BLM Public Lands Rule

Support for BLM Public Lands Rule – Conservation and Landscape Health

Director Tracy Stone-Manning
Bureau of Land Management
1849 C St. NW, Room 5646,
Washington, DC 20240
Attention: 1004–AE92

RE: (Doc # 2023-06310) Support for BLM Public Lands Rule – Conservation and Landscape Health

Dear Director Stone-Manning:

We are a consortium of independent chapters of the National Audubon Society that are interested in seeing that America’s public lands are managed in a balanced way that benefits current and future generations. While scientific understanding has improved and tools to manage the lands have expanded, the challenges to our nation’s public lands have increased. Therefore, we applaud the Bureau of Land Management’s (BLM) Public Lands Rule and the intention to promote conservation and prioritize the health and resilience of ecosystems across those lands.

Our nation needs this forward-thinking approach to create a clear process by which to manage our nation’s public lands to ensure healthy landscapes, abundant wildlife habitat, clean water and balanced decision-making.

The BLM’s impact on our nation cannot be overstated, as it manages one out of every 10 surface acres across the country and 30% of the nation’s mineral and soils. With more than 245 million acres of rolling sagebrush hills, deserts, grasslands, forest, and wetlands, the BLM manages some of our nation’s most iconic and loved landscapes.

Congress tasked the BLM with a mandate of managing public lands for a variety of uses such as energy development, livestock grazing, timber harvesting, and recreation while ensuring maintenance of natural, cultural, and historic resources. It is the latter obligations that we are collectively interested in, and the important step the BLM has taken to put conservation on equal footing with other uses.

BLM lands bring substantial recreational dollars to nearby communities, provide physical and mental health opportunities for people of all means and backgrounds, hold invaluable evidence of human prehistory, are rich in cultural heritage and sacred sites, provide critical wildlife corridors across the western United States as well as habitat for more than 3,000 species, many of which can be found nowhere else. These public lands, and the diverse animal and plant ecosystems they support, are an essential part of the way of life for many western communities and Tribal nations. They also are an important legacy.

Conservation is a shared American value, perhaps the most fertile political common ground today. Americans love nature and the outdoors, wild landscapes and iconic wildlife, and conservation remains a common bond among us, regardless of where you live. We want our public lands managed sustainably so that we may be able to pass them on in healthy condition to our children, grandchildren and generations to come.

We commend the BLM for taking action to promote conservation and land health, which are consistent with its mission, authorities and responsibility. While the federal agency has largely focused on oil and gas, mining and other extractive uses, we feel that these must be balanced with conservation, recreation, wildlife and watershed health, and cultural resource protection. Thus, together, we voice our support for the BLM’s three main components of the proposed Public Lands Rule: (1) protect the most intact, healthiest landscapes, (2) restore landscapes back to health, and (3) ensure wise decision-making, based on science and data.

Our nation’s public lands are experiencing extreme weather events such as wildfires, droughts, and severe storms – which are occurring at increasing frequency and intensity. This proposed Rule drives us in the direction of having healthy intact landscapes that are more resilient and able to recover more easily in the face of natural disasters. In keeping with passage of the Inflation Reduction Act and the Infrastructure Investment and Jobs Act, this proposed Rule would allow federal land managers to identify and prioritize lands and waters that require ecosystem restoration work, such as removing invasive species.

Where there are existing intact landscapes, the use of conservation management tools should be encouraged. Areas of Critical Environmental Concern (ACECs) is an existing administrative tool available to the BLM which has historically been under-utilized and inconsistently applied. The proposed Rule includes the first-ever regulations on ACECs, and we are happy to see that it provides clarification on and expansion of its use. With the adoption of the Rule, ACECs can play a critical role in protecting important natural, cultural, and scenic resources, intact landscapes, habitat connectivity, and ecosystem resilience.

We are also encouraged to see habitat connectivity and wildlife corridors emphasized in the proposed Rule. Such connectivity is essential to allow migrating wildlife – including birds – to adapt to a changing climate, and BLM could strengthen the language to more broadly identify habitat connectivity and migration corridors as a conservation priority in recognition of their important role in supporting ecological resilience.

With 90% of the lands managed by BLM being open to natural resource leasing and development, we are encouraged to see conservation leases discussed in the proposed Rule. We recognize that conservation leases would not disturb existing authorizations, valid existing rights, or state or Tribal land use management. As presented, conservation leases could be used for two purposes: restoration and compensatory mitigation (where impacts cannot be avoided). Therefore, we support conservation leases as a mechanism that can lead to better managed lands by realizing more durable protections and restoration efforts.

In closing, America’s public lands are a national treasure. This rulemaking is an important opportunity for BLM to restore balance to its land management priorities and to encourage an inclusive approach to conservation that includes co-management with Tribal nations and the consideration of land health in all decision-making.


CC: Secretary of the Interior Deb Haaland
U.S. Department of the Interior
1849 C St. NW
Washington DC 20240