The Board of County Commissioners has taken a strong stand in opposition to national planning rule changes proposed by the Bureau of Land Management, saying they will negatively impact county interests and citizens.
The commissioners contend the proposed Resource Management Planning Rule (also known as Planning Rule 2.0) fails in its aim to modernize agency resource management planning in four key areas:
1) The proposed rule violates public lands management policies and practices of long standing, and also violates current federal law;
2) The proposed rule would adversely affect the policy of multiple use on public lands by creating special priority treatment for recreation and other activities at the expense of economic resource use;
3) The proposed rule de-emphasizes local input into public lands planning decisions;
4) And the proposed rule would ultimately cause harm to Delta County's agriculture-based economy that relies on access to public lands resources for human economy sustainablility.
In its comment letter on the proposed rule to the BLM's Washington office, the BoCC expanded on those four main points as follows:
• Commissioners believe the proposed rule "outright violates the multiple use balance by allowing for single issue versus multiple use planning in formulation for a Resource Management Plan." The proposed rule "fails to meet the regulatory mandate of the Federal Land Policy and Management Act (FLPMA) on several counts; specifically on the multiple use and sustainable yields clauses."
Multiple use of public lands has long been the cornerstone of Delta County's position on public lands issues.
• The BoCC also states that, "The proposed rule would fundamentally reorient federal land-use planning by de-emphasizing [the current federal law] focus on multiple use and sustained yield." In its place, the proposed rule would favor "enhanced prioritization and response to short-term political expediency and non-stakeholder involvement" in public lands policy decisions."
The commissioners state that they and other Western counties do not support the concept of "Areas of Critical Environmental Concern (ACEC) during the planning assessment period." That is because "the multiple use standard required in FLPMA is violated by the inclusion of the ACEC process."
• Further, the proposed rule all but eliminates the requirement that Federal land use planning be "consistent with state and local plans." Instead, the proposed rule would require that state and local plans receive "consideration" in the federal planning process.
The proposed rule places an emphasis on "landscape scale" management. This, the BoCC believes "erodes local input by removing authority from BLM state directors and field managers [and] necessarily concentrates all land use planning in Washington D.C.
Other stipulations in the proposed rule "place BLM in position as the sole determiner of whether local government land use plans have been properly "approved and adopted," and so acceptable to BLM for consideration in planning.
The proposed rule places additional burdens on local governments. It shortens the time period that local government staffs have to review and comment on complex rule changes, in some cases by as much as half; and, it elevates the role of non-governmental organizations such as special interest groups to equal with that of the elected government officials in land use planning.
The proposed rule diminishes the role of counties as cooperating agencies in formulating land use policies and plans. And another of the proposals would shift responsibility onto local government to demonstrate that agency plans are inconsistent local ones.
• The county commissioners caution that the rule will ultimately hurt the county's natural resource and agriculture-based economy. The proposed rule adds a mandate for preserving and protecting public lands "in their natural conditions." The term "natural condition" is not defined and as such is the functional equivalent of withdrawing public lands from resource development economic uses." The county's letter also states, "Use of the undefined term 'natural condition' appears to be an invitation to curtail and exclude historic livestock grazing use and practices on BLM [managed public] lands."
Also, in future planning, consideration of impacts to local economies will be downgraded in favor of management decision based on "the quality of scientific, scenic, historical, ecological, environmental, air and atmospheric, water resource, and archaeological values of public lands," the commissioners state. And, "consideration of economic impacts to local economies will be diluted" by considering them in a national economic context.
"Delta County respectfully suggests that it is unreasonable and a suspension of common and legal sense to assert that the proposed rule will have no significant effect on the human environment," the letter states.
The commissioners admonish BLM to "appropriately consider its multiple use objectives to provide for Western counties and their respective economies."
In conclusion, the county requests a through reconsideration of the proposed planning rule. "Because of the concerns outlined in these comments, we request that the BLM revise the proposed rule to be consistent with its authority and obligation under the Taylor Grazing Act, FLPMA, the Multiple Use-Sustained Yield Act, and all other applicable statutes."
The BLM's Uncompahgre Field Office is hosting public meetings on its own, long-awaited draft Resource Management Plan this week and next in Hotchkiss and Delta. The UFO confirmed that if the proposed rule is adopted nationally that it will apply to planning processes, such as drilling applications, and amendments to the finalized UFO Resource Management plan once it is adopted.
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