Nevada Cattlemen’s Association on countering BLM’s ultimate land grab

BLM’s Conservation Rule: The ultimate land grab

In April the Interior Department released its proposal for a rule that would turn land management on its head, and lead to the loss of millions of acres in grazing leases, mining claims, timber permits, and access to countless roads. The proposal creates vague “conservation leases” with no protections for existing permit holders or exclusions for foreign entities. Being open to the highest bidder, “conservation leases” could put public lands out of beneficial production and supplant existing multiple uses on public lands. Visit the Federal Register where you can submit your comments. 

Talking points curated from an email sent by Nevada Cattlemen’s Association

On April 3, the Bureau of Land Management published the proposed rule on “Conservation and Landscape Health”. The rule, which amends a longstanding interpretation of the Federal Management Policy Act (FLPMA), has raised significant concerns among the grazing community. The proposal was developed without stakeholder involvement, which is evident upon review of the contents.

Please take action by submitting comments to the proposed rule here. Comments are due June 20^th by 9:00PM.

Talking points to consider including in your written remarks:

• Livestock producers have always been BLM’s primary partner in fulfilling the agency’s mission of managing landscapes for multiple use and sustained yield. BLM’s failure to collaborate with producers and other stakeholders in promulgating the rule is a great mistake. BLM should withdraw the proposed rule and start over, engaging with stakeholders in a forum that would promote open dialogue and address fatal flaws in the existing proposal.
• The rule as proposed will cause many unintended consequences. Obstructive groups that profit from litigating agencies no doubt see a lot of opportunity in this proposal.
• The Bureau of Land Management does not have the capacity to do the work that is required of them now. The ambiguity and layers of the rule will be impossible to navigate, further delaying other key management activities critical to multiple use on public lands.
• The rule as proposed provides a definition of conservation that is limited to restoration and protection, not active management of the landscape. Conservation is an outcome to support the sustained ongoing use of landscapes in a healthy and productive manner, but is not a use itself.
• While a conservation lease could be applied on top of another multiple use, the inverse does not appear to be true. The BLM intends to limit new or existing multiple uses where a conservation lease system already exists, which gives the conservation lease an inappropriate power to limit or eliminate other multiple uses in a way that no other use can.
• The failure to clearly distinguish between conservation leases, compensatory mitigation, restoration objectives and bonding confuses existing authorities in BLMs toolbox.
• The activities contemplated in the proposed rule are already available. BLM can accept private dollars for conservation through the BLM Foundation and has several avenues available to accept public input on conservation measures.
• Areas of Critical Environmental Concern (ACECs)- BLM has a long track record of their inability to manage an ACEC after designation. The agency’s interpretation that FLPMA directs them to prioritize protection and designation of ACECs is incorrect and conflicts with other components of the proposed rule.

BlueRibbon Coalition is also facilitating public comments through their webpage withdrawtherule.com.

The deadline for public comments is June 20. Flood BLM with your comments.

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