While ISPMB applauds the BLM for adding conservation to one of the Multiple Use uses, we have concerns that are noted throughout our document.

Please feel free to use ISPMB’s response to craft your response to the BLM in your own words.  We know this could take time but it is so important, especially with the grazing recommendations we have inserted.  The BLM also proposed Conservation leases which we are very concerned about as you will read.

You can read the entire BLM proposed rule here.  You will also add your comments here.

 Submit your comments at regulations.gov

You can start your document with the following:

We congratulate the BLM for recognizing and codifying what has been the law of the land since the passage of FLPMA in 1976.  The protection of the environment should be the number one priority of public land management.

FLPMA states unmistakably that “the public lands be managed in a manner that will protect the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archeological values: that where appropriate, will preserve and protect certain public lands in their natural condition; that will provide food and habitat for fish and wildlife and domestic animals; and that will provide for outdoor recreation and human occupancy and use.”

Multiple Use is clearly defined by statute to ensure that these values are given equal or even greater footing than extractive and destructive uses of public lands.  FLPMA states that all public lands require, “harmonious and coordinated management of the various resources without permanent impairment of the productivity of the land and the quality of the environment with consideration being given to the relative values of the resources and not necessarily to the combination  of uses that will give the greatest economic return or the greatest unit output.”

For the rest of your reporting, just note the following recommendations for their rule-making such as:

• The rule should either include all permitted lands for Conservation leases or none at all.
• In lieu of Conservation leases, the BLM should revise existing regulations.
• The BLM should retain full responsibility for managing public lands.
• The final rule should consider domestic livestock a disturbance agent.
• The final rule should note that livestock grazing is not an acceptable restoration practice.
• The final rule should include meaningful public engagement at all levels of planning, decision-making, and throughout the project implementation.

Please note that this is extremely modified to make it easy for your response to the BLM.  You may close your discussion hoping that BLM will make wise decisions regarding this rule-making.

Please thank them for the opportunity and submit your commits.  You do not need to put your personal information in this letter, nor should you.