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D. Being Good Neighbors: How can the BLM D. Being Good Neighbors: How can the BLM E. Reducing Litigation: How can the BLM E. Reducing Litigation: How can the BLM E. Reducing Litigation: How can the BLM E. Reducing Litigation: How can the BLM F: "Right-sized" Environmental Analysis: How F: "Right-sized" Environmental Analysis: How build trust and better integrate the needs of build trust and better integrate the needs of create legally defensible documents and avoid create legally defensible documents and avoid create legally defensible documents and avoid create legally defensible documents and avoid can the BLM more closely match the level of can the BLM more closely match the level of state and local governments, tribal partners, state and local governments, tribal partners, the delays associated with legal challenges? the delays associated with legal challenges? the delays associated with legal challenges? the delays associated with legal challenges? NEPA analysis to the scale of the action being NEPA analysis to the scale of the action being and other stakeholders? and other stakeholders? Solution #1 Solution #2 Solution #3 Solution #4 analyzed? analyzed? Solution #3 Solution #4 Solution #1 Solution #2 It seems to me that given the reality that federal lands serve multiple interests, some that compete, litigation is a given. The only solution that might help would be efforts to try to bring together environmental and conservation groups with mining and extraction interests to forge relationships of trust. Might seem naive, but worth the effort. Avoid "one size fits all" approaches to land management. Amend Appendix A (I) (B) of the Land Use Planning Much of the legal challenges and delays can be Amend the Endangered Species Act as recently Handbook to recognize that local citizens know the avoided through legislation to amend or repeal the proposed by House republicans. land better than "distant interests." Distant Equal Access to Justice Act. This act provides a interests don't have to live with the land financial incentive for NGOs to sue the federal management positions they often take. government and settle once they get their way. The net result is a well-funded network of attorneys in environmental organizations who make a living suing federal agencies. Roll back federal over-reach at the EPA. More government-to-government consultation with tribes, earlier in the process. Clear open communications straight forward language. This is a joke. You are only doing this so you can say that you asked for public input. The above statement is completely asinine. "Discrete idea"code for top secret. Absurd. I'll bet whomever wrote that believes themselves to be clever. Make greater use of Categorical Exclusions. Vest greater decision-making authority at the field office level. Maybe there can be more levels besides just a FONSI or a 1000-page EIS. Answer the question, "is an enviromental analysis need"!! ANY negative and direct environmental impact, no matter how small it is perceived by someone uneducated in the natural sciences, can have significant indirect impacts upon other parts of the environment as a whole. Stop looking for ways to wipe out species so Trump's buddies can get richer. Seek support of applicable state legislatures, county commissions, and LOCAL tribal leaders (if applicable) of all proposals, rules, policies, etc. Note that the US Constitution clearly limits federal land ownership to that obtained "by the Consent of the Legislature of the State". Sometimes extra measures may need to be put into place to protect this economic impact to keep the recreation available, even though from the land managers standpoint, it may not be feasible or make sense. At this point, the local government that would be the most negatively impacted, should have a bigger say in how the land is managed, and may have to provide some resources to ensure it is managed properly. All law-enforcement authority must be taken from the BLM. Instead, the BLM should rely on the sheriffs for all law enforcement functions. The BLM must aggressively pursue the "multipleuse" concept and cooperate with all users (state legislators, county commissions, LOCAL tribal leaders (if applicable), sportsmen, campers, backpackers, miners, rangers, loggers, etc). Work directly with special interest organizations and non-profits in scoping major actions and implementing Land Use Plans and Amendments. Set aside time and ask known stakeholders for comments up front. The Antiquities Act must be rescinded or amended. Seek support of applicable state legislatures of all Seek support of applicable state legislatures, county If the amendment route is taken, all changes of land proposals, rules, policies, etc. Note that the US commissions, and LOCAL tribal leaders of all status from "multiple use" to monument, park, Constitution clearly limits federal land ownership to proposals, rules, policies, etc. Note that the US wilderness status, etc. must be initiated at the local that obtained "by the Consent of the Legislature of Constitution clearly limits federal land ownership to or state level -- not from environmental activists or the State". that obtained "by the Consent of the Legislature of lame-duck presidents in the final days of their the State". administrations. Note that the US Constitution clearly limits federal land ownership to that obtained "by the Consent of the Legislature of the State". All changes in status must be severely limited to protect significant natural, cultural, or scientific features -- not vast tracts of land, most does NOT comprise significant natural, cultural, or scientific Maintain publicly accessible comprehensive GIS database with project descriptions and tracking so public can inspect pending actions and comment on issues. Public concern should play a greater role in analysis. A national map database like the US Energy Information Agency maintains for energy infrastructure should be maintained for all BLM NEPA reviews with layers that can be toggled by program. More transparency will provide more appropriate level of analysis. BLM can do this by making decisions based on ecological needs; not political. Change nothing Ensure all the proper stakeholders are engaged, and The power players for the major groups need to be that they all have agreed to the proposed plan. If involved, and the smaller groups that can not be the person in the room does not have the authority represented in the collaborative need to have an to sign for the organization, they need to get understanding with those that are in the room, that someone that can. Once everyone has signed that the best interest of their respective members and they agree to the completed document, and that users are being represented to the best of their they can live with it the way it is, then that will ability. mitigate litigation in the future. You've got too many people trying to think up unnecessary questions. Change nothing Understand what the scope of the area being analyzed is, and don't let scope creep affect the planning process. It is hard, because everyone wants their little bit included. If the whole area was analyzed from the beginning to understand the potential issues with the area under that land managers area, then the smaller environmental analysis would not be required. Kern County did something similar to this with the oil and gas industry to help speed up the process of approving new wells and the infrastructure associated with the industry. It seems to be working, and was a long time in the planning and implementation phase. We would like to send you a document. Please provide an email address. Thank you. We would like to send you a document. Please provide an email address. Thank you. Science-based decisions. Rigorous use of best management practices. We would like to send you a document. Please We would like to send you a document. Please provide an email address. Thank you. provide an email address. Thank you. Work to get the law changed whereby groups are reimbursed their legal fees whether they win or lose. I will try to do the same. It's outrageous that groups with an agenda can file a lawsuit and be reimbursed their legal fees by the US government whether they win or lose. They then take that money to file another lawsuit, filling their coffers to continue this practice, further their agenda. I don't know where to start. Help me help you in eliminating this practice. Make few, if any, "exceptions" in management for individual stakeholders. We would like to send you a document. Please provide an email address. Thank you. We would like to send you a document. Please provide an email address. Thank you. Not sure about this one. We would like to send you a document. Please provide an email address. Thank you. How about revising the NEPA? We would like to send you a document. Please provide an email address. Thank you. include and collaborate these groups as well as the establish that the litigants will pay all legal fees if public to put pressure on the litigants they loose establish time limits on suits and how long they can linger engage local/regional BLM personel and public in early decision making and not engage NEPA unless absolutely necessary. for instance..establishing a water source/well on BLM should have the opportunity for a Catagorical Exclusionand not a full NEPA analysis Double the amount pf public meetings for all NEPA. Hire people who can explain the process patiently. By not pushing for development on projects so much. Listen to the public and stop pandering to developers. Litigation comes from political influence that shortens BLM review. BLM should stick to their mission and stop being influenced by corrupt political entities. Do not streamline NEPA!!! That is asking for litigation and you will get it! Make sure everybody is heard by lengthening public BLM almost never has a long enough review Add more public meetings and have more review and adding more meetings. But you will process. All EIS documents should have a standard notifications in local papers. never get rid of potential litigation. Move on. 120 day review process. By making things too short, BLM always ends up with incomplete analysis. It takes so long and expensive to get any project Do wants best for the land. Don't Cave to frivolous done on the land, that all parties agree on except lawsuits. And those that do Sue need to pay their those that don't want cattle, cars or people on the own cost not with taxpayer money. land. The best managed lands are managed local. The best managed lands are the ones the ranchers and BLM have worked on the bring water and feed to the land which brings wildlife and great pastures for cattle and other livestock. We seem to have a cut and reduce mentality instead of a growth and increase grazing possibilities mentality. I believe we do need to look at the impact the decisions will make on the land but we need to realize of the best managed lands for grazing are the best Managed lands for everything else The BLM needs more scientists to understand exactly what the conditions on the ground are. Lawsuits stem from stakeholders' assumption the land is theirs to use no matter it's condition. With a clear baseline of condition, and a long term landscape view, the BLM will have defensible positions. The right size of analysis depends on how much knowledge the BLM has of the area. Less knowledge requires more analysis. Create an atmosphere that is more open. Many Stop the game playing. BLM has meetings with Train BLM employees to collect repeatable Purge agenda driven BLM employees that are BLM employees only socialize with each other. stakeholders so they can check a box. They come measurable data, analyze results and write reports dishonest. They are not at community events. They hide from to the meeting with a closed mind and and an intent about trends. Assure that if someone else goes out the public. They are not proud of their jobs. That to limit what they will say. They participate because to collect the same data they will get the same creates a broken system. Encourage them to be out it is required, not because they want. Train BLM results. there in the public as part of the community. employees that the right thing to do is work with Encourage them to open up. the stakeholders who are affected by their management decisions. Stop playing games when public involvement is Change the culture at BLM. The employees are Create a common sense cost benefit analysis required. Instead, truly engage the stakeholders and paid high salaries with very little accountability to wherein the time and money spent on the NEPA listen, learn and act on what they have to say. anyone. Make them produce. Require weekly time process is looked at relative to the risk to the reporting that includes results tied to goals. Shake environment from a particular activity. Create up the organization. Make it come alive. People more categorical exclusion lists. will feel better if they are productive. That will take a shift in the culture. Reward the achievers. Stop the apathy. Streamline EAs and EISs with good templates. If sued, BLM should look to proceed in an expedited manner (always dependent on the federal court's calendar). Long delays and requests for continuances should not be coming from BLM. BLM should refuse requests for continuances from opposing parties. Discovery, if necessary, should be prompt and within the designated timeframes of the civil rules. Elimination of all legalese from main and/or most Allow all comments to be provided electronically. important planning documents. All NEPA related Succinct ideas can be absorbed. The current e- documents should be condensed for all to read and platform I'm using to type these comments is a good understand. Supplemental legal treatise can be example. included, but it should not be necessary to submit comments. Provide for the necessary resources to do a Make decisions that you will defend in court. Show Reduce willingness to pay EJA fees to litigants. thorough job. Increase cost recovery or 3rd party the public that appeals don't result in negotiating contracting opportunities to gain additional BLM down a decision. That encourages more. Be willing work capacities. to defend all land management decisions to show the special interest groups that once BLM considers all issues, resolves them appropriately, and makes a decision, it means business on implementation. Tough one. Judges who don't know NEPA too well, Consider preparing more "programmatic" NEPA like to land on side of conservatism and push EISs. documents that allow/facilitate many small future BLM should consider ways to make a small and projects to be approved using Determination of efficient EIS easy to prepare. That way, BLM can NEPA Adequacy or Categorical Exclusions. avoid losing the debate of whether an action has the potential for significant impacts. I have no idea. Too many lawyers. BLM should consult earlier in the NEPA/review process rather than wait until litigation later on in the process. Revise NEPA and include the following Statute of Require that all administrative appeals be exhausted Limitations: for categorical exclusions, 3 months, for before any litigation before a federal district court. environmental assessments, 1 year, and for Congress carved out this process in the environmental impact statements, 2 years. appropriations bills for the grazing program only- it Otherwise litigation follows the Administrative needs to be applied to all actions and all programs. Procedures Act with a Statute of Limitations of 6 years for all actions. Develop protocols for different levels. Unfortunately, the impacts of a region studied under NEPA will have a farther reach than the land itself (see economic concept of externalities), and therefore BLM will have to evaluate the effects of changes to one parcel of lands to other parcels (e.g. wildlife connectivity, cultural landscapes). Add more categorical exclusions. There should be Add a new regulation requiring environmental one that could be applied to any program for a assessments consider potentially significant impacts project in an existing disturbed setting where there only. This negligible impacts should not be are little or no resource values. considered. B LM managers should incorporate all input from interdisciplinary team staff specialists instead of picking and choosing what input they want. Right size anslysis is already in place with NEPA with the use of categorical exclusion, determination of NEPA adequacy, environmental assessment, finding of no significant impact, and environmental impact statement. Managers should make sure all input is incorporated by interdisciplinary team members. Exercise due diligence in engaging public officials. Exercise due diligence in communicating the potential environmental impacts. Operate in good faith with landowners. Play a supportive role in protecting neighboring landowners. Legal challenges are not necessarily a bad thing. In many cases, such challenges are protecting natural resources and members of the public who rely on them. Uphold the rights of citizens who rely on the land, water, and natural resources that are impacted by drilling and infrastructure projects. Delays are needed to ensure compliance with Any time waterways and drinking water resources Hazards are abundant with drilling and regulation at each step of the process. Streamlining may be impacted, due diligence must be exercised in infrastructure projects. Each project must be the process does not protect members of public. assessing potential risks. carefully analyzed whether it impacts a community of 100 people or 100,000 people. Implement Planning 2.0 Follow the NEPA process meticulously. Give legally defensible reasons for BLM decisions at Never exclude any contributions during the public every stage during the NEPA process, inviting phase of the NEPA process. informal challenges at that time. Eliminate shortcuts to the NEPA process. Implement Planning 2.0 Scale is a subjective description that is particularly subject to abuse. Never assume ahead of time that the NEPA process should be adjusted to match a preconceived scale. Let the needed scale emerge from the process. Go to the public - instead of making us come to you. Do not ignore the public. Stop trying to take illegal action and then maybe you can avoid delays associated with legal challenges. Why are all of your questions written with bias embedded in them? Are you kidding me? Don't you have lawyers that can figure this out for you? Use less lawyers Follow the law in the first place, and stop using shortcuts to bow to industry pressure. BLM can avoid litigation by protecting the environment and ecosystems that rely on it. Legal challenges only happen when the BLM is influenced by industry with profit motive. Uphold the laws that exist. Strengthen the laws that protect public lands. Follow the law. There is nothing wrong with legal challenges. We live in a democracy. Provide time for adequate comment. BLM cannot circumvent NEPA and other environmental laws. If a policy needs to be challenged, BLM should not circumvent the legal challenge by devious means. If BLM fully considers the best scientific evidence to support an action, its policy should be sound and will not be as easily challenged. But the agency needs to depend on science and full consideration of environmental impacts. The best way to avoid legal challenge is to follow the letter of the NEPA law. Take environmental groups seriously. Don't let industry get away with actions that are bad for the land. What makes you think the levels are not matched? You need MORE environmental analysis - what you Work more closely with the public to see if they are do now is down sized. happy with how much you are analyzing. What? Keep NEPA the way it is, it works fine. There are already varied analysis dependent on the situation and action to be taken. Environmental interactions are complex whether the field of action is large or small. Thorough investigation is the right way to go. Keep NEPA as it is. There's a reason it's rigorous. Find folks in the agencies that can mentor new Have more outings that include these stakeholders, Decide early who is the person over the Project. people coming in, BLM is notorious for those in high picnics, safety days, BBQ, offer classes at the offices Are the experienced? Competent in the NEPA positions to hoard the position to the detriment of or somewhere, brown bag information lunches, Process? A good leader? the Agency. Or the folks already established, were open house at the office, reach out to schools, never mentored so they don't know how or have colleges, universities, sharing NEPA information to the time. people. Help everyone have a opportunity to understand NEPA in fun, interesting ways. Again NEPA Teams seem like the best answer. Involve the Agency Lawyers early Train your employees (can't teach an old dog new There is no "Right-size," Every analysis is unique, tricks), or hire employees who understand creating every environment is unique, there is no one-size- legally defensible documents. Agencies have created fits-all. Go to the Law. Stay within the Law. Don't their own cesspool of employees who don't care. cater to Industry or the current or future Other employees carry the load, work well in administrations. teams, are conscientious, dedicated, and hardworking. Agency leaders need to hold their employees together and lead like a leader. Most don't, due to any amount of reasons. When you skirt the rules you will have litigation. Do your job and protect the land, water, air and environment. Thoroughly analyze all impacts to public lands, and take the time necessary to do it right. Provide past success examples. Show success stories. Educate If it doesnt pertain to the situation, throw that part out. Litigation can be reduced by following the law and maintaining / expanding the environmental review process. Providing access and transparency to the subsequent reports and recommendations can also reduce legal challenges. Hold workshops, online webcasts and other online meetings . Host debates, discussion groups and open houses at Being lawyers from all sides into the discussion convenient times and places to give the public a early. chance to hear pro's and con's about a project. Work out differences before the documents are finalized. Include all impacted stakeholders in the process. I have given this answer in the first part.1. BLM often uses report authors who lack expertise. 2. BLM often uses many piecemeal reports to say each impact is not significant without looking at cumulative impacts. 3. BLM often uses reports that do not look at overall, long-term effects. Good lawyers can draft documents that should be legally defensible. Planning outcomes should emphasize integrated resource management. Who determines the "scale"? This can be in the eye of the beholder. Follow the law and be transparent about it. First, analyze whether the scale of the action is directly related to the level of analysis needed. Matching the level of analysis to the scale of action may not be the approach to take. A small action could lead to large consequences. I believe BLM is usually challenged because the scope of their reviews is too narrow. By embracing the overall situation, BLM can probably limit legal action against the agency. Scientific data analyzed by top peers. Establish stepped-down planning processes NEPA has already withstood numerous legal challenges and should be left intact as it has proven that in the courts stop destroying the environment! stop destroying the environment! When issues arise, listen, communicate, and figure out solutions among the effected citizens. Don't shorten the NEPA process, or cut the people or the science out in favor of shorter times and big industry. That will not improve the process, just create more problems in the future. I don't think this is currently a problem. stop destroying the environment! It's already in NEPA called a ROD. stop destroying the environment! stop destroying the environment! Hire the best environmental scientists to draft the preservation plans. stop destroying the environment! Have many more EIS. That's how NEPA was intended to work. EAs are really only suitable for the smallest of projects. Listen to citizen concerns. Use public meetings to gather citizen ideas about how to solve the problem. Keep the citizens, be they tribal or other, actively involved in what you are doing, and the case in any court will be stronger. Through the citizen base you have developed, ask for in-put on how the expedite legal challenges. Consider all aspects of the consequences. For Priorities must be made known to the citizens. For example, reintroducing the wolf to Yellowstone example, in Colorado, farming and ranching have National Park met a great deal of concern from the first call on water use. Developers are always ranchers and farmers around Yellowstone. The trying to get change the law so that industry and wolves help balance the food chain in the park, but urban gets first call. When the citizens of Colorado we understand the BLM does help ranchers who have known the consequences of changing have lost animals. priorities, they vote to keep water on agriculture. Skipping proper analysis leads to conflicts, redundancies, and inefficiencies. When in-depth analysis and public input is conducted early on, there are fewer delays and legal challenges down the road. Sidestepping or rushing analysis inflates the process and increases costs to taxpayers and industry. there is not a streamlined process. environmental NEPA is law and BLM cannot undermine it concerns outweigh the need for speed to make Don't cut out public input and attention to Industries should not form environmental policy. NEPA has withstood many legal challenges over the quick profits environmental impacts. Of course industry opposes any regulations that years. It is the best tool we have to protect public Give the public a chance to weigh in on decisions might cut into profits or delay financial gain! If they lands from ill-conceived actions. Parts of the act and evaluate the environmental impact of actions. It were truly concerned about the health of our public frustrate industry factions because it provides is not only the law, it's also the best thing for our lands, they wouldn't be opposed to a process that multiple opportunities for public input. public lands. carefully evaluates environmental impact. As a However, it is intentionally a rigorous process steward of our public lands, BLM has an obligation designed to uphold public trust and scientific to do what is best to protect our natural and integrity. Any action BLM takes must follow laws cultural resources. and: Insist the BLM fulfill its obligation and maintain Use the best available science strong environmental review practices. Our long Fully explore reasonable alternatives term public and environmental health is not worth Solicit and consider public input in an accessible, any private company's short-term profits. transparent process give the public and environmental law experts the time to evaluate. Transparency Follow the law. Do not shortcut. Use the best available science., and fully explore reasonable alternatives. Pro bono lawyers I don't know, but I do know BLM should be following the law. Maybe BLM should hire additional staff to ensure the process is complete and timely. Don't be afraid to trim the fat Create an awareness and education campaign Don't allow projects unless there is sufficient Examine regional impacts (eg, air quality, water funding to fully execute the NEPA process. It is law. resources, large mammal migration...) not just the impact of an individual well, for example. Advertise scoping well so that important issues are not inadvertently left out of analyses. work with all stake holders Honest open transparent communication will certainly help when dealing with any entity. The full NEPA has been shown to discover possible conflicts that might produce delays or litigation. A shortcut procedure will result in more, not fewer legal challenges. NEPA is the law of the land and BLM should follow it. Work with stakeholders to come up with win-win solutions involve stakeholders throughout the process Create a citizen's academy to educate involved stakeholders Consider regional impacts in a large analysis, then supplement with smaller individual analyses that reference the large analysis. Need to look at the area as sections and take out the trouble areas Don't forget that law dictates much of the NEPA process. Though sometimes cumbersome, even with the process, some environmental impacts are overlooked; our world cannot tolerate much skimping on the process. Common Sense. Multiple use in mind. The goal of Environmental Analysis is to "get it right". BLM is tasked with maintaining the long term vitality of the public lands, with long term health being the key goal. A shortened analysis may suit the short term goals of those wishing to make a profit from public lands, but it does not serve the long term environmental vitality of the land. Work with local planning departments Work with local leaders to assess community interest and likely opposition Honor stakeholders equally - not bending to those with the most money and/or political power. The BLM can create legally defensible documents and avoid delays associated with legal challenges by working with legal people who are skilled, have the best interests of the People and the Planet as the priority and are not in the pockets of the corporate entities hell-bent on greed, power and extraction of our valuable resources and cultural heritages for corporate profit. Build a skilled and dependable team that is trained to "measure" each action that responds to the health of the Planet and will of the People instead of responding to the pressure of corporate greed and government manipulation. Talk with potential litigants early and all through the Be very thorough in developing your plan; address process all issues in the first draft and solicit input with potential litigants early in the process Listen to input Invite and visit with stakeholder in person and digitally Advertise heavily in the area being analyzed as to how folks can have input Base all decisions on solid science! Base all decisions in equal partnership with all stakeholders. Maintain the public trust now and for future generations - think long term! Dedicate the necessary time and study up front to avoid costly litigation and "fixes" down the road. Carefully consider how you define scale of the action being analyzed." Is it economic, number of acres, proximity to public scrutiny? All actions will have impacts - sometimes "small scale" acting will have large scale impacts. Commit to careful analysis and public input on every action. Make those that appeal or sue pay for the government time spent on the appeal or suit. Frivolous law suits are too easy now with no penalty for the plaintif. Now there are cut and paste appeals that sometimes do not even have the correct project. The government is maintaining an industry to fight themself. Appeals and suits should have merit not just be able to move forward on a shotgun basis. Shotgun. Sing say the NEPA document violates everything hoping one will work to stop the project By using sound interpretation of science in NEPA documents- that is probably best developed by people with suitable scientific backgrounds at NOCC or state office levels, and used consistently across the BLM at the field office level. Example, the NOCC rangeland ecologist could summarize the relevant livestock stocking rate literature for the U.S., and come up with a defensible and specific set of recommendations based on it, that could then be used by each Field Office during livestock permit re n ewa l NEPA Use the natural hierarchy of the BLM to address NEPA at the right scale...use programmatic level NEPA written at District, State or National levels wherever possible to cover the needs of multiple field offices or recurring issues so at the field level, just the details of a specific action need to be addressed, and a lot of the action would be covered by a DNA Listen with an open heart. Avoid delays by not rushing analysis. Awareness of the law is the first step in reducing litigation. If the BLM (for some reason or another) takes a tack (legal or not) that conflicts with the interests of stake holders, there's going to be litigation. One way to avoid it is to focus on using the land for lowimpact recreation vs. "resources" development (oil and gas). Education about managed forests, sensitivity to the interest of Indian tribes over artifacts and history. IMO the "greener" the BLM becomes and the more pro-active in that direction, the less litigation it will deal with down the road. Now, however, it's probably a different story. It is sad that litigation is necessary. It is because conservationists, fishermen, wildlife advocates, hikers, backpackers, campers feel it is the only option as their voices are not weighed appropriately. BLM has a job to balance use and extraction and mining seem to win. They never clean up and the tax payer is stuck with the bill. They just file for bankruptcy. The ATV fad is tearing up the west and damage fragile areas, housing developments, dams that are not necessary, sprawl and its consequence need to be given even more importance than in the past, not less. You will always have legal challenges if you take away public lands from the public these lands belong to all of us. If a local party wants That goes for hunters & outdoor enthusiasts who to use the land for business purposes they need to should sign waivers to protect BLM pay for use Accept that the NEPA process is the law. As a steward of our planet BLM is obligated to protect our natural and cultural resources. Do not be swayed by industry and money. I don't know Careful and scientific analysis should be performed. Data cannot just be invented. Studies need to be made. We don't need to streamline the process. That would only help industry and not give the general public time to get their position together. We need more, not less science. we need more time not less before we do irreversible damage. There only is a limited amount of wildland. Once gone it's gone forever There only is a limited amount of wildland. Once gone it's gone forever. Sell all the BLM land and pay off the debt Sell all the BLM land and pay off the debt Sell all the BLM land and pay off the debt Sell all the BLM land and pay off the debt Sell all the BLM land and pay off the debt Your premise here is flawed. You cannot reduce Your premise here is flawed. You cannot make Incorporate the possibility of litigation into the litigation. As long as the BLM is making a decision, documents bulletproof. The most you can do is project planning. someone will not like it and will protest, appeal, and learn the right lessons from the lawsuits. If you lose litigate it. The only way to avoid the delays of a because you did not analyze 'X' in this document lawsuit is to shutter the entire federal government. (whatever X is), the lesson is NOT "We must always analyze 'X' in every document from now on." The lesson is, "Why did we have to analyze 'X' in this document, and when is it appropriate to analyze it in future documents?" Sell all the BLM land and pay off the debt Sell all the BLM land and pay off the debt Sell all the BLM land and pay off the debt Give the state offices the ability to decide what to Stop trying to make NEPA documents bullet proof. do with settlement offers and possibilities. Do not EAs and EISs have gotten so large because BLM make them waste time and resources going through keeps holding to the mindset of "If we just add more the zero-value added process of waiting for the WO pointless analysis about more non-relevant stuff to make decisions that they do not have the we'll win next time, you betcha." Focus on what's experience on the ground with a given project to important to the decision, not on how much can be make wisely. crammed into a single document. By listening from the beginning and following what I heard public wants not corporations. Keep it local. Keep public and adjacent lands free of harmful materials and activites. Planning 2.0 Planning 2.0 See previous suggestions, if your partners and stakeholders are on board for the whole process, it is much more likely that you will experience fewer legal entanglements. I don't think this is possible. Planning 2.0 Fulfill all requirements of the NEPA. Planning 2.0 Planning 2.0 Planning 2.0 I think all environmental analysis needs to be thorough. It is necessary to preserve and restore a healthy environment in America. Planning 2.0 Fulfill the legal obligation to carefully evaluate environmental impact via the NEPA. Environmental integrity should be top priority. That is the default nature of this planet. Any change should be considered with care. Planning 2.0 Shut down Corporate frivolous rights to sue. Shut down Corporate frivolous rights to sue. A solution other than moving to Denver - do not Never, ever force state and local governments to let BLMers stay in Washington DC more than 10 come to the BLM - always travel to them instead. years - make sure everyone is moving around in the Have RAC meetings at those places. system and staying in touch with issues and constituents. So, how do corporations and other agencies do it? BLM has always been reluctant to adapt from other agencies and entities. They simply need to look around at agencies and entities who have a fantastic record of legally defensible documents and adapt those methods and formats. Ask such agencies and entities for advice. Report internal politicization of BLM employees who abuse their authority or overstep the boundaries of Policy or ethics. Be honest and trustworthy. Live up to your obligations to the public. Pass Torte reform to exclude intervention litigation Develop a legal screening committee to determine that fails to have direct ownership or business authenticity of legal intervention groups. involvement in BLM property or actions. Stop government grants to groups using the money to sue the government. Listen to your general public. Listen to your general public. The oil and gas EAs are all nearly identical - cut and The Burning Man EA, at least the first ones, circa paste - EA after EA after EA. It's because of the 1997-2000, by their size, looked more like huge workload that EAs, especially oil and gas, environmental impact statements - they probably impose on small BLM staffs, which are all relatively should have been, because the event areas have small throughout the west. It's far better to have footprints similar to open-pit mines, though Burning one programmatic EA for each oil and or gas field. Man does not remove public lands from public use Of course as noted before, oil and gas area-wide or like open-pit mines and oil and gas fields do. fields should actually be environmental impact statements instead of EAs. The impact is due to effectively removing all that land from public use for decades and maybe even permanently, though BLM will always state that it's temporary. It's not a lie but it's not the truth either. Make your analysis thorough and honest. To cut corners on scientific analysis would be like cutting corners on the Bill of Rights. Begin with the premise that nature does not reign over humans, but rather is subject to our benefits, and to be maintained for our benefits Remove all legal barriers that fail to pass the first criteria in Solution 1 The problem isn't creating legally defensible Engage your legal opponents in the creating documents, it is taking legal actions in the first place. solutions before it goes to court. The BLM lacks inventories of its resources. The BLM The BLM severely lacks staff at all levels. Compare should invest heavily in inventory of its forests, BLM with the Forest Service or Park Service. This range, water, wildlife, fish, plants, cultural resources, basic lack of staffing creates gaps in process that recreational opportunities, minerals, roads, facilities, results in increased vulnerabilities to litigation. and invasive species. Often times the BLM relies on There are just not enough people to do the outdated information in its NEPA documents. This is enormous jobs that are asked of the existing staff. the basis for much litigation. The staff that are there do their best but it seems to be not enough. Increase staffing at the Washington Office, State Offices, District Offices, and Field Offices. Increase training. Be honest with local agencies about constraints I think the only way to work with most tribes is by placed on BLM as a federal agency. Some things they going and talking to people, not asking them to may want aren't legal and if they know that right comment by mail with a deadline. Not all tribal away it can avoid disappointments later. Also let it officials represent the general opinion (true also of be known that there is considerable decision space county commissioners) but you can usually find within those legal boundaries. someone to give you a summary what's most important to them. Follow NEPA, don't try to cut corners. Someone will always find a flaw in the document. By doing things right the first time, especially transparency and respecting and valuing public comments in the NEPA process. By taking more time to listen to the public early on, Remind the administration that NEPA is a law meant and then develop alternatives based on the main to help agencies make better decisions and issues people bring up, you can avoid taking a lot of incorporate the values of the people whose land this time after the fact dealing with appeals, document is. Complex and far-reaching decisions take time to re-writes, and litigation. When people can see by reach, if done properly. "Streamlining" to make it go reading your documents that you listened, not faster will only result in more lawsuits. necessarily doing exactly what they suggested, they are less likely to challenge. See page i, # 4 Consider the scale of consequence a decision might have. Small actions may have large consequences. The BLM NEPA Handbook from 2008 identifies issue-based NEPA which is efficient and focused. However, most offices do not employ this method. We even see some "kitchen sink" documents. The solution is to increase training for staff and managers. Use the guidance already given. If it's a full field gas If public scoping or known significant issues indicate development in the last habitat for sage grouse, it's a an EIS is likely to be the best level of analysis, don't no-brainer, do an EIS. NEPA regs have a complete do an EA first in order to get out of it. It will only and easy to understand list of things to consider extend the time it takes. when deciding. Please do NOT change the NEPA process currently in place. See page 1, # 4 Don't try to shortcut the NEPA process or rush projects through without a thorough analysis of potential environmental and cultural impacts. Do not cut out or disregard public input on a proposed action. All concerns must be addressed and potential impacts mitigated. Have bipartisan support of all decisions and documents. A central digital repository, of course, with templates of all standard forms, letters, etc, for any BLM-associated person or entity that needs to file a report can do so anywhere. An app would allow wide access with trackability, encouraging report filing in the field & immediately. Monitor the input to verify quality of reporting, at least until the practice of immediate & standardized documentation is worked into the culture. Better science. BLM science seems very targeted towards industry. Local communities are not engaged early in the process and listened to. By being totally transparent in any and all projects and processes. By creating total community involvement through solicating community input and then by proceeding through the process and conforming to all local and state regulations, requirements and policies. Follow the rules of law in all BLM functions and exclude special interests in creating policies and procedures. NO special consideration for any organization or group without public input and guidance. Making sure the process is followed and all stakeholders are involved should reduce litigation. push for compliance with law and policy The level of NEPA analysis could be adjusted according to the level of environmental / cultural impact anticipated from the proposed project. Pre scoping with affected stakeholders would be a great way to gather early information on project impacts. This would also help build trust. Always err on the side of more/better/further analysis. When trying to match analysis to scale of action, it is far better to be on the 'good data' side of things than the 'missing data' side. Set specific standards that must be met to classify an action or an analysis, then take that standard & create a numerical or other score which can be matched with each other without doubt. Gain trust first then reducing NEPA to match the scale of the action will be easier for the public to accept. Better science on the big picture will help build that trust. Simply spend the time necessary to study and determine all of the issues that will impact the project from the state and local standpoints. Involve te local community and get input regarding what issues need to be included in any analysis. ALWAYS consider the impact of any project on the involved communities. There is no "one size fits all" approach to NEPA analysis. "Right-Sized" according to who? I do not agree with short-cuts and hope the BLM will not cave-in to corporate pressure to minimize the appropriate analysis scale. size your plans/nepa to the issue at hand-one size does not need to fit all Return control of all Federally controlled lands to the States. Many of the problems that end up in litigation are due to the classic bureaucratic approach of thinking that one solution fits all of the related problems. Getting the Federal Government out of the way and letting the States handle the problems associated with the lands within their boundaries will not solve all of the problems but it will go a long way toward ensuring that decisions are legally defensible within the state. Return control of the Federal Lands to the States. This would ensure that States such as California which wants to preclude any use of Federal (at that point State) lands can do as it wishes while other states can determine what is right for their citizens and their economy. By eliminating one large level of bureaucracy the size of the NEPA analysis can be reduced substantially. Not only will the analysis be more accurate but it will be cheaper and thus more cost effective. Obstructionist and protester should left our of the process. The should be a maximum time limit and number of Anyone who challenges a proved operating plan or If the challenger of any action losses in court and meeting put on any project and if the time limit or plan that is approved by BLM shall need put up a does not have the money require to pay all of the number of meeting is going to exceed that number bond in favor of the operator for its losses or delays court cost, for loss of time and profit then the the BLM shall be required to immediately approve and shall be responsible for all court costs including attorney taking the case on the part of the the plan. those of the BLM and the operator. challenger shall pay thos No one should be able to make any challenge to a plan unless he can show that it actually effects his life and wellbeing. No government agency should be able to file an action challenging an operating plan. No NEPA required for operations under 20 acres in No NEPA required on small mine where no size or on already disturbed land. hazardous chemicals are used Do more public -interest pieces (PSAs) on TV and radio in high-concentration tourist areas Clear and simple policy statements would help--in Get signatures from employees, volunteers and everyday English and also Spanish would help (NOT groups of regular users on wavers before receiving "legalese") permits to enter certain BLM lands Improve training of seasonal personnel By doing the hard work in setting goals and policies. Do not bend regulations to industry folks including grazing, energy and recreationists. Some local flexibility should be possible between each management unit. Consult with engineers qualified to assess environmental effects on water scarcity and quality, forestry experts on forested areas, wildlife authorities on environmental effects due to human encroachment, etc. BEFORE making any policy changes that will affect uses by stakeholders Do not bend decisions when the agency is pressurized from particular lobbyists. We can best create legally defensible documents by With that said, it is simply not possible to avoid legal I strongly recommend that the BLM revise the following the process to the letter. This doesn't challenges. They will happen no matter what. planning regs to eliminate the protest process. Let necessarily mean analysis that goes on an on for them go directly to federal district court which they hundreds or thousands of pages. Following the will do anyway and save an average of 6 months or process is the single most important thing we can more on the process. This is the single biggest thing do to withstand legal challenges. we could do to save time and complete plans faster. Look at the issues involved, the likelihood of legal challenges, the stakeholders involved and the overall level of risk. The level of analysis should match those factors. Too many times, we analyze the impacts of non-issues. This is partly due to the tendency to cut and paste from past documents without really thinking. Quit locking up lands for national monuments and wilderness. Strengthen science-based decision making. Accept the fact that legal challenges are part of the Preserve flexibility for future uses by not allowing process. impairment of resources. Place ethics and public benefit over private gain. You need to have Congress change the laws that are allowing the law suits. Take into account the stewardship history and reputation of any party to a BLM agreement. For example; a mining company with a history of leaving toxic tailing ponds behind is an obvious bad choice for future dealings especially compared to say an outdoor sportsman 's group that practices and promotes low impact activities. Have an Attorney review documents before forcing them on the public. It should be obvious when something illegal, unethical, or unconstitutional comes down the pike. Defer to attorney, not big campaign contributors. Recognize that NEPA analysis is not tied to the scale of the action but rather that an assessment of IMPACTS and consideration of alternatives is required. In other words, a small scale action may have major impacts and many alternatives may exist. The NEPA rules need to be changed. If the action PROTECTS THE ENVIRNOMENT, then that would seem to be just the right amount Less higher manager federal oversight, more decision making ability on the part of local field employees, and more training for local field employees so they know exactly how to do their job right. Do not remove NEPA Seems like, if all parties were involved, there'd be less chance of litigation. As an organization, your 'feet on the ground' would have to build trust. Scrupulously comply with all legal requirements during the planning process and create a paper trail documenting all actions as they are taken. Make your decisions based on science and the law. Do not try and circumvent the legal process. This is the million dollar question, you CAN'T. If Perhaps create programmatic nepa documents that you take shortcuts, it will be appealed. Especially allow for small scale actions that would require then since most the RMP/forest plans in the west were to not be analyzed everytime for NEPA. Take for just completed with sagegrouse-tied requirements. instance livestock trailing. Just give them the okay & You HAVE TO ATTACK THE CAUSE, the Non cover it in the RMP's/forest plans, or allow CX's of profit interested publics status as "non-profit", and such small insignificant actions. 2) make frequent filers of appeals pay a large upfront fee to appeal. If they lose, the federal government gets the money. NEPA is driven by the appeals process. TEST2 During legal proceedings, the BLM should not agree Prompt discovery by BLM during litigation. If other to any continuances from the opposing party. In parties fail to provide discovery, BLM should move addition, when feasible, BLM should move for to compel, quickly. expedited proceedings. Stop listening to a handful of uninformed government officials and individuals who want to give away our public lands and allow them to be destroyed. Protect and preserve more BLM lands such as lands Make more lands off limits to oil/gas exploration, off with wilderness characteristics and convert them to road vehicle use, grazing, and other activities that wilderness areas that will be protected and destroy the lands. Period. No potential leases, etc. preserved for all time. The San Rafael Swell area Get the profit factor out of our public lands. and all wilderness study areas in Utah should become wilderness areas. This would show the public that the BLM has the best intentions for our public lands. Advocate for long lasting preservation of clean water and clean air. none. Firstly do scientific research by independent or Never allow industry or local demands to outweigh Realize the long term consequences of any projects- university-based researchers. Do not rely on old the results of research. take the First People "7 generation view" of the past research that may be flawed or not accurate or environmental consequences of development. not current. acknowledge seasonal aspects of public participation and seek dates that maximize potential public input NEPA documentation is often inaccurate, overstates data/science, references science papers/studies which are also inaccurate or biased or both. This practice needs to be corrected. Publishing the truth will reduce litigation. get as much upfront buy in from diverse interests as make sure to include as many points of view as get rid of the comparative proposal process that possible possible before creating drafts docs requires including extreme alternatives that have no chance of being approved. concentrate on the Litigation can be reduced by returning the Equal Revisiting the effectiveness of the endangered alternatives that are closest to real compromises Limit Litigation. Access to Justice Act back to its original intent. species act, considering recovery goals than habitat. Do not remove NEPA Comply with the law governing the NEPA process in all actions. Always err on the side of environmental protection and more analysis rather than less. Limit the ability of professional interested publics appeal rights on the types of NEPA, it will allow for the smaller, less in-depth NEPA documents. If you don't limit the appeal rights of these interested publics, it will just be held up in court, netting you nothing. TEST2 "One size doesn't always fit all." Perhaps proper training of BLM employees to determine what is "right-sized" on a case-by-case basis. You can't. There is so much out there that we still do not understand about the environment and there are many more discoveries of cultural resources to be made that a thorough environmental analysis has to be made. Keep all BLM lands off limits for leasing and OHV activities. Then you would not need NEPA analysis. Realize that there is one world, one environment. It Use scientific information to identify the scope of is interconnected. Environmental scopes are projects. necessarily large. Do not shortcut or diminish research. That prevents legal challenges if the law if followed. BLM needs to understand and use an "Incremental NEPA" as often as possible to save time money. BLM defaults to NEPA on almost every project. BLM needs to relax the rules to allow more projects to be satisfied with an EA or CE. Small tasks should not require the same level of analysis as large ones quick fixes need to be made easier to do One size does not fit all. Match the size of the NEPA analysis to the size of the project. Flexibility would be useful in adapting NEPA to the size of the project. Help involve organized groups to do on the ground In Arizona I have been organizing meetings with the Figure out a way that the groups that continue to Consider everyone's issues, not just those that can work with partnerships and working together with user groups and the agencies to start a dialog and file the law suits do not get reimbursed for them. pay for lawsuits. grant ideas. build partnerships. This is working because we are Make them responsible to pay for their work. The all there because we were invited as participants. motorized community does not get paid back for any lawsuit that is filed. This does not make it fair. If the paying field was a little more even maybe the lawsuits and litigation would decrease. Collaborate as one with State, USFS, COE agencies Less paperwork and obstructions are the best way to do that. But finding a way to do that is very difficult do to federal regulations. Is it possible to look at all of the areas that require NEPA and maybe come up with a scaled down version for areas with less environmental and habitat concerns. This might help with the amount of work involved. Do not hold special meetings with specific user groups. Private meetings with specific groups make other users suspicious. Place importance on local knowledge of game habitat, use data, and historical importance of areas and trails. Not everyone is a scientist but it doesn't mean that what they tell you isn't true. Invite public participation. Don't know. Have less secrecy in developing the project. What is the point? Apply the Grazing Rules to All Programs/Projects. Amend the NEPA and Include Statute of Limitations For several years Congress has required through on Litigation. There are no statute of limitations the Interior Appropriations Act, that administrative provisions under the NEPA. As a result, litigation is remedies must be exhausted, prior to a litigant governed by the Administrative Procedures Act. submitting a case to a federal district court. The Under the APA, the generally accepted statute of special case should be applied to all limits applied is 6 years. The NEPA should be programs/projects, not just the grazing program for specifically amended and include the following time those agencies that have an administrative protest frames: categorical exclusions - 3 months; and/or appeal process. For those agencies that do environmental assessments - 6 months; not have an administrative appeals process, such environmental impact statements - 2 years. process should be created. Give the land back to the states. I have no idea. Limiting the scope of the review will limit the challenges. Smaller projects and shorter time frames will help. Prepare and use more templates to aid the project. Actively listen to and understand protests that are For example, information regarding impact of part of the process. Consider meeting with the climate change in an RMP is largely the same across people filing them to improve understanding. the nation. Headquarters could draft the basic Consider mediation sessions between some of the material so each field office only has to work on parties prior to finishing the process. specific issues related to the uses they are considering. Even then emission impacts associated transportation, solar fields, wind towers, an oil well, etc and not going to differ greatly from place to place so prepared information could be used several places and then updated as needed. Slow down and follow the existing NEPA process. It works if you follow it. The NEPA and NHPA apply to discretionary federal Amend the Recreation & Public Purposes Act. actions only. Under the 2014 National Defense Under this Act, certain federal lands can be leased Authorization Act (PL 1 13-191), Under Section or conveyed to States or local governments for 3009 (a) (2) (A), Congress directed the BLM to recreation, schools etc. The Act needs to be convey public lands to the City of Yerington. The modernized that clarified that when a project meets "action" before the BLM was to comply with the the criteria of the Act, that the convey of land is Act ("...the Secretary shall convey...") which is non required and is not subjected to any land use discretionary. And yet the federal agency spent planning (such as section 202 of the Federal Land money and staff time to comply with both the NEPA Management Policy Act). There is no federal and NHPA. 40 CFR 1508.18 should be amended interest in a local government bundling a school on and state that mandatory Congressional acts are not public land and leasing the parcel to them. All Act a "major federal action." The NHPA should be `actions' should be to convey the land out of federal amended and state the same (aka not an ownership at fair market value. "undertaking"). Give the lands back to the states. Mandate the use of the lowest level of review possible. Have employees justify the need for an EIS. If the environment is in danger, all efforts must be taken. Size of project should not matter. Follow established NEPA process. It works if you follow it. Do it right the first time: include the input of ALL stake holder and users. Need more tome for analysis Litigation has become its own industry. Special interest groups exist based on their ability to claim harm and obtain court settlements. Short of legal system reforms, one solution is to increase the level of proof required to assert damage. The only way to reduce the delays is to focus on the costs and benefits of challenges. If a group can receive disproportionate benefits relative to its costs of a challenge, challenges will abound. By hiring highly trained personnel or training By having agency personnel stay on task during the existing personnel and demanding all agency NEPA process and not taking outside detail jobs personnel follow the BLM's laws, rules, and such as firefighting during the summer months when regulations and not their own personal wants, field information gathering is most important the desires, or opinions the BLM can create more legally BLM can create more legally defensible documents defensible documents and avoid the delays and avoid the delays associated with legal challenges. associated with legal challenges. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Need more time for analysis NEPA protects our environment and citizens. Environmental analyses should be thorough. Identify assumptions: Perfection does not exist, perfect knowledge does not exist. The impact of man is often overstated. Analysis should begin with a better understanding, or at least acknowledgment of the earth's immense creative and destructive powers that have existed for 4 billion years. The impact analysis should be able to identify how human action will be different from the existing natural processes. No input Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts Collaboration should begin early, before scoping Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering (the process by which agencies solicit input on the more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing issues to be addressed and how they will be fewer challenges in the long run and should help responsible development with reasonable evaluated), and allow everyone--ranchers; miners; avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. o not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. By tracking legitimate background paperwork before reaching courts The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Open communication up front would avoid litigation later Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Have an policies thoroughly legally vetted ahead of time. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Winning greater collaboration from stakeholders Adhering to science-based decisions, considering early on, and free sharing of ideas, will mean fewer ecological as well as economic values, truly balancing challenges in the long run and should help avoid responsible development with reasonable delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while should also reduce lawsuits. Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Good question. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. ***The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to ***Greater collaboration and sharing of ideas, while ***Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Collaboration should begin early, before scoping The BLM should make it easier for states to (the process by which agencies solicit input on the share data--particularly wildlife management issues to be addressed and how they will be data--with the agency and vice versa. This would evaluated), and allow everyone--ranchers; miners; include the identification of wildlife migration energy developers; recreation groups; other federal, corridors and other habitat data, and other state and local agencies; and members of the scientific information that is important to hunters, public--to tell the BLM their wishes and concerns anglers, and other backcountry recreation about the planning area, and share any data they enthusiasts. have about the area. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. No decisions without public input Know that the public is watching & we care about Make wise decisions what happens to our land Be truthful in decisons Keep solutions simple The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts more time-consuming in the beginning, will result in Adhering to science-based decisions, considering to reach areas that lack access to electronic fewer challenges in the long run and should help ecological as well as economic values, truly balancing communications. avoid delays and lawsuits at the end of the process. responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Gain the collaboration and input of as many Base decisions on data-driven, factual science that stakeholders and community members as possible promotes the well-being of the land and the people so no one feels ignored or slighted. before any other types of gain, such as profit, development, or mining of natural resources. If the greater good of the earth and the land is the number-one priority, then it will be less likely to face serious opposition from the majority of the Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while people. Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Keep everyone aware Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Keep things simple Do not destroy what we have Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Shortcuts are never good solutions and should be discouraged. Always make sure to have the latest scientific data applicable and to continually revise based on any changes in this information. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step.  Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications avoid delays and lawsuits at the end of the process conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to reater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic and spiritual values, fewer challenges in the long run and should help truly balancing responsible development with avoid delays and lawsuits at the end of the process. reasonable conservation, keeping the public well- informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, spirituality, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base decisions on the best available science Weigh ecological needs as highly as resource use and extraction Keep the public well informed with early and frequent opportunities for input Weigh the input of the general public as heavily as base plans on the latest science and public opinion Plan across BLM and other boundaries to broaden that of the extractive industries the scope Get a good lawyer Make it easier for states to share data--particularly Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering wildlife management data--with the agency and vice participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing versa, including wildlife migration corridors and to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable other habitat data. communications avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. No clue Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications avoid delays and lawsuits at the end of the process conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Tribal governments should be encouraged to The BLM should make it easier for states to participate, and the BLM should make special efforts share data--particularly wildlife management to reach areas that lack access to electronic data--with the agency and vice versa. This would communications. include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. conferences including all parties spend a day with .... tours of multi agency scenario modeling, facilitated meetings transparent science based decision making, rational and agreed upon goals for economic providing transparent opportunities for participation development and ecological conservation The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. The BLM should always be looking for opportunities Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while to share ideas and collaborate across its own field ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in office boundaries and with other public landowners, responsible development with reasonable fewer challenges in the long run and should help such as state agencies, tribes, and other federal conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. agencies, as well as private landowners providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Let BLM managers broaden planning to the is vulnerable to legal challenge later in the process. district or multifield office level as needed to better Let BLM managers broaden planning to the address cross-boundary issues and simplify the district or multifield office level as needed to better number and complexity of resource management address cross-boundary issues and simplify the plans. number and complexity of resource management plans. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. a good foundation of understanding the needs of all groups and a adhered to process that doesn't skip stages or is not transparent and multi agency/cross boundary participation Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. hold clearly advertised meetings - LOCALLY (not held 500150 miles away) enlist LOCAL persons to hold LOCAL information carefully craft ALL proposed actions meetings. consider LOCAL conditions when crafting proposed do NOT take actions without LOCAL input actions carefully consider PEOPLE before government income LOCAL input LISTEN to LOCAL input The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM to make it easier for states to share data on wildlife management, wildlife migration corridors, habitat data, scientific information important to hunters, anglers, and backcountry enthusiasts. Tribal governments should participate, and the Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering BLM should make efforts to reach areas that lacking more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing electronic communications. fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Collaboration should begin early, before scoping Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering (the process by which agencies solicit input on the participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing issues to be addressed and how they will be to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable evaluated), and allow everyone--ranchers; miners; communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. This is a tough one. Be open when presenting a plan, be ready to accept new scientific ideas. Be willing to discuss in all media why you are making the decisions. Open and transparent discussions with a willingness to work together is best. There will always be someone who will sue, take steps to Tribal governments should be encouraged to reduce the number of people take this step. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Don't enter into agreements that are against the will Support the public's interests in protecting our lands of the people to leave our lands and wildlife alone. and wildlife. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Ask the tribal elders the best way to communicate with their tribe. Greater collaboration and sharing of ideas, while I'll say it again, science is not the enemy. Adhering more time-consuming in the beginning, will result in to science-based decisions, considering ecological as fewer challenges in the long run and should help well as economic values, truly balancing responsible avoid delays and lawsuits at the end of the process. development with reasonable conservation, keeping The Endangered Species Act is under great threat the public well-informed, and providing adequate right now. Working with wildlife groups early on opportunities for participation should also reduce along with industry may cut down on problems. lawsuits. Collaboration should begin early, before scoping The BLM should always be looking for opportunities Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while (the process by which agencies solicit input on the to share ideas and collaborate across its own field ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in issues to be addressed and how they will be office boundaries and with other public landowners, responsible development with reasonable fewer challenges in the long run and should help evaluated), and allow everyone--ranchers; miners; such as state agencies, tribes, and other federal conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. energy developers; recreation groups; other federal, agencies, as well as private landowners. providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas would result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. No shortcuts ever. Ask for public and scientific advice. Let you state, district and local personnel work with you. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Primary purpose is to protect the land and wildlife from those who would try to exploit it and use it for their profit. Protecting what is does not require extensive planning other than repelling profiteers. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. Let BLM managers broaden planning to the district Base plans on the latest information, science, policy, or multifield office level as needed to better address and public opinion. If the science and/or public cross-boundary issues and simplify the number and opinion point to the need for an environmental complexity of resource management plans. impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Provide enough complete information that a plan will not be vulnerable to legal challenge later in the process. Base plans on the latest information, science (impartial, non-partisan, peer reviewed data), policy, and public opinion. Produce environmental impact reports. Allow and encourage BLM managers to broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Tribal governments should be encouraged to The BLM should make it easier for states to share participate, and the BLM should make special efforts data--particularly wildlife management data--with to reach areas that lack access to electronic the agency and vice versa. This would include the communications. identification of wildlife migration corridors and other habitat data as well as other scientific information that is important to hunters, anglers, and other back-country recreation enthusiasts. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits. providing adequate opportunities for participation should reduce lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration will reduce legal challenges. It is more time consuming in the short run, but is more efficient becasue it will reduce the delays associated with legal challenges. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic responsible development with reasonable fewer challenges in the long run and should help communications. conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, Do NOT encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do NOT skip that step. Let BLM managers broaden planning to the district Do not take short cuts. or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not short cut and leave the plan open to legal challenges. Base plans on current science and address public opinion. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share Tribal governments should be encouraged to data--particularly wildlife management data--with participate, and the BLM should make special efforts The public land belongs to the taxpayers and not the agency and vice versa. This would include the to reach areas that lack access to electronic ranchers or the oil companies. We refuse to identification of wildlife migration corridors and communications. They should participate in the exchange the lives and souls of wild horses, bison, other habitat data, and other scientific information management of bison, and wild horses and protect wolves and other wildlife just so ranchers and the that is important to hunters, anglers, and other them. big business can make a profit. Release all the wild backcountry recreation enthusiasts. horses in holding pens and kick all cattle and big business off of OUR public lands. As long as you permit ranchers and big business on OUR public lands, we will continue to sue you. For any wild horses in holding pens, you MUST provide shelter. Keeping these horses in holding pens is costing the taxpayer a lot more money and we want them released. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. ribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Tribal governments should be encouraged to The BLM should make it easier for states to share participate, and the BLM should make special efforts data--particularly wildlife management data--with to reach areas that lack access to electronic the agency and vice versa. This would include the communications. identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Govt has got to remember you are not a Monarchy Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Don't brush issues under the table, remain transparent so the pitfalls are clear and obvious before negotiations and planning are undertaken. Have respect for the science related to the environment, the eco-system of the land, and the needs of wildlife in long-term sense, not just profits from economic development that might in some cases be harmful. Environmental protection laws can never be tossed Collaboration must be done beforehand, rather aside than during passage attempt Reach out widely to related areas and people and take all sides and issues into account to establish the need for an environmental impact study. Better sooner than later, and again, leave room for changes for unexpected events or climate changes. Do not take shortcuts Do not skip environmental impact statements The BLM should always be looking for opportunities The BLM should make it easier for states to share to share ideas and collaborate across its own field data--particularly wildlife management data--with office boundaries and with other public landowners, the agency and vice versa. This would include the such as state agencies, tribes, and other federal identification of wildlife migration corridors and agencies, as well as private landowners. other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Put more effort in the foundation of the plan = less Adhering to science-based decisions, considering effort later. More specifically, greater collaboration ecological as well as economic values, truly balancing and sharing of ideas in the beginning, will result in responsible development with reasonable fewer challenges (e.g. delays & lawsuits) later. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Use science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Starting with science-based decisions, with ecological values considered, truly balancing responsible development with reasonable conservation, keeping the public well-informed with full transparency and providing sufficient opportunities for participation. Greater collaboration and sharing of ideas in a factbased matter will reduce litigation. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. See procedures of Participative Action Research (PAR) or consult Quaker literature for examples. the delays are necessary when outside influences are attempting to abuse public lands for personal profit! Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multi-field office levels as needed to better opinion point to the need for an EIS, do NOT skip address cross-boundary issues and simplify the that step. number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Avoid encouraging many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Plans should be based on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Shortcutting this process leads to future legal challenges. Allow BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Proceed slowly, as if future generations depend on what you do. Think seven generations ahead. Tribal governments should be encouraged to Collaboration should begin early, before scoping Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts (the process by which agencies solicit input on the more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic issues to be addressed and how they will be fewer challenges in the long run and should help responsible development with reasonable communications. evaluated), and allow everyone--ranchers; miners; avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Follow the science Collaboration and transparency to avoid surprises Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data-- particularly wildlife management data-- with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation- should also reduce lawsuits. Listen and try to accommodate ideas from others. Base plans of sound scientific data. Have a "settlement conference" before issuing documents or new rules. Negotiate first rather than litigate later. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Follow the science and public opinion Be attentive to cross-border issues Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do NOT skip that step. Base plans on science. The right size is the one that leads to the correct or Broaden the issues rather than constrain them. Let best answer. Don't short circuit the process. That entire regions (multiple jurisdictions) determine only leads to more litigation later. appropriate responses. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Since both the socioeconomic system and natural biota are/will be impacted by global warming, the A,EbM management approach would be a good option. Natural capital and ecosystem services in BLM properties needs to be integrated into the management plan (biotic; physical. chemical and socioeconomic aspects. It often helps if local stakeholders develop Since most NGO lawsuits are based upon agreements on contentious issues outside of the procedural issues or legal technicalities, BLM state/federal planning process. For example, when documents should make sure that these problems the Stellwagen Bank National Marine Sanctuary was are avoided. formed in 1989, the environmentalists and fishermen/women agreed on allowing fishing, but prohibiting oil/gas development. When the Northeast Deep Sea Canyon and Seamount National Monument was designated in 2015, it became a no take wilderness area which ticked off the fishing interests. Pre-consultation with various stakeholders before a project plan is developed can provide a solution to erring in haste and repenting at leisure. I got nothin' on this except for make sure your lawyers are more clever and committed than the ones for your opponents. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share Encourage tribal governments to participate, and data--particularly wildlife management data--with make special efforts to reach those without the agency and vice versa. This would include the electronic communications. identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Base your decisions on science, If science or public Focus on collaborating and sharing ideas. Though opinion, keep the public well informed, and provide more time-consuming in the beginning, that will numerous well-publicized opportunities for public result in fewer challenges in the long run and should participation. help avoid delays and lawsuits at the end. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multi-field office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. BLM needs to match the project plan with the There are negative lessons to be learned from the local/state/federal management entities and ensure dispute between the Monomoy National Wildlife coordination and cooperation between the Refuge and Town of Chatham dispute on control of management the bottomlands and fishing practices/coastal entities and impacted public/stateholders. A good erosion. With Relative Sea Level Rise and storm example would be the Cape Cod National Seashore related (Northeasters and Hurricanes) leading to and outer Cape Towns. Wellfleet and the CCNS coastal erosion are developing a joint plan for the Herring River salt and land accumulation elsewhere, this problem will marsh restoration project which is a "Blue Carbon" continue into the future. endeavor. Here again, I am out of my league. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Avoid shortcuts that could make a plan vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step.  The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts more time-consuming in the beginning, will result in to reach areas that lack access to electronic fewer challenges in the long run and should help communications. avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic responsible development with reasonable fewer challenges in the long run and should help communications. conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering Base plans on the latest information, science, ecological as well as economic values, truly balancing policy, and public opinion. If the science and/or responsible development with reasonable public opinion point to the need for an conservation, keeping the public well-informed, and environmental impact statement, do not skip that providing adequate opportunities for participation step. should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Let BLM managers broaden planning to the district Base plans on the latest information, science, policy, or multifield office level as needed to better address and public opinion. If the science and/or public cross-boundary issues and simplify the number and opinion point to the need for an environmental complexity of resource management plans. impact statement, do not skip that step.  The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering Tribal governments should be encouraged to more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing participate, and the BLM should make special efforts fewer challenges in the long run and should help responsible development with reasonable to reach areas that lack access to electronic avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and communications. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Collaboration should begin early, before scoping Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering (the process by which agencies solicit input on the more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing issues to be addressed and how they will be fewer challenges in the long run and should help responsible development with reasonable evaluated), and allow everyone--ranchers; miners; avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. Adhering to science-based decisions, science is always legally defensible The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. The BLM should always be looking for opportunities Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while to share ideas and collaborate across its own field ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in office boundaries and with other public landowners, responsible development with reasonable fewer challenges in the long run and should help such as state agencies, tribes, and other federal conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. agencies, as well as private landowners. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. Tribal governments should be encouraged to participate. The BLM should develop a procedure to follow when an action involves tribal lands since my people in these areas lack access to electronic communications. Using science when making these decisions, Greater collaboration and sharing of ideas among all considering ecological as well as economic values, the interested parties, in the beginning, will result in truly balancing responsible development with fewer challenges. reasonable conservation will help minimize any legal challenges. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Do not encourage shortcuts that make a plan vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public Provide sufficient review time and public hearings to opinion point to the need for an environmental listen to the science and make sure the decision is impact statement, do not skip that step. sustainable for the long term environment. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. Base plans on the latest information, science, policy, Do not rush a plan through. This will only lead to and public opinion. If the science and/or public more legal challenges. opinion point to the need for an environmental impact statement, prepare the impact statement as soon as possible. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Utilizing input from Question D, economic, human created changes, and conservation of existing conditions combined with scientifically verifiable physical, ecological, environmental and location data create a consensus plan to start with. Base plans on the latest applicable information, science, policy, and public opinion and any possibly needed environmental impact statement. Use the fewest and simplest resource management plans possible to cover all aspects of the action. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. This is important. Make sure every voice feels Verify data to be sure it is up-to-date and not taken heard by providing ample time and addressing their out of context. views in the written solutions and documents. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts more time-consuming in the beginning, will result in Adhering to science-based decisions, considering to reach areas that lack access to electronic fewer challenges in the long run and should help ecological as well as economic values, truly balancing communication avoid delays and lawsuits at the end of the process. responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering Ensure all documents are clearly written in plain participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancin language to eliminate the possibility of to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable misunderstanding. Technical jargon can be communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and translated into plain english or whatever language is providing adequate opportunities for participation needed for the intended audience. should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Don't try to take shortcuts. Include a complete environmental analysis. Let BLM managers broaden planning to the district or multi-field office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Let BLM managers broaden planning to the is vulnerable to legal challenge later in the process. district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Make it easier for states to share data like wildlife management data with the agency and vice versa, like in the identification of wildlife corridors and other scientific information of benefit to outdoor recreational enthusiasts, be they hunters or fishermen. Tribal governments should be encouraged to participate, and the BLM should reach out to areas on tribal lands that lack electronic communication access. There should be a greater collaboration and sharing Adherence to scientifically based decisions, of ideas to avoid lawsuits. considering ecological as well as economic values would be of great importance and would balance responsible development and reasonable conservation, keeping the public well informed and providing opportunities for public participation. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. I would like to see a way in which those with a vested economic interest in the plan (ie, those paying BLM fees) are clearly identified when providing input by stating what and how many leases/fees agreements they possess. Their short term interests need to be balanced with the long term future interests of American people. Don't send mixed signals. Perceptions of bias of Adher to science-based decisions, and to long range Be sure to include regulatory and other legal Greater collaboration and sharing of ideas, while those convening or facilitating the process or in the forecasting of ecological impacts when evaluating sources that are covered by the planning process so more time-consuming in the beginning, will result in information available contribute to lack of trust. shorter term economic interests of stakeholders. general public can understand constraints. If a fewer challenges in the long run and should help Keeping the public well-informed, and providing regulation would have to change to allow a avoid delays and lawsuits at the end of the process. adequate opportunities for participation should also proposal, stipulate how that regulation would have reduce lawsuits. to change. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic responsible development with reasonable fewer challenges in the long run and should help communications. conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. I would recommend not encouraging so many Base plans on latest scientific information, policy and shortcuts that a plan is vulnerable to legal challenge. public opinion. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Develop a process and encourage BLM managers to Base plans on the latest information, science, policy, broaden planning to the district or multifield office and public opinion. If the science and/or public level as needed to better address cross-boundary opinion point to the need for an environmental issues and simplify the number and complexity of impact statement, do not skip that step. A plan is resource management plans. vulnerable to legal challenge later in the process. Let BLM managers broaden planning to the district Base plans on the latest information, science, policy, or multifield office level as needed to better address and public opinion. If the science and/or public cross-boundary issues and simplify the number and opinion point to the need for an environmental complexity of resource management plans. impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step.  Tribal governments should be encouraged to Collaboration should begin early, before scoping Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts (the process by which agencies solicit input on the ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic issues to be addressed and how they will be responsible development with reasonable fewer challenges in the long run and should help communications. evaluated), and allow everyone--ranchers; miners; conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. Collaboration should begin early, before scoping The BLM should make it easier for states to share (the process by which agencies solicit input on the data--particularly wildlife management data--with issues to be addressed and how they will be the agency and vice versa. This would include the evaluated), and allow everyone--ranchers; miners; identification of wildlife migration corridors and energy developers; recreation groups; other federal, other habitat data, and other scientific information state and local agencies; and members of the that is important to hunters, anglers, and other public--to tell the BLM their wishes and concerns backcountry recreation enthusiasts. about the planning area, and share any data they have about the area. Share data such as wildlife, habitat data with others Include the Tribal agencies Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Share ideas and be open in collaborating with others Stick with science based decisions; animals and plants need a place to live too Economics is not the only consideration, we need to preserve wild life and habitats for future generations. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This includes the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should reduce lawsuits. The BLM should always be looking for opportunities to share ideas and collaborate across its own field office boundaries and with other public landowners, such as state agencies, tribes, and other federal agencies, as well as private landowners. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Tribal governments should be encouraged to participate and the BLM should make special efforts to reach areas that lack access to electronic communications. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas with all ecological as well as economic values, truly balancing impacted entities, while more time-consuming to responsible development with reasonable begin with, should result in fewer challenges and conservation, keeping the public well-informed and help avoid delays and lawsuits at the end of the providing adequate opportunities for participation process. should reduce legal challenges. Base plans on the latest information, science, Let BLM managers broaden planning to the policy, and public opinion, and weight each one district or multifield office level as needed to better appropriately (public opinion nor policy should ever address cross-boundary issues and simplify the outweigh science when it comes to the safety and number and complexity of resource management health of our environment). If the science and/or plans. public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district Base plans on the latest information, science, policy, or multifield office level as needed to better address and public opinion. If the science and/or public cross-boundary issues and simplify the number and opinion point to the need for an environmental complexity of resource management plans. impact statement, do not skip that step. Don't take short cuts, this leads to legal challenges Be sure to include science as well as public opinion and an environmental impact statement Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy Let BLM managers broaden planning to the district and public opinion. If the science and /or public or multifield office level as needed to better address opinion indicate the need for an environmental cross-boundary issues and to simplify the number impact statement, do not skip that step. and complexity of resource management plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering Do not encourage so many shortcuts that a plan is ecological as well as economic values, truly balancing vulnerable to legal challenge later in the process. responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. It is always important to remember to keep the public involved in whatever process you use. It is always important to keep the public involved with whatever process you use. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Keep the lines of communication open at all times by inviting extemporaneous comments. Stop slaughtering programs Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Again some of this covered in 'A' Everyone who may have ideas needs to be included Also sound science is critical to the underpinning of and have an opportunity to reply. these activities and all participants would have a way to easily read and hear the background or science- based decisions Negotiate in good faith with stakeholders. Get representative stakeholders in a room together to clarify the tradeoffs and conflicting interests before taking legal action. Do not encourage so many shortcuts that a plan is Let BLM managers broaden planning to the district vulnerable to legal challenge later in the process. or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. All this takes time and transparency so that science, Consider environmental impact statements be policy and public opinion are considered. completed and again shared with all in ways previously discussed. Consistent practices and thoughtful analysis allow supportable extrapolation from limited data. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Again the biggest solution is allowing the public balancing impacts between the public and the BLM balancing science-based decisions, considering allow meetings with open forums to allow discussion input along the way with meeting and through direct input and transparency of the ecological as well as economic values, truly balancing announcements highlighting progress or problems project responsible development with reasonable conservation, which can be obtained with meetings etc. Involve lawyers with environmental expertise to data sharing via collaboration with tribal councils, participate Use collaboration in the early stages of planning; Use scientific data and be transparent about federal/state agencies, environmental groups, collaboration and transparency will decrease discrepancies ranchers, land owners, energy development lawsuits over the long term companies, concerned citizens Tribal governments should be encouraged to The BLM should always be looking for opportunities Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts to share ideas and collaborate across its own field ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic office boundaries and with other public landowners, responsible development with reasonable fewer challenges in the long run and should help communications. such as state agencies, tribes, and other federal conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. agencies, as well as private landowners. providing adequate opportunities for participation should also reduce lawsuits. Use common sense. Make decisions that allow the local district to do work and expansion, within plans, without having to come back for public review. Collaborate Open transparency Set up a mediation process The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts more time-consuming in the beginning, will result in to reach areas that lack access to electronic fewer challenges in the long run and should help communications. avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. don;t take any shortcuts always base the decisions on the most current science and environmental information available avoid shortcuts to prevent litigation allow BLM managers to broaden planning to the district or multi-field level to better address cross boundary issues Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Make the analysis fit the project. Replacing a culvert should not require a NEPA review. Removing a tree that is causing issues for those recreating should not require a NEPA review. Common sense. Be thorough and open to scrutiny. Get public input in a step by step process Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Work with tribal governments and reach out to them, and especially those in areas without electronic communication. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Collaborate and share ideas in the beginning of the planning process to avoid later challenges, delays, and lawsuits. Stick with scientifically based decisions and balance ecological and economic needs. Engage in responsible development that takes conservation seriously into account. On the economic side, consider the long term, not just short term extractive goals. Keep the public informed, keep the development responsible. Allow participation. These steps will reduce lawsuits. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Avoid shortcuts to avoid legal challenges. Don't circumvent environmental impact statements or the latest in good public policy and science. Don't ignore your own scientists. Stop firing them.  The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Bring all stakeholders together to share ideas early Keep all parties informed every step of the way. in the process. Begin with sound science. Do not politicize the problem or viable solutions. Deal on the merits of issues raised and address all concerns. Follow suggestions in steps A - D. Be professional and be transparent. Do not rely on consultation with the proponents or First and foremost assure that the information in Follow the principles used for Questions C and D: opponents of a particular project to determine the the documents is trustworthy. Transparency and Good Neighbors. project's impacts. Conduct an independent study under direct supervision of the BLM. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other should also reduce lawsuits. backcountry recreation enthusiasts. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. If you listen and cooperate with involved communities, litigation would be much less likely. Demographics tht have historically been ignored need to be encouraged to speak up and given a forum. Getting everyone on board to begin with will limit Base decisions on solid and well researched scientific the legal challenges down the road. studies so that it is defensable beyond any doubt. The BLM should make it much easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater COLLABERATION AND SHARING OF Adhering to science-based decisions, considering participate, and the BLM should make special efforts IDEAS, while more time-consuming in the beginning, ecological as well as economic values, truly to reach areas that lack access to electronic will result in fewer challenges in the long run and BALANCING responsible development with communications. This is extremely important! should help avoid delays and lawsuits at the end of reasonable conservation, keeping the public well- the process. informed, and providing adequate opportunities for participation should also reduce lawsuits. Collaboration should begin early, before scoping The BLM should make it easier for states to share (the process by which agencies solicit input on the data--particularly wildlife management data--with issues to be addressed and how they will be the agency and vice versa. This would include the evaluated), and allow everyone--ranchers; miners; identification of wildlife migration corridors and energy developers; recreation groups; other federal, other habitat data, and other scientific information state and local agencies; and members of the that is important to hunters, anglers, and other public--to tell the BLM their wishes and concerns backcountry recreation enthusiasts. about the planning area, and share any data they have about the area. Begin by having a clear understanding of the Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering applicable laws and the purpose of those laws. more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing Again, BLM's primary constituent is the land and its fewer challenges in the long run and should help responsible development with reasonable ecosystem. Making that clear will remove many avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and objections and causes of action. providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Be aware of work already done that is similar in nature. Have a library of relevant studies and outcomes available for all interested parties. Hold meetings early in the process with stakeholders to avoid confusion and wasted effort. Don't worry so much about the size, but whether the NEPA process adequately covers the important factors. A bigger project will have more components, requiring a bigger document. Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, Recognize all of the citizens and area's that will be and public opinion. If the science and/or public impacted so that you can do a fully and accurate opinion point to the need for an environmental assessment. impact statement, do not skip that step DO NOT encourage so many shortcuts that a plan Base ALL PLANS on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, DO NOT SKIP THAT STEP! Every action has more ramifications than BLM is interested in exploring. "Right sizing" implies that under some circumstances it is acceptable to do minimal review of a proposal. That is not acceptable. Start from the broad questions. If the proposal is truly minimal, the analysis will narrow itself. Without asking the broad questions first, it is only too likely that only one aspect of a proposal is addressed, leaving questions unanswered and adverse impacts undescribed. Narrowing the scope of an analysis too soon leads to more work later and the very real possibility of adverse impacts unconsidered. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The big land grabbers have a great deal of money to Get the public involved early but wide spread put into their quest for profit. There is no way to publicity. avoid some of their efforts. You need a legal defense fund and need to reach out to other users and organizations for support It must be easy for states to share data-especially Tribal governments should not be forgotten. Special Greater collaboration with all stakeholders and a wildlife management date with the BLM. Data would efforts may need to be taken to reach areas that sincere desire to understand all concerns could include wildlife migration corridors, habitat data, lack access to electronic communications. possibly result in fewer lawsuits and delays during and scientific data important to hunters, anglers and the process. outdoor recreation enthusiasts. Decisions should be SCIENCE based. There should be consideration of ecological as well as economic values. Responsible development should be balanced with reasonable conservation. If the public is well informed and able to participate, lawsuits should be reduced. If people feel like they have been run rough shod over by the government, resistance will be the result. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Difficult. Front-end agreements of stakeholders and interested parties would help, but not prevent litigation. It only takes one. That is a tough one as Attorneys are the most prolific money makers, of all occupations. You are up against the legal industry (Check out the yellow pages). You would need an extremely savvy one to be on your side in working out those plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier to share data on wildlife management such as migration corridors and habitat. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas. Using science based information. Looking at ecological concerns in addition to economic. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Make more use of nationally based "conservation, hunting, and environmental groups. Reach out to them like your agency use to reach out to beef, sheep, mining, petroleum and other destructive user groups. This is public land! Emphasize non destructive use and insist that the land and water be returned to its original state at the user's expense. Shortcuts in planning process can lead to legal challenges later in the process Plans should be based on the latest information, SCIENCE policy and public opinion. Environmental impact statements are a necessity if science and public opinion point to the need. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base it on cost, acreage, stakeholder rights. For example, tribal rights trump all. Mother Nature's processes should always be front and center and not capitalistic 'developers'. You should always be looking all the way down the watershed, so to speak, for the harm that may be done. Example: If a certain frog's habitat is in question, the developer can not get away with just saying that the pond, which is their breeding ground will not be impacted by the development up the hill. Frogs do not spend their whole life just breeding by ponds. They forage and have places to go, and other frogs to see. If you get my drift. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Be thorough. This means no short cuts that can lead to challenges later. Base plans on the latest information, science, policy and public opinion. If an environmental study is warranted, don't skip it. The BLM should always be looking for opportunities to share ideas and collaborate across its own field office boundaries and with other public landowners, such as state agencies, tribes, and other federal agencies, as well as private landowners. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Make it easier for states to share data--particularly Encourage tribal governments to participate, and wildlife management data--with the agency and vice the BLM should make special efforts to reach areas versa. This would include the identification of that lack access to electronic communications. wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas takes Reduce lawsuits by: adhering to science-based more time in the beginning but means fewer decisions, considering ecological as well as economic challenges in the long run plus will help avoid delays values, truly balancing responsible development with and lawsuits at end of process. reasonable conservation, keeping the public well- informed, and providing adequate opportunities for participation. The BLM should let everyone involved share data they have about the area. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. The BLM should base the plan on the latest If science sees a need for an environmental impact information, science, policy, and public opinion. statement, the BLM must not skip this step. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Make it easier for states to share data...... particularly wildlife management records, endangered species of plants and animals data-- with the BLM and make it easier for all to data share. Tribal governments and their members should be encouraged and helped to participate. The BLM must be particularly sensitive to the lack of access to electronic communications. It begins at the start: Spend the time at the outset to collaborate and share ideas. Don't be afraid of controversy at the start. Time spent at that stage will prevent much on the back end. Adhere religiously to science-based decisions. Consider the ecological as well as economic values but truly balance responsible land development with absolutely necessary conservation, keeping the public well informed and provide opportunities for participation in the process. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Have regular meetings, as well as special meetings when you hit a snag, that includes all of the bodies you've listed as well as interested citizens. Might want to invite some activist organization lawyers to your meetings. Again...same answer...invite interested and affected parties to the table using a variety of means to make sure everyone knows what you're doing and when then can show up and participate. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Let BLM managers broaden planning to the district or multi-field office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Let BLM managers broaden planning to the district vulnerable to legal challenge later in the process. or multi-field office level as needed to better Base plans on the latest information, science, policy, address cross-boundary issues and simplify the and public opinion. If the science and/or public number and complexity of resource management opinion point to the need for an environmental plans. impact statement, do not skip that step. Do not encourage or support so many shortcuts Base plans on the latest information regardless of the the plan is vulnerable to legal challenges later in the source whether science, policy or public the process. opinion. If either science or public opinion point to a need for an environmental impact statement, DO NOT SKIP THAT STEP! Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans Issue your invitations to participate, updates, and I'd have to see examples to intelligently comment reports in plain English in the beginning, with any further about this one. required references to documents and laws listed at the end. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other should also reduce lawsuits. backcountry recreation enthusiasts. Make it easier for states to share data--particularly Tribal governments should be LISTENED TO and wildlife management data--with the agency and vice encouraged to participate, and the BLM should versa. This would include the identification of make special efforts to reach areas that lack access wildlife migration corridors and other habitat data, to electronic communications. and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Don't assume that special language shortcuts are understood by all participants. Avoid jargon. Avoid regional nicknames for common locations and processes. Use clear and common language and test the documents on the general public to ensure clear communication before conflicts arise. Consult the legal personnel of non-governmental organizations to understand their particular concerns. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Collaborate early and often. Use most recent science. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other should also reduce lawsuits. backcountry recreation enthusiasts. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Ensure that actions which have effects outside of the Consult academic leaders in the areas of science BLM administered areas are considered. where impacts might be occurring. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Don't do or offer shortcuts. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Include the state and local governments, tribal partners, and other stakeholders into the decision making, The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Don't until a true and legal system is instituted. Ask the public to participate in making the decisions. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Reduce it to plain language before "translating" it. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Collaboration should begin early, before scoping, and allow everyone to tell BLM their wishes and concerns for the planning area Adhering to science based decisions, consider ecological values over economic considerations. Keep the public well informed Do not separate Native American's from non Native American's while discussing the issues. Work to help each understand the others' stances. Be present, not just for meetings, but year round so Be transparent and respond in a meaningful way to you can understand what the land means to the queries. people, and how culture plays into it. Keep your focus on your legal mission. Be honest, clear in your answers and recognize where the plan varies from the direction some groups had wished. Provide a timely appeals process. Don't encourage shortcuts that make a plan vulnerable to legal challelenge. Base plans on latest scientific data. Include policy and public opinion. If needed, or requested, complete an environmental impact statement. Do the thorough analysis any project deserves. accept info from all sources from data If you have more buy-in on the front end there should be less in the way of challenges. It makes logical sense. Also, every decision cannot be based on the bottom line, so making sure comprehensive evaluations are done with sensitivity to all viewpoints is crucial. integrate suggestions from all sources to action respect those who have other facts respect and integrate the to the needs of the local community Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. think about something besides money Honor science, honor facts, honor sensitivities to the environment and nature, be open and do the due diligence from the start should help to bring things to successful conclusions more gracefully. Be transparent. Be comprehensive. Again, it's not always just about the bottom line. understand that many want the environment and nature preserved as is understand that every decision you make affects a review the latest scientific facts broader area Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step.  The BLM must make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to a wide variety of users. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. get all parties to agree to documents, especially the environmental groups. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. N/C N/C Close legal loopholes designed to subvert the public interest in favor of profiteers. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Why not benefit from free private expertise? Tribal governments, which are deeply affected by Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering BLM changes, should be encouraged to participate, more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing and the BLM should make special efforts to reach fewer challenges in the long run and should help responsible development with reasonable areas that lack access to electronic communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and We want partners, not adversaries. providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Conducting in-depth analysis and public input early on results in fewer delays and legal challenges down the road. N/A N/A N/A N/A N/A N/A Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public It's smarter and more cost-effective to go more opinion point to the need for an environmental slowly if that will produce a thorough analysis. impact statement, do not skip that step. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. Assess the degree of complexity in an action, which may be a more accurate guide than the scale of an action. N/A N/A Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Don't allow private energy interests to destroy public lands. Once destroyed the lands are gone forever while the energy company moves on. Decisions that remove lands from the public can never be undone and should only be done in the The BLM should always be looking for opportunities Collaboration should begin early, before scoping most cautious, regulated manner. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while to share ideas and collaborate across its own field (the process by which agencies solicit input on the ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in office boundaries and with other public landowners, issues to be addressed and how they will be responsible development with reasonable fewer challenges in the long run and should help such as state agencies, tribes, and other federal evaluated), and allow everyone--ranchers; miners; conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. agencies, as well as private landowners. energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Stop the greed Stop the greed Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Stop the greed Stop the greed Stop the greed Adhere to science-based decisions; consider ecological as well as economic values; balance responsible development with reasonable conservation; keep the public well-informed; and provide adequate opportunities for participation. Do not take shortcuts that make a plan vulnerable to legal challenge later in the process. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic responsible development with reasonable fewer challenges in the long run and should help communications. conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Stop the greed Don't allow private energy interests to destroy public lands. Once destroyed the lands are gone forever while the energy company moves on. Decisions that remove lands from the public can never be undone and should only be done in the most cautious, regulated manner. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. If corruption and/or greed leads to abuse of the natural resources under BLM control then it is BLM's duty to defend those same resources from those who would exploit the land for their own short sighted profit. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Input from tribal governments should be solicited, and the BLM should make extra effort to reach areas that lack access to electronic communications. Better initial collaboration and outreach should result in fewer delays and lawsuits. Adopting science-based decisions and emphasizing ecological values should reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to birders, anglers, and other backcountry nature enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer problems in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not allow shortcuts that will make a plan vulnerable to later legal challenge. If the science and/or public opinion ibdicate the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Avoid shortcuts that make a plan vulnerable to legal Base plans on the latest information, science, policy, challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Adhering to science-based decisions, considering Acknowledge climate change! ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas will benefit everyone in the long run. Stick to science based professional decisions that keep the environment and species preservation first and foremost. Development that isn't in the best interests of managing the land for the benefit of the masses should be discouraged and prevented. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Discourage shortcuts, due diligence should prevail and prevent lawsuits later Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Easier for states to share data. Tribal governments should be encouraged to participate. Collaboration and sharing of ideas. Adhering to science-based decisions. Keeping the public well-informed. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering Tribal governments should be encouraged to more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing participate, and the BLM should make special efforts fewer challenges in the long run and should help responsible development with reasonable to reach areas that lack access to electronic avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and communications. providing adequate opportunities for participation should also reduce lawsuits. Providing adequate opportunities for participation Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, should also reduce lawsuits. vulnerable to legal challenge later in the process. and public opinion. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. vulnerable to legal challenge later in the process. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other back should also reduce lawsuits. country recreation enthusiasts. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to outdoor enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data with the agency and vice versa. This would include wildlife migration corridors, other wildlife and habitat data, and other scientific information. Tribal governments should be encouraged to participate at earliest stages of planning. Special effort needs to be made to reach areas and communities that lack access to electronic communications. Greater collaboration and sharing of ideas, while more time consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, policy, is vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage shortcuts that make a plan more Base plans on the latest information, science, policy vulnerable to legal challenges. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and The usefulness of the internet should aid in this. providing adequate opportunities for participation should also reduce lawsuits. Tribal governments should be encouraged to participate, & the BLM should make special efforts to reach areas that lack access to electronic communications. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. WORK WITH TRIBAL GOVTS! THEY'VE BEEN EXCLUDED FOR FAR TOO LONG. Shockingly, if you put in more work in the planning stage it'll result in fewer changes later in the process. FOLLOW SCIENCE!!!!!! Consider the ecological impact. In the long run this makes economic concerns sustainable. Don't use up the resources for short term gain. Make sure that you factor in long term economic growth, which only works when you take account of ecological concerns. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Shortcuts beget legal challenges. Just stop taking them. Once again, SCIENCE!!!!  The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. With these new Zones, and their overlays, based on Allow access and input to these long-range plans, or If all agencies are sharing information and working this new database, create Ideal Long-Range Plans Zones, from all parties, long before any specific together to create the Zones based on science and that incorporate ideal uses and protections, and areas of planning are proposed. When specific natural features, and the overlays that include all start all planning using these Zones that are based plans are proposed, make sure that transparency parties' interests, and if all parties, both private and on natural processes and features, with their and open two-way communication are emphasized. governmental, are invited to participate right from overlays of current and historical uses, jurisdictions As long as all parties know that Ideal Long-Range the start, and if transparency is universally applied, and ownership. Plans are only an ideal, something to be worked the no-suprises approach will make any problems towards eventually, all parties should want to work stand out right at the beginning, where they can be towards solutions that make sense for everyone, immediately addressed, before they can become the including future generations, and rather than a sense festering frustrations that incline towards legal of disenfranchisement, a sense of participation and actions. accomplishment. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. The BLM should always be looking for opportunities Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while to share ideas and collaborate across its own field ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in office boundaries and with other public landowners, responsible development with reasonable fewer challenges in the long run and should help such as state agencies, tribes, and other federal conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. agencies, as well as private landowners. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should facilitate wildlife management data sharing among states and the agency, including the identification of wildlife habitat, migration corridors and other scientific information that is important to back country recreation seekers. "Adhering to science-based decisions, considering Collaboration and transparency always help. ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits" [Pew Charitable Trusts statement]. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Always put people and the environment before corporate profits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Public Input Transparency Always put people and the environment over corporate profit. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The broad planning approach of the Zones will address the consolidation of separate yet interrelated areas of environmental planning long before any specific planning projects are tackled. Any resource management conflicts or cross boundary issues will be apparent, and hopefully resolved, during construction of the overlay maps. These Zones and overlays will need the cooperation of lawmakers on a national level, but a fresh approach that greatly simplifies and unifies governance of our public lands, with transparency and fairness for all parties is long overdue Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Plans should be based on up-to-date inputs. If any inputs point to the need for an environmental impact statement, do not skip that step. Shortcuts in planning make a plan vulnerable to legal challenges later in the process--so the BLM must do a thorough job. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Public Input Transparency Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Encourage participation of tribal governments, especially making efforts to reach areas where electronic communication may not be available. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Collaboration and sharing ideas may take more time Consider ecological as well as economic impacts, so in the beginning, but will make for fewer challenges that development will be responsible and include later on, for fewer challenges and less likelihood of conservation, providing opportunities for lawsuits. participation. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Let BLM managers broaden planning to the district vulnerable to legal challenge later in the process. or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Taking short-cuts makes plans vulnerable to lawsuits. Make sure plans are based on the latest information, science, and public opinion. If public opinion points to the necessity of an EIR, make sure one is done. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Well publicized and easily accessible information about opportunities for public participation - public meetings, comment periods, presentations, etc. - is essential to achieving well-conceived decisions and efficient project implementation. Abundant public input is critical to good results. Increased public participation and process transparency leads to decisions that better address multiple and sometimes conflicting viewpoints, broader buy-in to the final decisions, and less resistance (meaning fewer delays) to implementation. Streamlining should not be at the expense of public Well publicized and easily accessible information participation and transparency. Constraining about opportunities for public participation - public opportunities for public input not only is an affront meetings, comment periods, presentations, etc. - is to democracy, but what is gained in near term essential to achieving well-conceived decisions and efficiencies is more than lost in long term conflicts. efficient project implementation. A proactive, thorough, and inclusive public outreach process may delay project approval, but it will streamline implementation. A shoddy process will result in protests, lawsuits, and other project implementation delays while creating an atmosphere of distrust that will hamper future projects. Americans expect nothing less than transparency and the opportunity to voice concerns. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Let BLM managers broaden planning to the district vulnerable to legal challenge later in the process. or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Unsure any concern person knows about the actions Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Right size a for scale of action, who knows what the scale of an action will? Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. inform on progress or lack of progress and why...what can be done and when legal challenges help protect areas, there will be legal challenges and there should be... use science (recent) to support the solution find non-lethal solutions that benefit all parties a little... allow all parties to participate Keep it simple! The more "add-ons" there are, the more loopholes somebody will find to complicate a plan they do not like. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. use science for good, and use science ongoing try not to shove stuff through Get the EPA's budget to a point where there are enough people to handle all the needs. THAT is one of MY priorities for this agency :) Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should always be looking for The BLM should make it easier for states to share opportunities to share ideas and collaborate across data--particularly wildlife management data--with its own field office boundaries and with other public the agency and vice versa. This would include the landowners, such as state agencies, tribes, and other identification of wildlife migration corridors and federal agencies, as well as private landowners. other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. The BLM should always look for opportunities to Collaboration should begin early, and allow Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while share ideas and collaborate across its own field everyone to tell the BLM their wishes and concerns ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in office boundaries and with other public landowners, about the planning area, and share any data they responsible development with reasonable fewer challenges in the long run and should help such as state agencies, tribes, and other federal have about the area. conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. agencies, as well as private landowners. providing adequate opportunities for participation should reduce lawsuits. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information. providing adequate opportunities for participation should also reduce lawsuits. open forums were people can voice their concerns, objections, or approval I don't think there is a solution to preventing Use legal advise wisely litigation, there is always someone or group who is going to be unhappy with the process or outcome Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts more time-consuming in the beginning, will result in to reach areas that lack access to electronic fewer challenges in the long run and should help communications. avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. form an opinion based of the exact data/information use a team approach to analyze and present required information, and keep data collection to the Base plans on the latest information, science, case/project in question Do not encourage so many shortcuts that a plan policy, and public opinion. If the science and/or is vulnerable to legal challenge later in the process. public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Stop doing the stupid stuff that creates the legal challenges! Stop fulfilling the wishes of lobbyists and money pushing special interest groups and instead fulfill the wishes of the citizens of the United States. Do the morally and ethically right thing. Document (continued from above) You never go to attorneys what you did and why. In the large health care 1 st for guidance on how to treat the public, the system where I way employed (28,000 employees). tribes, or fulfill what has been entrusted to you. When we were faced with a difficult situation we The law can tell you NOT to steal and not to go did NOT go to our attorneys for guidance. We out of your way to harm. The law cannot hold you first determined the moral and ethical thing, by the accountable to benefit the public, to bring joy to the ethics of the healing professions and the values of tribes. This is the realm of morals and ethics -- "Do our institution, that we should do. Then we unto others....." Never let the Law be your guide documented thoroughly. Sometimes (but not when making important decisions. always) we would consult our attorneys and ask them, "What is the prudent way to do this thing THAT WE ARE GOING TO DO?" We never went to attorneys first for guidance. (continued below) The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do your best at helping the endangered animals and Maybe going in another direction would solve the plants that may be impacted by one of your problem. It might be more expensive but less decisions by talking to the experts in those areas of litigation and less delays (may save money). expertise on how to complete your job with the least amount of damage. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Make it easier for states to share data, especially wildlife management data. Encourage tribes to take part, and reach people off Don't try to balance irresponsible development with Remember that the lands belong to the public, not the grid. conservation, and keep the public informed. the next loud rich guy who threatens you. Stop being a typical government agency with bloat and special interests dictating everything. Our government appears to think that we citizens are stupid. We are not stupid. We are just fed up with the same stuff/different day. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Always go with the experts in the field (Universities Sometimes listening to the ranchers or owners of and good environmental organizations that are not the land that are impacted can give very good radical) and not on a company that picks their own information on how to proceed. experts. Let BLM managers broaden planning to the district Do not encourage so many shortcuts that a plan is or multifield office level as needed to better address vulnerable to legal challenge later in the process. cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest science and public opinion. If they think you need an EIS, get one. Work more at education of public on just what you do and the laws that govern what you do. The how and why! Follow federal law! Including a more diverse group of stakeholders. speak to your enemies The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Encourage tribal governments to participate, and find a way to communicate with remote regions which have little access to electronic media. Do not encourage so many shortcuts that a plan is Adhering to science-based decisions, considering vulnerable to legal challenge. ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. This is a tough one. It has been my experience that Don't coverup impacts. Take in lots of data at the often things that seem small end up big. Get start not later. You can always simplify and shorten information from as diverse sources of possible later. impacts. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts.^ Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and/or public opinion. Point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district, or multi field office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Make it easy for states to share data, especially Encourage tribal governments to participate. Make More time spent at the beginning getting greater wildlife management data such as migration special efforts to reach areas that lack access to collaboration and sharing of ideas. corridors, habitat, and scientific info important to electronic communications. hunters, fishers, and other backcountry enthusiasts. Stick to science-based decisions, consider ecological as well as economic values, balance responsible development with conservation, keep public wellinformed, and provide adequate opportunities for participation The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Avoid shortcuts that make a plan vulnerable to legal Base plans on the latest info, science, policy, public challenges opinion, and an environmental impact statement if indicated. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step!!! The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other back- should also reduce lawsuits. country recreation enthusiasts. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. All imperiled wildlife. plant and insect areas must be taken into account and reserved. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM must make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. This may mean that this avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and information is printed out and posted in local stores All concerns from any group must be fully providing adequate opportunities for participation within the tribal areas. Even better would be to addressed at all times. should also reduce lawsuits. Politics and have meetings in these areas so that questions may corporation interests should NEVER play any part in be asked and answered, even if it would require any decision. meetings whenever the process is changed or progresses. It is imperative that Tribal governments be included if any of their lands are at all to be included. Also all sacred lands MUST be off limits for any change. Collaboration should begin early, before scoping (the process by which agencies solicit input on the issues to be addressed and how they will be evaluated), and allow everyone--ranchers, miners, environmental organizations, energy developers, recreation groups, other federal, state and local agencies, and members of the public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas as well as Adhering to science-based decisions, considering a willingness to build on common ground, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible, sustainable development with science- fewer challenges in the long run and should help based conservation, keeping the public well- avoid delays and lawsuits at the end of the process. informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not allow so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If an environmental impact The BLM must always realize the probable need for statement is needed due to the science and/or totally on-hands meetings in tribal areas. public opinion pointing for it, do not skip that step. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multi-field office level as needed to better opinion point to the need for an environmental address cross-boundary issues and simplify the impact statement (EIS), do not skip that step. number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Collaboration and creating opportunities for collaboration The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Tribal governments should be encouraged to Collaboration should begin early, before scoping Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts (the process by which agencies solicit input on the ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic issues to be addressed and how they will be responsible development with reasonable fewer challenges in the long run and should help communications. evaluated), and allow everyone--ranchers; miners; conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Share ideas, follow the science, do not neglect the environment. I'm not a lawyer. make planning as broad and comprehensive as possible Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Different decisions for different districts Tribal governments should be encouraged to The BLM should always be looking for opportunities Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts to share ideas and collaborate across its own field more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic office boundaries and with other public landowners, fewer challenges in the long run and should help responsible development with reasonable communications. such as state agencies, tribes, and other federal avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and agencies, as well as private landowners. providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Improve public Access to BLM land Do research ahead of time and make sure that you have the very best lawyers on your team. Wealthy people can afford lots of litigation and lawyers, but poor people cannot. Therefore you need to defend through your legal team those who cannot defend themselves, not least of which the flora and fauna that you are designated to protect. Be proactive by sending out information to interested parties and the media and setting up a mediator before it goes to litigation. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. The BLM should always be looking for opportunities Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while to share ideas and collaborate across its own field ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in office boundaries and with other public landowners, responsible development with reasonable fewer challenges in the long run and should help such as state agencies, tribes, and other federal conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. agencies, as well as private landowners. providing adequate opportunities for participation should also reduce lawsuits. Any lawyer(s)/lobby representing profit making groups should NOT be recognized The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Have teams of scientists, advocates and local people ready to move to analyze environmental issues. Keep you research up-to-date so that you apply just the right amount of analysis. How? Examine the issue, the stakeholders, and the area and then adjust accordingly. Proactively seek comments prior to beginning the analysis Consider generally accepted principals from the forest service and other state and national land entities. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Don't encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Corporations are not citizens....they should NOT BE RECOGNIZED in the use process. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. NEPA is the law and cannot be undermined for private profit. NEPA upholds the public trust and scientific integrity. Do it right and the legal challenges will fade. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other should also reduce lawsuits. backcountry recreation enthusiasts. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Collaboration should begin early, before scoping (the process by which agencies solicit input on the issues to be addressed and how they will be evaluated), and allow everyone--all public citizens, local and area concerned citizens, recreation groups; other federal, state and local agencies; and all members of the public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing Greater collaboration and sharing of ideas, while responsible development with reasonable more time-consuming in the beginning, will result in conservation, keeping the public well-informed, and fewer challenges. All citizen voices must be involved providing adequate opportunities for participation and heard and used in decision making. should also reduce lawsuit Maintain and support the updated manual (MS-1780, Where local governments do not have expertise in 2016) and handbook (H-1780-1) on engaging tribal planning or NEPA, provide more robust support governments. and liaisons to assist in engagement. Ensure that processes are open and transparent and Cutting corners on key aspects of NEPA such as that public participation opportunities are provided relying on quality data, considering a reasonable and input is addressed to reduce conflicts that often range of alternatives and responding to substantive lead to legal challenges. comments are the biggest risks for drawing legal challenges and delays from those challenges being successful. Rely on accurate, up-to-date science. NEPA requires a consistent and thorough analysis of all projects. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. The purpose of NEPA Is to ensure that agency decisions are informed as to the environmental consequences of decisions and made with the benefit of public input. These should remain the guiding principles for NEPA processes. BLM should maintain sufficient resources to conduct compliant NEPA analysis. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. By being transparent, and by listening to and documenting suggestions for compromise solutions - or even redesigning the proposal -- BEFORE someone is upset enough to sue. Spell out fine schedules for extraction violations. Make any extractors enter into legally binding contracts. Just like if a private citizen breaks any other law. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Adhering to science-based decisions (not Greater collaboration and sharing of ideas, while Writing legislation in such a manner that precludes participate, and the BLM should make special efforts "alternative 'facts'"), considering ecological as well as more time-consuming in the beginning, will result in judicial challenge is truly heinous, is the mark of to reach areas that lack access to electronic economic values, truly balancing responsible fewer challenges in the long run and should help small-minded people who are afraid and cannot communications. development with reasonable conservation, keeping avoid delays and lawsuits at the end of the process. really justify what they are doing, and should never the public well-informed, and providing adequate be resorted to in a true and honest society. opportunities for participation should also reduce lawsuits. NO matter what you do, they are going to sue. Stop allowing them to sue on language. make them pay for for analysis to establish scientific facts to prove their argument. until they do keep the decision in tack. right now you close until the facts come out and then ends up taking forever. look at the milkweed in the Imperial Dunes. Science proved the facts and it took years to re-open. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The use of Determinations of NEPA Adequacy The use of categorical exclusions should include (DNA) should be discouraged. Where a categorical thorough consideration of extraordinary exclusion is not appropriate, a focused circumstances that indicate NEPA analysis is environmental assessment that shows the BLM is required. Using categorical exclusions to permit evaluating potential impacts is more consistent with drilling should be subject to heightened scrutiny NEPA. given the potential for impacts. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Any changes to the legal requirements for At the beginning of each section of a document, environmental analysis should have the goal to make explain why this section has been included. For the analysis documents more readily example, EXPLAIN, in plain English, what understandable. That might allow you to fairly 'significance of impact' means, and what the criteria avoid repeating boilerplate language and required are. Don't sprinkle surprise facts -- which might be responses in section after section. The reason for offputting about a project -- throughout a document onerous length and detail in docs is to make sure as though you are hiding them. Make documents everything has been disclosed so people will searchable. Use easily understandable graphics, and understand the effects of a project. There are not just tables. Use aerial photos, with orienting better ways to foster that understanding. landmarks labeled, as the bases for maps. Use funds to regulate extractors with personnel on the ground who can preform inspections and force the extractor to install monitoring equipment that has a log. Use technology. These are multi-million dollar wells, they can afford some remote monitoring equipment. Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Do more CE NEPA Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. If the BLM adequately addresses citizen concerns, the risk for litigation would go down drastically. Demonstrate to the public that the agency truly does its due diligence. Be more responsive to legitimate citizen concerns. Do what makes the community happy. Make certain that any action really does review all potential alternatives, placing citizen concerns(i.e. those citizens that actually live and work within areas affected by any given action)at the top of the list of priorities, rather than as an begrudged afterthought. Do not streamline the process too much Actively invite---and ease the process for---states Tribal nations need special attention, since Base all analyses SOLELY on current, peer-reviewed Make habitat conservation, not commercial Aggressively inform the public at all stages. and conservation organizations to share wildlife electronic communication may be limited in remote science. interests, the clear priority. management data with BLM, and vice versa. areas. Important areas include wildlife migration corridors, habitat data, and population status of keystone species. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other should also reduce lawsuits. backcountry recreation enthusiasts. Genuinely invite participation and collaboration by the public and conservation organizations, and genuinely prioritize that input. Be deliberative rather than hasty. Base the analysis on current, peer-reviewed science. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. hire people who know the law. it would be nice to have courts available at any time but it is not realistic. hire judges,appoint judges,lawyers to Tribal governments should be encouraged to litigate Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. you have to know your area which means "hands on"analysis. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. other habitat data, and other scientific information that is important to hunters, anglers, and other Adhering to science-based decisions, considering backcountry recreation enthusiasts. ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments MUST participate, and the BLM Greater collaboration and sharing of ideas, while Adhering to SCIENCE-based decisions,--NOT should make special efforts to reach areas that lack more time-consuming in the beginning, will result in CORPORATE GREED-- considering ecological as access to electronic communications. fewer challenges in the long run and should help well as economic values, truly BALANCING avoid delays and lawsuits at the end of the process. responsible development with CRITICAL conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. BLM owes the mandatory duties in Section BLM owes the mandatory duties in Section 202(c)(9) of FLPMA to state, local and tribal 202(c)(9) of FLPMA to state, local and tribal governments. The state, local and tribal governments, but not to other non-governmental governments need BLM to establish a clear process stakeholders. This distinction should be clarified in for how those units of government can learn of and BLM policy and guidance. exercise their rights under Section 202(c)(9). Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and PUBLIC OPINION AND INPUT. If the science and/or public opinion point to the need for an environmental impact statement, DO NOT SKIP THIS STEP Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans.  The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while Tribal governments should be encouraged to more time-consuming in the beginning, will result in Adhering to science-based decisions, considering participate, and the BLM should make special efforts fewer challenges in the long run and should help ecological as well as economic values, truly balancing to reach areas that lack access to electronic avoid delays and lawsuits at the end of the process. responsible development with reasonable communications. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Follow the science. Improve inclusion. Ensure that all legally required policies, procedures and regulations were followed at each step in the planning and review process. Listen to all stakeholders and give careful consideration to all substantive comments. Give primacy to the intent of enabling legislation of specific monuments or NCAs, where applicable, in considering the priorities among alternative management strategies. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Involvement in scoping by groups who are prone to litigate. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. Do your homework! BLM should consider the number, scope and severity of potential impacts to water and air quality, to landscape integrity and resilience, and to wildlife habitat and breeding success to determine the appropriate level of NEPA analysis. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Use unbiased scientific data to assess the impacts of the project. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Case law has upheld the intent of Federal Land Similarly, the Mining and Minerals Policy Act of 1970 We support legislation to establish a procedure for Local BLM offices should have the ability and the See responses to A. above. Policy and Management Act of 1976 (FLPMA) as (MMPA) encourages development of domestic resolving claims to certain rights-of-way on public authority to make decisions on historical rights-of- allowing for more than one use on individual acres, natural resources.The Act states that "it is the lands. S. 468 was introduced in February 2017 and ways. If there is a dispute between the local and BLM should reaffirm this principle in policy continuing policy of the Federal Government in the assigned to the Senate Committee on Energy and government and the local BLM office, the matter and management handbooks. FLPMA established the national interest to foster and encourage private Natural Resources. The purpose of this Act is to could be elevated to the state BLM director. If there statutory guidelines for BLM's management of enterprise in...the orderly and economic achieve judicial and administrative efficiency for and are no agreements, the national BLM Director shall federal lands. Under this Act, Congress specified development of domestic mineral resources, to reduce the costs typically associated with, have the final authority to adjudicate the matter. that the lands are to be managed "on the basis of reserves, and reclamation of metals and minerals," resolving right-of-way claims under R.S. 2477. Most multiple use and sustained yield..." The law further and it is therefore "the responsibility of the rural local governments lack the resources to file a states that BLM lands are to be "managed in a Secretary of the Interior to carry out this policy quiet title suit in federal court; the current policy is manner which recognizes the Nation's need for when exercising his authority under such programs based on case law. Prior to litigation, local domestic sources of minerals, food, timber, and as may be authorized by law other than this Act." governments could work collaboratively with local fiber from the public lands..." BLM offices to present historical data to keep roads open without a federal court order. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other back should also reduce lawsuits. country recreation enthusiasts. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Consider how best to support state and local priorities across jurisdictions, such as managing wildlife migration corridors, backcountry recreation, cultural and historic resources and wildlands. By ensuring that processes are open and transparent and that public participation opportunities are provided and input is addressed to reduce conflicts that often lead to legal challenges. By using accurate, up-to-date science. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The purpose of NEPA Is to ensure that agency decisions are informed as to the environmental consequences of decisions and made with the benefit of public input. These should remain the guiding principles for NEPA processes. BLM can define the right amount of analysis to match the scope of decision-making, without setting specific limits on pages or range of analyses. This scope and scale may be defined geographically as more than one field office, more than one state, or a smaller portion of a field office. This scale may also be defined by the breadth of issues to be addressed. Programmatic NEPA and the flexibility for defining planning areas in FLPMA and BLM guidance support this approach. Research relevant tribal treaties and cultural/religious significance of lands involved. Desecration of burial grounds or other sacred sites should automatically cause serious delay, if not automatic rejection of any proposed project, regardless of economic potential. We would not tear down the Lincoln Memorial to get a finite amount of copper or gold, or turn Arlington Cemetery into an industrial park. The same standards of respect should apply to other holy places. Make sure all parties are included from the beginning, with their ideas fully represented and voices heard, with appropriate documentation of that participation. Make sure the scientific data are irreproachable, upto-date, and not based on ridiculous ideas of pseudo science, such as the current administration has been perpetuating, such as climate-change denial. I'm not a lawyer - no suggestions here. Tribal governments should be consulted, and the BLM should make special efforts to reach areas that lack access to electronic communications. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Please give more time for this public comment period. The 21 day period provided is insufficient Tribal governments should be encouraged to for the public to be able to adequately comment. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Consider the biological as well as geological scope Be prepared to address domino effects, whereby of potential effects: is it potentially harmful to huge one change sets off adverse results nearby, with a areas because of the freshwater aquifers involved? chain of negative impacts in an area larger than Which areas might have limited regional impact originally considered within the scope of a project. because of drainage patterns or lack of precipitation? Clear definitions of Categorical Exclusions National Park Service has good examples. Use EAs for most projects. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do NOT encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do NOT skip that step. Please give more time for this public comment period. The 2 1 day period provided is insufficient for the public to be able to adequately comment. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Develop regional data bases of information from trusted sources and then allow those secondary sources to be used in future analysis. Once an air quality report is done for a region for example there is no need for the same study to be completed 1 year later unless conditions have changed dramtically. Realize a one size solution doesn't fit all. Develop streamlined NEPA for low impact projects and allow local planning documents to suffice when reasonable. Flexibility is the key. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other should also reduce lawsuits. backcountry recreation enthusiasts. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Provide generous public hearing opportunities and act in the public interest. Allow for collaboration among stakeholders to make documents that address concerns of stakeholders. Share progress on the progress of the planning with Base plans upon scientifically defensible tenets. stakeholders, including public to find out problem areas. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Balance ecological and economic concerns. Adhere to the legal process without shortcuts. Plans should be scientifically based. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Include all groups from the beginning when an action is proposed to get everyone's input. Not everyone will get what they want, but everyone should have a voice. Native Americans have too often been excluded from decisions that impact tribal lands. Unfortunately, many of these people still do not have the access to electronic equipment that the rest of us take for granted. These people must be included in the process so they have a say in decisions that affect their tribal lands and heritage. Hold meetings before the process starts to hear Work across boundaries so different agencies and Do not take shortcuts. if an environmental impact Development and conservation both have to be legitimate objections that could be headed off early. demographics impacted know what is happening study is indicated, do it first. In the long run it saves taken into account. Economic impact has to be before it starts.I live near the Des Plaines River. All time and makes for a better relationship. All you taken into account. the towns along the river were taking their own have to do is look at the Dakota Access Pipeline steps to mitigate flood impact. Finally they started debacle to see how important it is to do studies working together and have set up flood controls first. including watersheds, flood walls, raising road beds, etc., that are finally having a positive effect along the river. The solution took years of planning. it took time to purchase property, get permits, etc., funding. before the plan could be put into action. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic responsible development with reasonable fewer challenges in the long run and should help communications. conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Work across boundaries so different agencies and demographics impacted know what is happening before it starts and are given a chance to work together for a better solution.I live near the Des Plaines River. All the towns along the river were taking their own steps to mitigate flood impact. Finally they started working together and have set up flood controls including watersheds, flood walls,removing dams, raising road beds, etc., that are finally having a positive effect along the river. The solution took years of planning. it took time to purchase property, get permits, etc., funding. before th e plan could be put into action Do not encourage so many shortcuts that a plan Let BLM managers broaden planning to the district is vulnerable to legal challenge later in the process. or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Tribal governments should be encouraged to Collaboration should begin early, before scoping Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts (the process by which agencies solicit input on the more time-consuming in the beginning, will result in Adhering to science-based decisions, considering to reach areas that lack access to electronic issues to be addressed and how they will be fewer challenges in the long run and should help ecological as well as economic values, truly balancing communications. evaluated), and allow everyone--ranchers; miners; avoid delays and lawsuits at the end of the process. responsible development with reasonable energy developers; recreation groups; other federal, conservation, keeping the public well-informed, and state and local agencies; and members of the providing adequate opportunities for participation public--to tell the BLM their wishes and concerns should also reduce lawsuits. about the planning area, and share any data they have about the area. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Have a detailed monitoring process for any project that you approve, let stake holders know how to make complaints and actually follow-up on the complaints. First and foremost adhere to science based decisions. Do not ignore science as many in the current administration want to do. Starting with the first scoping meeting, take Do not ignore tribal treaty rights as has been done Do not try to cut corners. If a full EIS is needed, do Do not try to take short cuts. Do your analysis at participants concerns seriously and build them into far too often in the past with disastrous results. one. Always err in the direction of caution and do the level that it needs to be done. If a full EIS is the analysis. Do not try to minimize risks. Where an analysis that is detailed enough that it doesn't needed, do one. they exist they need to be spelled out in detail. need to be challenged. Recognize that some There need to be detailed, enforceable mitigations proposed projects may be so dangerous that the and all stake holders need to be assured that there best alternative is the no project alternative. When will be monitoring to make sure that mitigations stakeholders lives, health, property or way of life is actually occur. likely to be destroyed by a project they will sue and they have every right to do so. Do not ignore stakeholder concerns. Begin with as broad a scoping meeting or meetings as possible. Have greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Take into account ALL aspects of what you are trying to do affects EVERYONE AND EVERY LIVING CREATURE AND NATURE. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Take the time to study all of the impacts of what you want to do, make sure everyone is aware of what you want to do and can voice concerns Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Have clearly written laws and agreements that reduce the loopholes for individuals wanting to work with the BLM. Lawsuits are always going to happen, but taking away ambiguity in rules and regulations makes the job simpler. BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other back should also reduce lawsuits. country recreation enthusiasts. See Paragraph A The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. See paragraph A Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. FLPMA Section 202(c)(9) states, "...the Secretary Non-local public are typically unfamiliar with local Consistently and correctly uphold the laws, policies, Provide the public, cooperating agencies, and Ensure a full administrative record is kept for all shall...coordinate the land use inventory, planning, resource conditions and the values of the non-local guidance, etc. applicable to each project or planning State/local governments meaningful and appropriate decisions with input that was received. and management activities...with the land use public may not be consistent with balanced land type. involvement in all planning processes. planning and management programs.considering management. In seeking to better understand public the policies of approved State and tribal land values, the BLM should prioritize the public values of resource management programs." It is clear local people who live near a planning area, and Congress intended that BLM consider not only the depend on the multiple use and sustained yield of plans of state, local, and tribal governments but also the area's natural resources. their programs and policies. Proposed regulations should be consistent with FLPMA Nothing should elevate the status or influence of non-governmental organizations or the general public above that of an elected official or cooperating agency. Coordination should be happening outside of the NEPA and planning process. Dedicate staff to develop and provide technical assistance to enhance communications across local, tribal, state and federal partners. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. BLM should always be looking for opportunities to share ideas and collaborate across its own field office boundaries and with other landowners, including state agencies, tribes, other federal agencies and private landowners Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering Consistent with the Federal Lands Policy and participate, and BLM should make special efforts to more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing Management Act Section 202(c)(3), give priority to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable the identification and protection of areas of critical communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well informed, environmental concern. providing adequate opportunities for participation should also reduce law suits. Consider whether the pre-decisional and appeal process used by the USFS is more efficient than BLM's process. Collaboration will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Balancing responsible development with reasonable conservation and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Avoid unnecessary verbosity. Review and possibly remove recently promulgated Analyze alternatives that are reasonable and address Internal Memorandums (IM) that increase the time the issue at hand to avoid unnecessary time and and complexity of certain NEPA processes. (i.e. IM costs. 2017-36 Considering Backcountry Conservation Management in Land Use Planning Efforts and PIM 2017-003 The Council on Environmental Quality Guidance on Consideration of Greenhouse Gas Emissions and the Effects of Climate Change in National Environmental Policy Act Reviews) Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy and public opinion. If the science and or public opinion point to the need for an EIS, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Keep true to the agencies mission statement and respect all opinions. Be transparent with public comment, scientific reports from pier reviewed sources, stakeholder meetings and keep politics out of it. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. It is not the BLM's place to change environmental law or work to shortcut results. Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to As an attorney, I feel that greater collaboration and Adhering to science-based decisions, considering participate, and the BLM should make special efforts sharing of ideas, while more time-consuming in the ecological as well as economic values, truly balancing to reach areas that lack access to electronic beginning, will result in fewer challenges in the long responsible development with reasonable communications. run and should help avoid delays and lawsuits at the conservation, keeping the public well-informed, and end of the process. providing adequate opportunities for participation should also reduce lawsuits. Unfortunately, BLM has tried to "skimp" in the past Base plans on the latest information, science, policy, and has ended up being sued. Do not encourage so and public opinion. If the science and/or public many shortcuts that a plan is vulnerable to legal opinion point to the need for an environmental challenge later in the process. impact statement, do not skip that step. Also, don't try to claim there are not cumulative impacts when there obviously are. The BLM needs to work more with the public to resolve concerns that arise regarding various projects. The public often seems to feel as though their comments are disregarded, which often results in litigation later on. When people see that substantive changes occur to a proposed project as a result of public comment, then litigation is less likely. Here in Nevada the changes to the Bald Mountain mine expansion plan as a result of public comment is a good example. The alternatives developed as a result of concerns raised by the public around how mule deer would be affected by the mine expansion sufficiently addressed these concerns so that l __ ._? ? _ .. .................. i ? ii_ _ Greater collaboration of ideas, and adhering to science based decisions. Keep the public well informed throughout the planning process. Do not streamline or 'push through' permits for extractive uses. They must go through a legitimate process or they will always be challenged in courts. Require new NEPA process for projects that are 're Do not encroach on tribal lands, designated or starting' after a period of inactive years. Relying on known to be valued. Even if BLM technically has the old and outdated NEPA will result in legal right, this will always result in protracted and bitter challenges. legal action, and bad PR. Strong reliance on science and environmental protection. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. By law the EIS is intended to take a "hard look" at the impacts of a project, thus the extent of the analysis should roughly scale with the extent of the project. Predetermined scaling of the analysis seems contrary to the "hard look" mandate of NEPA. Rather the agency should be prepared to expand the analysis and possibly collect any additional data as necessary to fulfill that mandate. BLM should not be closed off to expanding an EIS if a new impact of the project arises through the NEPA process Base plans on the latest scientific information, and public opinion. If a 'new use' is only new in that it is commercial, but the same use is established by private users in the area, scale down the NEPA. Look at the total scope of the action being considered and include it in public news releases. If a use has been shown historically to have unanticipated consequences (i.e. drinking water pollution on Navajo Reservation from uranium extraction) expand the NEPA to account for long term, unanticipated consequences and institute periodic reviews. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing the agency and vice versa. This would include the to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable identification of wildlife migration corridors and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other habitat data, and other scientific information providing adequate opportunities for participation that is important to hunters, anglers, and other should also reduce lawsuits. backcountry recreation enthusiasts. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states and regions to share data--particularly wildlife management data--with the agency and vice versa. Action should come from a broad-based decision making process, not silo management. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering Consistency in planning the application of decisions participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing will limit the chances of special-interest trolls to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable manipulating the system to their own ends and at communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and taxpayer cost. providing adequate opportunities for participation should also reduce lawsuits. Annual review of what generates opposition so that Do not prioritize short-term profit/savings for ANY Do not encourage shortcuts that will make plans better care is taken in the initial stages will not only entity over long-term goals or doing what is right. vulnerable to legal challenges later in the process. reduce problems but also, if they feel they are really being heard, give satisfaction to more people ELM needs to acknowledge that working with so Incorporate ACHP's Recommendations for ELM can reduce litigation by covering all the bases, Etter decisions come from better coordination. many stakeholders takes time and that it will allow a Improving Tribal-Federal Consultation (Sept. 14, crossing all t's, etc. The agency should be able to There are many advantages to doing both NEPA reasonable amount of time for the process. 2015) into BLM's NEPA planning. Implement the defend all its decisions, and should not make final and Section 106 processes early in the planning recommendations in the ACHP's report Improving decisions until BLM has all the relevant information. process. Examples from BLM include the Solar Tribal Consultation In Infrastructure Projects (May Create a checklist so you complete Issues A-D Energy EIS and Programmatic Agreement (PA), the 24, 2017) and in the DOI, DOJ, and ACOE report above prior to making decisions. West Mojave Travel EIS and PA, and the Desert called Improving Tribal Consultation and Tribal Renewable Energy Conservation Plan EIS and PA. Involvement in Federal Infrastructure Decisions (Jan. 18, 2017) to improve overall compliance with federal requirements and tribal consultation. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Etter coordination with other compliance processes would increase efficiency and reduce duplication of efforts. Cbnsider expanding the list of categorical exclusions to include actions that usually don't have any impact on cultural resources or effects to historic properties. This expanded list must be compiled in consultation with SHPOs, Indian tribes, and other stakeholders. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Let BLM managers broaden planning to the district Base plans on the latest information, science, policy, or multifield office level as needed to better address and public opinion. If the science and/or public cross-boundary issues and simplify the number and opinion point to the need for an environmental complexity of resource management plans. impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Collaboration should begin early, before scoping Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering (the process by which agencies solicit input on the more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing issues to be addressed and how they will be fewer challenges in the long run and should help responsible development with reasonable evaluated), and allow everyone--ranchers; miners; avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. The BLM should always be looking for opportunities The BLM should make it easier for states to share to share ideas and collaborate across its own field data--particularly wildlife management data--with office boundaries and with other public landowners, the agency and vice versa. This would include the such as state agencies, tribes, and other federal identification of wildlife migration corridors and agencies, as well as private landowners. other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Giving everyone the same goal allows all Adhering to science-based decisions, considering stakeholders to focus on achieving a solution ecological as well as economic values, truly balancing together, as a group, which builds trust and respect. responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation Make it easy for stakeholders, especially states, to be Special and early outreach (in the appropriate should also reduce lawsuits. It's all about collaboration and sharing ideas and Need to be science-based decisions, based upon able to share data and experiences, including venues) to Tribal governments is important (e-mail information. Time-consuming, but necessary for local conditions and balancing development with relating to wildlife migration and the importance of and the Internet are not always going to be the best achieving the best results. conservation. migration corridors on public and private lands. sources of outreach or information). Keep the public well-informed with adequate opportunities for participation in the process every step of the way. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Don't allow shortcuts - ever. Do the full scale assessments for all projects and management assessments to ensure fact-based planning. Be completely transparent in all analytical efforts so there are no surprises. Make sure the process and the resulting plans are solid and will withstand possible legal challenges. Balance public participation and input with latest "on-site" information, science, and best policy practices. consult everyone prior to filing anything The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. By doing the right thing for the land we live in and the flora and fauna the exist on it. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. I don't know Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. By actually considering the analysis, rather than blindly doing what only a few bad apples at the top want to do to our mother earth. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share Tribal governments should be encouraged to Transparency of intentions for BLM planning, Adhering to science-based decisions, considering data--particularly wildlife management data--with participate, and the BLM should make special efforts greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing the agency and vice versa. All of this information to reach areas that lack access to electronic more time-consuming in the beginning, will result in responsible development with reasonable should be made immediately available to the public communications. fewer challenges in the long run and should help conservation, keeping the public well-informed, and at large. This would include the identification of avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation wildlife migration corridors and other habitat data, should also reduce lawsuits. and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhere to science-based decisions, consider Collaboration and sharing of ideas at the front-end ecological as well as economic values, adhere to should result in fewer challenges and delays at the responsible low impact development, provide many end of the planning process. opportunities for stakeholder participation. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Avoid encouraging so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public Doing it right up front saves so much time in the opinion point to the need for an environmental end. impact statement, do not skip that step. Include the triple bottom line analysis for every decision, economic, social and environmental. Ensure there are dedicated staff responsible for safeguards in every planning process. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, BLM managers should broaden planning as needed and public opinion. If the science and/or public to better address cross-boundary issues. opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Collaboration should begin early, before scoping Make it easier for states to share data--particularly Adhering to science-based decisions, considering While more time-consuming in the beginning, (the process by which agencies solicit input on the wildlife management data--with the agency and vice ecological as well as economic values, truly balancing greater collaboration and sharing of ideas, will result issues to be addressed and how they will be versa. This would include the identification of responsible development with reasonable in fewer challenges in the long run and should help evaluated), and allow everyone--ranchers; miners; wildlife migration corridors and other habitat data, conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. energy developers; recreation groups; other federal, and other scientific information that is important to providing adequate opportunities for participation state and local agencies; and members of the hunters, anglers, and other backcountry recreation should also reduce lawsuits. public--to tell the BLM their wishes and concerns enthusiasts. about the planning area, and share any data they have about the area. It is also critically important to encourage Tribal Government input and to ensure an outreach process is in place for areas where electronic communication is limited or nonexistant. Share data Greater collaboration with all parties during the entire process. Adhering to science-based decisions that not only Keep the public well-informed, and providing consider ecological as well as economic values and adequate opportunities for participation should also balancing responsible development with reasonable reduce lawsuits. conservation. Stick to the science and you have irrefutable People don't like to be blind sided. If they have reasons. Opinions can be contested, not facts. more information and made their voices heard along the way, there is less likely to be a lawsuit that unravels your plans at the end. More time should be spent in preliminary outreach to those who might be effected by a project of change. There would be less recrimination and protests would be heard outside a courtroom. Adaptive management decisions based on available science and the results of increased documentation and monitoring will reduce legal challenges. Engage a variety of people whose backgrounds complement BLM personnel Collaboration from the outset Include current research and science in planning Don t come to meetings with the answers already settled on. Collaboration!! The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering Don't do illegal things or try end-run short cuts to participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing avoid appropriate environmental assessment. to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Base plans on the latest information, science, policy, Allow BLM managers broaden planning to the and public opinion. If the science and/or public district or multifield office level as needed to better opinion point to the need for an environmental address cross-boundary issues and simplify the impact statement, do not skip that step. number and complexity of resource management plans. Avoid including shortcuts that a plan is vulnerable to Base plans on the latest information, science, policy, legal challenge later in the process. and public opinion. Where the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Stick to the science Heed public opinion Recognize those factors that will be effected and those that will not and focus on those related to the actions desired. Analyses must be based on scientific interpretation of information acquired from previous documentation and monitoring. Scaling up acquisition of this information will require increased initial effort but will pay off with reduce future efforts. Keep projects simple, well researched, and inclusive Do due diligence regarding the plan especially of contemporary science and other factors that are related to those affected part of the development of the plan Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. I expect you to implement the solutions advocated by the Pew Trusts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share The Tribal governments should be encouraged to BLM should be sure to share any of their ideas data such as the wildlife management data with the reach every possible area to participate, and the with everyone concerned, while it may be more right agency and vice versa. This could include the BLM should make special efforts to reach everyone time-consuming to start with, it will result in fewer identification of wildlife migration corridors and in those areas that lack access to computers or cell challenges in the long run and should help avoid other habitat data. They could also share other phones to keep up by electronic communications. delays and lawsuits at the end of the process. information that is important to hunters, anglers, and other back country recreation enthusiasts. Adhering to the science-based decisions, considering ecological, economic values and balancing responsible development with conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic responsible development with reasonable fewer challenges in the long run and should help communications. conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering Remove political appointees. participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. I expect you to implement fully the solutions advocated by the Pew Trusts. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Don't encourage so many shortcuts as this makes the plan more open to legal challenge later in the process. BLM should base their plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step as it is very important for everyone involed. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Adhering to science-based decisions, considering participate, and the BLM should make special efforts ecological as well as economic values, truly balancing to reach areas that lack access to electronic responsible development with reasonable communications. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Tribal lands are NOT public lands. Base your analysis on current science. Put environmental interests first. be open don't pollute and kill Collaboration should begin early, before scoping Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering The BLM should make it easier for states to share (the process by which agencies solicit input on the participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing data--particularly wildlife management data--with issues to be addressed and how they will be to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable the agency and vice versa. This would include the evaluated), and allow everyone--ranchers; miners; communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and identification of wildlife migration corridors and energy developers; recreation groups; other federal, providing adequate opportunities for participation other habitat data, and other scientific information state and local agencies; and members of the should also reduce lawsuits. that is important to hunters, anglers, and other public--to tell the BLM their wishes and concerns backcountry recreation enthusiasts leading to less about the planning area, and share any data they lawsuits because of shared information will lead to have about the area. less misunderstandings. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Early on suggest that each environmental Early on, include relevant legal feedback from other organization have their lawyer review and comment federal and state organizations in all on legal aspects and then review and reply, maybe correspondence. negotiate Pretty simple: honor tribal treaties and sovereignty. Damned if I know. People and groups that are unhappy will sue. Retain better lawyers. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Make use of research that has already been done on similar projects in similar locations as a starting or reference point. don't use chemicals don't use plastic Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Ask employees to review and comment on actions Include, without penalties, employees who may not being considered. agee with all actions. No shortcuts. Use science. Listen to the public. Really listen. No help here. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Tribal governments should be encouraged to The BLM should make it easier for states to share participate, and the BLM should make special efforts data--particularly wildlife management data--with to reach areas that lack access to electronic the agency and vice versa. This would include the communications. identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. ribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. If organizations of all sides are brought in during the it all goes to Listening beginning they can own it too . This could eliminate certain litigation Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district Base plans on the latest information, science, policy, or multifield office level as needed to better address and public opinion. If the science and/or public cross-boundary issues and simplify the number and opinion point to the need for an environmental complexity of resource management plans. impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. this is a false equivalency question, everything is interconnected Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Being more inclusive in planning process will yield more acceptable outcomes, fewer disgruntled stakeholders, and fewer legal challenges. Collaborative solutions that are built upon a strong scientific framework will be more defensible in court. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Know the law! Work for cooperation from all concerned. Avoid perception of favoritism. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Base decisions on objective science Bring all stakeholders to the table prior to taking any action Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do it right the first time. Do not shortcut NEPA Allow BLM offices to work together across district analysis and utilize strong science, as this will yield a boundaries to reduce duplication of effort. result that will be vulnerable to challenge and result in repeated NEPA analysis and associated costs. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science points to the need for an environmental impact statement, do not skip that step. Do your homework. Bring in efficiency personnel. Bring in locals familiar with details involved. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Strive to better address cross-boundary issues and simplify the number and complexity of resource management plans Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do the Proper Environmental Impact & Land Use studies thoroughly AND correctly from the get go, allowing for public input on any proposals being processed. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Increased public input and transparency up front. By Making data, planning criteria, and resource engaging the public early and often, the BLM will information publicly available and easy to access have a more user friendly planning process that from the start will lead to greater transparency, better integrates the needs of stakeholders. increased trust and better public engagement. I don't think this is possible in our litigious society. Who ever doesn't get what they want will attempt to achieve it in the courts. Possibly a loser pays fees legislation would help. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. By honestly & ethically approaching it from the POV "What is BEST for the taxpayers (think shareholders or trustees here) who own this land?" Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Invest in non-linear systems analysis projects w/ local universities. Always remember who owns the land and what is in their best interest "Right Size" implies that something (profit for example) could justify reducing the import of environmental concerns. I repeat, the land is owned by ALL citizens. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share Tribal governments should be encouraged to Greater collaboration and sharing of ideas in the data--particularly wildlife management data--with participate and the BLM should make special efforts beginning will result in fewer challenges, delays and the agency and vice versa, including identification of to reach areas that lack access to electronic lawsuits in the long run. wildlife migration corridors and other habitat data, communications. and other scientific information important to hunters, anglers, and other backcountry recreation enthusiasts. Adhering to science-based decisions, and considering ecological as well as economic values should reduce lawsuits. Truly balancing responsible development with reasonable conservation should reduce lawsuits. Keeping the public well-informed and allowing participation should also reduce lawsuits. Do not encourage shortcuts which make a plan vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip it. Complete an environmental impact statement. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should always be looking for opportunities Collaboration should begin early, before scoping Adhering to science-based decisions, considering to share ideas and collaborate across its own field (the process by which agencies solicit input on the ecological as well as economic values, truly balancing office boundaries and with other public landowners, issues to be addressed and how they will be responsible development with reasonable such as state agencies, tribes, and other federal evaluated), and allow everyone--ranchers; miners; conservation, keeping the public well-informed, and agencies, as well as private landowners. energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. ase plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. BLM's credibility with its neighbors is harmed when planning and NEPA deadlines are routinely missed. For example, BLM's Washington DC office (WO) is slow and unpredictable in how it processes required Federal Register notices relating to important planning and EIS efforts. Local BLM project leads are often in the dark about how to navigate this WO maze. Top BLM management should ensure that Federal Register notices are handled by the WO in a timely, clearly traceable, and effective manner. BLM should stop attempting to downplay, deflect, BLM should not make NEPA promises or create BLM should more proactively encourage minimize, or ignore strong public concerns during performance expectations relating to monitoring collaboration among different stakeholders and planning and NEPA processes. BLM managers tend and mitigation that it likely cannot keep. For interest groups, including sportsmen and to want to avoid controversy at all costs, always put example, BLM may say in a grazing allotment permit environmental groups. The prospects for BLM in the most positive light, and conceal renewal EA that it will monitor utilization each year compromise and reduced conflicts increase when embarrassing or conflicting information. These and identified key areas every three years to ensure there are face-to-face meetings and people with tendencies often backfire and contribute to the that permit conditions would be met and that the different backgrounds and viewpoints have an frequently successful litigation against BLM. This is standards for rangeland health would be followed. opportunity to build positive relationships. especially true with grazing related NEPA analyses. In stark contrast, the actual records may show that, Sometimes collaboration works and sometimes it in the preceding ten-year period for that allotment, does not in solving controversies. Despite this these one and three year promises were often not uncertainty, BLM should nevertheless encourage met due to range staff vacancies, excessive collaborative efforts wherever possible. Nothing workload, or other reasons. BLM should be honest ventured, nothing gained. about its workload limitations. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. I believe that this category largely overlaps "A. Focused Analysis" above, and so my previous suggestions in this category stand, including with respect to adding more CXs and using more programmatic EAs with tiered supplemental EAs and DNAs. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Using good science instead of resource to be had Good science in Environmental Impact Study Including all concerns in final outcome Do it right the first time. Take your time and cut no corners from the beginning. It takes longer but insures better results. There might not be a streamline action where sensitive areas are concerned Protecting our natural lands is your primary occupation. If social media and 'normal' forms of media are not accessible to certain parties, other means of communication must be found, e.g. one-on-one meetings and the postal system ('snail mail'). No one should be excluded from the process due to political affiliation, religion or sexual orientation. The BLM must do its homework process to starting Keeping people well informed from the start should Avoid speaking down to people to allow them to Never assume that there is only one solution or any project (i.e. the planning phase) to avoid missing avoid any surprises along the way. better understand the information and data being answer to a project. Keep open minded. key stakeholders. presented. Avoid jargon. And keep the discussions as science-based, evidence-based as possible. Avoid over-simplification and too short an analysis of a project otherwise the review will be pointless and cause unnecessary delays as people ask and require further information and data. I.Cbordinate, collaborate and integrate across sectors, departments, and divisions to better understand and streamline the process. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Respect the fact that most Americans want conservation and renewable land-use applied to public land management. Respect existing protections, and avoid allowing Cease political attempts to exclude conservation- commercial and industrial activity from damaging minded people and interests from the courts. wilderness and recreational areas, and other lands already assessed as being of unique or critical value. Make legal decisions and create rules and processes that protect our valuable resources. Commit to thorough planning processes. If BLM stops unnecessary extractive activities there will be no need for legal representation. Consider the performance standard history of the company. Companies with high proven standards should undergo a less vigorous NEPA review. Each of your specialists ares super busy with their The BLM has the flexibility allowed it in the law Yes the BLM is required to complete the NEPA single resource that they are responsible for and at while still being able to meet the intent of the law. review, however do not have to include the time it seems that these specialist will create more They need to exercise their flexibility at times such unnecessary items. We have experienced the work than necessary in order to justify the as minor changes to a plan of operation - we are specialist analyzing species that do not live in the importance of their resource. an example of this is having to do a complete NEPA review on a 3.8 acre habitat that we were proposing. wildlife and archaeology that we have experienced. modification sandwiched between two approved mines. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. If BLM stops extraction there will be no need for NEPA analysis. Consider different resources and plans based on individual characteristics and input from proponents. Tier the NEPA review to past EA's since most past plans are very similar to current Plans of Operation. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process.  The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Support the sharing with states of wildlife migration Important: Take care to communicate with tribal Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering and other data for all stakeholders. governments, especially those areas without internet more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing communications capabilities. fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation Keeping plan development well aligned with should also reduce lawsuits. scientific data, showing all entities involved or concerned with the project that ecological and conservation values are placed before economics, and ensuring that no affiliated business, corporation, private party, or foreign interest stands to profit from the ultimate planning outcome. Building collaboration takes time - so give it plenty of time and reach out to unlikely voices as well as state, county and tribal governments. Create easy ways to share data especially about wildlife Publish when RAC's are meeting to get turnout Inform (publish) the public (Social media, newspapers, etc.,) as to whom the representatives are on each RAC, so that constituents can reach them If you invest in creating equal collaborations which Adhere to science-based decisions Balance responsible development with reasonable requires an initial input of time, you will have less conservation litigation. Strong, trusting relationships will pay you in volumes. This may never happen--but open processes can More publicity as to what, where and why decisions lead to fewer lawsuits, so eliminating RAC's won't are made. help this. consider ecological as well as economic values Try to minimize negative effects on "victims" Value scientific input A continuation of science based decisions that have been vetted by representatives from the various involved parties. The more collaboration the is and the more open, transparent sharing of decisions would garner more trust and acceptance of decisions. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Time is NOT of the essence here. ALL information submitted needs to be seriously studied, regardless of the source of submittal. The environmental impact MUST be first priority, particularly if it involves destruction of land, contamination of water or air quality, displacement and loss of flora and fauna. Once gone, these are gone forever...irreplaceable.. altering and playing a large part in the possible loss all life upon earth. Refrain from shortcuts that can leave plans open to Base your plans on up-to-date scientific evidence future litigation balanced with public opinion The greater the risk to the environment or the area that's affected needs more scrutiny. Foresee potential problems Weigh possible negative effects on people. Use the data that is found. Listen to your public and shareholders - needs of the people as well as regulations for various public entities and state or national government involved in the project. There must always be a balance in workshop The BLM must always emphasize to local interests The BLM needs more help and review from their While the BLM conducts NEPA training for most The review process at state and WO levels must be Better resource management plans and allocations Thorough analysis of sensitive resources, such as attendees that represent the wide spectrum of that public lands have stakeholders throughout the DOI Solicitors, and there needs to be more staff (though not enough, see previous comments), consistent and streamlined. Very often a document should prevent consideration of actions that would T&E species, candidate species, cultural resources, interests and users of public lands, and an honest nation, and that no local or special interest has Solicitors, or similar legal assistance, during the the emphasis is usually on EA level documents. is held up for too long because of lack of guidance require extensive analysis not covered in the RMP etc., should not be streamlined, regardless of the effort by BLM to clearly acknowledge conflicting priority over those of the wider public. planning process. Typically RMP's and EIS's are only There is very little training for developing EIS and and little emphasis on timing to reviewers. I have EIS. scale of the action. Better development of the RMP philosophies, desires, etc., and to explain to all reviewed at the end of the process, and solicitor's RMP level documents. Though local staff may seen documents go through reviews at the state and EIS should address these issues at the plan level. participants that BLM is guided by law and policy, comments often find major problems that can participate in developing specific sections of NEPA office, be cleared, and then go to the WO where Further analysis would then be reduced or not by which group has the most political clout or require major re-writes, analysis, or other delays. documents, often there is no training or guidance the same issue that was OK at the SO is questioned eliminated local support. Solicitors are overwhelmed by the number of NEPA on seeing the bigger picture of the entire document by staff at the WO, sent back to the SO, and then documents, and cannot keep up with the demand. or process. This can result in conflicting actions and reviewed by a different staffer (maybe because of a Another level of legal review should be required inconsistencies between resources and programs, staff transfer, reassignment, etc.), and sent back to throughout the process, and perhaps a new leading to vulnerable documents. the field office, then repeated endlessly. There must category of staff can be developed to help local be a better emphasis on timeliness at the review offices and NEPA/Planning staff to avoid problems level so there is ample time for legal review. before formal solicitor review Make it easier for states to share data - particularly Maintain and support the updated manual (MS-1780, Increase collaboration and sharing of ideas, while Adhere to up-to-date and accurate science-based Ensure that processes are open and transparent and Do not cut corners on key aspects of NEPA such as Do not encourage so many shortcuts that a plan is Maintain sufficient resources to conduct compliant wildlife management data - with BLM, and vice 2016) and handbook (H-1780-1) on engaging tribal more time-consuming in the beginning, will result in decisions, considering ecological as well as economic that public participation opportunities are provided relying on quality data, considering a reasonable vulnerable to legal challenge later in the process. NEPA analysis. Public comment and response to versa. This would include the identification of governments and encourage tribal governments to fewer challenges in the long run and should help values, truly balancing responsible development with and input is addressed to reduce conflicts that often range of alternatives and responding to substantive Base plans on the latest information, science, policy comments should be the rule not the exception for wildlife migration corridors and other habitat data, participate, and make it easier for smaller tribes avoid delays and lawsuits at the end of the process. reasonable conservation, keeping the public well lead to legal challenges. comments, since this will likely result in legal and public opinion. If the science and or public NEPA processes. This is more consistent with and other scientific information that is important for with few resources to participate. Make special informed, providing adequate opportunities for challenges as well as delays from those challenges opinion point to the need for an EIS, do not skip NEPA's goals and the importance of public input for hunters, anglers and other backcountry recreation. efforts to reach areas that lack access to electronic participation should also reduce lawsuits. being successful. that step. decisions that affect public lands. Consider how best to support state and local communications. priorities that cross jurisdictions, such as managing wildlife migration corridors, backcountry recreation, cultural and historic resources and wildlands. Balancing other uses with energy development is vital for addressing the vitality of affected communities. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Collaboration should begin early, before scoping, and allow everyone--ranchers; miners; energy developers; recreation groups; other federal, state and local agencies; and members of the public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in responsible development with reasonable fewer challenges in the long run and should help conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Where local governments do not have expertise in -Consider how best to support state and local Ensure that all of the mandates of FLPMA and NEPA Ensure there are ongoing, meaningful opportunities Include quality data, consider a reasonable range of planning or NEPA, provide more robust support priorities that cross jurisdictions, such as managing are fully complied with and to actively build trust, for public input into the agency's decisions on the alternatives, and respond to substantive comments. and liaisons to assist in engagement. wildlife migration corridors, backcountry recreation, credibility, and respect with public lands use and management of our public lands. cultural and historic resources and wildlands. stakeholders Propose actions that fall within environmental and safety law and policy. Use clear and straightforward language. Open dialogue/ communication can forestall surprised/ angry responses, with FAIR and EQUAL participation by citizens AND "special interests". The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step.Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. this is a case by case basis depending on the project. Reserve Categorical Exclusions for extreme BLM can define the right amount of analysis to circumstances. match the scope of decision-making. This scope and scale may be defined geographically as more than one field office, more than one state, or a smaller portion of a field office. This scale may also be defined by the breadth of issues to be addressed. Provide an opportunity for interdisciplinary team of Get the issues and potential issues up front right agency professionals, those who would be impacted, away so they don't arise later. and members of the public to give input about the level of analysis. EXPECT THE NEED FOR AN ENVIRONMENTAL ASSESSMENT! If we can't live with [on] this planet, we will NOT live without it... Science must inform all decision-making. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on current information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step.  The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Get all who may be affected by a project involved from the beginning. That means not just industry and ranchers, local citizens, etc -- but also people from far away who may use the land for recreation. Their tourism dollars are good for the local economy. If before making ANY decision, BLM pays close Don't rely just on industry to do comprehensive attention to 1) the concerns of local people whose analyses of things like environmental impact. lives will be directly affected, including safety of water supplies, soil, and air, 2) the well-being of area wildlife, 3) interests of tribal communities whose heritage may include sites on BLM lands, and 4) the interests and concerns of those people and entities that don't have a lot of money, and IF BLM truly treats those needs and interests as having equal value with the interests of industry and ranchers - then maybe you can avoid legal challenges. Don't lie to people. Don't hide information. early collaboration science-based decisions, not just economic ones The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts more time-consuming in the beginning, will result in more time-consuming in the beginning, will result in to reach areas that lack access to electronic fewer challenges in the long run and should help fewer challenges in the long run and should help communications. avoid delays and lawsuits at the end of the process. avoid delays and lawsuits at the end of the process. Recognize that "the environment" isn't just some Everything is connected. All water flows Do not imagine that business-based analysis of place where people hug trees. The environment is downstream. Air moves generally from west to east. anything applies to the natural world. For example, where we live: the air we breathe, the water we Don't pretend that what is done on BLM land has frack-quakes won't stop just because industry drink, the soil that supports our crops and gardens. no effect on communities and people "in the plume" representative are not directly affectedly them and By "we", I mean children, pregnant women, parents, and downstream of that land. No analysis that ignore their effects. non-parents, elders, all races, and people of every ignores the fact that any piece of BLM land is part of socio-economic status. Even "captains of industry" a much larger three-dimensional environment can and political leaders. Those life-essentials need to be ever be a "right-sized" analysis. given priority for protection -- priority over profits. BLM properties should be "cleaner" and environmentally safer than developed communities because they do not belong to only the few. You must mandate an environmental impact analysis and statement Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhere to science-based decisions. Early participation of stakeholders can help avert later feelings of policy imposition and coercion. By increasing participation on the front end, the effect will be to reduce the amount of litigation because those groups that are likely to sue have already been included in the process. This should also improve the planning process by reducing the need for costly and time-consuming supplements that can delay decision-making. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, policy, is vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. To reduce redundancies in environmental reviews BLM should adopt a schedule to update Resource and improve local participation, BLM should engage Management Plans (RMPs) on a rolling basis and to in long range planning at the landscape level, develop mechanisms for consistent monitoring and incorporating public input as early as feasible. amendment of those RMPs. Regular analysis of management strategy and efficacy would make the RMP revision process less onerous, and would allow BLM to incorporate the best available science continuously into its planning process. That analysis would then not have to be repeated constantly at the project level Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Make science based decisions that support biodiversity Collaboration and transparency in the planning process Make decisions science based Keep the public and other federal and state agencies involved throughout the process. Because in many cases BLM land abuts state and federal Parks, Planning should be regional and support wildlife. For example, science may tell us that a particular species travels x miles to find food every day , planning with adjacent public lands to assure that that population can have safe access to its territory. While collaboration is more difficult and time consuming, it will result in a better outcome and more efficient use of agency resources The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Tribal governments should be encouraged to The BLM should make it easier for states to share participate, and the BLM should make special efforts data--particularly wildlife management data--with to reach areas that lack access to electronic the agency and vice versa. This would include the communications. identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. The requirements for NEPA reviews of major 2.ELM should assign a project manager for any 4.Eliidance on the scope of integration of federal actions continue to be abused by opponents NEPA project with the appropriate skills to manage greenhouse gases/climate change evaluations must of multiple use activities on BLM lands. The said project. be established following are options BLM should consider to reduce the possibility of legal challenges: 3.Ehe process of mandating alternatives in the NEPA review creates delays and unnecessary 1 .Established regulation, policy or agency evaluations which adds costs. The scope of requirements to have a set schedule for the NEPA alternatives and its utility to the NEPA process process. This will facilitate timely environmental should be reconsidered. reviews and reduce costs to both the agency and industry. The BLM should establish a requirement to have EIS documents completed within 24 months after initiation of a review. 5.Ehe BLM should also reduce mandatory actions to limit the abuse by advocacy organizations to redefine agency priorities through litigation. The BLM should initiate rulemakings to narrow the scope of NEPA for certain actions. While NEPA defines the basic terms of an analysis, the details of those definitions are framed by regulatory interpretation. By limiting the scope of NEPA reviews, the BLM will limit the scope of litigation in the federal domain. The agency should also establish deadlines for interagency coordination regarding federal permitting. Leasing protests should also be specific to individual parcels and should identify issues with that specific parcel. Currently, BLM spends countless hours responding to protests that only identify general issues. The agency should have the authority to disregard protests that do not identify why an individual parcel should not be leased. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. Greatly improve and speed up the WO handling of Many tribal governments are poor, under staffed, The truth will set you free! BLM often loses BLM's dysfunctional management culture and Fire openly biased, unproductive, and/or field Federal Register notice packages. There may and have very limited travel budgets. If BLM is litigation because it tries to low ball, downplay, or excessive bureaucracy causes vastly more NEPA incompetent managers and employees. High be huge delays and uncertainty related to the serious about genuine tribal involvement, either ignore important information that is relevant to a delays than those caused by litigation. Instead of performers at BLM are rare and punished for their labyrinth in the WO in getting something actually BLMers will need to make more trips to meet tribal NEPA analysis. BLM also loses litigation because it looking at litigants, BLM should look in the mirror hard work and initiative. This is because they set published in the Federal Register. representatives or BLM will need to reimburse tribal makes arbitrary decisions to please powerful to find the cause of most NEPA delays. For the bar high for themselves, and they are then representatives for their actual travel expenses to ranching, mining, or oil interests. BLM would win example, many BLMers likely find it difficult to keep expected to keep to it. Meanwhile, slothful and BLM meetings. more lawsuits if it is honest, does not try to hide or up with their NEPA work when they are faced with incompetent BLMers receive little or no obfuscate data, objectively evaluates feasible many other bureaucratic processes and deadlines. accountability. This is fundamentally unfair and why alternatives in good faith, and makes reasoned Death by a thousand cuts. Take required annual many high performing BLMers leave for better jobs decisions that track with the analysis outcome. trainings, most of which are highly redundant from and work environments. Judges do not substitute their judgment for BLM year to year. Instead, have initial tests on the unless there is evidence of some impropriety. content and if an employee passes they don't need When BLM loses lawsuits it is usually because BLM to take the whole training.. was at fault. Make more CXs available to reduce the need to do Laser focus NEPA analysis on the actual issues or many EAs. resources that are present or may be affected. Put minimal focus on explaining what is not present or would not be affected. Make documents fair and airtight. Consult with stakeholders Give the protection of the environment number one priority, and those wishing to protect the environment will be less apt to make legal challenges. Do what is right, and you won't be sued. Local communities, economies, customs, and culture Coordination and consistency with state, local, and Add more clarity to regulations. Failure to include a are most impacted by changes in federal land tribal plans and policies are paramount to successful reasonable range of alternatives is a common source management. While impacts at the regional or planning efforts and are required by FLPMA. of litigation. What constitutes a `reasonable range' is national scale are important, they must not be the Coordination should be a continual dialogue too subjective and needs more definition. focus of an impacts analysis. Assessing impacts at the between BLM and engaged state, local, and tribal local level is necessary and appropriate and should governments. BLM should take steps to encourage be required. this dialogue with all governmental entities with interests germane to the development of federal land management plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. If a real problem exists, challenges in the courts are Remember, sometimes tiny things are most the best way for that to be handled. Do not make important. this impossible. Input from conservation organizations Administrative special designations created by policy have added complexity to the planning process that inflates analysis requirements. Policy borne designations such as Lands with Wilderness Characteristics and Backcountry Conservation Areas introduce additional layers of bureaucracy to federal lands and complicate the planning process. It is important to keep in mind that an ACEC is the only administrative special designation authorized by FLPMA Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should reach out to stakeholders in their regions annually with a review form that asks how are things going, what can be done better, and then follow-up and respond when comments come in. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. We addressed this issue above when we requested The BLM needs to focus on what are the issues that Engage and listen to the public as often as it takes. Involve affected Applicants in the development of Sit down with the environmental and engineering You can maintain 3rd party communication that applicants are not locked entirely out of the are causing legal challenge in each region and ensure Engage the NGOs early on the process. As an Instruction Memoranda (IM). BLM developed IM staff of an applicant. Identify what impacts are protocol and still ensure that the proper NEPA process. The use of MOUs and rigid third- that those areas are covered in the NEPA industry, we will regularly meet with various WY-2016-018 to require large reclamation bonds expected and focus the analysis on those impacts. information is obtained. The BLM needs to party contractor arrangements on EA projects documents. We are seeing the BLM get focused on environmental groups on bigger projects to collect for existing facilities. This IM stemmed from oil and For example, we recently completed an EA for the recognize that it is possible to have open and results in weaker documents, poor communication, topics that have never been challenged in a court of comments and to try to get the purpose of the gas operators that abandon wells and do not rebuild of an existing facility. We were not allowed transparent communications between the applicant and analysis that is prone to legal challenges and law. For example, applicants in Colorado working project out to the public. Regularly engaging the complete their required reclamation. The BLM to see what resources were going to be and the agency. delays. with the State Office are expected to provide PODs communities that are presenting the challenges may incorporated electric utilities into this requirement. incorporated into the analysis. So we were surprised that are literally hundreds of pages and are being result in a minimum having better transparency. Electric utilities are in the communities for to see that crucial topics for electrical infrastructure told this will protect the BLM from legal challenges. generations. The industry is stable and power lines such as migratory birds, noxious weeds, and soils The legal challenge is usually coming from poor are not abandoned and left on the landscape. were not analyzed. This has become a significant analysis. Another example involved IM CO- 2017-003 which problem as we went to construction and the contained poorly worded fire-related stipulations agencies started making demands for mitigation of being added to transmission line ROW grants. these resources, even though they were not included in the EA analysis. The BLM can foster greater collaboration and The BLM must adhere to science-based decisions, sharing of ideas, while more time-consuming in the considering ecological as well as economic values, beginning, will result in fewer challenges in the long truly balancing responsible development with run and should help avoid delays and lawsuits at the reasonable conservation, keeping the public well- end of the process. informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM must base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering Respect past decisions and protections such as ecological as well as economic values, truly balancing National Monuments responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Asking stakeholders for input in an iterative process will encourage trust. If not already done, work on making it as easy as possible for entities to share data with each other. One example might be setting up a controlledaccess database using an industry-standard software platform, where access could be shared with state, local, and tribal officials so that they could easily upload information. The presence of armed personnel automatically triggers negative reaction to the visual stimulus. Why invite trouble. Courts should narrow scope of litigants to real APPLY DICTIONARY DEFINITION TO "SPECIAL" stakeholders. An example of participation of people and "UNIQUE": There are places that are truly and entities from someplace else having a complete special and unique that rightly belong to all misunderstanding of the real issues at hand was Americans in every state. Western states have Baltimore, MD based PEER protests against last given up a greater share than most states for the year's Vegas to Reno race. common good. There's people from other states that continue asking for us to give up more. Federal or not, what's not special or unique should be managed for the people most affected. It's not America's public land. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. This is probably the key to any improvement discussed above. Frivolous litigation being used as a weapon to change land use by stopping essentially all uses and getting paid for it is incomprehensible. This is sucking the life out of the agency's ability to responsibly manage the resources under their charge and the uses related to the same. No management or "natural regulation" will incur long lasting damage to the social, economic and ecologic sustainability of the resources The BLM manages for society. We must develop legislation that will either limit frivolous litigation, make the litigant pay for their efforts and be civilly liable for costs and damages caused by their actions. Early-stage charrettes with stakeholders will allow for input and decrease tensions later down the road. The BLM should follow the NEPA process as outlined in the law to avoid legal challenges. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. My understanding is that much of the law is based Facilitation collaboration and communication with on what a "reasonable" person think or do under a interested parties early and often also seems likely given set of circumstances. Based on this, grounding to reduce misunderstandings. decisions and plans in science is likely to consistently provide the most defensible position. Recognize only State, County, and Tribal governments as coordinating entities. Remove management of public lands with wilderness Lobby Congress to remove "No-slaughter" characteristics. Stick to management of public lands regarding wild horses and burros. as they are designated. APPLY THE KISS PRINCIPLE TO SCALE BACK NEPA REQUIREMENTS TO FIT THE PROJECT: An example from community planning most people may be familiar. Planning to build a big project like a shopping center requires area planning and extensive studies and engineering to address infrastructure (traffic patterns, storm runoff thru the area, increased run-off from structure roofs, paved areas, etc.). Building a house planning can be done with cookbook formulas. Applying NEPA to small projects is unnecessary and prohibitively expensive. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Protect the environment rather than looking for ways to use it. You could limit this by limiting the issues that are covered in a scoping of a certain action. An action is generally developed to accomplish a specific goal on the landscape and has specific issues that are important to this action and goal. Including the input of different jurisdictions will allow for a clear understanding of the risks of any given action. Scientific uncertainty should warrant a moreinclusive, deliberative and "right-sized" process and outcome. The BLM should follow the NEPA process as outlined in the law; it prescribes appropriate review guidelines. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. One thing to try might be to have managers make a statement of expected scale at the start of a given plan, and to use that statement to determine whether the plan needs to involve a small working group, a district office, a multi-field office, or nationwide BLM. I am not completely familiar with the current process regarding this issue, but it seems that an estimate of scale, performed by knowledgeable BLM managers at the beginning of a plan, would potentially save time and prevent argumentation later Abandon "Landscape" scale analysis. Most affects Reduce time frames for NEPA analysis. Set minimal take place within one-half mile of the surface time frames--complete analysis or remove the disturbance. restriction.  Tribal governments should be encouraged to Collaboration should begin early, before scoping Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts (the process by which agencies solicit input on the more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic issues to be addressed and how they will be fewer challenges in the long run and should help responsible development with reasonable communications. evaluated), and allow everyone--ranchers; miners; avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. BLM Field Offices should be encouraged to maintain The BLM should look for and engage in an interested party call list. This should include opportunities that allow for cross agency work. other agencies, tribal governments, NGO or particularly interested citizens. When new projects emerge, a staff member from the BLM should make phone calls to these partners and inform them on what is going on and see if they have questions. This forms more personal relationships and allows interested parties to learn first hand what is happening. These individuals can also be beneficial for helping spread the word on specific projects that the BLM has going on. In decision making processes, the BLM should be For mining or exploration projects, the BLM should The BLM should invest staff time and energy into clearly considering ecological, social and economic be developing clear guidelines early on for participation with collaborative efforts. Doing so can factors. Do these projects make economic sense, do expectations in best management practices and help to reduce challenges later on in the process by they benefit or at least not cause degradation to the reclamation of the site. This should always include a identifying concerns or problems early on so these natural environment, are they supported locally and 3-5 year monitoring timeline after project can be addressed. Collaborative efforts have been socially? Using best available science to inform completion and before bonds are released. Bonding shown to strengthen projects, making them less decision making and providing opportunities for the should also be adequately secured to include vulnerable to legal challenge. Collaboration should public to engage early on and multiple times unintended impacts on waterways and other be supported and encouraged from the highest throughout a NEPA process should also help later sensitive resources. Bonding should fully cover levels of the BLM so field offices know they have the delays and minimize legal challenge. remediation efforts in the event of site green light to invest in these opportunities. abandonment. A more stream-lined process that is more responsive to the concerns of local governments and agencies and to the public will result in fewer lawsuits challenging BLM's Plan and land exchanges. The New Mexico State Land Office (NMSLO) suggests that BLM local leadership be given more autonomy and decision-making over the Planning and NEPA process, to facilitate faster decisions that better take into consideration local concerns and priorities. In and of itself, this is likely to reduce litigation. Longer comment times for local governments Remember Commissioners represent the whole county Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Encourage BLM staff to work with other agency staff Don't short change the need to do analysis on when needed, especially on the issues that do not projects. Often encouraging "minimum level" stop at jurisdictional boundaries (grazing, wildlife analysis results in stall outs later in the process habitat, migration, etc.) This makes projects much because of legal challenges that come later. We see stronger and scientifically sounder. this all too often with mining projects in particular. The New Mexico State Land Office (NMSLO) suggests to BLM that environmental analysis focus on and address local concerns first, working closely and early on in the process to involve local governments and state agencies. Currently, BLM's analysis of the pending Rio Grande Del NorteSabinoso Wilderness Exchange is held up in review in Washington D.C., after resounding support from both federal and state local agencies and the public. Moving the direction and review of the scope of environmental analysis from local BLM to the centralized federal level reduces the ability of BLM staff to nimbly respond to local concerns, and to efficiently process and complete land exchanges. This answer may not be appreciated. Stop allowing politics to unduly influence resource decisions. Make sure that the decisions themselves are grounded in their analysis. To avoid litigation delays make the process more responsive. How long does it take to receive resolution of an appeal to IBLA? Too Long! If something is taken to the court system, get some resource lawyers engaged to assist the litigation. Other than that, understand the system and don't just sit back and say it is out of BLM hands once it is in the court system. DOI needs to be engaged. Look at the CEQ direction. Consider the direction More categorical exclusions for thorough brevity and do it. Look more closely at reclamation and the end result if the proposal is surface disturbing. Consider the scale of the action and its likely long term influence on the environment. The analysis should reflect the associated scale of activity. Off-site impacts that extend beyond any one community's or county's boundaries must be considered in analysis. Such impacts include, but are not limited to, impacts on air sheds, impacts from methane leakage, or watershed impacts from tracking fluid leakage, blow-outs and defective well casings. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Greater collaboration and sharing of ideas, while Collaboration should begin early, before scoping more time-consuming in the beginning, will result in Adhering to science-based decisions, considering (the process by which agencies solicit input on the fewer challenges in the long run and should help ecological as well as economic values, truly balancing issues to be addressed and how they will be avoid delays and lawsuits at the end of the process. responsible development with reasonable evaluated), and allow everyone--ranchers; miners; conservation, keeping the public well-informed, and energy developers; recreation groups; other federal, providing adequate opportunities for participation state and local agencies; and members of the should also reduce lawsuits. public--to tell the BLM their wishes and concerns about the planning area, and share any data they have about the area. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. BLM must make it easier for states to share data The BLM must make every effort to involve, Just like w/ the topic of transparency, greater Stick withe the science. Science based decisions, especially wildlife management data - and this goes encourage Tribal governments to participate and collaboration and sharing of ideas will result in ecological as well as economic will balance both ways - you share your data and encourage the should make special efforts to reach areas that lack fewer challenges - this may seem time-consuming in responsible development w/ conservation. states to share theirs. You must respect their access to electronic communications. The Tribes the beginning but will pay off in the end. we can position and recognize that we all have the same must be included and outreach is critical. Foster a not continue the us against them paradigm. goals and interests. of special importance is data on we're in this together, we have the same wildlife migration corridors, habitat info and other preservation goals, foster respect for our native scientific data that is important to hunters, anglers peoples. and back country recreation enthusiasts. Build a consensus that everyone can get behind Getting consensus of people who are directly Get more citizens involved in the process instead of doing it your way affected by policy Do a Better Job with Socio-economics REPEAL OR REFORM THE EQUAL ACCESS TO JUSTICE ACT Quit Colluding With Special Interests keeping the public well-informed and providing Establishing a coalition of interested parties who can Short-cuts should be avoided. this will minimize the EIS is crucial - if the latest scientific information, adequate opportunities for participation should help work together to participate in the planning process vulnerability to legal challenges. public opinion point to the need for an EIS do no reduce lawsuits. should result in fewer challenges. skip that step. Don't strongarm people because that leads to confrontation Limit Reviews/Revisions to the Minimum Required by Courts Better Use of County and State Consistency Requirements The environment affects people so right size is where your trouble could start Make Decisions Locally with Coordination Tread carefully Develop Better Adaptive Management The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. See Notes Below If all stakeholders in a planning issue are included early in the planning process and can give their input, later legal challenges will be minimized See Notes Below This is related to the initial question - environmental and public opinion data should drive the analysis, even if the planning ahs to include several BLM offices see 1st screen for Topic/Point "A" - all 5 are under it. see 1st screen for Topic/Point "A" - all responses are under it. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering Let BLM managers broaden planning to the district participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing or multifield office level as needed to better address to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable cross-boundary issues and simplify the number and communications. avoid delays and lawsuits at the end of the process.. conservation, keeping the public well-informed, and complexity of resource management plans. providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Stop all mineral extraction and you wont have to worry about NEPA. ALWAYS CHOOSE DO NOTHING ALTERNATIVE. NO MORE DRILLING. NO MORE FRACKING. TRANSFER ALL BLM LANDS TO PARK SERVICE OR WILDERNESS DESIGNATION Do not encourage so many shortcuts that a plan Base plans on the latest information, science, policy, is vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. 5.EVest in training for BLM employees for their 2.Ssign a BLM representative as a planning planning process including the ability for local liaison for each of the RMPs for tribes and local governments to be cooperating agencies with BLM. governments who can attend or participate in the planning team meetings and the local government meetings throughout the process. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Make the plan thorough enough to minimize the chance of legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Stop all mineral extraction and you wont have to worry about NEPA. ALWAYS CHOOSE DO NOTHING ALTERNATIVE. NO MORE DRILLING. NO MORE FRACKING. TRANSFER ALL BLM LANDS TO PARK SERVICE OR WILDERNESS DESIGNATION The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while participate, and the BLM should make special efforts ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in to reach areas that lack access to electronic responsible development with reasonable fewer challenges in the long run and should help communications. conservation, keeping the public well-informed, and avoid delays and lawsuits at the end of the process. providing adequate opportunities for participation should also reduce lawsuits. Base plans on the latest information, science, policy, Let BLM managers broaden planning to the district and public opinion. If the science and/or public or multifield office level as needed to better address opinion point to the need for an environmental cross-boundary issues and simplify the number and impact statement, do not skip that step. complexity of resource management plans. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. A "Good Neighbor" would actually talk to it's Get out there and fight the false narratives of those Know what you own ahead of time neighbors.... the adjacent land and mineral owners. that are preventing you from doing your job. Your Industry is not your neighbor. Politicians and other "neighbors" know these claims to be false, why are government agencies are not your "neighbor". you not standing up for yourself? You have far When you limit your contact to more resources than private citizens to get your industry/politicians/activists, you completely message out. All false narratives do is delay the disengage your true neighbors. process. You contribute to the delay by feeding into it. Delays like this in non-contiguous acreage positions literally harms your true neighbors, the adjacent mineral and land owners. Communicate more effectively, this should not be a No deed or title transfer to any outside foreign Provide appropriate notification of public hearings A one size fits all approach does not work for every Eliminate the Social Justice section. This has covert process. Let your neighbors be involved. entity should ever occur. These are the mineral and to your real neighbors, especially in the rural areas location. There are big differences between large absolutely no bearing on land use and only serves to Push back against false narratives. land assets of the American people. where there are non-contiguous acres and no daily contiguous land/mineral positions of the western generate unnecessary paperwork. Whether or not newspaper outlets. states compared to the segmented and fractured you decide to lease should not have any bearing on nature of places like the WNF. The WNF should the educational background of people in a certain be the poster child on what not to do regarding area. scalability. Here you involved 12 counties through only politicians and industry representatives of 3 geographically distinct and culturally diverse areas, where you only needed to involve one Ranger division in 2-3 counties and could have even been further pared down by township. Talk about a waste of time, money and resources! Keeping the public informed with opportunities for participation, greater collaboration and idea sharing early on, making decisions based on data and science and honestly working to balance conservation of public resources with responsible development should, over the long run, minimize delays and lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. When appropriate allow BLM to extend planning to multifield office or district level to better address cross-boundary issues and simplify the number of resource management plans. Base plans on the latest data, science and public opinion in determining the extent/need for an environmental impact statement. Doing otherwise invites legal challenges and delays later on. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Being guided by the best science available, rather than by partisan politics and/or specialized commercial interests. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Scoping meetings should encourage interactions among those with different views and backgrounds. Stop trying to avoid controversy and concealing embarrassing information. You often lose lawsuits because of biased analysis or arbitrary decisions. Admit when illegal actions like chronic trespass More effective collaboration should reduce the grazing are occurring and are relevant to an analysis prospects of litigation. Stop the bias against of effects. collaborating with environmental groups. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Be mindful of legal challenges later in the process; Base plans on the latest information, science, policy, avoid shortcuts; be thorough and forward thinking. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. This category overlaps with the first one. Please see my comments under A. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. When reviewing and commenting on EA & EIS The BLM has a use it or lose it policy for vacation. the government should stop reimbursing NGOs for BLM needs more people trained in the NEPA documents, it would be beneficial if BLM can Therefore most staff take time off from mid-Nov to their legal fees. If NGOs had to pay for their own process. Currently the BLM has only 1-2 NEPA incorporate their comments directly into the EA or January 1. if you have a project permit seeking BLM legal fees, they would not sue as much. specialists per office. if the BLM had more people EIS document, via MS Word 'redline & strikeout' approval, the circulation of your permit approval is trained in the NEPA process per office, they could mode. currently BLM prepares a long table or letter stalled during the months of November & review NEPA documents more timely, and they and says "rewrite this sentence". Consultants December and nothing gets done. Solution, don't could prepare better documents (to ensure cannot read BLM's mind. in some instances, it would have a use it or lose it policy. if there is work to be defensibility). be quicker if BLM just rewrote the sentence how done, staff needs to be available to process permit they wanted it. BLM says 'we don't want to do the applications. permit applications, the EIS process, consultants work'; however, time is money; and can't be stalled for 1-2 months during Nov & Dec multiple reviews/revisions of documents by BLM & while staff takes their end of year leave. consultant cost money. Streamline the process and have BLM enter in their comments redline / strikeout mode directly into EA or EIS. Reduce the appeal timeframe from 30 days to 15 days. when projects are appealed, have a mandatory court needs to rule on this within 45 days. these appeals cannot extend for years. have a check list EA (there is not the need to instead of preparing hundreds of pages of text, use prepare documents of hundreds of pages). All maps to easily convey/identify the existing "existing environment" write up should already be environment. within the BLM's RMP (there is no need to rewrite it within the EA or EIS). The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Make it easy for state agencies to share scientific date, such as information on wildlife habitats, migration corridors, and other scientific data with BLM, and vice versa. Encourage participation by tribal entities and Follow the letter and spirit of all relevant laws and consider ways to communicate with tribal personnel regulations (NEPA, the Wilderness Act, the Clean and other interested parties if/where electronic Water Act, etc.) communication is limited. Early and ongoing collaboration as described If decisions are based on sound science and carefully previously, as well as sufficient opportunities for balance various interests in light of ecological as well public participation, will reduce conflicts and delays as economic considerations as appropriate to the during the process and make litigation afterwards place/issue, litigation will be less likely. less likely. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Carefully consider up-to-date science, policy guidelines, legal requirements, and public opinion. When these point toward a full EIS, do one. Don't try to evade the law. Do the planning at the appropriate level in accordance with the complexity of natural processes and units. Plan across agency offices - and even agencies - when that will yield better, more consistent, and perhaps fewer, plans and sounder management. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. States should be able to access information. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Native Americans have a strong interest in what is being planned. Tribal governments should be encouraged to participate, and the BLM should make special efforts to reach areas that lack access to electronic communications. Greater collaboration and sharing of ideas, while Taking into account and adhering to science-based more time-consuming in the beginning, will result in decisions, considering ecological as well as economic fewer challenges in the long run and should help values, truly balancing responsible development with avoid delays and lawsuits at the end of the process. reasonable conservation, keeping the public well- informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Do not encourage so many shortcuts that a plan Adhering to science-based decisions, considering participate, and the BLM should make special efforts is vulnerable to legal challenge later in the process. ecological as well as economic values, truly balancing to reach areas that lack access to electronic responsible development with reasonable communications. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Base plans on the latest information, science, policy, Follow The Pew Charitable Trusts' suggestions and participate, and the BLM should make special efforts more time-consuming in the beginning, will result in and public opinion. If the science and/or public advice regarding this matter. to reach areas that lack access to electronic fewer challenges in the long run and should help opinion point to the need for an environmental communications. avoid delays and lawsuits at the end of the process. impact statement, do not skip that step. Follow The Pew Charitable Trusts' suggestions and advice regarding this matter. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Centralized data collection points Round tables Centralized data collection points Round tables Clear, concise statements with causes and effects spelled out. Editor, please! Maintaining a dialogue with stakeholders is key. Collaboration should begin early and allow Tribal governments should be encouraged to By adhering to science-based decisions, by Greater collaboration and sharing of ideas, while everyone to tell the BLM their wishes and concerns participate, and the BLM should make special efforts considering ecological as well as economic values, by more time-consuming in the beginning, will result in about the planning area, and share any data they to reach areas that lack access to electronic truly balancing responsible development with fewer challenges in the long run and should help have about the area. communications. reasonable conservation, by keeping the public well- avoid delays and lawsuits at the end of the process. informed, and by providing adequate opportunities for participation should reduce lawsuits. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. 3.Db more than pay lip service to the economic and cultural impacts of the proposed action on local communities, landowners and businesses. Sec. 102 [42 USC 4332] of NEPA requires that "proposals for legislation and other major federal actions significantly affecting the quality of the human environment" be analyzed and alternatives considered before being implemented. It was not intended to prevent productive use of resources or protect endangered species at any cost. I.Comments should be given priority of 2.13) reduce frivolous lawsuits designed to delay importance, 1 st those who have a financial vested action, those who appeal decisions should be liable interest, 2nd local governments and agencies, 3rd for any harm they cause to stakeholders and the State government and agencies, 4th national resources. Such as the lack of management of our government and agencies, 5th advocacy groups, 6th forest because of law suits, which have caused our general public. The only entities that should be able forest to burn up in catastrophic fires? They should to litigate are those with a financial vested interest. not be rewarded through the EAJA, winning on one minor point of the numerous unscientific points and opinions they put forth, forcing the agency to go back and do more analyzing because of a summary judgment by a judge whose only understanding of the local resources or the management needed for health of land, is the propaganda that is put forth by obstructionist. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Mitigation criteria should be identified and established early in the NEPA process, including but not limited to applicable policies, guidance (IM's), regulations and state or other FLM requirements as appropriate. Think globally, act locally. What are the long-term effects of the suggested rules or laws, and what precedents does this involve. From the beginning institute a well designed plan that is invulnerable to legal challenges. Base plans on the latest information, science, policy, Do not encourage so many shortcuts that a plan is and public opinion. If the science and/or public vulnerable to legal challenge later in the process. opinion point to the need for an environmental impact statement, do not skip that step. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Let BLM managers broaden planning to the district or multifield office level as needed to better address cross-boundary issues and simplify the number and complexity of resource management plans. I.lEan activity has been going on for years, (ranching, mining, farming, timber or other) and project falls in the normal course of use of land, (wells, fencing, roads and other infrastructure) the categorical exclusion should come into play, NEPA should not be necessary. 2.Qie more Programmatic NEPA analysis so that NEPA for individual projects can just include any consideration specific to the area for which action is proposed. Greater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Not all of the perceived "needs" of state and local The BLM must request more resources at the local One way to reduce litigation is to develop full EISs It can take years for the Interior Board of Land The BLM should develop meaningful regulations and The BLM has no radiological clean-up action This question assumes that there are a number of In general, the questions asked by the BLM are governments, tribal partners, and other level for scientific research and for reviews of for all large hard rock mining operations and other Appeals (IBLA) to make a decision. The BLM must guidance documents for regulation of specific standards and no specific requirements with respect alternatives for Environmental Analyses, where that leading questions and not specifically geared to stakeholders are compatible with the protection of applications. Delays in NEPA reviews are often the operations that clearly will have a significant impact demand more funding for the IBLA. It should not aspects of land use on BLM administered lands. the storage of low-grade ore, accumulation of waste is not the case. NEPA reviews must meet certain improving the overall regulatory programs of the public lands. The BLM must not bow to local result of limited funding and other priorities in local (particularly cumulative impacts) on the take 2 years for a decision on a small mining Currently, there is no meaningful guidance rock, site erosion and degradation, dispersal of federal regulatory standards regardless of the "scale BLM, improving the BLMs enforcement of existing interests, whether for recreation, off-road vehicle offices. There are not enough knowledgeable staff environment. For example, the proposed 10-fold operation appeal, as has happened in an appeal I document for the regulation of hard rock mines, radioactive and toxic materials onsite and offsite, of the action." Sometimes, what the BLM or regulations, or addressing the numerous other use, mining, oil and gas development, grazing, or persons to complete the reviews in a timely manner. expansion of the Daneros Uranium Mine, San Juan was involved in. I have also been given a decision in specifically, uranium mines. None of the BLM signage and fencing, reclamation, noise pollution, industry may consider to be a small action can have failures of the BLM to protect and properly manage other uses that could be detrimental to the short Delays can also be caused by the failure of the BLM County, Utah, clearly warrants an EIS, rather than 2 weeks, overturning the local BLM office permitting regulations address the unique aspects of uranium cumulative impacts, and similar impacts from significant impacts, including significant cumulative federal lands over the past 50 years or more. term and long-term health of public lands. to provide a comprehensive and well-written draft the EA that is currently being developed. A hard decision, so I know quicker decisions are possible. mining, including radiological and toxic uranium mine operations. This must change. The impacts. Anything that comes from a directive by President NEPA document. The NEPA scoping process rock mine over 10 acres extent, where the site has contamination of land, air, and water. BLM must develop standards and requirements for Donald Trump and the current Department of should be improved and expanded. Timing is already been adversely impacted by mining activities, uranium mines. Interior Director is suspect. affected by local priorities and maybe the fact that clearly warrants a full EIS. the proposal is on hold due to economic considerations; e.g., uranium mines are on standby and do not know when, or if, operations will recommence. The BLM should provide an opportunity for public The BLM could build trust by requiring the update comment on supplements to Plans of Operations, of any decades-old Plan of Operations that does not particularly when the BLM has not enforced the meet current standards for such plans. The BLM requirements for Interim Management Plans. In should not allow the continued operation of a hard 2014, a uranium mine permittee submitted Interim rock mine based on a half-page (double spaced) Management Plans for mines that had had several description of a uranium mining operation, a half periods of suspension of operation over the page (double spaced) reclamation plan, and an previous decades. Yet, when the Plans were finally Environmental Analysis that is only a few pages long. submitted to the BLM office in Monticello, Utah, the Nor, should the BLM allow for the operation of BLM did not provide any opportunity comment on mines where there are no Plans of Operation; for the plans, which were rather generic and could have example, the Sage Mine and La Sal Mine (part of the been greatly improved. La Sal Mine Complex) in San Juan County, Utah, when there is no evidence of a Plan of Operations being submitted to the BLM and no BLM NEPA have them posted on BLM website ?? The BLM should limit the total period of The 5-year reviews of cessation of operation (43 nonoperation of a permitted mine to 20 years or C.F.R. 3809.424 (3)) must be meaningful and less and limit a continuous period of nonoperation consider factors other than an acceptable surety. to 10 years. The BLM must amend its regulations The BLM must also consider (but not be limited to): regarding temporary cessation of operation so that the condition of the mine and mine site, past mines are not allowed to remain on standby operational history, current and past compliance indefinitely. The BLM should more clearly define with Interim Management Plans and other BLM mine "operation." requirements, current and past compliance with other applicable state and federal regulations, the status of the economic feasibility of expected restart (for example, the price of uranium over the previous 10 years), and likelihood of restart of mining operation in the near future, given the The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Maximize opportunities for state and local government active engagement in all steps of the planning process from pre-planning discussions through the final Governor's consistency review. Maintaining constant communication in active engagement can go a long way to reducing litigation. Support efforts to encourage Congress to adopt reasonable limitations on payment of legal fees to plaintiffs who challenge planning and project documents. When significant substantive changes are made between the Proposed Action and the Final Plan, provide an additional but limited time for public comment before issuing the final decision. Simplify the regulatory processes so that there is less opportunity for procedural challenges through litigation. From our experience working with local and FCM has had many positive experiences providing regional BLM offices, we know that a short public comment on planning processes with the comment period or less opportunity for comment is BLM and other agencies, particularly when paired exactly what we want to avoid. Adequate with NHPA Section 106 consultation for cultural opportunities for comment allow for local resource preservation. stakeholders, local government, Tribes and tribal members, organizations like Friends of Cedar Mesa, and the broader public to have a say in how our shared lands are managed. Since all the hard work in creating BLM Planning 2.0 has been thrown out, we do not support any efforts to undermine public input into the NEPA process. If anything, public input should be expanded, especially when the agency knows an action is likely to be controversial. As noted previously, the biggest way to avoid Because of suggestions in the public comment litigation is to get all the stakeholders together to process and NHPA Section 106 process, the phases plan at a landscape scale and find compromise and techniques of a 2015 fuels reduction project before specific projects come up. If processes and near Blanding, Utah were changed to require hand their resulting decisions are open, transparent, and thinning techniques that are more protective of allow for robust public participation, there will be archaeology. This change also allowed for more reduced conflict and litigation. More specifically, the wood to be cut and brought to nearby roads for BLM can follow through on all NEPA requirements personal in-home use by local Anglo and Native such as relying on quality data, considering a American populations. This shows how NEPA reasonable range of alternatives and responding to processes can be used to change projects and substantive comments since these often drawn legal therefore avoid litigation. challenges and cause delays. Take law enforcement rights away from BLM and retrain so they don't violate the laws of the public and create lawsuits for civil rights violations. For documents that when the designation of an area has been made they cannot be changed. If environmental activists want an area and they get it they can't try to move into areas dedicated for the publics use. use locally sourced / familiar to area and aware of impact of actions Do not encourage so many shortcuts that a plan Base plans on the latest information, science, is vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Researching to stay informed and active communication between agencies that might have already dealt with issues at hand. Thoroughness is good, though. BLM should be authorized to develop generic NEPA analysis that can be applied by reference to proposed actions that are comparable in type and extent and are being proposed for lands that are similar in type. No matter what, NEPA analysis needs to consider Recently, we experienced a land issue that environmental impacts on behalf of the American exemplifies exactly what we don't want with NEPA public. This should never change. To address the and planning processes. In 2016, a local section of a issue of scale, the BLM can look to programmatic significant cultural land feature, the Comb Ridge NEPA and flexibility in defining planning areas. that was held in trust by the State of Utah, was offered up at auction. This culturally-rich square The use of categorical exclusions should be mile section of the Comb Ridge was sold without minimized to allow for a thorough analysis of public comment and without consideration of what impacts. it means to the broader American public. For This would include using categorical exclusions for decades, it has been visited by Americans of all ages drilling, as an exclusion is not a "right-sized" analysis and backgrounds - and now it is closed to the for this time of activity. public. Figure out actual impacts and no guess and hope. Actual not what ifs Greater Attention to Economic Impacts of Hire BLM Staff from the State and Local Better Incorporate Socio-Economic Information into Repeal or Reform the Equal Access to Justice Act Work with Department of Justice to Review Definition of the Term "Immediate" in Wild Horse Range improvements Should Receive Automatic Develop Adaptive Management Policies and Decisions and Focus on Maintaining Historical Uses Communities and Provide Incentives for Employees BLM Documents and Implementing Policies Settlement and Dispute Resolution Policies and Burro Management Categorical Exclusions Procedures to Invest in a Long-term Relationship in the BLM land use plans and policies have significant Community BLM planning and decision making has profound Although primarily a statutory issue, the Equal The BLM has recently entered into settlement Wild horse overpopulation has become one of the In Utah, successful wildlife habitat improvement Adaptive management should be a standard part of impacts upon state and local governments socio-economic consequences on the people who Access to Justice Act (EAJA) incentivizes constant decisions that bind the BLM to implement plans that most pressing issues impacting BLM rangeland in projects frequently receive swift and efficient NEPA BLM processes, and projects using adaptive throughout the west. Whenever BLM chooses to Residents of communities located near BLM land live and work in rural Utah. The livelihoods of litigation of BLM decision-making by special interest are not consistent with state law, policy or Great Basin. Although the Wild Horse and Burrow analysis under categorical exclusions. The use of management should require less lengthy analysis. In modify a grazing permit, deny access to a portion of typically have the greatest understanding of the local thousands of Utahns depend on livestock ranching, groups and is one of the primary impediments to regulations and develop rules that were approved Act requires the BLM to "immediately remove these categorical exclusions has been a boon to order to facilitate efficient and effective adaptive land, slow down restoration and rehab projects, ecosystem, range management practices, and mining, oil and gas extraction, and other multiple timely and effective management. The EAJA through the Administrative Procedures Act. excess animal from the range so as to achieve wildlife by avoiding the long delays that afflict other management, the BLM should develop specific etc., the impacts may be small to a national socioeconomic conditions. Local residents are use activities that occur on certain BLM lands. BLM program has effectively been hijacked by deep- Further, when entering into settlement, the BLM appropriate management levels" when it determines projects requiring an EA or EIS. Unfortunately, policies and procedures on adaptive management economy, and may not have a large impact on the typically very well suited to staff BLM field offices. documents can avoid many legal challenges if the pocketed organizations and no longer serves its often pays exorbitant legal fees that do not go back that overpopulation exists. However, courts have range improvements on BLM land designed to which should then be incorporated into the BLM overall state economy. However, seemingly small The BLM should prioritize hiring local residents so documents fully consider and analyze the intended purposes of empowering plaintiffs of to the land or improve state and local economies. been hesitant to enforce this provision of the law benefit livestock typically require an EA, even when handbook. The BLM has said that it has "initiated decisions which appear to only impact a few users as to benefit from their expertise and build trust socioeconomic consequences of a proposed modest means. The State encourages the leadership The State requests because the term "immediate" is not defined in the the impact of a range improvement is very similar to an effort" to develop such policies and procedures, of public lands, often time result in great impacts to with state and local governments and other decision. Although the BLM land use planning of the BLM and Department of the Interior (DOI) statute. The BLM's management of wild horses and that of a wildlife habitat improvement project. BLM (see BLM Land Use Planning Handbook, page 36) small rural communities throughout the State. stakeholders. Many cities and towns near BLM land handbook does provide for the incorporation of to work with members of Congress on ways to burros would be more transparent and consistent should resolve this inconsistent and duplicative but this effort appears to have stalled. BLM should suffer economically due to over-regulation of socio-economic information, the handbook should improve and reform EAJA. with the law if the BLM defined the term immediate problem by analyzing range improvements under swiftly complete policies and procedures on range resources and inadequate private land. be amended to provide for greater consideration of in its land use planning handbook. NEPA categorical exclusions. management and add them to the BLM handbook. such data. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. The BLM needs to present an EIS when there are The state and district websites BLM recently When addressing range health and "thriving natural significant effects from its proposed actions. It removed must be restored in order to provide ecological balance," the impacts of wild horses and cannot short-circuit the NEPA process by ignoring stakeholders with the information needed to input burros must be analyzed in the context of livestock the substantial, incremental effects of a given action NEPA processes. The public could visit these sites grazing impacts, the impacts of road-building for or series of actions on natural communities, critical to have an overall view of the multiple use of our mining, oil and gas leases, and off-road vehicle use. species and their habitat, and historical resources. public lands, including mineral, oil and gas leases, the Wild equines, whose numbers are dwarfed often 60 Such species and resources includes wild horses and numbers of wild equines in holding, roundup plans to one by cattle and sheep grazing permits, and burros that are recognized by the 1971 WFRHBA and how many wild horses and burros were being whose impacts are dwarfed by other commercial as integral to the range environment. Likewise, the adopted out by state. Eliminating this information uses of public lands, cannot be scapegoated for BLM should prepare an EIS whenever a given plan of amounts to censorship. It does not serve the BLM range degradation or habitat damage. Their positive action will have cumulative impacts, including or the public. It is not NEPA-compliant. impact to local communities, ecotourists, indirect or secondary effects that can be reasonably photographers, and other species should be fairly foreseen. analyzed. No shortcuts anywhere throughout the process. If the science point to the need for an environmental impact statement, do not skip that step. See earlier comments regarding the need for EIS in appropriate circumstances. Using Epex, we track and act only upon required processes, constantly working to make them more efficient. Epex can be used for any repeatable process, allowing the users to manage by exception while the solution automatically moves through the steps of the process. Issues that arise are logged with action items and assigned to an appropriate user. Tasks and action items are on each users home page. Do the right thing and YOU WILL NOT GET SUED. YOU know what the right thing is. It is NOT rocket science. Plan to help our fellow creatures. It is easy. Membership in organizations that take public Do more than pay lip service to the economic and Encourage federal employees to participate in positions for or against certain land uses, legislation cultural impacts of the proposed action on local appropriate professional and/or scientific or regulations relating to BLM, or which have been communities, landowners, and businesses. Sec. 102 organizations. Certification of professional involved in legal action against BLM, should be [42 USC 4332] of NEPA requires that "proposals qualifications and participation in continuing forbidden for BLM employees, or at least, their for legislation and other major Federal actions education requirements for certification should be participation in such organizations should be fully significantly affecting the quality of the human encouraged, or even required. disclosed when they participate in NEPA analysis. environment" be analyzed and alternatives This restriction would not apply to professional or considered before being implemented. It was not scientific organizations which do take advocacy intended to prevent productive use of resources or positions or engage in legal actions against BLM. protect endangered species at any cost. Simplify and clarify the procedures for preparation To reduce frivolous lawsuits designed to delay of NEPA documents and compliance with the ESA. action those who appeal decisions should be liable This may require rewriting the NEPA and ESA for all court expenses if they fail to win the appeal. legislation and/or rewriting the regulations based on the laws. Most of the litigation concerns procedural issues, not environmental ones. Federal employees should not have to be lawyers to do their jobs. If you BLM goes to court on the scientific basis for the decisions, you will probably prevail. If BLM will prepare documents that propose actions Reduce the size and scope of NEPA to include only For routine and accepted actions, it is sufficient to based on reasonable interpretations of data and analysis specific to the local area and the just state that the action will be carried out environmental laws and that have scientific and action being proposed. Many NEPA documents according to accepted best management practices economic merit, local people and honest scientists contain extensive reviews of literature or and only include any issues of concern that are will help BLM prevail over frivolous lawsuits. A descriptions of the local environment contain known or suspected to exist with the planning area. winning record will help discourage appeals. material that is either not relevant to the project in Building a fence requires adherence to BLM's best question or has been amply covered in previous management practices and the law requires NEPA analysis and need not be repeated. archaeology and endangered species be protected. The only NEPA issue should be the economic and environmental costs and benefits of building or not building the fence. Be thorough and work with all sides of the issues. Make it easier for BLM and states to share data --particularly wildlife management data. Include wildlife migration corridors identification, other habitat and other scientific data important to recreation groups Encourage tribal governments to participate. Reach areas that lack electronic communications. Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing fewer challenges in the long run and should help responsible development with reasonable avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Publish results of meetings. Stream live meetings. Don't shrink already established Monuments! Don't ignore the public. Don't make short comment periods. Don't lease oil, gas, coal, etc. lands right next to National Parks and Monuments. Consider the whole ecosystem! Don't undo the ESA, clean air, clean water, etc. protections to the environment. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, vulnerable to legal challenge later in the process. policy, and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. Don't try to eliminate participation of the public. NEPA when done properly is a good tool to analyze conflicts. Do it always! 3.Db more than pay lip service to the economic and cultural impacts of the proposed action on local communities, landowners and businesses. Sec. 102 [42 USC 4332] of NEPA requires that "proposals for legislation and other major federal actions significantly affecting the quality of the human environment" be analyzed and alternatives considered before being implemented. It was not intended to prevent productive use of resources or protect endangered species at any cost. That's tough. Two groups will always sue: big oil versus environment. If the public could vote on public land issues, some issues might stay out of court. I.Comments should be given priority of 2.13) reduce frivolous lawsuits designed to delay importance, 1 st those who have a financial vested action, those who appeal decisions should be liable interest, 2nd local governments and agencies, 3rd for any harm they cause to stakeholders and the State government and agencies, 4th national resources. Such as the lack of management of our government and agencies, 5th advocacy groups, 6th forest because of law suits, which have caused our general public. The only entities that should be able forest to burn up in catastrophic fires? They should to litigate are those with a financial vested interest. not be rewarded through the EAJA, winning on one minor point of the numerous unscientific points and opinions they put forth, forcing the agency to go back and do more analyzing because of a summary judgment by a judge whose only understanding of the local resources or the management needed for health of land, is the propaganda that is put forth by obstructionist. Allow a longer period of tI'm for public comment and read the emails. I.IDan activity has been going on for years, (ranching, mining, farming, timber or other) and project falls in the normal course of use of land, (wells, fencing, roads and other infrastructure) the categorical exclusion should come into play, NEPA should not be necessary. 2. Use more Programmatic NEPA analysis so that NEPA for individual projects can just include any consideration specific to the area for which action is proposed. Expedite and prioritize projects where local Eidopt new policies or update the mining laws to governments are attempting to partner with BLM to prevent "new mining" claims on lands where an take over some of the land management R&PP application has been applied for. Currently a responsibilities. (As an example, Cooperative jurisdiction has to wait for the NORA to be Recreation Management Agreements). published, new mining claims should not be permitted once the R&PP has been filed. Share the public comments on-line ELM needs to develop range of alternatives within six (6) months after closing of the scoping period and publish them for thirty (30) day public comment period build cooperating agencies & the public comments into the process reach out to know litigators and bring into the process Focus on being procedurally correct in the NEPA analysis. Activists are going to sue, but have been successful only when BLM is not procedurally correct. Make sure all scoping comments have been addressed even those comments that were considered but not analyzed. current using EA vs EIS process EA vs EIS currently getting BLM into litigation issues. A full EIS should be used to help minimize litigation issues Make sure the analysis mirrors the proposed action In several situations the only two alternatives that and a reasonable set of alternatives. should be analyzed are the proposed action and the no-action alternative. Consistency and Administrative Review with local government and cooperating agencies. Establish Geographic Boundary early and maintain. Provide deference to private landowners on surface Consistent application with County Land Use plans. Accurate and comprehensive Socio-economics use agreements with federal mineral leases. information. Reasonable alternatives should only include issues falling within the established scope of purpose and need. Maintain the Geographic Boundary. Avoid legal challenges in the first place. Ideally, BLM NEPA documents would include impacts to local governments. When creating a Resource Management Plan that NEPA documents, specifically environmental The projects should be supported by science, not will guide future management of public lands, we assessments, are too long. Over-analyzing natural litigation. encourage the BLM to review local planning resources that will not be impacted makes the guidance documents to ensure consistency between document longer and more time consuming to read. the BLM and local entities. La Plata County has a The BLM should really focus on reducing the length Comprehensive Plan to guide future development of of NEPA documents. If there are no significant the County. Coordination between the BLM and impacts or issues, then why are the documents local governments for future development and more than 200 pages long? public lands would help to discourage future conflicts. Upgrade the technology and use existing platforms to determine who will be impacted. The nepa input of a single citizen should be considered with equal weight as that of a national organization. It is not fair that an organization of thousands of people who may never see this blm land can have greater weight than local people who use the land. Have your employees well trained in nepa requirements, and do honest monitoring to maintain compliance. Take disciplinary action against employees who violate nepa, and against monitors who fail to perform properly. I hope there is some sort of metric in place already to help determine how much analysis is given to each scale of action. Seems that there should be a smaller amount of analysis for actions that do not involve machinery, construction, grazing; i.e. "heavy impact" actions. Guiding non-motorized trips does not require as much NEPA analysis as rebuilding a culvert or re-developing a road. The analysis should look at who is being impacted Recommended solutions may include changes to and what resources (environmental, community, BLM policy (e.g., Bureau manuals, handbooks, etc.); socioeconomic and others) are being impacted. changes to regulations; and/or changes to laws. Contacting local governments, tribes and stakeholders early in the process - at the scoping phase - can help limit the scope by determining the potential impacts and those affected by them. Just good planning and monitoring. As described in responses to A and C, a single Early stakeholder engagement, including local and BLM must actively involve land users (e.g. those with process and a single comprehensive analysis for a state governments, other regulatory agencies, and existing rights or authorizations) in agency efforts to project even if it crosses multiple agencies or Tribes, would help to better establish trust between change land use policies or BLM guidance (e.g. jurisdictions would help to improve stakeholders' the entities and improve the opportunities for input manuals, handbooks, etc.). The BLM should have ability to participate in a meaningful way in the from BLM's partners to be incorporated into the sufficiently flexibility to continue pre-existing land process. Equally important it would also help the BLM's analysis and documents as they are use rights rather than retroactively imposing new BLM avoid potential legal challenges of piecemealing. developed. conditions or requirements on pre-existing infrastructure. Gl~eater collaboration and sharing of ideas, while more time-consuming in the beginning, will result in fewer challenges in the long run and should help avoid delays and lawsuits at the end of the process. Adhering to science-based decisions, considering ecological as well as economic values, truly balancing responsible development with reasonable conservation, keeping the public well informed, providing adequate opportunities for participation should also reduce law suits. The Agency's analysis should use the existing conditions as the baseline rather than a pristine or undisturbed setting against which to evaluate potential environmental impacts from a proposed project. This is particularly important when the agency identifies avoidance, mitigation, or restoration measures. The Agency should perform an initial assessment to evaluate the impact of the proposed action based on available information and assumptions at the time that an application is filed, rather than wait for all survey, and analysis detail to be definitive. oDsed on this initial assessment a determination of the level of NEPA analysis would inform the applicant on how to proceed with non-federal agencies and non-governmental organizations. oDwould be understood that the Agency's final level of analysis may differ from the initial assessment in the event that the actual data varies from the initial assumptions. Db not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Dse plans on the latest information, science, policy and public opinion. If the science and or public opinion point to the need for an EIS, do not skip that step. Dt BLM managers broaden planning to the district or multi-field office level as needed to better address cross-boundary issues and simplify the number and complexity of RMPs. Invite tribes to be cooperating agencies in the NEPA Provide updates, in person in key local communities Research ecological impacts, determine ecosystem process. if possible. Include any new or updated information. services valuation, consider the dual impacts of Continue to solicit comments and thoughts. climate change and changes to resource managements, and in general ensure that ecosystems are considered fully for the value they provide as undisturbed areas. There should be a process to stop a project (the Ensure community and tribal use of areas, "No Action" alternative) if there is a risk of particularly activities that are not permanently permanent or impactful damage. The "No Action" disruptive or that require intact ecosystems, are alternative seems to be more of a placeholder than fully considered. a real alternative when large industrial projects kick off the NEPA process. BLM needs to develop range of alternatives within six (6) months after closing of the scoping period and publish them for a thirty (30) day public comment period. When creating documents, BLM needs to make sure Limit the range of alternatives and try to adhere to they are compliant with the procedural aspects of having only a proposed action and a no action NEPA and FLPMA. alternative. A standard 120 day review for all Environmental Impact Statements and a 60 day review for all environmental Assessments. Our public lands must remain in public hands! Be science-based. Design science-based research (if Very large industrial projects, particularly those that Projects or land management changes which, needed during the planning process), include tribal have high risk to subsistence activities or traditional combined with expected climate impacts on habitat, knowledge where the project(s) are in tribal areas. ways of life (including non-tribal traditional ways) should continue to require lengthy review. Engage local scientists from communities, possibly should continue to require lengthy review. through a sit-down meeting (not a webinar) just with scientists in the area (including those at colleges and county or borough level). Consider allowing local non-government scientists to be called in as subject matter experts during the internal NEPA reviews (non-public discussion of draft chapters) While all scoping comments have to be considered, Limit the range of alternatives and try to adhere to BLM needs to be sure it is analyzing only those that having only a proposed action and a no action are in relation to the proposed action and alternative. discounting those that are unrelated or unrealistic. Make use a RAC / Advisory council input's on responses to comments before publishing. Often litigation is undertaken because the response to the original concern is not detailed enough and/or is written in a manner that makes the submitter believe their comment was not seriously considered. By getting feedback from a RAC or Advisory council prior to publishing a more public-friendly response might be worked out that shows the comment was seriously considered and provide a more weighty response to why the comment could not be implemented. Create new methods of consultation and This is an often researched topic. Of related stakeholder input. Move beyond sending out letters interest: and awaiting responses - have online questionnaires, http://library.rpa.org/pdf/RPA-Getting-Infrastructure- project dedicated websites, email/text prompts for Going.pdf -- this is a 2012 planning roundtable pending deadlines, etc. document. It was developed by a very interesting list of contributors, and offers some sound case studies for best practices. BLM's credibility with its neighbors is harmed when planning and NEPA deadlines are routinely missed. For example, BLM's Washington DC office (WO) is slow and unpredictable in how it processes required Federal Register notices relating to important planning and EIS efforts. Local BLM project leads are often in the dark about how to navigate this WO maze. Top BLM management should ensure that Federal Register notices are handled by the WO in a timely, clearly traceable, and effective manner. 1. BLM should stop attempting to downplay, 2. BLM should not make NEPA promises or create BLM should more proactively encourage deflect, minimize, or ignore strong public concerns performance expectations relating to monitoring collaboration among different stakeholders and during planning and NEPA processes. BLM and mitigation that it likely cannot keep. Even in an interest groups, including sportsmen and managers tend to want to avoid controversy at all office that has lost over half of its previous range environmental groups. The prospects for costs, always put BLM in the most positive light, and staff, managers are reluctant to acknowledge the compromise and reduced conflicts increase when conceal embarrassing or conflicting information. practical reality of diminished capacity to do there are face-to-face meetings and people with These tendencies often backfire and contribute to promised monitoring. BLM should be honest about different backgrounds and viewpoints have an the frequently successful litigation against BLM. its limited capacity and the likelihood that it won't opportunity to build positive relationships. This is especially true with grazing related NEPA be able to do many of the things that it ideally Sometimes collaboration works and sometimes it analyses. should be doing. Hiding the true facts and ignoring does not in solving controversies. Despite this reality increases the chances for successful litigation uncertainty, BLM should nevertheless encourage against BLM.NEPA analyses. collaborative efforts wherever possible. Nothing ventured, nothing gained Realize the value of mineral development to the Realize and communicate the value of mineral Develop a legally defensible EA template that will Evaluate, via a Solicitor's Opinion, BLM's communities, states and tribes and account for such development to the communities, states and tribes. consistently be applied throughout a state office for jurisdictional authority to impose surface-based within the agencies joint analyses. all project proponents seeking to bring forth a stipulations or restrictions on fee lands. project. BLM could address this through an instructional memorandum, and doing so would make the documents much more defensible, as deficiencies within the document would be more readily apparent. Follow NEPA regulations and applicable guidance, and require comments/protest to be specific to the lands being offered for lease based on peer reviewed supporting data before delaying action. EAs should use a consistent template or format across all field offices, to the extent that is possible. see earlier comments EAs are frequently required by BLM when they're not necessary, as CX or DNAs should be sufficient to meet CEQ's NEPA compliance. Adhere to the CEQ's Guidelines concerning EA review periods, which states that EAs should be completed within three months. Land use plan decisions are subject to protest The following language was used in the decisions for procedures under the regulations at 43 CFR 1610 priority solar and wind energy authorizations: and are not subject to the potential lengthy appeals "approval of this decision constitutes the final to IBLA under 43 CFR 4. Most other decisions of decision of the Department of the Interior and, in the BLM, however, are subject to potential lengthy accordance with the regulations at 43 CFR IBLA procedures. The Department and BLM 4.410(a)(3), is not subject to appeal under streamlined the approval process for priority solar Department regulations at 43 CFR Subpart 4.400." and wind energy projects by issuing decisions not These decision packages for priority projects were subject to appeal to IBLA. It is recommended that signed at the Department level and were reviewed the BLM consider approving other high priority at length by the Office of the Solicitor. There were leases and authorizations (oil & gas, geothermal, very few delays associated with subsequent legal coal, mining, powerline and pipeline), especially challenges due to this upfront review by the Office those leases and authorizations consistent with of the Solicitor. existing approved land use plans, without appeal to IBLA. Most implementing actions and approvals of leases A major EA or an EIS for a proposed action and authorizations on the public lands are consistent with an approved BLM land use plan consistent with land use allocation decisions already should be the exception rather than the rule. The made in existing approved BLM land use plans. The NEPA analysis should only focus on those significant scope of the NEPA analysis for these actions should resources of potential affect and not all resources therefore be limited to the very site-specific affects that exist in the area. These other identified of the proposed action and not readdress the resources can be cross-referenced to previous previous land use allocations addressed in the land discussions included in the existing land use planning use plan decision. A Determination of NEPA documents. Using a geospatial database system, as Adequacy (DNA) or a limited scope EA should be noted in other streamlining recommendations, for the starting point for the level of NEPA analysis for identifying resource data layers and documenting most proposed actions on public land that are land use plan allocations should also assist in more consistent with land use allocation decisions from an focused NEPA analysis for specific implementation existing approved BLM land use plan. actions or proposed actions on the public lands. Meaningful consultation for ANCs includes, but Meaningful consultation for ANCs also includes, but BLM should establish appropriate policy and For instance, in the recently-issued Alaska EIRMP, BLM should emphasize that management planning Consistent with the BLM Manual, BLM must should not be limited to, consultation on: again is not limited to, providing reasonable advance guidance with regard to wilderness characteristics BLM erroneously conflated reduction of impacts to decisions relating to wilderness characteristics must meaningfully "engage cooperating agencies, the identification of planning issues; preliminary notice to ANCs of all local meetings, to ensure that that is consistent with the agency's multiple use wilderness characteristics with maintenance of be based upon careful and reasoned consideration public, and other interested parties" [including resource management alternatives and preliminary ANCs have the opportunity to participate at the mandate. Although BLM Manual 6320 outlines wilderness characteristics, and expanded the roles of the specified factors, including "whether the lands ANCs] in the land use planning process as it relates rationale for alternatives; the draft resource community level--to hear firsthand the issues, several outcomes from considering wilderness of wild and scenic rivers, ACECs, Primitive, Semi can be effectively managed to protect their to the management of lands with wilderness management plan or amendment (including concerns, and recommendations being raised by characteristics in the land use planning process, Primitive, and Backcountry recreation management wilderness characteristics" and "the extent to which characteristics." BLM should revisit its policies and potential ACECs and any special management stakeholders at that level, and to be in a position to recent BLM resource management planning zones, and riparian conservation areas, by asserting other resource values and uses of lands with procedures to ensure that such engagement takes attention that would occur if they are formally meaningfully provide their views or additional data decisions have failed to apply this guidance in a way that it will manage these area in a manner consistent wilderness characteristics would be forgone or place in a meaningful way. designated) and associated draft environmental or information to help inform the planning process, that provides stakeholders with reasonable clarity as with maintaining wilderness characteristics over the adversely affected if the wilderness characteristics document; early notice of any final decisions that when appropriate. to how BLM will manage lands with regard to those life of the plan. Such obfuscation over how BLM are protected." These factors are particularly may have a significant impact on ANC land interests; characteristics. intends to address management of wilderness important in Alaska, where significant tracts of land and implementation. characteristics under the plan inappropriately have been selected and are likely to be conveyed results in the potential for vast areas of lands to be under ANCSA and where access to non-federal managed as de facto wilderness. inholdings, guaranteed under the ANILCA, will be needed. Follow FLPMA and manage for multiple-use and sustained yield. Recognize that you are going to be sued no matter what you do. Make decisions and move on. Routine or activities with known disturbance of public land should be processed with an EA or categorical exemption. Disband the practice of privatizing public lands and public resources (i.e., wild horse off-range holding facilities are generally closed to the public, though the public still owns and pays for these animals and their care). Throughout the West, the BLM is seen as a VERY SIMPLE: FOLLOW THE INTENT AND THE paramilitary organization, with the obvious LETTER OF EXISTING LAWS! fracturing of trust this brings. Empowering local people (i.e., citizen science teams), getting more employees more "face time" in rural areas, and less military-style operations would go a long ways towards healing the broken public trust. Hiring people with actual relevant knowledge in a given location would also help. Westerners in general do not appreciate East Coast lawyers telling them what will or will not work in a given watershed. Accept that legal challenges are a necessary and Recognize your responsiblity to the public and the VERY SIMPLE: FOLLOW THE INTENT AND THE important component of democracy, and plan for public trust first and foremost - not the wealthy LETTER OF EXISTING LAWS! them. Eliminating them is a short road to tyranny. If private interests who can and do budget for full the laws are good and are followed, spurious time lawyers to challenge and weaken the laws challenges are already easily discarded. which protect the public interest. Accept that these players have a lot to gain and the public has a lot to lose -- and your primary duty is to uphold the public trust. Spend the money the public needs on better legal defense teams or we all lose. Lawsuits are a fact of life so avoiding them by kowtowing to special interests is not only foolish but unAmerican. Go long for our people. Recognize what all biologists already know, that Hire more "boots on the ground" with an emphasis wider areas can and are affected by smaller, focused on documenting both small and large scale actions within an ecosystem, and address the consequences of a proposed action, including the upfront research needs responsibly. Narrowed "known unknowns." We have plenty of people focus may speed up the process but will externalize interested in environmental careers but who find no numerous costs which can and often do have lasting sustainable career paths, especially in the current negative consequences. administration. Set up more paid internships with solid career pathways and get our best and brightest in the field and at the drawing boards. The BLM should make it easier for states to share data--particularly wildlife management data--with the agency and vice versa. This would include the identification of wildlife migration corridors and other habitat data, and other scientific information that is important to hunters, anglers, and other backcountry recreation enthusiasts. Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering participate, and the BLM should make special efforts more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing to reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and providing adequate opportunities for participation should also reduce lawsuits. Do not encourage so many shortcuts that a plan is Base plans on the latest information, science, policy, vulnerable to legal challenge later in the process. and public opinion. If the science and/or public opinion point to the need for an environmental impact statement, do not skip that step. BLM should make it easy for states to share fish and State Game and Fish agencies should be invited to The benefits of collaboration and effective public Collaboration and effective public involvement will wildlife data such as the location of important fish, participate as a Cooperating Agency in the planning involvement far outweigh the costs in terms of time improve the planning process by reducing the need wildlife and hunting/fishing areas, and the economic process to allow for more efficient sharing of and money. Early participation of stakeholders can for costly and time-consuming supplements that can value of wildlife viewing and hunting and fishing. information and ideas. Tribal governments should help to avert later feelings of policy imposition and delay decision-making. In addition, BLM should: BLM should incorporate information from the be encouraged to participate, and BLM should make coercion. By increasing participation on the front ofidhere to science-based decisions that fairly Western Governors Association's wildlife corridor special efforts to reach areas that lack access to end, the threat of litigation will be reduced because considers and balances ecological and economic initiative into the Assessment Report and the electronic communications. those groups that are likely to sue have already values, planning effort. been included in the process. ofidhere to all applicable laws and administrative procedures and thoroughly document all decisions. BLM should not take "shortcuts" that will make a RMP vulnerable to a legal challenge later in the process. BLM should base its plans on the latest information, science, policy and public opinion. If the science and or public opinion point to the need for an EIS, do not skip that step. Solution #1: Streamlining Protests See link in additional comments. Solution #2: BLM Protest Response Deadline See link in additional comments. Solution #3: Full Force and Effect After Denial of Protests Solution #4: Remove Interior Board of Land Appeals Process for Timber Sale Decisions See link in additional comments. See link in additional comments. Solution #1: Page Limitations for Environmental Assessments See link in additional comments. Solution #2: Tiering to Programmatic EISs See link in additional comments. BLM should make it easier for states to share data - Tribal governments should be encouraged to Adhering to science-based decisions, considering Greater collaboration and sharing of ideas, while particularly wildlife management data - with BLM, participate, and BLM should make special efforts to ecological as well as economic values, truly balancing more time-consuming in the beginning, will result in and vice versa. This would include the identification reach areas that lack access to electronic responsible development with reasonable fewer challenges in the long run and should help of wildlife migration corridors and other habitat communications. conservation, keeping the public well informed, avoid delays and lawsuits at the end of the process. data, and other scientific information that is providing adequate opportunities for participation important for hunters, anglers and other should also reduce law suits. backcountry recreation. Do not encourage so many shortcuts that a plan is vulnerable to legal challenge later in the process. Base plans on the latest information, science, policy and public opinion. If the science and or public opinion point to the need for an EIS, do not skip that step. Eliminate the practice of utilizing geo-spatial tools as BLM must retain flexibility in land use plans to BLM should provide increased training to dedicated Rigidly adhering to the provisions of FLPMA and the The utilization of "administrative designations" that BLM should make modifications to plans, revisions Quality NEPA analysis that is consistent with the Consider smaller planning areas that are sub-regions the centerpiece of analysis and decision-making. address the needs of various state and local staff who then become planning team leads. Those planning regulations will lead to defensible NEPA severely limit land use activities should be eliminated or amendments when valid protests warrant. Too requirements of FLPMA and the land use planning of a geographic area associated with a particular Tools such as rapid eco-regional assessments (REAs) governments and tribal partners. Accordingly, the team leads should then select third party documents, plan amendments and revisions. Law to the extent possible. The designation of Areas of often, BLM will reject valid protests for invalid regulations is critical. Quality is often sacrificed at field office. This can be authorized by the State and habitat equivalency analysis (HEAs) only scratch agency should move away from the "zoning" contractors who have land use planning expertise suits are inevitable but when filed, the agency should Critical Environmental Concern (ACECs), Resource reasons anticipating that protesters will not take the the expense of quantity under the guise of creating Director pursuant to existing regulation (43 C.F.R. the surface of data gathering and should drive approach where certain classes of activities are and appropriately direct and manage those vigorously defend their analysis to put an end to the Natural Areas (RNAs) and Back-Country areas has next step to appeal the decision. Legal challenges a defensible NEPA document. BLM must provide 1610.1 (b)). Aspects of regional and ecosystem agency decision-making. There is no substitute for prohibited or intensive uses are directed to a contractors to ensure quality documentation that "sue and settle" phenomenon. Non-governmental become prolific. In addition, other special may be reduced by virtue of earnestly working to adequate and specialized training to its planning planning may have intellectual merit or appear localized data collection that is ground-truthed for specific area(s) for administrative convenience or will withstand judicial scrutiny. NEPA processes organizations (NGOs) constantly allege NEPA management areas (e.g., SEZs, military land use resolve protests instead of flatly dismissing them. leads. In turn, those agency professionals must be attractive in terms of reduced workload, but they reliability. Too much emphasis has been placed on reasons grounded in pressure from non (both planning and project level) have become deficiencies because it is common for agencies to nexus zones) and related plans (e.g., Travel responsible for monitoring the process, focusing the are not practicable, timely or cost-effective. predictive trends, identifying regionally-significant governmental organizations. This trend grew out of consultant driven with the tendency to over-analyze cede to their demands for additional analysis instead Management Plans, Visual Resource Management analysis on significant issues and not be led by third Modern land use plan revisions can take over a riparian habitats and estimating habitat loss. Not the renewable energy boom (designation of solar for the sake of covering every conceivable baseline of defending the analysis that was completed. Plans) layer additional management restrictions party consultants who may not be motivated by decade to complete. This is not what Congress enough focus is being placed on local land use energy zones or SEZs) but does not work well for condition and potential effect to the detriment of NGOs then seek reimbursement of their fees under that are impossible for stakeholders to navigate and strict regulatory compliance or appropriate scale. intended and BLM cannot properly serve its conditions and implementing management objectives other types of land uses (e.g., mineral exploration quality documentation that meets the specific the Equal Access to Justice Act and the cycle BLM to administer. These designations trigger customers (i.e., the public land users) by continuing grounded in multiple-use. and development, linear projects, grazing). criteria of the planning regulations. continues. The number of legal challenges can be lawsuits which would be reduced if eliminated. in this fashion. reduced by eliminating this practice. Within each Arizona planning effort/document, BLM should identify the importance of our state's rich heritage and historic traditions of hunting and angling and the yearly economic contributions from sportsmen and sportswomen. BLM should work collaboratively with State governments to manage and conserve game and sportfish species and their habitats in a manner that respects private property rights and State management authority over wildlife resources. The planning rule should direct BLM to develop BLM should provide explicit direction providing a overarching procedures and implementation specific designated timeline and process for handbooks/guidelines in coordination with state coordination with the state wildlife agencies during agencies to minimize negative impacts to statutory the development of any planning regulation or authorities and the state's ability to fulfill state trust guidance. responsibilities. BLM should also provide explicit direction designating a timeline and process for collaboration and conflict resolution between BLM and state wildlife agencies before the release of any final planning documents with potential to impact state jurisdictional authorities and its ability to manage wildlife on public lands. Too often agency BLM policy, including for NEPA, is issued in memoranda, guidelines, bulletins, and the like, that bind the regulated community without adherence to the processes required by the Administrative Procedure Act. DOI should issue a directive to its bureaus, including BLM, to not issue such binding documents without compliance with the APA. BLM should focus on the proper scope of the If a project (such as a wind met tower) is of a NEPA document and should include only the part of type or in a category known to have no significant the project over which the agency has approval environmental impacts, it should be categorically authority or should utilize "small handles," which is excluded from the requirement to prepare and EA when BLM has statutory authority to approve only a or EIS. small part of a larger project. BLM should add to their list projects that are If BLM has no authority to influence the non- likely to be considered categorical exclusions (CEs). federal activity (legal control and responsibility), it should not include that activity in its NEPA analysis. In other words, federal jurisdiction over a small part of a project should not force the whole project to be reviewed, rather only the section on federal land should be reviewed. Cooperation- the BLM should work collaboratively The BLM should prioritize and accommodate active The BLM should not develop procedures, rules and Provide the public with adequate notice of the We support tracts of intact and undeveloped with AZGFD to manage and conserve game and management on the landscape to improve, restore guidelines for planning in a vacuum. Coordinate the impending plan, as well as a fair amount of time to habitats commonly referred to as "backcountry" wildlife. Any planning rules should also include an and enhance key habitats, by identifying habitat in efforts with the state, AZGFD and municipalities to comment on the matter, at least 60 to 90 days. because they are important for fish, wildlife and assessment and impact on hunting, angling and need of restoration and enhancement during the minimize negative impacts on their respective state A potential planning rule should fully analyze the public lands hunting and angling. These intact recreational shooting to ensure there is no net loss assessment stage, with clear objectives for desired trust responsibilities and jurisdictions. impact of any potential loss of public lands to habitats should be conserved, restored and to these pursuits. conditions throughout the process. The BLM should provide direction outlining multiple-use and wildlife related recreation. enhanced, but at the same time, sportsmen and designated timelines for collaboration, cooperation, Wildlife, wildlife resources and AZGFD's authority women need to be able to access these lands and The assessment of wildlife migration corridors Burro numbers are out of control! We would and conflict resolution prior to the release of any and need to proactively manage wildlife should be a the BLM should ensure access is not negatively across the landscape would be a critical step in implore you to manage these feral animals as final planning documents that might negatively key component considered in any special land use impacted. While we support the identification and supporting responsible management of all wildlife. previously outlined in your management plans. Our impact state jurisdictional authorities for the designation under review. conservation of backcountry areas, we do not native wildlife is suffering at the mouths and feet of management of wildlife on public lands, including believe those efforts necessarily need a special The restoration and enhancement of habitat is these animals, including some of our endangered any that might involve special designations. designation in order to achieve those results. extremely important to sportsmen. Too many BLM species. Burro mitigation and control efforts should managed habitats are threatened or negatively be included for any planning areas where they are impacted by noxious weeds and destruction from found. feral burros. Most sportsmen support habitat conservation along One such action that is in dire need of attention is a with balanced energy development. Proper planning comprehensive analysis of the impact feral burros can ensure both are possible, but that planning are having on our Arizona landscape. As stated should not be limited to just oil and gas leases, it previously, wildlife habitat in our state is being should also include wind and solar energy destroyed by burros and populations of native developments too. There are wildlife and habitat wildlife are suffering because of them. issues that emanate from wind and solar developments. These plans should be specifically A comprehensive analysis of the feral burro on identified in the BLM planning regulations to ensure Arizona's wildlife and wildlife habitat might be just the responsible and balanced development of our the impetus needed for some overdue revisions to public lands with a conservation eye towards both the Wild Horse and Burro Act. the landscape and the wildlife. Consider and offer non-Federal solutions to collective management challenges, such as allowing NGOs to assist in visitor education, trail/facility maintenance, and routine monitoring. Implement existing laws and regulation as they were intended not according to DC agenda. Exercise good judgement and commonsense. Tier analyses effectively. Avoid entangling broad Incentivize collaborative solutions. Use ADR more BLM, DOI, other agencies and non-Federal partners Accept that litigation is sometimes the hallmark of a See E.1 above- narrowly define purpose and need Consider establishing page limits for certain projects programmatic vision with site-specific itail, so frequently and creatively to force career litigants must meaningfully contribute to iasonable successful process and is often unavoidable. and adhere to those boundaries. or documents. Re-create a possibility that an RMP that programmatic planning can resume its proper away from ideology and organization building into statutory and/or regulatory reform. It is not 1970, Litigation need not equal "delay" where there is no can again be a 30 page exercise in broad visioning. limited role. fishing or cutting bait on real Solutions. we have overshot the preservation target and injunction. created too many impediments to reasonable Have a productive dialogue with stakeholders. DOI must avoid encouraging and supporting alien action. We need to have consequences (pay legal fees) for Exercise good judgement and commonsense in the Ample regulations and laws are already on the Work towards a solution that works for all parties. (environmental) interest group litigation that outsiders that initiate frivolous law suites to delay or NEPA process. BLM often uses excessive time and books for major projects. Enforce them in ways that Be creative problem solvers. supports an outside the regulations DC agenda. ruin allowable land use projects. effort to diesect projects that will have a minimal or they were originally intended. Match the NEPA no impact even in the worst case situation. Use effort to realistic future impact. A lot of projects are your time wisely burdened NEPA overkill and a waste of BLM man power and time. Train BLM employees and teams on the importance Continue Secretary Zinke's "Build the Trust" efforts. Implement greater flexibility for field specialists on Establish a state committee of resource experts to Take another look at the Public Rangelands Re-emphasize the potential for using Categorical The right size EA deserves a serious review by the Thoroughly trained NEPA specialists that work as a of becoming involved in local communities and It is most productive to have him visit the western policy and guidelines when applying and using conduct an independent review of a challenged Improvement Act of 1978, (P. L. 95-514, 43 U.S.C. Exclusions as an expedient means to get emergency legal community that is familiar with public lands team could be a positive influence on developing activities so they are better understood and public land states and listen to issues, concerns, and adaptive management. A good start would be set up document, including field evaluations if necessary, to section 1752) and the initial Nevada Section 8 resource treatments accomplished where necessary. resource management and actions that typically lead iron clad NEPA documents. Emphasis should be on accepted as part of that community rather than solutions submitted by affected members of the the LUPs as a guidance document and is much less either support the BLM position or provide approaches to allotment management plans and Wildfires, associated runoff, protecting essential to litigation. Issues like land disturbing activities on expediency and strong expertise in getting the job uninformed outsiders who are here for a short time public and local government entities. Consider a stringent. recommendations on how to change and improve, their challenges to proposed projects. Emphasize sage grouse habitat, moving cattle to non-used watersheds, critical habitats, waterways, and water done and permitted so the necessary action is not to dictate to us. TENURE is a good plus for BLM Roundtable style meeting in each public land state Review and change the misuses that are occurring with the preparation of a written report on their the importance of using this very beneficial pastures can be used in effective fuels management supplies. Grazing and recreation should not be held up by bureau policy and the "cannot do that" employees to establish a trust relationship, they gain that invites people as representatives of various on the Equal Access to Justice Act, by the anti findings. approach to expert review and overview of a targets. Emergency post fire seedings for watershed associated with this category. attitudes prevalent in much of today's BLM staff. respect and confidence and get better cooperation public land multiple uses. This has proven to be grazing and environmental groups. They have contested project. When a Section 8 review team protection and erosion controls that hit the critical and management. These valuable employees do not most effective and gave the Secretary a chance to effectively used this source to sue BLM, mostly report supports the BLM's position or proposed planting windows should warrant the use of a CX. create a relationship that results in a misuse of any talk with the user representatives concerning issues based on procedural issues, not substantive policies. project, the Court would need to look very closely resources as has been a concern by some high level and the needs for change. Lincoln County was part at the challenge and its validity. government administrators in the past. of the June 26 Pahrump round table with Secretary Zinke and found him to be receptive and interested in issues and solutions discussed. Every BLM planning and NEPA process must include The BLM planning and NEPA processes should give The BLM planning and NEPA processes should give Support Equal Access to Justice Act (EAJA) reform. BLM should better implement and give deference to Much of the cumbersomeness of NEPA has been BLM must employ full use of categorical exclusions BLM should complete more programmatic NEPA to a county/counties/state preferred alternative. This deference and have a strong bias towards use and deference and have a strong bias towards use and Litigation would be reduced if EAJA loopholes were results/outcome based management rather than facilitated through case law. We believe misguided (CX) under NEPA and development new CXs to tier to. alternative would be the local Federal/Natural selection of local, user and stakeholder coordinated selection of local, user and stakeholder coordinated closed that allow special interest groups to bankroll rigid boxes. Examples include rigid "on/off" dates court actions on NEPA must be reined in through separate "major federal actions" from minor Resources Plan in the county master plan or be initiatives (i.e., Coordinated Resource Management, initiatives. their litigious actions. for grazing which often reduces flexibility and often Congress. Congress could provide clarity on what actions. Don't "settle away" tools in the tool box in developed to be consistent with this plan. BLM Nevada Collaborative Conservation Network). forces graziers to be in the wrong place at the "major federal actions" require EISs and what could litigation like was done on some CXs. should be directed to select this alternative or wrong time. Outcomes must be monitored using be covered under EAs or CXs. provide very clear and justified rationale when this trend monitoring, not monitoring snapshots in time. alternative is not selected (or even components are To assist, BLM should consider using stewardship not selected). contract-type management. Results speak for themselves in defending against litigation. DOI should consider regulatory revisions that DOI and the Federal Government should consider better define the scope of environmental review for supporting legislation to either repeal the Equal particular kinds of actions. A good template is Access to Justice Act or means-test eligibility for fee regulations by the Corps of Engineers. For shifting. The EAJA was intended to facilitate example, the Corps permits river crossings, and it meritorious claims by resource-poor plaintiffs to has well-developed policies that limit NEPA analyses enforce federal law. Today there are a large for proposed river crossings to the crossing site and number of professional non-governmental nearby uplands, and exclude review of the project organizations that are very well-funded and bring as a whole. Clear jurisdictional lines improve legal large volumes of litigation solely to impair federal defensibility and the length of legal challenges. resource development. In that context, the EAJA facilitates excess and abusive litigation. A thorough Environmental Impact Statement for the Coal lease modifications should be handled with leasing of significant amounts of coal (+ 100 million categorical exclusions or at most an EA. The tons) and other resources is appropriate, since the limitations on acreage inherently minimize the leasing decision establishes the primary federal and impact of the modification, and any environmental lessor obligations. For all subsequent decisions, review should focus on new effects not considered including mine plans, exploration plans, and lease in the original leasing NEPA document. modifications, there will seldom be reason to do more than an EA, and many decisions can be conducted under a CX. Within each Arizona planning effort/document, BLM BLM should work collaboratively with state wildlife The planning rule should direct BLM to develop should identify the importance of AZ's rich heritage agencies to manage and conserve game and overarching procedures and implementation and historic traditions of hunting and angling and sportfish species and their habitats in a manner that handbooks/guidelines in coordination with state the yearly economic contributions from sportsmen respects private property rights and state agencies for areas of mutual interest and and women including: approximately $54 million for management authority over wildlife resources. The management authority. For example, lack of wildlife and habitat conservation, $1.2 billion to the planning rule should direct BLM to evaluate the meaningful coordination with state agencies during state's economy, support for more than 18,000 effect of agency actions on trends in hunting and the development of the USFS Planning Rule and jobs, and $132 million in state and local taxes (State fishing participation and address declining trends by complete lack of coordination on subsequent of Arizona Proclamation on hunting and fishing implementing actions that expand and enhance implementation guidelines, significantly increased signed by Governor Douglas A. Ducey on hunting and fishing opportunities. state agency appeals/objections. This resulted in September 16, 2016). The planning rule should unnecessary and costly state and federal planning direct BLM to consider and analyze impacts to the delays. economic and recreational values of hunting in agency actions. Direct BLM to ensure effective communication with The BLM should provide explicit direction for a The planning rule should direct BLM to use the interested parties, clear and concise writing of specific designated timeline and process for `Desk Guide to Cooperating Agency Relationships documents, adequate time for review, effective coordination with the state wildlife agencies during and Coordination with Intergovernmental Partners' notice of availability, and meaningful incorporation the development of any planning regulation or as well as the existing Travel Management process of comments. Develop a designated timeline/process guidance including policy, rules, manuals, handbooks, for designating roads through the `Route Evaluation for collaboration and conflict resolution between and plan amendments to facilitate appropriate state Tree Process,' which is an effective method of BLM and state wildlife agencies before the release of wildlife agency involvement, including the planning/collaboration. Through these processes, any final planning documents with potential to development of guidance for special designations or the Arizona Game and Fish Department and BLM impact state jurisdictional authorities and its ability allocations including wilderness, wilderness Arizona have experienced a tremendous amount of to manage wildlife on public lands to avoid costly characteristics, Areas of Critical Environmental success in building science-based, defensible and unnecessary administrative/legal appeals, and to Concern (ACEC), Wildlife Management Area Resource and Travel Management decisions. comply with federal laws including the Governors' (WMA), Recreation Opportunity Spectrum and Consistency Review to ensure consistency with state Visual Resource Management classifications, plans, policies, and programs. Cooperative Management Area, etc. BLM should abide by statutory and regulatory timeframes for completing NEPA analysis. When an EA is required, BLM should ensure it is completed within a 3-6 month period, per the Energy Policy Act of 2006, and when an EIS is required, it should take no longer than 18 months, per Council on Environmental Quality guidance. If social trust is a precious commodity, then trying to dissuade people from cynicism is a priority. Working with law students in your vicinity, including those who might be studying in more distant regions, and therefore becoming acquainted with different cultures within this huge country might lead to the development of documents that convey both acquaintance with local culture and other models that could work in the future. Involve law students who are "diverse," so that local people who may be largely from one background, also become more familiar with the diverse face of the U.S., whose citizens are stakeholders in our public lands In many ways, BLM is at the mercy of the federal It will remain difficult to create legally defensible The Administration should work with Congress on BLM should support legislation to limit venue for courts, which have construed the requirements of documents as long as they are so long and complex. ways to limit opportunities for unaccountable actions challenging energy projects on public lands NEPA to require more procedure and delay than Several policies enacted without Congressional groups to sue to stop energy projects that create or leasing decisions to either the judicial district Congress ever envisioned when enacting the statute. mandate or a rulemaking process during the Obama jobs and economic opportunities. Having the where the project or leases exist/are proposed or Because of the myriad requirements contained in Administration should be overturned, as they Administration support legislation to prevent the the D.C. District Court, which has broad regulations, policies and other guidance documents, created more complexity and made planning use of the Equal Access to Justice Act as a means of jurisdiction and an extensive history of analyzing it is very easy for environmental groups to find documents even longer and more indefensible. The using taxpayer dollars to fund litigation from large regulatory issues. Requiring litigation to be filed in deficiencies in documents to exploit in court. When complexity of the sage grouse plans and their environmental groups is one way. Another is one of these courts would more closely align the the documents are several thousands of pages with associated Instruction Memoranda are a case in reducing the statute of limitations for legal action with a court that has the appropriate several thousands more pages of supporting studies, point, as is the Master Leasing Plan process. While challenges to energy projects from six years to expertise. it is very easy to flyspeck BLM's analysis to find a redoing the sage grouse plans will take time, the IMs ninety days, the same timeline that energy supposed deficiency. BLM should therefore do as and the MLP policies can be overturned in short developers and lessees must meet to challenge complete a job as possible, but more robustly order. BLM should also consider simplifying other federal decisions. defend itself from the inevitable court challenges. policies and guidelines to reduce vulnerability in court. The NEPA process is initiated for wells on private BLM frequently requests information that is not or state lands even when only a minority of the oil required in the EA but would be beneficial for BLM and natural gas resources being accessed are to collect. This information is collected at the federal, using the "federal nexus" as a reason for company's expense and is often unrelated to the BLM to become involved in wells in which it has project. The scope of EAs should be limited to only a minority of mineral interest and/or when the information that is truly required for NEPA well is not on federal or tribal surface. Once BLM compliance, and field offices should be directed to determines the federal nexus requirement is met, it stop requesting additional information for its own holds up development of individual private minerals, benefit and is inconsequential to the project at potentially for years, while conducting NEPA and question. permitting. Rather than undergoing that additional NEPA, BLM should recognize its minority interest and determine that additional NEPA is not required. The planning rule should direct BLM to analyze and The planning rule should direct BLM to demonstrate The planning rule should provide for adequate The planning rule should direct BLM to fully analyze Wildlife, wildlife resources, and the Arizona Game The planning rule should direct BLM to include minimize negative impacts to wildlife related the mutual agreement/concurrence of the state public/formal comment periods of at least 90 days. the cumulative impacts of further loss of public and Fish Department's authority and need to Species of Greatest Conservation Need (SGCN) and recreational access in special land use designation wildlife agency and USFWS for all fish/wildlife Pre-NEPA consultation should not be a replacement lands that provide for multiple-use and wildlife actively manage wildlife must be included as a Species of Economic and Recreational Importance areas and provide for development of alternate conservation, protection, and management plans. for adequate public and formal evaluation/review of related recreation and economic opportunities primary component and/or priority characteristic of (SERI), as identified by the Arizona State Wildlife access routes when existing designated access (Ex. `The Secretary of the Interior, acting through draft proposed planning documents. Reducing public prior to recommending or approving special land any special land use designation including, but not Action Plan, within planning documents in an routes are closed across private land. the Director of the U.S. Fish and Wildlife Service comment periods may appear to reduce the process use allocations and designations. The Multiple-Use limited to: national monuments, recreation analysis of effects to such species. If the proposed and the head of each appropriate State fish and timeline, but more often leads to additional Sustained-Yield Act of 1960 and the Federal Land management areas, Recreation Opportunity action in the NEPA analysis potentially adversely wildlife agency for the State in which the public conflicts, appeals, objections, and litigation, delaying Policy Management Act of 1976 prohibit federal Spectrum allocations, wilderness, and recommended affects any wildlife species, the responsible Federal lands are located, shall develop a comprehensive the overall process and implementation of decisions. agencies from affecting the State's wilderness. official must make the relevant information available plan, reflecting mutual agreement regarding jurisdiction/responsibilities. Managers of public lands to the public and inform decision-makers and the conservation, protection, and management of fish are mandated to provide multiple-use recreational public of a reasonable alternative to avoid or and wildlife resources for conservation and opportunities on public lands to present and future minimize those impacts. rehabilitation programs to be implemented on generations. public land under his jurisdiction.) The planning rule should direct BLM to recognize The planning rule should define dispersed recreational shooting as an appropriate and publicly recreational shooting as "any shooting that is valued activity under federal multiple-use mandates carried out in a legal and safe manner, does not and cite the importance of hunting and recreational cause resource damage, and does not result in shooting as a gateway to hunting (Executive Order litter" to distinguish between responsible target 13443). Include EO 13443 in all planning documents shooting and irresponsible recreationists engaging in and direct agencies to `Increase structured hunting illegal activities including littering, poaching, and programs and recreational shooting opportunities as intentional destruction of vegetation. Further a means of achieving a net increase in federal land restrictions and/or elimination of areas due to a hunting'. Include reference to Pittman Robertson minority of offenders does not provide a balance of funding (derived from firearms and ammunition multiple-use and directly impacts responsible sales) that provides for wildlife and habitat shooters. conservation on public lands. BLM should incorporate local socio-economic data into management plans. Tribal partners should comply with NEPA, Listen to local stakeholders and find solutions that regardless of whether the land is held in trust status address all concerns. Fear of lawsuit should not by the Bureau of Indian Affairs. outweigh common sense and making the right decision. BLM should adhere as closely as possible to congressional intent (viz., assuring the multiple-use policy is followed on public lands) Let common sense be the guide. Smaller BLM should strive to work with landowners to actions/projects should have an appropriate and accomplish mutually beneficial outcomes. similar corresponding NEPA analysis. The same can Duplicative process could be reduced by partnering be applied to larger proposed actions/projects. and coordinating with permittees. BLM needs to uphold the agency's current BLM should only apply wilderness area management A change in several federal laws is required to BLM needs to strengthen the protest process to When civil action occurs related to the management BLM needs to clearly define what the term `"may To more closely match the level of NEPA analysis to commitments and management practices. Without techniques on federal lands officially designated as reduce the numerous frivolous lawsuits BLM faces dampen the recent trend to "sue and settle." BLM of wild horses & burros on private lands, local be" adversely affected' means. Without a clear the scale of the action being analyzed, BLM needs to this, it is hard for conservation districts to fully trust wilderness study areas. Wilderness study areas are when it comes to enacting its federally instructed should ask Congress to enact legislation that would courts in the state where the issue develops should definition, no improvement can be made to reduce work with the local units of government. When BLM. not permanent designations & adequate reviewal of charges. Congress needs to provide the general require plaintiffs in legal actions over resource preside. When federal lands are involved, the the number of frivolous lawsuits waged against BLM. conducting the environmental assessments or Wild horse & burro populations should be properly area designations is required. public full access to data giving accurate management decisions to bear the costs of litigation nearest federal court to the lands where the issue environmental impact statements, BLM should invite managed based on sound, scientific rangeland health representation of the administration of EAJA. That & all other costs caused by an inordinate delay in arose should preside. the local governments affected to work in step as practices to ensure protection & preservation of access would allow for the tracking of EAJA implementing agency-approved management plans, the cooperating agencies they are in order to use critical native wildlife habitat & multiple land use. disbursements, including information regarding including requiring posting a bond in the amount of their local knowledge and expertise to streamline BLM cannot provide any special plaintiff organizations, attorney's fees and monetary at least $100,000 to guarantee the costs of such the process. management/protections of abandoned, feral, stray awards distributed as a result of actions undertaken actions. or otherwise unauthorized horses & burros. The on EAJA. The EAJA should additionally be amended BLM cannot grant any special management area to disallow reimbursement of legal expenses to any designations for WH&B's outside of currently party that does not have permanent residence in defined HMAs. the immediate affected area or is not personally impacted. Stop violating NEPA, EPA, and other public land laws. Keep engaging stakeholders to reach thoughtful, science-supported, coordinated public land use plans instead of giving out public lands and public lands leases in a firesale. Leave it alone. The NEPA analyses are fine. EEI believes that the production of NEPA documents that are consistent in format and based on the best science available is key to avoiding delays associated with legal challenges. Project proponents desire regulatory certainty; and while that may not always be attainable, moving forward in the process as designed is the best way to arrive at a decision for a project. As stated in B, early stakeholder engagement is crucial to identifying project concerns early in the process so conflicts can be resolved. Our industry regularly meets with various environmental groups on bigger electric infrastructure projects to collect comments and to try to get the purpose of the project out to the public. Regularly engaging with concerned communities may result in both greater transparency and forestalling future judicial challenges. One of the primary limiting factors in public lands Activist groups engaging in habitual litigation abuse grazing management has been litigation. It is and attempting to drive agency policy through legal problematic that members of the "interested public" harassment should not be guaranteed stakeholder are given equal status to grazing permittees in status or otherwise rewarded for their behavior. management actions. Those with long-term contractual agreements, such as grazing permittees, should receive stakeholder status beyond that of the "interested public". The role of true stakeholders needs to be enhanced and further defined. WMA believes BLM should consider the performance standard history of the proponent. Companies with high proven standards should undergo less vigorous agency review. The BLM should hire and train personnel who are WMA believes BLM should exercise its statutory qualified to coordinate projects and lead teams. flexibility when warranted. When NEPA reviews Too often the project leaders were promoted are not necessary or warranted, the agency needs beyond their skill set into a leadership position, but to act rather than become mired in processes that cannot lead, decide and act. Once these people are produce nothing meaningful. Minor revisions to in place they need to be given more authority to plans of operations often become subject to such move project along in the process, quickly, unnecessary actions. efficiently and in compliance with established programs. NEPA reviews should be focused and not include unnecessary items. BLM must recognize that they cannot prevent litigation in many cases. Collecting data and creating analyses that are beyond the appropriate scope of a project merely delay the process and often create additional issues for litigious groups to use challenge. BLM's objective should not be to eliminate legal challenges but rather to fairly and consistently administer its legal authority as mandated by Congress. Doing so will of its own accord lead to greater defensibility. BLM's actions are defensible when they rest on (1) consistent approaches to developing administrative records for decision, (2) pertinent science and specialized experience, and (3) best practices developed and shared among district offices and within the Interior Department to ensure efficient use of governmental and non governmental resources. Create a policy of "no sue and settle" with litigious Begin interacting with local and state governments organizations. The documents usually are not the at the outset of an action. Invite them to contribute problem, the problem is that BLM will not defend through either cooperation or coordination. There them in court. will always be conflicts but there are more when local government's priorities and plans are not considered. Do not make it possible for lawyers to earn a fortune by attacking the BLM and the project proponents, all the while being paid by the taxpayer. BLM should try to utilize Categorical Exclusions or Cat Exes as much as possible; especially in areas where surface disturbance impacts have already occurred. Categorical Exclusions can be processed fairly quickly, thereby allowing applicants to complete projects in a timely manner while still ensuring natural resource protection. The grazing permit renewal process has become far To allow more appropriate, site-specific, and lengthier than is practical due to NEPA landscape-scale management, grazing permit requirements. NEPA and/or its implementing renewals should be exempted from NEPA review. regulations need to be amended to focus NEPA Rather, grazing should be generally authorized review at the Land Use Planning level and not at the through NEPA documentation at the land use implementation-decision level--such as grazing planning level. Then allow land managers the permit renewal. This one change would greatly flexibility to manage in accordance with current streamline the decision-making process for agency climate and ecological factors--such as for wildfire staff in the field and allow them to adequately prevention. manage the land, as opposed to being behind a desk working through exhaustive procedural documentation BLM should take into consideration different WMA believes BLM could use a tiered NEPA review resources and plans based on individual process tied to a proponents' past Environmental characteristics and input from proponents. Assessments as many past plans are very similar to current plans of operations. The creation of a streamlined approval process for BLM should consider fully adopting an "issues- emergency and maintenance activities associate with based" approach already in use in some district electrical infrastructure in areas previously offices. Under such a procedure, any components reviewed by BLM should be a priority focus in of the environmental, cultural, or historic review efforts to right-size the level of NEPA analysis. that are not an issue in a particular project or request for authorization are summarized, providing an explanation as to why further review is not necessary and dispensing with that review. Such an approach would save substantial time and resources. Stop writing NEPA documents that analyze everything in the world, with citations. O'eate documents that analyze only the affected environment and defend them. Create Oogrammatic analyses for normal actions such as permit renewals. Expand the Categorical Exclusion provisions. For small projects, you tie up a whole lot of BLM talent that can not be put to good use elsewhere. If BLM personnel are nit-picking some small litle item, the other projects are held up, thus the economy stagnates. Trust your managers to make good decisions. If they can not make good decisions, transfer them to a non decision making role. The BLM can create legally defensible documents and avoid legal challenges by acting within the scope of the law P rior to issuing a decision record, the BLM should consult individuals or organizations to address legal concerns. BLM has historically moved pushed forward illconceived, highly controversial proposed actions with utter disregard for the preference of the American people and for existing policies and laws which govern the agency. The BLM has much discrepancy when it comes to taking actions. NEPA should always be adhered to because it was instituted to protect the public and the agencies from taking action without considering all available information. It's unfortunate when the BLM receives valid information and ignores it. Extensively and technically train BLM employees and Tenure in a BLM District is a plus for a good Use greater care with policy and guidelines Establish a state committee of resource experts (i.e. Revisit the Public Rangelands Improvement Act of Reassess Categorical Exclusions(CX's) as an This subject warrants serious review by legal Carefully trained NEPA specialists working as a teams at the Training Center, including on the employee to establish a trust relationship. With development, allowing greater flexibility for the field University, USDA ARS, State Dept. of Conservation 1978, (P.L. 95-514, 43 U.S.C. Section 1752) and the expedient means to apply emergency resource scholars familiar with public lands resource team could potentially be a significant factor in recognized importance of becoming involved in local more resource familiarity and user interface on specialists to be nimble and flexible in applying and & Natural Resources; State Dept. of Agriculture, initial Nevada Section 8 approach to addressing treatments. Examples might include wildfires with management and the actions typically leading to developing mostly "bullet proof" NEPA documents. communities, sports, service organizations, management and problem solving, they gain respect utilizing adaptive management. If too rigid, the anti Conservation, Wildlife, USDA-NRCS) to be available allotment management plan (AMP) challenges to the need to access ACEC's or wilderness areas to litigation. The issues that would likely most qualify The emphasis should be on expediency and strong churches, etc. so they are better accepted as a part and confidence from the state and locals resulting in grazing and other organizations will quickly find to conduct an independent review of a challenged proposed projects, emphasizing the importance of fend off fire movement, protect critical sage grouse would be land disturbing activities that impact view- expertise in getting the job completed and of the community rather than uninformed outsiders better cooperation and management over the long openings for legal action. Stated in another way, document, including a field evaluation if necessary, having and utilizing this very beneficial, yet seldom habitat, or move livestock to pastures that are not sheds, critical habitat, waterways and water supplies. permitted so needed action does not become that are here to dictate to the locals. Utilize local haul. As such they are more able to sell needed make LUPs "advisory" in nature or a "guidance" to either support the BLM position or provide utilized approach to expert review and overview of scheduled at the time for grazing, and also flooding Grazing and recreation are uses that typically would strangled in bureaucratic policy and "can't do's". research as a first approach to solutions and to help changes and experience management on the land. document and much less prescriptive. recommendations on how to improve it, and a contested project. If a Section 8 team review and or other emergencies. CX's should also apply in the not fall into this category. avoid litigation. We learn more when allowed to be there long prepare a written report of their findings. While this report supports the BLM's position or proposed case of fuels management where targeted livestock enough to see our plans through to fruition. These approach might not solve every challenge, it would action, the Court would need to look very closely at grazing can be utilized to remove flashy fuels (i.e. valued BLM employees do not create a love likely help the Administrative Law Judge (ALJ) or the challenge and its validity. cheatgrass) at the proper time to protect other relationship with the users that results in misuse of Interior Board of Land Appeal (IBLA) in their resources. Emergency post wildfire seedings for the resource, as has been the concern of some high- opinion and ruling determination if supported by watershed protection and hitting the critical planting level government administrators over the years. such a committee of experts. window should also warrant use of a CX. WDFW appreciates the opportunity to partner with BLM in restoring habitat and species. For example, in eastern Washington, we have worked with BLM for years on greater sage-grouse, sharp-tailed grouse, pygmy rabbits and ferruginous hawk conservation. Address existing problems with "Equal Access to Justice" provisions, which have been and continue to be badly abused. Aggressively challenge both "standing" and lawsuits that are based on unreasonable premises, and establish a reasoned basis in case law. Proceed with the analysis and decision while any lawsuit(s) is pending, with the consideration that a judge may consider and issue a stay, if appropriate and warranted. Eliminate the practice of "sue and settle", as a Keep in mind that in today's environment these The first step in conducting a right-sized analysis If a CE cannot be applied, BLM should utilize a pre practice that promotes collusion to the detriment of documents are likely going to be challenged would be to determine if a Categorical Exclusion screening process that identifies and assesses the public good. regardless of how "bulletproof" the environmental (CE) can be applied to the project. CEs are resources and potential impacts, considering direct analysis is. Taking longer time for document review underutilized by the agencies and should be and indirect impacts only at this stage. Base the and belaboring unnecessary analyses does not help encouraged by the agencies where appropriate. level of analysis on the relative area of impacts and avoid a challenge and in fact, may only provide more Where CEs are determined to be appropriate, they nature of the proposed disturbance. Establish initial topics for scrutiny. must be adequately documented as they will screening criteria and thresholds. Levels of analysis undoubtedly draw challenges from stakeholder may include; 1) EA; 2) Expanded EA; and 3) EIS. To groups. However, the use of CEs can cut date, whether or not a proposal would potentially significantly back on the resources needed for NEPA be controversial has entered into the determination projects. of level of analysis. This is inappropriate, as the analysis should focus on the proposed action and potential impacts, rather than perceptions and politics. Maintain the thorough NEPA review process to ensure that negative environmental impacts of large projects are minimized. Reexamine the NEPA regulations regarding document length and detail. The CEQ issued guidance (2012) that highlights the original intent of the regulations. EAs were originally intended to be approximately 10-15 pages while EISs were typically up to 150 pages, but could be as large as 300 pages. Based on recent coal mine project approvals, the length of EAs can be over 300 pages while EISs take up volumes of binders. BLM needs to set limitations on document length and a reasonable level of detail that is required for various types and sizes of projects. The routine of overcompensating for perceived deficiencies with additional and often unnecessary analysis, detail, and length must stop. We must live with the long-term consequences of land use decisions made by federal land managers. Maintaining the thorough NEPA review process will ensure that negative environmental impacts of large projects are minimized. The BLM should evaluate ROW access agreements Based on current science, perch discouragers are Ensuring staff knowledge of the fundamental tenants Consistency with state policies and regulations is In correlation to Solution #2, Sage-grouse are a NEPA documents that are consistent in format and The BLM has recently required EAs for maintenance The BLM should try to utilize CXs as much as for roads and transmission lines that cross BLM not effective and should not be required for new of the agency's authority and processes as well as key to avoiding contentious litigation. To the extent trust resource of the state wildlife agencies, and based on the best science available is key to avoiding projects, when they have previously analyzed similar possible especially in areas where surface lands based upon the impact to the public land projects or recommended for maintenance projects. having some knowledge of the industries regulated that states have developed plans to address issues therefore the states should act as the lead regarding delays associated with legal challenges. This projects with Categorical Exclusions (CX). BLM disturbance impacts have already occurred. without triggering BLM permitting process on (See APLIC www.aplic.org). They can also create by the agency is key to ensuring the agency is under BLM review, the agency should seek sage-grouse conservation and management. consistency can only be achieved through detailed should remain consistent with historical precedent Although some surface disturbance impacts on private land. For example, when one transmission maintenance challenges and safety issues for electric advancing legally defensible, durable decisions. cooperation, not controversy. For example, RMPs Likewise, for trust species under the jurisdiction of directives, guidelines and/or standard operation on future maintenance projects. For example, if a public land are pre-NEPA, it is possible to collect line crosses 99% private land and crosses BLM land line crews who climb and work on these structures. should be consistent with state sage-grouse the USFWS, such as migratory birds, endangered procedures put forward by State/Regional Office certain type of maintenance project received CX natural resource data (biological, cultural, etc.) to for 1% of its length, the applicant is required to BHE has been required to install perch discouragers executive orders (EO) and plans that may states species, and eagles, the BLM should coordinate with personnel. The BLM must use these detailed clearance, the same projects should receive CX identify past impacts or to identify potential future provide BLM analysis for 100% of the line. The BLM on some transmission lines in sage-grouse habitat have invested significant time and resources into in USFWS, who is the lead agency for these species. directives, guidelines and/or standard operating clearance in the future. impacts based on newly proposed activities. CXs should not require 100% analysis on these types of within its service territory pursuant to agency the development of workable solutions. Having procedures to implement the NEPA process can be processed fairly quickly, thereby allowing projects and should allow for appropriate levels of stipulations. BHE has monitored lines to assess different requirements or core area habitat successfully. Inconsistency opens doors for legal applicants to complete projects in a timely manner analysis based on individual projects. discourager effectiveness from 2012 through 2015, boundaries than states leaves the BLM vulnerable to challenges. A significant concern is when BLM while still ensuring natural resource protection. If indicating that perch discouragers are ineffective litigation with states and other stakeholders. decision makers avoid making decisions because the NEPA analysis on a proposed action proceeds a with a 2.4 higher perch rate, higher raptor and they are anticipating legal challenges. To avoid a reasonable range of alternatives, it reduces the corvid perching, and 93% mechanical failure. more protracted process, make a decision in a potential for legal challenges and subsequent project timely manner. delays. The agency must always keep in mind its fiduciary The agency must respond to public input by responsibility to the American public as it manages adjusting its plans in response to both public public lands for the benefit of All Americans. To this comment and relevant scientific information. end, collaboration and information dissemination should begin very early, and the agency should be as open as possible in promptly and widely disseminating information regarding proposed projects, and in providing adequate opportunity for meaningful public comment. The BLM should collaborate across offices and with The agency must base its decision on good science, as many stakeholder groups as possible in as open a rather than on political expedience. Such science manner as possible. This will ensure better land use must include ecological and wildlife considerations. planning and fewer legal challenges. The agency The agency must keep in mind that it is entrusted must always keep in mind that an open planning with the responsible management of the nation's process which relies on the best science available public lands for all Americans, for a wide variety of and which engages all affected stakeholder groups is sustainable uses as per both the 1971 FPLMA and necessary in order to best manage the nation's common sense. BLM lands cannot thrive or support public lands under its jurisdiction. these uses if the agency ignores good science. Economic values are also to be considered but not to the exclusion of environmental factors. The agency must also keep in mind that economic values are often dependent on ecological health. BLM could provide more training to its planning staff on the BLM NEPA process as defined by existing regulations, CEQ guidelines for NEPA, and the legal framework from established case law. In many cases, BLM planning staff do not have the knowledge and background required to guide the agency through a legally defensible NEPA process. Be willing to have work done by volunteers. Offer volunteer, internship opportunities as these are ways for BLM to get work done and for others to find out about BLM. Help in finding solutions, what can stakeholders do to help the process along? We ask that the BLM establish a step at the We strongly support the best practice of the BLM RMPs should provide a solid framework that guides beginning of the planning process where the agency vetting alternatives with cooperating agencies and leasing to areas with important deposits and ensures collects known existing information about a planning the public before issuing a draft RMP. By vetting an appropriate balance between development of oil area before initiating decisions about resource alternatives with cooperating agencies, the public and gas and sustaining other multiple uses of public allocations. This process would increase and stakeholders before issuing a draft RMP, the lands, including fish and wildlife. There need to be coordination and use of information provided by BLM is able to respond to feedback and refine a limits on how easily that balance can be overturned the state agencies and counties. By collecting draft RPM to a point more closely reflecting the when or if circumstances change regarding either information up front, such as known fish and wildlife critically important input it receives. This can easily development potential or the needs of fish and habitats, migration corridors, and energy resources, be accomplished while simultaneously maintaining wildlife. BLM should ensure that leasing locations, the agency will be better prepared to make special privileges of state and local cooperators. levels and terms continue to meet multiple use goals informed, data-based decisions and allocate by carefully monitoring achievement of planning resources in ways that minimize conflicts among objectives. Unanticipated impacts may require BLM stakeholders. to re-visit terms of availability for oil and gas leasing. Get material into the public's hands early. Make it accessible and not something we find out about because some intern in a lobbying firm in DC is searching thru the federal register or pops up because of a google alert. Get the word out to the public. Listen to the public's suggestions and if possible adapt BLM's procedures to incorporate suggestions. This allows for public by-in to the process rather than the feeling things are purposely hidden by BLM. By including the public and stakeholders in the process the whole way, all can see what is being done before it gets to the litigation phase. The BLM must use NEPA where science and public To streamline planning, the agency must start with opinion indicate. The agency has in the past tended the latest and best scientific and policy analysis, and, to under-use NEPA and has often attempted to skirt as trustee of the public's lands, it must also engage NEPA review for proposed projects and actions the public in its plans. If science and public opinion which do indeed have major environmental impacts. indicate the need for NEPA analysis, then the The agency must never skirt NEPA analysis or agency must conduct a full NEPA analysis. attempt to take shortcuts to such review. Such attempts to skirt NEPA will ultimately result in more legal challenges and poorer planning decisions. BLM could choose the level of NEPA analysis only BLM could consider beginning complex analyses after scoping comments have been solicited and directly following scoping, but prior to full NEPA reviewed. Current practice is for BLM to announce development. This could result in a more the level of NEPA analysis (EA or EIS) when manageable (right size) NEPA process and outcome soliciting scoping comments. This does not allow document. Starting complex analyses prior to for BLM to consider the level of public controversy preparing a full NEPA process could help streamline or other potentially significant issues that arise the length of time that cooperators are involved. during scoping prior to determining the level of NEPA analysis. Determining the level of NEPA analysis after scoping would allow the level of analysis to more closely match the scale of the action being analyzed. All BLM field offices should provide a 30-day public We believe the lease nomination process is review and comment period for Determinations of outdated and warrants review and refinement to NEPA Adequacy (DNAs), Environmental design a more comprehensive approach to lease Assessments (EAs) and unsigned Findings of No nomination that better comports with resource Significant Impacts (FONSIs) for oil and gas leases. management plan objectives and implementation. Currently, each state decides whether to offer a pre evaluation of lease parcels offered and then a 30-day public review of the environmental assessment. This will ensure BLM acquires public input upfront, which will obviate the need for additional environmental review and reduce or eliminate objections and litigation. BLM staff (including managers) must be honest and Trust can be built by using local governments' input While Congress must act on this, BLM must provide Consider reforming EAJA or policy so that when a Reduce the length of the EIS/EA planning and straight forward with the local government officials. and Land Use Plans that have been vetted through a Congress with real information about how the Equal special interest group litigates and wins over an decision documents. By drafting 100 - 1,500-page After several blatant lies to county commissioners, public process. While allowing all Americans' the Access to Justice Act (EAJA) is paralyzing the agency ideology in the name of conservation or documents, you are providing that much more permit holders, etc., trust is potentially impossible opportunity to comment and offer suggestions, to the point they cannot take the necessary actions environmentalism, that at least 50% of the monies information for them to file suit on. That large of to reestablish with that staff remaining in the office. input from the locally elected officials must be to meet their mission. The cost of planning, defense reimbursed for legal fees needs to be used for on- document cannot be followed and understood by Ex: Field manager requested funding from the weighted much heavier. of decision, payment of EAJA to plaintiff, next round the-ground conservation of that species or anyone but gives ammunition to litigious groups. County and the oil and gas industry to do a project of planning, lawsuits, etc. is a primary cause of the environment. For example, if a special interest indicating that they couldn't move forward without agency not being able to meet their mission, "to group files suit over Sage Grouse habitat, and is the funding ($300,000+). The County and industry sustain the health, diversity and productivity of the successful in winning the suit, that group must apply did not contribute but within two months, the public lands for the use and enjoyment of present a least 50% of the monies reimbursed to restoring project document was released with significant and future generations". This loophole provides or mitigating habitat for Sage Grouse. challenges for the County and industry that taxpayer dollars to fund special interest groups to appeared to be retaliation for lack of contribution. continually sue the federal agency. BLM should strive to be a good neighbor by doing BLM should publicly recognize the important role their part to prevent and eliminate invasive species. that permittees play in partnering to manage and improve lands. By clearly defining who is allowed to participate in the process and the weight their comments will carry. lOhis can be achieved by: i.Hbving from "coordinating" with state & local governments to "partnering" 2.Odding a consistency review for agencies & local governments 3.Ooving to weighted comments -- Those that have a tangible interest in the land and are economically affected ("affected parties") by the planning outcome should have a higher say in the process than those whom hold a purely physiological interest ("interested parties"). By adding tangible numbers and trigger points for requiring NEPA analysis. Og. an activity that constitutes a less than 10% change to current practice is should be categorically excluded. Economic analysis must be conducted and relevant Develop and adhere to reasonable timelines for to the community impacted. When an EA in Rio completion of NEPA analysis. Five to ten years is an Blanco County includes an economic analysis with unacceptable time frame and can only be Fort Collins, CO included (200 miles away, urban interpreted that some agency staff member does area vs very rural area made up of 75% federal not want to move forward with the project. lands, front range of Rocky Mountains vs western slope community), the analysis is useless. At best, we conclude laziness on BLM staff's part to gather local data, at worst we conclude there is a motive for including Fort Collins data that skews the results to benefit the staff's desired outcome. BLM should reconsider its position regarding the BLM should ensure consistency in access road installation of new power lines underground or requirements for permits which would allow access converting existing lines from overhead to for existing ROW-permit holders to conduct underground as a possible permit stipulation or operation and maintenance activities without mitigation option. Underground power lines have additional permitting or road closures. Inconsistency higher cost, reduced reliability, greater ground in the local field office requirements create disturbance during construction and repairs, longer challenges in efforts to improve, maintain, and outage periods for customers, and may not always ensure safety, reliability, and operational conditions, be feasible from engineering and operations through access to existing electric power lines. perspectives. Underground lines can conflict with Access to conduct current ongoing maintenance cultural resources while mitigating for species like work in order to improve reliability of the line and sage-grouse. For more detailed discussion of the also to repair or replace damaged equipment as environmental and engineering constraints needed is necessary to ensure safe and reliable associated with underground power lines (see operation. APLIC website www.aplic.org). EA's must be reduced to a size and scale that allow In 1987, The Executive Office of the President's for meaningful input. One hundred plus pages of an Memorandum to Agencies: Forty Most Asked EA are an indication there is a lot of fluff and CYA Questions Concerning CEQ's National included rather than "here is what we are Environmental Policy Act Regulations found at proposing" and "this is why". The length alone, https://energy.gov/sites/prod/files/G-CEQ- deters many local governments as well as private 40Questions.pdf #36 answers the question re: citizens from engaging in the process because it is How long and detailed must an EA be? The Council extremely intimidating and time consuming. They advises keep EAs to not more than -10-15 pages. are currently being developed in a manner that 36a. How long and detailed must an EA be? requires legal or specialized assistance for "...the Council has generally advised agencies to interpretation. keep the length of EAs to not more than approximately 10-15 pages." When a change is made to current practice without Unless significant changes occur, surveys should not performing NEPA; reinstating said change should have to be completed multiple times. not require NEPA. Or Example: Once an area has had an Or example: if AUMs on an allotment are archeological, paleontological, etc. study conducted suspended; they should excluded from NEPA for future studies should be conducted only if reinstatement. supported by substantial data. The BLM can build better trust with all stakeholders by ensuring it advances its statutory obligation to allow multiple uses on public lands while protecting natural resources in a timely manner. Balancing these objectives is the very cornerstone of the NEPA process. The process allows all stakeholders to have a voice at the table, provide reasonable public comment and proposes realistic solutions to potential impacts. Utilize Resource Advisory Councils (RACs) for meaningful input rather than using them as a box to be checked in the process. Follow their guidance if you are going to spend the time and money to convene them. They have not been effective for many years as their input has been brushed aside. Stay within the law. Focus on problem solving goals and actions. Remember to address all stakeholders, not just Any proposed action must consider the entire historically preferred ones. ecosystem effects. Shortcuts and short term benefits that undermine ecosystem resiliency should be Encouraging volunteer efforts means acknowledging More than anything else, changing that paradigm to In regards to litigation, the agency must understand It is also an intimidation tactic that has seen a lot of Improvements in outreach to stakeholders and dropped immediately. It may take changes to the Endangered Species Act Given the litigious nature of land use planning it may NEPA originally envisioned Environmental Impact during planning processes that people and one of acceptance of public participation will go a that it is a tool used by some organizations to success in recent years and has become an members of the community may not stop litigation, that are above this effort to achieve the goal of not be possible to streamline the process any more Statements to be no more than 300 pages. This recreation have an integral right to enjoy pubic land. long way to help revive the BLM's reputation with influence land use planning.. important source of funding for some non but may lessen support for that litigation. reducing litigation but that doesn't mean that BLM and retain legally defensible decisions. This really practice has long since been abandoned, but stakeholders. governmental organizations. efforts to improve outreach and transparency needs to to be asked from legal experts to perhaps doing smaller, discrete analyses will allow should be abandoned or perceived as ineffective determine the size of documentation needed for for less voluminous documentation. legal defense. Planning efforts should strive to plan consistently Provide a presumption that historical usages of an Avoid planning based on decisions or information across agency boundaries and insure that the goals area will continue unless there is a scientifically valid that has been declined to be applied by partners. and objectives of the process match the scope of reason to change the usage of the area. ACEC or WCA should not be based on modeled guidance given. Regional plans should provide species habitat that was already not utilized by regional standards that streamline local planning and partners. not serve as a replacement for local planning. Do not allow federal lands planning to become a Planning efforts should strive to remain consistent replacement for an Endangered Species listing effort with the scope and objectives of the Process. with the US Fish and Wildlife Service Avoid the artificial elevation of small planning issues Travel management planning must occur at the into large planning issues. most local level possible BLM recognition of the USFS determination that winter travel is different than summer travel. The Organizations submit that a formal recognition by the BLM of the recent US Forest Service determination that winter over the snow travel and summer travel on federal public lands are significantly different planning issues and often provide different recreational opportunities highlights an opportunity where significant cost savings could be obtained. The Organizations submit that such a determination would further many of the local determinations that have been made as most users are not aware of BLM management of an area for winter recreation as a result of the Service First principals. decisions based in scientific and factual information bringing stakeholders into the process early utilize science based information for decision making Prepare Supplemental Programmatic Geothermal EIS: BLM should prepare and issue an updated Supplemental Programmatic Geothermal EIS (SPGEIS) for commercial geothermal leasing and development as well as related transmission. To the extent possible, refer to the new SPGEIS as adequate environmental review in order to avoid additional duplicative NEPA exercises. This SPGEIS should be used to establish "Geothermal Energy Zones," regions where geothermal resources are strong, utility-scale development is encouraged and the SGPEIS would be deemed adequate environmental review for at least initial exploration activities. Establish CX for most Geothermal Casual Use (CU) activities: BLM should declare that CU permits are not needed for most noninvasive geothermal exploration activities. Casual Use is an action on Federal Lands that causes no disturbance. Geothermal developers need a Casual Use permit for many types of early exploration activities, such as aerial surveys with small drones, sampling existing water wells, etc. All federal lands are open to Casual Use by the public with no prior notification, permitting, or approval from DOI. While CU permits are not especially difficult to get, they take 1 month on average. If developers can limit their CU burden, that would represent a real savings. Currently, the Planning Handbook emphasizes documentation of "disputes or controversies" without proper consideration of their factual basis. Developing strong data on recreation will more narrowly define disputes and controversies, leading to a more efficient dispute resolution and planning process. Stakeholders looking to engage in resource development frequently look to an RMP as the final word on recreation in the planning area, and when plan components are based on incomplete information, this situation is likely to lead to unnecessary conflicts because developers may erroneously assume that areas lacking specific documentation concerning their recreational value Investment in sound, thorough planning efforts with maximum stakeholder input is the most effective way to increase ultimate efficiency. Sound plans will enable more amendments to be developed at an EA rather than EIS level, ensuring that analysis is proportionate to the activity under consideration. Do more than pay lip service to the economic and Require professional certification, where available, Most of the litigation concerns procedural issues, Management programs on public lands impact and If BLM will prepare documents that propose actions Cease the practice of Sue and Settle. Once the More field staff time must be focus on collecting Reduce the size and scope of NEPA to include only cultural impacts of the proposed action on local of ID team members for those resource specialists not environmental ones. Federal employees should influence what can or cannot be done on associated based on reasonable interpretations of litigious organizations realize that practice no longer reliable/defensible data to support decision making data and analysis specific to the local area and the communities, landowners, and businesses. Sec. 102 for which appropriate certification programs exists, not have to be lawyers to do their jobs. If you BLM private lands. Public land actions affect not only the environmental laws and that have scientific and exists, they will stop filing frivolous lawsuits. process and NEPA analysis. This will ultimately lead action being proposed. Many NEPA documents [42 USC 4332] of NEPA requires that "proposals e.g. range management, forestry, soil scientist, goes to court on the scientific basis for the natural resources of the district but water rights, economic merit, local people and honest scientists to less litigation and staff time consumed. Rely more contain extensive reviews of literature or for legislation and other major Federal actions archaeologist, engineers, etc. decisions, you will probably prevail. To reduce tax base, and the general welfare of the people. will help BLM prevail over frivolous lawsuits. A on analysis/information and expertise provided by descriptions of the local environment contain significantly affecting the quality of the human frivolous lawsuits designed to delay action those Understand that coordination under FLPMA has winning record will help discourage appeals. agency specialist in development of preferred and material that is either not relevant to the project in environment" be analyzed and alternatives who appeal decisions should be liable for all court been validated several times in our federal courts other alternatives. Many times this information is question or has been amply covered in previous considered before being implemented. It was not expenses if they fail to win the appeal. and that, although perhaps inconvenient, it is the minimized or overruled by management for reasons NEPA analysis and need not be repeated. intended to prevent productive use of resources or law. Federal laws require local coordination in the that are not supported by any data analysis/scientific protect endangered species at any cost. planning and management of public lands. information and no supporting rationale. Conservation Districts and Counties are the logical entities to coordinate land management plans at the local level. Make it easier for states to share data--particularly Tribal governments should be encouraged to Greater collaboration and sharing of ideas, while Adhering to science-based decisions, considering wildlife management data--with BLM and vice versa. participate, and BLM should make special efforts to more time-consuming in the beginning, will result in ecological as well as economic values, truly balancing This would include the identification of wildlife reach areas that lack access to electronic fewer challenges in the long run and should help responsible development with reasonable migration corridors and other habitat data, and communications. avoid delays and lawsuits at the end of the process. conservation, keeping the public well-informed, and other scientific information that is important to providing adequate opportunities for participation hunters, anglers, and other backcountry recreation should also reduce lawsuits. enthusiasts. Do not encourage shortcuts that may make a plan vulnerable to legal challenge later in the process. Base plans on the latest information, science, and policy. Acknowledge and include informed public opinion in the overall process. If the science and/or public opinion point to the need for an environmental impact statement, then prepare one. ELLM should use designating legislation as the guiding documentation as well as approved BLM policies. For example...Non-discretionary designations made by the Secretary of the Interior, Congress, or the President are not established or amended through the BLM land use planning process. These non-discretionary designations would, however, be identified in a resource management plan, and management direction for the designation, including plan components, would be developed, consistent with the over-arching direction provided in the proclamation, legislation, or order through which the non-discretionary designation was established. BLM can refer to the language in FLPMA regarding BLM currently has multiple manuals in place such as special designations which states that BLM "shall Manuals 6250 and 6280 which guide the manage the public lands under principles of multiple administration and management of National Trails. use and sustained yield, in accordance with the land use plans...except... where a tract of such public land has been dedicated to specific uses according to any other provisions of law it shall be managed in accordance with such law." The NEPA process clearly outlines when the different gradients of analysis can and should be used. We strongly support following the guidelines NEPA outlines. Without setting specific limits on a range of analyses, BLM can define the right amount of analysis to match the scope of decision-making. This scope and scale may be defined geographically as a single field office, more than one field office, or perhaps more than one state. This scale may also be defined by the breadth of issues to be addressed. Programmatic NEPA and the flexibility for defining planning areas in FLPMA and BLM guidance support this approach. Utilize collaboration and innovative approaches to balance energy development with BLM's obligation to protect historic and archaeological resource. For example, a collaborative effort among the BLM, the New Mexico SHPO, archaeologists, tribes, and industry in the Permian Basin in New Mexico led to a Programmatic Agreement under Section 106 of the NHPA that has shifted practices away from an ad hoc system of "flag and avoid" for archaeological sites toward a comprehensive program that has greatly improved management of the area's archaeology while providing greater certainty and timeliness for industry. Establish a system for policy guidance development that includes opportunities for public review and comment, including for interim guidance. Extend or update guidance upon expiration so that the status of the direction is clear and implementation is appropriate. Perform systematic cultural resource surveys to Utilize block surveys to identify cultural resources develop better baseline documentation of historical prior to permitting decisions rather than relying on and cultural resource sites on public lands and their "flag and avoid" surveys later in the process. The significance. The Federal Land Policy and BLM should require (not just recommend) the use Management Act, the National Historic Preservation of block surveys with 40-acre minimums before Act (NHPA), the Archeological Resources permits are issued. Protection Act (ARPA), and several Executive and Secretarial Orders require BLM to conduct inventories of cultural resources, yet only about 10 percent of BLM-administered lands have been surveyed. Lack of survey and inadequate data can lead to costly and time-consuming modifications, as well as litigation, when significant cultural resources are identified late in the process or during project development. As appropriate, use programmatic environmental Conduct planning at different scales for different impact statements in conjunction with kinds of decisions. Many cultural landscapes stretch programmatic approaches to comply with Section across state, district, and field office boundaries and 106 of the National Historic Preservation Act, often overlap with areas of interest for energy and pursuant to 36 C.F.R. 800.14(b). Doing so provides mineral development. Effective planning should flexibility and increases efficiency of analysis for consider indirect and cumulative effects of ground individual projects in areas identified as having disturbing activities at the field, district, watershed, minimal conflicts with other resource values. The and landscape levels. BLM should utilize Master Programmatic Environmental Impact Statement Leasing Plans developed through a collaborative (PEIS) for utility-scale solar energy projects and process to help guide energy development and associated Programmatic Agreement under Section avoid and minimize conflicts with cultural and 106 provides an example of sound planning that natural resources. provides greater certainty for developers while assuring protections for landscapes containing important cultural resources. To ensure consistency with the Navel Petroleum At a minimum, exempt Alaska from Wild Lands Exempt Alaska from the BLM policy directive to To ensure accurate and consistent interpretation See "Right-sized Planning Areas" and "Travel Reserves Production Act of 1976, which applies to Secretarial Order 33 10, which conflicts with several conduct agency-directed wild and scenic river and implementation of ANILCA, work cooperatively Management Step-down Plans." the National Petroleum Reserve Alaska, and FLPMA, provisions in ANILCA that apply to BLM wilderness reviews during the RMP planning process, affirming with the State of Alaska to develop comprehensive promulgate regulations for integrated activity reviews and exceptions to Wilderness Act direction in ANILCA that allows only ANILCA regional guidance for Alaska that can be planning or revise BLM policies to exempt prohibitions, resulting in BLM multiple use lands congressionally authorized reviews. applied to planning efforts and other management integrated activity plans from regulations and being managed more restrictively than designated actions. directives that apply to resource management Wilderness. Reinstate former Interior Secretary planning, such as wild and scenic river reviews, and Gale Norton's Alaska Wilderness Review Policy, directives that implement the Wild Lands Secretarial which authorized wilderness reviews in Alaska only Order (3310). when there is broad support by the State and Federal elected officials representing Alaska. BLM should make early involvement in planning a Adhering to science-based decisions, considering standard part of agency practice, which would ecological as well as economic values, truly balancing emphasize the value of such engagement as it is responsible development with reasonable likely to result in better alternatives, more conservation, keeping the public well informed, opportunities for stakeholders to discuss and providing adequate opportunities for participation resolve major differences early in process, and less should also reduce legal challenges to agency risk of appeals and legal actions later in the process. decisions. There is good evidence that early and ongoing public engagement can shorten the planning process. Flexibility in Geographic Scale - improvements Allow flexibility for BLM managers to broaden should facilitate appropriately scaled plans, including planning to the district or multi-field office level as plans for areas that cross state lines or other needed to better address cross-boundary issues and jurisdictional boundaries. This could reduce simplify the number and complexity of RMPs. problems caused by arbitrary administrative boundaries that do not line up with ecological boundaries. It could also facilitate effective regional or off-site mitigation by enabling agency staff to coordinate more effectively between where the impact is occurring and where mitigation actions take place. In addition, we suggest that the BLM include examples for regional resources such as groundwater aquifers in the planning handbook. BLM should conform to state and local laws as this is the peoples government. Including tangible numbers/percentages and triggers Developing solution alternatives that are the least for requiring NEPA analysis. contentious, while also being the most inclusive of multiple-use objectives. Including weighted measures during the scoping Stakeholder Experts of subject matter should be period for predetermining the scale and size of the consulted while determining the greater impacts of item in question. This would simplify further analysis a project or action for the purposes of establishing because the size and scope has been predetermined. the size and scope. While also bearing in mind that renewals have been previously vetted and do not require to the fullest extent the NEPA process. BLM should require that ID/NEPA team members The economic impact of a project should be given in- Litigation opportunities are reduced when and resource specialists be professionally certified depth analysis that is inclusive of the long-term procedural requirements are clear. BLM should when appropriate certifications exist (i.e. range economic impacts. Similarly, BLM should publicly simply and clarify the procedures for preparing management, forestry, soil science). Membership in recognize the important role that permittees play in NEPA documents and for complying with the ESA. advocacy or litigious organizations should either be partnering to manage and improve public lands. This should include tangible numbers and trigger forbidden for BLM personnel, or fully disclosed BLM should also conform to State laws. For points for requiring a NEPA analysis - for example, when they participate in NEPA analysis. example, if a State's range law dictates that it is a an activity that constitutes less than a 10 percent "fence-out" state, BLM should conform to the fence- change to a current practice may be categorically out rules. BLM should also strive to work with excluded from a NEPA analysis requirement. states by participating fully in preventing and eliminating invasive species. Not all public comments are created equal. Comments from stakeholders with a tangible interest in the land and who experience economic consequences from land use decisions should be assigned more value than comments from those who hold a purely incidental interest in the land. Similarly, in order to prevent frivolous litigation, litigants who unsuccessfully appeal BLM decisions should be liable for court costs and legal fees. Inconsistencies identified through the coordination Permittees should be included in all communication Scientific literature or studies that are cited in an EA There should be categorical exclusions for process should be included in the Draft EA, the EIS, between BLM, USFWS, and any other involved should be restricted to those specific to the area, reissuance of permits when no substantial changes and et cetera. Currently, this information is placed agencies, regarding the permit or project analysis. ecosystem, or action in question. The number of have occurred. For routine and accepted actions, only in the Final document, if it is published at all. Too many times, our producers have been on the alternatives considered in an EA should be such as building a fence, it should be acceptable to This is too late, ignores the intent of the losing end of the "finger-pointing game" while BLM restricted only to those that are feasible limit assessment to adherence to accepted best Coordination Statute, and fails to give stakeholders claims they're waiting on a USFWS decision, and economically and legally. Any alternatives that are management practices - these practices already take a meaningful opportunity to comment during the USFWS claims they're waiting on a BLM decision. contrary to BLM's mandate should not be included. into account current requirements that archaeology public comment period for the Draft. This can delay a project for years, and often and endangered species be protected. Focus should requires the permittee to file FOIA requests in be placed on environmental and economic costs order to see the communication in question. when there are known issues of concern within that specific planning area. To build trust, you must be trust worthy. The BLM A neighbor is one that is situated near another. If the BLM had better communication with the needs to show the public that it cares and will try to The BLM needs to have offices near the various people, there would probably be fewer legal benefit the public. The people need to see that they places they oversee. They could be regional so that challenges. can rely upon the integrity and justice of the BLM. the BLM officers can actually learn to understand an area by living in or close to it. The BLM needs to take into account the views of the people and incorporate these views into their policies. By disregarding the people, there will be legal challenges. It appears that often the BLM follows the dictates of The BLM needs to listen to the people and Communicate and consult with the NEPA. politicians and those out for personal gain rather understand their viewpoint (s). They should try for than protecting the public lands and the things living a compromise when issues arise. on these lands. Until the BLM really takes into account the voices of the people and protects our public lands, there will be legal issues. Share information. Emphasize and recognize past, present, or potential In every plan, proactively and meaningfully address Re-focus BLM policy and regulations to emphasize Require the BLM use or deferentially consult the Preemptively limit legal challenges from inholders Proactively and respectfully engage adjacent state, For reviews of proposed actions or development Raise the threshold for the use of "mitigation" actions that "avoid" and "minimize" harm, requiring access needs to private, state, other federal and non- multiple use and sustained yield management states and the U.S. Geological Survey, Department and adjacent land owners by narrowing local, and private landholders early in the planning plans, use the minimum analysis necessary and the measures. Limit mitigation measures only to additional "mitigation" from a permittee as a last federal inholdings across BLM-managed lands, principles. Policy and implementation should of the Interior's independent science agency, to management plan areas to smaller regions consisting process, even before deciding on planning area simplest practicable analysis for the scale of the proposed actions and activities which cannot resort. When it is required, prioritize approval of including: access guarantees under state-specific encourage use of the public lands rather than focus develop background materials, surveys, and reports primarily (>80%) of BLM managed-lands. Use boundaries, and ensure they are meaningfully proposed project. Examine the use or lack of use "avoid" and "minimize" and which would result in mitigation that can be undertaken by the permittee, legislation (ANCSA, ANILCA), national legislation on forbidding activities or segregating uses in prepared on physiography, soils, geology, hydrology, statutory and regulatory provisions for access as consulted at every step of the planning process. and the broad availability of Categorical Exclusions. major or significant losses or impacts. Clearly preferably on-site or within a reasonable distance of (RS-2477 rights of way), historic/known routes, different times or areas without demonstrated user ecology, minerals, hydrocarbons, vegetation, wildlife, intended. Reduce the scope of plans and policies to There is a considerable loss in trust that stems For uses that currently do not fall within a define the level of impacts and "losses" that require a permitted activity, rather than defaulting to transportation/utility corridors, etc. Especially over conflicts. Land use plans should evaluate and and habitat for management plan areas and in the reflect only the issues which directly affect BLM- directly from superficial or condescending Categorical Exclusion, consider whether season or mitigation measures. requiring arbitrary financial payment to a mitigation the last 5-10 years, the theme has been to identify address all possible land uses including grazing, regions of proposed projects requiring permits, managed lands. engagement in plan development that may require size limitations might qualify them. Be clear, bank or to fund agency initiatives outside the areas where access should be limited due to locatable and leasable mineral development, logging, leases, or plans of operation. lasting and detailed direction to ensure consultation consistent, and reasonable in applying Categorical appropriations process. Take care to ensure that perceived and marginally supported impact threats. natural resource exploration, access, subsistence, with affected property owners is duly reverent and Exclusions and in determining whether additional monetary mitigation is not duplicative of fees An approach that focuses on access needs instead of infrastructure, agriculture, as well as recreational effective. NEPA is required. The Alaska State Office has done collected under "cost recovery" and bond barriers, and on verifiable resource issues, is more uses. a good job with this on a state-specific level, which programs, while being mindful of fees excised by consistent with the BLM's mandate and will result in may be instructive in a national effort. sister agencies. better access and fewer impacts. Reframe the permit submittal and review process to Facilitate a purposeful return and renewed fidelity Respect the Governor's Consistency Review process Establish in regulation, or via the CEQ, or work Require agencies participating in permit evaluation Require all BLM resource management plans, land All existing and proposed ACECs should be There is noticeable inconsistency in the resources be a cooperative discussion between the applicant to multiple use and sustained yield mandates. Focus as a substantive consultation with a sovereign entity, with Congress to craft statutory amendments that to share data, background materials, preliminary use plans, permits and regulations clearly list which reviewed by an independent panel external to BLM, considered and acreage set aside to "protect" and the BLM. The permit process should focus on in recent years has been heavily in favor of with constitutional and statutory obligations of its require all federal processes related to a single conclusions, etc., in order to prevent duplication of laws provide statutory authority and for which such as an expert or academic advisory board, for identified resources (e.g., a few sq. kilometers to agreeing on the conditions and circumstances under preservation and protective status based on own, and provide duly robust and detailed proposal or application be performed concurrently effort and provide timely and defensible resolution provisions, describing how the action taken is consistency and verification of the "relevance" and tens of thousands, based on similar or identical which a member of the public can operate on the arguable and largely anecdotal threats to area responses to any perceived disagreements. to the extent practicable. Procedures pursuant to of permit requests required to satisfy noted obligations responsibly and "significance" criteria used to justify designation. justification). A state-by-state and nationwide public lands, not an antagonistic dictate of resources. For example, the solicitation of ACEC authorities under the Endangered Species Act, with the least effective burden on the regulated Such a panel should include expertise in geology, review should rigorously define the meaning of regulations and stipulations intended to preclude nominations early in the Central Yukon Resource Marine Mammal Protection Act, National Historic public. natural hazards, hydrology, botany, fish and wildlife, "''relevant" and "significant," limiting application of public use. Management Plan process resulted in over 50 Preservation Act, Clean Water Act, Clean Air Act, and other specialties indicated by eligibility criteria, the criteria to only those areas of "critical" concern, nominations covering over 35% of the planning area. and many others (e.g. 404 permits, biological as well as at least one representative with a keen and recommend ACECs no longer in need of The majority of proposals appear to be moving opinions, ambient air monitoring) should proceed understanding of the area at issue. designation. forward, even though the detailed resource simultaneously and in an order which provides the inventories, data reviews, and other analyses shortest time route to completion of the entire inherent in the planning process have not been project review. . completed or made available for review. Require nomination periods for ACECs and similar land use designations include the ability to nominate existing areas which can be considerably reduced in size or eliminated. Private citizens must sign non-collusion affidavits when working on FACA and other state and local committees and commissions, with penalties. Federal and state employees should be held to the same standards. Recognize that some organizations are going to Create a culture within BLM offices that encourages Create good land use plans that cover most site- appeal no matter what BLM does. Stop trying to BLM employees to work to on building successful specific actions. The best way to avoid a lot of placate them. Build good documents even though relationships with stakeholders and working out appeals of small projects is to cover the small they will be appealed. If they are good enough, BLM solutions that reduce NEPA and avoid appeals. project NEPA requirements with large NEPA will prevail and set precedent that reduces the long Build a culture that discourages employees from documents. Few NEPA documents means fewer term total of appeals. feeling disenfranchised to the point that they work appeals. closely with litigious groups. If employees feel that their only way to be heard is to help with groups appeal the documents they worked on, there will be a continuous loop of litigation and frustration. Build a culture that rewards good actions and severely punishes employees that financially benefit from appeals against BLM. Better land use plans will reduce the number of small project EAs. Better big documents will reduce the number of NEPA documents. The "right size" question may be answered by working towards the "right number". BLM should also start a dialogue about how best to One of the key challenges that communities and plan and work across jurisdictions that meet the landowners face in engaging with the federal other agency needs. Examples include watershed agencies is the high rate of personnel turnover. and forest health, enhancement of water quantity Providing "advance in place" options and requiring and quality for community use, development of the use of hand-over memos to document economic opportunities within the area, etc. community engagement, collaboration and findings could help to alleviate this challenge. As we highlighted in the first question, doing analysis In addition, true collaboration can dramatically thoroughly the first time can avoid litigation, delays reduce litigation. The agency should conduct a and costs in the long run. It is also critical to thorough review of known collaborative planning monitor the implementation of RMPs and/or and NEPA efforts that have resulted in resolving programmatic documents and adapt and make difficult resource issues, competing uses, etc. It adjustments as needed along the way. should then produce a report on what the results are and why the efforts were successful in precluding litigation or reducing litigation. Numerous collaboration studies have been BLM should explore the use of alternative dispute conducted that highlight what is necessary for resolution vs. automatically deferring to the court successful collaboration. Much of this is built upon system. Best approaches that other agencies and trust, relationship building, buy in, etc. This is not a organizations are using should be researched and fast and efficient process but once developed will explored before deciding the best process to be streamline future efforts, particularly at the local used. level, and reduce litigation risks If BLM has current RMP's and programmatic This will be particularly critical in land health documents that have been thoroughly and restoration activities. If public lands are not healthy rigorously analyzed they also have built a foundation and as a result, prone to disease infestation, invasion from which subsequent NEPA processes can be of monocultures of non-natives, severe fires, severe streamlined. This can take multiple forms but soil loss, deterioration of community water quality without that foundation the agency will never be and quantity, etc. then the management activities successful in implementing a streamlined approach associated with restoring land health should be the as it will be successfully challenged by the public and primary focus and concern. courts. Planning area leaders should attend local county commission meetings at least monthly if not more frequently, and go to lunch with them. Shorten the time needed to process project requests including APDs. And every and now and then admit when you're wrong. County commissioners would fall down faint and then get up and trust you more. Reform EAJA in a major way. This is the engine that Get legislative help to set clear objective bench drives most litigation: the hoped for pot of gold marks of what constitutes a valid EA, FONSI, and through an EAJA payout. Also consider giving local EIS with its sub-documents like Scoping report, government EAJA rights to recover attorney fees Range of alternatives, and impacts analysis. when they prevail in litigation with a federal agency, and/or recover against an NGO who files a frivolous action. Overhaul the IBLA and Administrative appeals process, to greatly shorten the process. Purge the DOI of the many ALJs who are in the tank for the enviro NGOs. Use local people to speak for you INVOLVE the communities -- pre-test your ideas be on site to speak to local people See prior responses. Get legislative support for objective markers on all NEPA docs in terms of page length, and certain criteria. provide as many alternatives as possible Ask a scientist request QUESTIONS & COMMENTS