewpoints like the Mascall Overlook.

Monument boundaries embraced in the
August 1971 master plan draft
Monument boundaries embraced a total of 15,680 acres in the August 1971 master plan draft. Note that the NPS split the proposed Sheep Rock Unit among parcels at Foree, Cathedral Rock, and contiguous tract extending from Blue Basin to Picture Gorge. Planners reduced the prospective Painted Hills Unit by omitting parts of its southeast corner, while also trimming the Clarno Unit by half a section.

While the master plan draft received this substantial revision from what it had been in January, members of the planning team also responded to the Washington Office's request for legislative support data. [108] This bevy of documents could serve as the basis for Interior's position on Ullman's bill, but required planners to assemble a general development plan, development schedule, land cost estimate, staffing summary, visitation forecast, and other materials. Rutter felt confident that all requirements for legislative support data had been met by September 24. Three months later, however, Deputy Director Thomas Flynn cited problems with acreage figures and cost data, so he recommended that Interior defer submission of its report. [109] Despite this setback, members of the planning team finished a report on land appraisals the following March and a new development schedule in June 1972. [110]

Virtual completion of the legislative support data almost coincided with another draft of the master plan. In the nine months since the August 1971 version went out for review, there had been several changes. One involved boundary changes in all three units, whereby the proposed monument's total acreage dropped from 15,680 to 14,402 acres. [111] In another change, planners backed away from as much fee acquisition as had been proposed previously. They opted for management of public domain land within the proposed monument by interagency agreement. [112] Despite the trend away from fee acquisition, the planners proposed fee acquisition of the Cant Ranch buildings to provide a venue for interpretation and management in the Sheep Rock Unit. [113] The only other change involved reducing what had been a projected 150 site campground at Painted Hills to 75 sites. [114]

Proposed boundaries in the NPS master plan draft of June 1972
Proposed boundaries in the NPS master plan draft of June 1972. Totaling 14,402 acres, these became the lines authorized by Congress two years later. Within the Sheep Rock Unit, reductions from the August 1971 plan took place at Foree. The largest drop in acreage, however, was at Painted Hills where planners brought back the eastern boundary to Bridge Creek. A focus on more river access led to a slight increase at Clarno.

Despite the relatively small scale of changes since the August 1971 draft, several components of the master plan encountered resistance from BLM. Several of their field personnel in Oregon repeated concerns first expressed in June 1971 that the monument could have serious impact on use and administration of adjacent BLM land. [115] Specifically, the Prineville district manager thought any prohibition on grazing in the Sheep Rock Unit might result in added demand for forage on adjacent BLM parcels. He also thought the elimination of hunting at Clarno could bring increased competition between cattle and area wildlife. [116] More importantly for the master plan's scope, BLM managers questioned the propriety of NPS proposals to develop facilities on the John Day River. They could not see how these facilities related to Ullman's intent in HR 488 because river recreation bore little relation to "proper development of the unique paleontological and geological resources." [117]

As it turned out, BLM did not pursue the grazing concern. They also accepted a prohibition on hunting within the monument's boundaries, but the NPS agreed in August 1972 that hunters could have access to adjoining land providing they transported their firearms across the monument in an unloaded, broken-down, or properly cased condition. [118] In regard to developing facilities along the John Day River, the NPS decided to defer construction of a primitive campground at Clarno until determination could be made whether this section met criteria for inclusion in the National Wild and Scenic Rivers System. [119]

Even though some agreement had been reached between the two agencies by September, this draft of the master plan remained on hold. The main reason appeared to be that the NPS wanted to coordinate completion of its master plan, legislative support documents, and an environmental impact statement (EIS) with preparation of a departmental report on HR 488. The House Committee on Interior and Insular Affairs had requested the report, but it had to wait while the NPS solicited comments on its EIS from a number of federal, state, and local government agencies. Revised and enlarged somewhat from a September 1971 draft, this environmental statement essentially reiterated direction given in the June 1972 master plan. [120] Rutter sent the EIS to Washington on June 2, but a Federal Register notice inviting comment on it did not appear until November 4. [121] No real impediments surfaced, so the department approved the draft in January 1973. [122]

During the formulation and review stage of the EIS, however, the NPS dealt with several matters which indicated that several planning issues needed further clarification before congressional hearings took place. The first arose in February 1972 when state parks director David Talbot transmitted a recommendation from the State Parks and Recreation Advisory Committee which suggested a name change from John Day to Thomas Condon Fossil Beds National Monument. [123] This idea went no further until one supporter sent letters to the two senators from Oregon, who then referred him to Interior. The department gave the letter to its board on geographic names, which sought guidance from the Oregon Board on Geographic Names. [124] In a memorandum to the NPS, the Interior board's secretary highlighted an Oregon board consensus that residents in Grant and Wheeler counties preferred the John Day name, even though some of them believed it to be overused. [125] The Oregon board eventually settled this question at its December 1, 1972, meeting. With NPS concurrence, they endorsed the name "John Day Fossil Beds National Monument" but urged that suitable recognition be given to Thomas Condon. Ullman thereby incorporated language stipulating that the Secretary of the Interior "shall designate some appropriate landmark, such as a visitor's information center, within the Monument area in recognition of the work of Thomas Condon" into a new bill (HR 1252) which he introduced on January 3, 1973. [126]

Another suggestion for a national recreation area surrounding the proposed monument led a considerably shorter life. As Ed Arnold of the Portland Field Office told Gordon Glass, such a change in the park proposal required starting anew with legislative support data, a master plan, and an EIS. Since the Grant County Planning Commission did not want further delay, they dropped further consideration of this idea. [127] Nevertheless, it surfaced again when two NPS representatives went to Canyon City in February to review the park proposal with local officials. The Oregon State Game Commission, who had been the originators of the idea for a national recreation area, believed that hunting could control deer-caused damage in bottomlands. They wanted the monument to embrace less acreage than the 14,400 proposed in order for control measures to be implemented. As an alternative to monument status for lands outside the state parks, the commission saw national recreation area designation as a way to permit hunting. [128]

With those sentiments expressed, the NPS representatives at this meeting found no actual opposition to the proposed monument. They realized, however, that some prime bottomland at Foree in the Sheep Rock Unit had inadvertently been included as a prospective acquisition in fee. As a result, they recommended a boundary revision for the Foree tract. In doing so, they found development of river access there to be impractical because of insufficient water, especially during irrigation season. [129]

These adjustments to the master plan seemed inconsequential until a month later, when the NPS began to find that some ownerships in the Sheep Rock Unit had changed over the past year. The first sign of trouble came just after the Canyon City meeting, when a new owner of 331 acres proposed for fee acquisition at Foree wrote to Ullman. In his letter, Bernard O'Rourke expressed alarm about the acquisition since he judged the remainder of his 700 acres as not viable for ranching without it. He asked for more information about Ullman's bill and whether public hearings on it might be held in Grant County, since the latter "would be essential to ensure that both the public and private land owners receive equitable consideration." [130]

This concern eventually led to more grassroots coordination by the NPS since Ullman wanted to smooth passage of HR 1252 by minimizing the fee acquisition of private holdings. [131] O'Rourke appeared to reach a compromise with NPS representatives Ed Arnold and Ernest Borgman on April 10, 1973, something which involved only 45 acres of fee acquisition and 290 acres in scenic easement. [132] A week later, however, they wrote to Rutter and explained that two other ownerships in the Sheep Rock Unit had recently changed and another landholder planned to sell. They saw each change as creating a high potential for conflict and the need to obtain the monument's authorization as soon as possible. [133] In response, Rutter urged Arnold and Borgman to proceed with contacting new owners so that they could be advised of the park proposal. [134]

As the link between NPS field activities and Washington, the regional office continued to coordinate updates on planning documents for the proposed monument. It now, however, moved away from sending planners on only occasional visits to the John Day country (where the NPS previously assumed it had unquestioned local support) toward more active involvement by two members of its planning team. Arnold took over for Burroughs as acting chief of the Portland office in early 1973, due to the latter's retirement. A few months earlier, Borgman likewise replaced Donald Spalding as general superintendent of the Klamath Falls Group. [135]

As a concept, the creation of group offices accelerated during Hartzog's tenure as NPS director because one of his reorganization studies recommended that small parks or NPS units in geographic proximity could be clustered. [136] Hartzog endorsed Spalding's idea of administering Crater Lake National Park, Oregon Caves National Monument, and Lava Beds National Monument from Klamath Falls, provided that each site retain some supervisory personnel on site. [137] Since Spalding had experience in new areas, he became Rutter's representative on the John Day evaluation study in 1967 and thereafter served as a member of the proposed monument's planning team. [138] Borgman's experience with new areas in Alaska and elsewhere made him a natural successor to Spalding, and coincided with a move by the regional director to exert more line authority over parks in the Klamath Falls cluster. These factors, and the need to work with local landowners contributed to Rutter giving Borgman more responsibility for the John Day project. [139]

Borgman and Arnold began talks with Sheep Rock Unit property holders in John Day on May 31,1973. [140] The two attended a meeting in Spray three weeks later, where they saw no objections to the proposed monument. [141] Arnold told a group of nearly 50 people at the gathering, "we are now ready, as near as I can perceive, to start legislative proceedings." [142] Ullman's representative at the meeting in Spray agreed with this assessment and thought the gathering had been helpful to the legislation introduced in January. [143] A representative from Senator Packwood's office, however, wanted to see more evidence of local support. [144]

In spite of this concern, Packwood and Oregon's other senator, Mark Hatfield, introduced an identical bill (S 2168) to Ullman's on July 13. [145] One day later, however, nine property owners in the Sheep Rock area signed a letter to Ullman which opposed prohibitions on grazing and hunting in the proposed monument, as well as scenic easements that "could in any way restrict or control agricultural uses." [146] Borgman responded by sending information on scenic easements to members of the group and, in a memorandum to Regional Director Rutter, recommended that plans for this type of acquisition be altered somewhat, particularly around Foree. [147] After attending two meetings with local ranchers in August, he also advised Rutter that some kind of arrangement could be worked out so that grazing might continue in the Sheep Rock Unit. [148] As for hunting, however, Borgman stood in firm opposition because this activity threatened the monument's viability. In addition, he and other NPS officials did not see how hunting opportunities or the area's deer populations could be significantly affected by national monument status. [149]

Further negotiation on these issues became necessary after Senator Packwood presided at an informal meeting on August 22, 1973, in Dayville. Approximately 150 people attended and approximately ten spoke. Most of the speakers expressed opposition to the proposed monument, which surprised Packwood because his correspondence had been running almost fully in favor of the project. Borgman read the situation as simply a lack of local support being expressed at the meeting, rather than clearcut opposition to the park proposal. [150]

Although he urged the monument's backers to assert themselves more, Borgman realized the necessity for a workable compromise with Sheep Rock area ranchers before congressional hearings on Ullman's bill took place. By the end of October, after another meeting in Dayville, several points of agreement had been reached. The NPS clarified restrictions on scenic easements by submitting a draft to the Sheep Rock landowners and agreed that hunting or predator control, in accordance with state regulations, could take place on these easements. Grazing privileges, as then existing, could continue except as might be voluntarily relinquished by the owner. The NPS also agreed to a minor boundary adjustment near the Mascall Overlook, deleting some acreage previously proposed for inclusion in the Sheep Rock Unit. [151] Accordingly, Ullman found these compromises acceptable and stated that open-ended language in HR 1252 allowing the Secretary of the Interior discretion to make boundary adjustments could be changed to limit such actions to minor ones. [152]

Borgman's most important negotiations (ones which he later remarked determined whether the NPS had a park or not) focused on acquisition of buildings at the Cant Ranch. [153] Talks with heirs Lillian Mascall and her brother, James Cant, Jr., began in May 1973, soon after their mother died. [154] During one of his visits with them in the following August, Borgman committed the NPS to an interpretive theme which included ranching history and the part ranching played in the dominant culture of north central Oregon He suggested the use of oral history in developing this theme, something which the owners of the Cant Ranch enthusiastically approved. [155] Neither Mascall nor Cant spoke in opposition to the proposed monument at Packwood's meeting in Dayville, and by early September one press account ran a photo of the ranchhouse as a prospective administrative office and exhibit building. [156] Although negotiations had really only begun at this point, Borgman's optimism could be more than guarded. The family needed money to pay inheritance taxes, something which made prospective preservation of the ranchhouse very inviting to them. [157] When Cant indicated a preference for selling the entire ranch rather than just part of it, Borgman told Ullman that this option or one involving a life estate might have to be worked into legislation. [158] The congressman did not see Cant's wishes as a problem, and in mid-November announced that agreement had been reached on a NPS plan for the proposed monument. [159]

James Cant, Jr., Lillian Mascall, and Ernest Borgman
James Cant, Jr., Lillian Mascall, and Ernest Borgman at the Cant Ranch, August 1978.
(NPS photo)

Despite some objections raised by one landowner m the Clarno Unit about restrictions related to scenic easements, Ullman arranged for a hearing on HR 1252 in December by the House Subcommittee on National Parks and Recreation. [160] What appeared to Borgman and Rutter as a bad omen, however, came in the form of a memorandum from Stanley Hulett, NPS associate director for legislation, on December 6. Hulett asked Rutter to submit "alternative management concepts" for the proposed monument, which he defined as proposals for less than total federal involvement at the site. The associate director wanted "overwhelming justification for transfer of the three state parks, rather than simply providing funds and technical assistance to the state. [161] Since Hulett asked a number of other questions concerning what the state had done in the past five years and about the necessity for NPS administration, Rutter sent him an interim reply on December 7. Rutter warned Hulett that the monument proposal "is now so far advanced and commitments so firm that any attempt to abandon it would be completely damaging to our credibility." [162] He further defended it by citing the area's national significance and its place in rounding out the National Park System. [163]

Three days later Hulett, through Assistant Secretary of the Interior John Kyl, recommended deferring action by the Congress on HR 1252. [164] Oddly enough, Hulett recommended that Interior submit a favorable report on the bill's predecessor, HR 488, submitted just over a year earlier. His subordinate, Ira Whitlock, submitted a favorable recommendation on HR 1252 on August 22, while in an acting capacity. [165] Nevertheless, the NPS officially remained uncertain as to whether a national monument represented the most advisable form of preservation. Hulett's stated reasons for this hesitancy included demands on the federal budget, the fact that over half of the proposed monument consisted of state park land, and concern about the state game commission's position on hunting. He did, however, pledge the administration's position on HR 1252 would be formulated by April 1974. [166]

As might be expected, both Ullman and Packwood testified in support of the bill. Ullman expressed dismay over the NPS recommending deferral, especially since he could cite planning documents and correspondence that addressed concerns which Hulett identified. Packwood read a shorter statement, largely confining himself to a testimonial about the fossil beds while also commending Ullman, the NPS, and local ranchers for their interest in protecting the area. [167] A representative of the National Parks and Conservation Association also spoke in favor of HR 1252, but recommended two changes. One involved using stream corridors to connect all three units of the monument, while also suggesting that the NPS minimize automobile- related developments through careful planning. [168]

The subcommittee chairman, Roy Taylor of North Carolina, concluded the hearing by charting this legislation's direction. He wanted to consider it again along with similar bills in order to report omnibus legislation in early 1974. Ullman commented that he had been pursuing national monument status for the John Day Fossil Beds too long to see it stymied by "bureaucratic indecision and the heavy hand of the Office of Management and Budget. " [169]

Despite this deferral, the proposed monument's master plan appeared to be moving toward completion. Rutter received word a few days before the hearing that the plan could be printed subject to a final review. [170] The regional director delegated this to Arnold, who in turn contacted Borgman. Both of them made corrections, but Borgman alerted Rutter that the master plan needed major revision. He strongly recommended it not be printed because the document did not reflect agreements that had been negotiated with affected landowners. Rather than put the cart before the horse, Borgman reasoned that a report to Congress made through Interior should reflect these agreements with supporting documents such as a master plan and environmental statement rewritten accordingly. He acknowledged that this endeavor involved a lot of work and expense, but saw dropping the John Day project as the only alternative. [171]

Rutter agreed with Borgman and stopped the master plan from going to press. The goal of completing it prior to further legislative proceedings had to therefore be abandoned. This is because the House subcommittee reconvened in late January 1974 to consider HR 1252 as part of an omnibus bill. The unfinished master plan did, however, provide direction for what the monument could encompass since Ullman's bill gave this authority to the Secretary of the Interior. It still represented a work in progress, but one which started to abandon a focus on recreational components, such as developing river access, in favor of strengthening justification for the monument based on preserving and interpreting scientific resources. [172]

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