BLM Planning 2.0

roan Plateau

The Bureau of Land Management (BLM) has prepared a proposed rule (known as Planning 2.0) to change how it manages federal lands and how it writes and implements Resource Management Plans. The Board of County Commissioners (the Board) is concerned that this effort represents a paradigm shift by the BLM away from localized decision making in favor or broader planning efforts at a landscape scale across geographic regions and political boundaries thereby reducing the voice of local governments and their ability to meaningfully participate in the process.

With over 62% of the County consisting of lands owned and managed by the federal government, Garfield County and the larger region continue to be largely dependent on the BLM’s multiple use and sustained yield provisions established and required under Federal Land Policy and Management Act of 1976 (FLPMA). Specifically, these public lands have sustained the livelihoods of our County and region by providing opportunities for livestock grazing, recreation, energy development and mining that are foundational cornerstones to our local, regional and state economies. Consequently, the manner in which the BLM manages public land, and Garfield County’s ability to meaningfully participate in the development of BLM land use programs, regulations, and decisions, is extremely important.

On Monday, May 16th, the Board approved and filed their formal comments with the BLM which include a cover letter from the Board highlighting key and broad sweeping concerns with two detailed sets of formal comments prepared by federal land policy attorneys, Rebecca Watson and Norm James on behalf of Garfield County. These comments work though finer details for the basis of FLPMA and where the BLM is required to coordinate and ensure consistency with local government rules and policies; further, they lay out the legal and practical architecture for the fundamental flaw that the BLM should not have applied a Categorical Exclusion to avert the National Environmental Policy Act (NEPA). In summary, the Board raises the following key concerns regarding the proposed rule:

  1. The BLM has elected to apply a Categorical Exclusion to the proposed rules rather than adhering to the requirement of an in-depth environmental analysis required by the National Environmental Policy Act (NEPA).
  2. The proposed rule diminishes the role of local governments in federal land use planning by diluting the FLPMA requirements for “coordination” and “consistency” with local governments;
  3. The proposed rule changes the direction in FLPMA to consider local impacts in favor of “landscape,” national and international concerns;
  4. The proposed rule changes the emphasis for the rules on “multiple use and sustained yield,” “principal and major uses” and impacts to “local economies” to ecosystem services, conservation and economies “at scale”;
  5. The proposed rule negatively impacts the BLM’s already reduced capacity to do work on the ground;
  6. The proposed rule increases the potential for litigation over plan objectives; and
  7. The proposed rule invites bias in data quality in the planning assessment and monitoring phases of planning.