Jul 5, 2023 Coalition Comments on Bureau of Land Management Proposed Rule on Conservation and Landscape Health
Dear Director Stone-Manning:
We appreciate the opportunity to comment on the Bureau of Land Management’s (“BLM”) Conservation and Landscape Health Proposed Rule (“Proposed Rule”). The undersigned organizations (collectively, the “Coalition”) include businesses in many areas of the broader economy, including energy, mining, grazing, and other community stakeholders that are impacted by this Proposed Rule. …
We are dedicated to ensuring that wise and lawful management practices are followed so that current and future generations may use and appreciate the natural resources with which America has been richly endowed. Our organizations and the companies and members we represent have a business presence across the country and a unique perspective on the importance and use of our public lands. Our members rely on access to public lands managed by BLM to conduct their operations and to serve their communities. Indeed, the broader business community across America depends on reliable, affordable, domestic energy and natural resources that are delivered from and across public lands to make and transport their products. As can be too often forgotten, businesses are made up of people, and hardworking Americans who live near, work on, and recreate on our public lands would be adversely affected by these proposed conservation and landscape health measures if the concerns raised in this letter are not carefully addressed. The Coalition shares the laudable goal of conserving and restoring our public lands; however, at the same time, the Coalition is concerned that the Proposed Rule exceeds BLM’s statutory authorities and conflicts with congressional directives.
With this perspective in mind, the Coalition urges BLM to reconsider the Proposed Rule. There are many ways to conduct the lawful conservation and the wise management of our country’s natural resources through appropriate actions taken pursuant to lawful authorities, including congressional actions to designate national parks, agency recommendations to Congress for additional wilderness areas, and use of Inflation Reduction Act of 2022 (“IRA”) funds for conservation efforts. But BLM’s Proposed Rule is both misguided policy and legally problematic, including for the following reasons…