The Bureau of Land Management has proposed a new rule that would be a major alteration to their land management policy. The BLM is proposing to allow for the creation of something they are calling “conservation leases” that any “qualified individual, business, non-governmental organization, or Tribal government” could be eligible for. The TPA has many concerns about how the proposal seems to suggest the transfer of management of public land and bypasses existing policies and procedures.
The following is a list of concerns that you can utilize for your comments in opposition (please rewrite in your own words to ensure they are not consolidated).
How to file comments:
First, tell the BLM about yourself:
- Who you are, where you’re from, what activities you enjoy on BLM Managed Lands and possibly how much money you spend when recreating (dining, recreational equipment, hotels, fuel, etc) on visits to these lands.
- Emphasize if you are a multi-use recreationist. Include all the activities you enjoy on public land, and what characteristics you look for in your experiences.
- The variety of benefits that recreational use of BLM lands provide to you. (exercise, thrill seeking, skill building, family time, connection with nature, etc.).
- That you support the comments submitted by local, state, and national groups (RwR, CORE, TPA etc).
Then to comment substantively on The Proposal, include these points in your own words:
- NEPA analysis of this Proposal must be required. The creation of this new regulation (“conservation leases”) must comply with Federal Land planning policies and NEPA requirements. It is not clear that this proposal fills either requirement. Approval of this Proposal as a Categorical Exclusion is a violation of NEPA.
- “Conservation leases” cannot limit or close access to public lands for any reason. Public access to public lands cannot be lost indirectly from the proposal.
- “Conservation leases” must be managed by the BLM. The BLM, not the public, should be required to monitor areas with leases to ensure impacts are not occurring to other uses or to hold a leaseholder accountable for violations.
- The proposal must ensure staffing is provided to manage the program. One large issue facing the BLM is a lack of staff. Existing staff can not be reallocated away from other projects and work on management plans that are often out of date.
- The Proposal fails to address what best management practices would be to protect multiple uses on public lands. To date, conservation leases have been targeted areas outside the multiple use mandate and as a result, best management practices on this issue may not exist. Clarification must be made that multiple uses will not be impacted and best management practices will be applied.
- Allocation of carbon offset credits must be based on an equitable system. It is not clear how leases are being considered the proper way to provide carbon offset credits. In Colorado, the motorized community created the Motorized Trails Program in partnership with Colorado Parks and Wildlife (CPW). This program now contributes more than $8 million per year to maintenance and trail conservation. Many projects funded by this program could be worthy of carbon offset credits but would not qualify if a “conservation lease” was required to create them.
- Intact Landscapes Definition: The Proposal seeks to protect intact landscapes but defines “intact landscape” in a manner that is too broad and ambiguous.
Deadline for comments:
June 20, 2023 July 5th, 2023 (deadline extended)
Please take this opportunity to submit a personal message to the BLM!Comment Here!
Where to File Comments:
U.S. Department of the Interior,
Director (630), BLM
1849 C St. NW, Room 5646,
Washington, DC 20240
Federal Register: Conservation and Landscape Health
BLM Proposed Rule: Conservation and Landscape Health
BLM Public Lands Rule Frequently Asked Questions
BLM Public Lands Rule Public QAs.pdf