Document ExE6Q920RyEk8N3adNv4xVpaR

m PUBLIC LANDS^^^J FOUNDATION^ For America's Heritage Public Lands Foundation P. O. Box 7226 Arlington, Virginia 22207 July 18,2017 The Honorable Ryan Zinke Secretary of the Interior 1849 C Street NW Washington, D.C. 20240 RE: Public Lands Foundation comments on creating planning efficiencies. Dear Secretary Zinke, I am writing to you in response to the email we received from acting BLM Director Mike Nedd on July 3, 2017 asking for our ideas on how BLM planning and environmental analysis processes can be improved. As you know, the most recent attempt to do this, known as Planning 2.0, was undone earlier this year under the provisions of the Congressional Review Act (CRA). The CRA states: "A rule...may not be reissued in substantially the same form, and a new rule that is substantially the same as such a rule may not be issued, unless the reissued or new rule is specifically authorized by a law enacted after the date of the joint resolution disapproving the original rule." Given this provision, we do not believe BLM should dedicate their limited resources to develop a new set of proposed regulations addressing how it carries out its planning and NEPA responsibilities. Instead the Bureau should focus its time and energy on manual, handbook, and administrative changes, and how it will deal with a 10% reduction in the number of employees who will be expected to complete land use plans, faster, and with less complexity. Acting Director Nedd's email states that a primary purpose of the review is "...that public input, especially at the local level, is an essential component of federal land management." Indeed, the Federal Land Policy and Management Act provides that: Land use plans of the Secretary under this section shall be consistent with State and local plans to the maximum extent he finds consistent with Federal law and the purposes of this Act, (emphasis added) (43 U.S.C. 712) Often the claim is made that federal land use plans developed under FLPMA must comply with local land use plans. That is not what the law says. The full text of the law must be used, including the qualifier that if State and local plans are to be used they must be consistent with federal law and the purposes of FLPMA. We believe it is important to remember that the sword of consistency can cut both ways. For example, local land use plans could prohibit secondary recovery of oil and gas resources, or prohibit coal leasing, or prohibit livestock grazing, even when these demands are not consistent with the purpose of FLPMA. !w<WTU.publichincL org We would like to make some suggestions, as follows: 1. Administratively fix the public comment period for environmental assessments (not EIS's) to no more than 30 days. 2. Direct that RMPs for statutorily dedicated lands, such as the O&C lands in western Oregon, Alaska, and legislated special management areas include alternatives that fully implement the mandates of the specific Acts. 3. Direct the USFWS and NOAA Fisheries (to the extent the Secretary of Commerce agrees) to be cooperating agencies with the BLM. Input from these agencies should be considered to have met the purposes of Section 7(a)(1) of the Endangered Species Act and that RMP, to the extent they do not implement onthe-ground projects, are found to have no effect and not subject to Section 7(a)(2) consultation. Direct that section 7(a)(2) consultations on implementing actions by BLM be completed within the statutory time frame of 90 days. 4. Assign a BLM representative as a planning liaison for each RMP for tribes and local governments who can attend or participate in planning team meetings throughout the process. Having a person with detailed knowledge and understanding to help a partner understand, participate, and influence the planning process can go a long way toward their being effective in putting their viewpoints forth. This would require an investment of funding for each planning effort. 5. Develop a companion document for each RMP which provides a summary for each RMP which local governments, tribes, and other stakeholders could refer to without having to read through the entire multi-volume set of documents. BLM planning documents are simply too voluminous and complex for the average user to wade through. The Public Lands Foundation is a nonprofit national organization incorporated in 1987 to support keeping the National System of Public Lands administered by the BLM in public hands, embracing multiple use management as prescribed by the Federal Land Policy and Management Act (FLPMA), and following sound environmental principles. We are a membership organization whose members are predominantly retired former employees of the BLM. As such, our membership represents a broad spectrum of knowledge and experience in public land management. Thank you for the opportunity to comment. Jesse J. Juen, President 8/29/2017 DEPARTMENT OF THE INTERIOR Mail - Re: BLM Requests Input for Future Planning Efforts and Environmental Reviews Streamlining, BLM_WO <blm_wo_streamlining@blm.gov> Re: BLM Requests Input for Future Planning Efforts and Environmental Reviews 1 message marsha holland (b) (6) To: "Streamlining, BLM_WO" <blm_wo_streamlining@blm.gov> Mon, Jul 3, 2017 at 2:38 PM responsive to local needs- no one listens to us. On Mon, Jul 3, 2017 at 12:30 PM, Streamlining, BLM_WO <blm_wo_streamlining@blm.gov> wrote: I write to you today to ask for your ideas. The President and Secretary of the Interior Zinke have asked the Bureau of Land Management (BLM) to take a new, in depth look into our land use planning and National Environmental Policy Act (NEPA) processes. As someone who cares about the nation's public lands, your input is vital to determining how the BLM will approach land use planning going forward. Our goal is to identify inefficiencies and redundancies that should be eliminated from our land use planning and NEPA processes, while ensuring that we fulfill our legal and resource stewardship responsibilities. By doing this, we will be able to dedicate more time and resources to completing the important on-the-ground work on our public lands. Balanced stewardship of the public lands and resources is more important to the interests of the country and its people than ever before. This mission is also more complex and challenging than at any time in our history. But with your input, we can strike that balance. We are opening a 21-day period, beginning on July 3, 2017 and ending on July 24, 2017, in which you can submit your ideas specific to how we can make the BLM's planning procedures and environmental reviews timelier and less costly, as well as responsive to local needs. This streamlining effort will help shape how we move forward. You can submit your input by going to this link: goo.gl/CYxqM5. The decisions made in land use plans and after NEPA analyses are fundamental to how BLM public lands and resources are used for the benefit of all Americans. We are committed to working cooperatively with state and local governments, communities, Indian tribes, and other stakeholders to determine the best ways to manage public lands for multiple uses and values, both now and in the future. This effort is not required under any laws or regulations. We are doing this because we strongly believe that public input, especially at the local level, is an essential component of federal land management. We look forward to hearing from you. Sincerely, Michael Nedd Acting BLM Director https://mail.google.com/mail/b/AJjsLra2ZY4XSkNIV2iZj_xF2vzbHvLYYBa9u4B7bePECkdoCcaZ/u/0/?ui=2&ik=c1ad5b0200&jsver=PX1Y7GgZjW4.en.... 1/1 8/29/2017 DEPARTMENT OF THE INTERIOR Mail - Re: BLM Requests Input for Future Planning Efforts and Environmental Reviews Streamlining, BLM_WO <blm_wo_streamlining@blm.gov> Re: BLM Requests Input for Future Planning Efforts and Environmental Reviews 1 message Maggie Sacher (b) (6) To: "Streamlining, BLM_WO" <blm_wo_streamlining@blm.gov> Mon, Jul 3, 2017 at 3:10 PM Can't help but notice they asked for this after shutting off comprehensive across spectrum public input. Sent from my iPhone On Jul 3, 2017, at 11:40 AM, Streamlining, BLM_WO <blm_wo_streamlining@blm.gov> wrote: I write to you today to ask for your ideas. The President and Secretary of the Interior Zinke have asked the Bureau of Land Management (BLM) to take a new, in-depth look into our land use planning and National Environmental Policy Act (NEPA) processes. As someone who cares about the nation's public lands, your input is vital to determining how the BLM will approach land use planning going forward. Our goal is to identify inefficiencies and redundancies that should be eliminated from our land use planning and NEPA processes, while ensuring that we fulfill our legal and resource stewardship responsibilities. By doing this, we will be able to dedicate more time and resources to completing the important on-the-ground work on our public lands. Balanced stewardship of the public lands and resources is more important to the interests of the country and its people than ever before. This mission is also more complex and challenging than at any time in our history. But with your input, we can strike that balance. We are opening a 21-day period, beginning on July 3, 2017 and ending on July 24, 2017, in which you can submit your ideas specific to how we can make the BLM's planning procedures and environmental reviews timelier and less costly, as well as responsive to local needs. This streamlining effort will help shape how we move forward. You can submit your input by going to this link: goo.gl/CYxqM5. The decisions made in land use plans and after NEPA analyses are fundamental to how BLM public lands and resources are used for the benefit of all Americans. We are committed to working cooperatively with state and local governments, communities, Indian tribes, and other stakeholders to determine the best ways to manage public lands for multiple uses and values, both now and in the future. This effort is not required under any laws or regulations. We are doing this because we strongly believe that public input, especially at the local level, is an essential component of federal land management. We look forward to hearing from you. Sincerely, Michael Nedd Acting BLM Director https://mail.google.com/mail/b/AJjsLra2ZY4XSkNIV2iZj_xF2vzbHvLYYBa9u4B7bePECkdoCcaZ/u/0/?ui=2&ik=c1ad5b0200&jsver=PX1Y7GgZjW4.en.... 1/1