BLM Conservation Rule Not Ready for Prime Time

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Tuesday, June 27, 2023
Chandra Rosenthal (303) 898-0798


BLM Conservation Rule Not Ready for Prime Time

Agency Lacks Capacity to Accomplish Intended Conservation Goals


Washington, DC — The U.S. Bureau of Land Management’s ambitious proposed Conservation and Landscape Health Rule has laudatory goals but is wholly unworkable given BLM’s current organizational capacity, according to comments submitted today Public Employees for Environmental Responsibility (PEER). In theory, the Conservation Rule, also known as the Public Lands Rule, would elevate conservation to equal status with the agency’s traditional “multiple uses” of drilling, mining, logging, and grazing. However, such an undertaking would require levels of regulatory sophistication that BLM has yet to exhibit.

Despite the clear emphasis on conservation as a priority, BLM has not explained why it cannot simply begin to enforce conservation values under its existing regulations. Moreover, the Rule –

    • Relies on BLM extending the land health standards it now uses to assess grazing to all its lands. Yet, BLM presently does an abysmal job of range management. It rarely requires allotments with failing grades to take steps to improve landscape health. Thus, it seems imprudent to double down on such a dysfunctional system;
    • Overlooks BLM’s woeful understaffing to adequately perform its current functions, let alone handle greatly enhanced analytic tasks of managing on a landscape-scale; and
    • Would allow oil and mining interests to lease vacant land as an “offset” against adverse climate and other damage they are wreaking on their original holdings.

“Conservation clearly could use a boost at BLM, but the agency needs to establish a track record showing that it can use Land Health Standards to manage for conservation values,” stated Rocky Mountain PEER Director Chandra Rosenthal, pointing out that BLM’s own field data indicates more than half of its grazing allotment acres fail land health standards with overgrazing as a significant cause – an area the size of Wisconsin. “Under its current regulations, BLM has no excuse for allowing half its rangelands to fail minimum standards for water, soil, native flora, and wildlife habitat.”

Among many lingering questions about the proposal, BLM has declared that it will not allow a conservation lease to retire a livestock allotment, no matter how overgrazed. That suggests the absence of any conservation benefit for the 150 million acres in its livestock program.

Even more concerning, BLM plans to increase its reliance on “remote sensing” using satellite imagery as a management tool. It is already using satellite data as the basis for wholesale renewals of hundreds of commercial livestock stock permits.

“BLM’s use of climate change as a justification is hard to take seriously because the agency has been notorious in ignoring the climate impacts of the activities it presently permits,” added Rosenthal noting, among other things, BLM’s refusal to even consider the climate impacts of its grazing program. “Giving BLM more regulatory discretion to issue more leases may, especially under future administrations, simply trigger a new corporate land grab, leaving little to ensure they are managed to provide real conservation value or public benefit

Public comments on the BLM proposed Conservation Rule had been due this week but BLM agreed to extend the comment period until July 5th.


Read the PEER comments 

Examine BLM proposed Public Lands Rule 

See BLM data on its’ administration of landscape health standards 

Note BLM’s growing use of “remote sensing” 

Revisit BLM completely ignoring climate impacts of its massive livestock program

Look at critical BLM understaffing

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