July 10, 2023

CSF Expresses Concern with BLM Conservation Rule as Currently Written

Article Contact: Taylor Schmitz,

Why it matters: The Bureau of Land Management (BLM) manages over 245 million acres of federal land and water and is required to maintain a multiple-use, sustained-yield mandate intended to support a wide range of issues including recreation, energy production, grazing, timber, among others.  It is critical that the BLM continues to support these Congressionally mandated uses, including hunting, fishing, trapping, and recreational shooting in a manner that is consistent with the guiding principles of the BLM.

  • Last Monday, the Congressional Sportsmen’s Foundation (CSF) submitted a comment letter on the BLM’s proposed “Conservation and Landscape Health” rule.
  • CSF fully supports efforts to promote and advance conservation on our nation’s public lands but is concerned that this rule may have unintended consequences on sportsmen and women and other users of BLM lands, whose support is critical to maintaining the popularity of these lands.

On Monday, July 3, CSF submitted a comment letter to the Bureau of Land Management expressing concerns about unintended consequences that could potentially stem from the BLM’s proposed “Conservation and Landscape Health” rule.

CSF has concerns about the definition of “conservation” as used by the BLM in the proposed rule. In the proposal, the BLM integrates the loosely defined term “protection” into the definition of conservation. There is a long history of efforts designed to undermine the “wise use” definition of conservation and promote a “preservationist” concept of conservation, which is inconsistent with the guiding principles established by FLPMA. CSF would like to see the true sense of the definition of conservation used that supports “the greatest good for the greatest number for the longest time” as established by Gifford Pinchot.

Specifically, the proposed rule seeks to establish conservation as a use of BLM lands. CSF questions the necessity of such an action as the BLM is already required to ensure the future of multiple uses and sustained yield as required by the Federal Land Policy and Management Act of 1976 (FLPMA), which established the multiple uses of BLM lands. CSF believes that conservation is not a use unto itself but rather an overarching guide on how the public lands should be managed to allow for “multiple use”. Conservation serves as the tool, not the use, to achieve sustained yield to support multiple uses.

Finally, CSF has significant concerns about the lack of clarity provided in the proposed rule regarding “conservation leases”, which is arguably the centerpiece of the proposal. We believe that FLPMA provides the authority necessary to implement conservation practices without the need to establish conservation leases. CSF questions what gaps currently exist and what is unavailable to the BLM to meet conservation outcomes that improve land health and ensure the future of multiple uses. The proposed rule states “The BLM will determine whether a conservation lease is an appropriate mechanism based on the context of each proposed conservation use and application, not necessarily as a specific allocation in a land use plan”. Unfortunately, the proposed rule does not provide any insight into how the BLM will determine what is considered “an appropriate mechanism”. For conservation leases to be successful, the BLM will need to work with stakeholders and users of public lands to develop clear, realistic guidelines that do not inadvertently elevate one use over another.

Unfortunately, CSF cannot support the proposed rule as currently written and we encourage the BLM to revisit conservation as a designated use of BLM lands, revise the current protectionist language included in the definition of conservation, revisit the necessity of conservation leases, and work with state fish and wildlife agencies, sportsmen and women, and other users of public lands before any further actions are taken.

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