BLM Rule Proposal May Devastate OHV Use on Public Lands

The BLM is considering a rule that could devastate our access to public lands. Watch this short video from Ben Burr at BlueRibbon Coalition to learn why you should be concerned.

The BLM is accepting public comment until June 20, 2023 on a proposal to adopt the BLM Conservation and Landscape Healtlh Rule BLM-2023-0001-0001 (Click to see the entire Highlighted Rule) which could lead to massive restrictions for public land access across all lands managed by the Bureau of Land Management. Following is an article that explains the basis for our concern, and will be used by UPLA as a starting point for comments to be submitted.

I enjoy accessing and recreating on public lands. I believe BLM managed lands are crucial to the health and well being of our country. Access for many different user groups is crucial. I am writing to provide feedback on the proposed conservation and landscape health proposed BLM rule. I do not support the rule as it stands and believe it will be detrimental to public land across the United States. I think FLPMA, as it stands does a sufficient job in directing management of our public lands and should not be altered with the proposed changes.

Conservation is already rooted heavily in land management, and does not need to have additional complex levels of rules that would benefit wealthy organizations rather than the US Citizen. The rule establishing that “conservation” be defined to include both protection and restoration is especially troubling.

There should not be a stated objective of BLM to prioritize designating new ACEC’s, which are often used to restrict public access. There are already substantial methods in place such as congressionally designated Wilderness and Wilderness Study Areas which restrict land management uses, and there should not be more prioritization for designations of land that could harm use such as ACEC’s.

The broad use of the terms “intact, native habitats” and “degraded landscapes” are troubling, vague, and unclear. Theoretically, if a person ever walked on land and left a footprint, that land could be defined as a “degraded landscape” or one that is no longer intact or native. These terms are used in key recitals in the document, without any definition of what they actually mean. Page 10 states “The proposed rule would define the term “intact landscape” to guide the BLM with implementing direction. The proposed rule (§6102.1) would require the BLM to identify intact landscapes on public lands, manage certain landscapes to protect their intactness, and pursue strategies to protect and connect intact landscapes.” Although the rule states that BLM would define the term, there is no definition present. The same is true with the terms “landscape” and “intact landscapes” on Page 11. There are many other instances of terms that are not clearly defined in the document, which means the definitions and intent of the rules will have to defined by the courts and the teams with the best lawyers.  

The proposed conservation leases make it possible for entities to essentially buy off our public lands for their own selfish purposes. The BLM should not be selling the land through these leases to the highest bidder restricting all other forms of use on public lands that benefit our nation in various ways. Only the best funded entities will have a chance to qualify and buy these leases, again removing the majority of users from participating.

We are extremely concerned that conservation extremist groups, such as Sierra Club and SUWA, would have the financial resources to bid on these leases to “restore” the land back to it’s natural condition, and to develop their own plan to “mitigate” the conservation activities by restricting access. Although the term of the leases is limited to 10 years, there are extensions allowed until the outcome is achieved. Based on prior experience, this would include removing roads and dispersed camping, which is the path to having the area declared as a Wilderness area resulting in even broader access issues.

It is also likely that this rule will be utilized as a tool for socioeconomic class discrimination. It is already common for conservation easements to be used by wealthy landowners in gateway Western communities to prevent development and turn these communities into enclaves for billionaires. The subject of this as a tool for wealthy or prospective landowners has even reached media in the Yellowstone Series. Conservation leases are used as a tool to keep the middle classes and working classes away from what eventually become private nature preserves for the wealthy. To spread this toxic outcome across the hundreds of millions of acres of BLM land is completely misguided.

The adoption of Conservation Leases should be stricken completely from the proposed rule.

Conservation is already used to restrict, regulate and deny access to public lands. By codifying conservation as a use, environmental groups will be given even more power to lock out the public from public lands. Lands are already sufficiently being conserved by various laws and Executive Orders such as NEPA, Clean Air Act, Clean Waters Act, Antiquities Act, Endangered Species and many many more. I do not believe the proposed rule is warranted or necessary. In order to gain better compliance, less complexity is needed in rulemaking, not more.

The rules requiring decisions be evaluated based on complex “high-quality science” removes the ability for all but the most well funded organizations to submit their “evidence.” Science is a study, and is generally composed of all different views of a subject. By codifying this as a requirement, it eliminates lesser funded organizations and citizens from making substantive comments that may represent a less restrictive approach to conservation. It has long been stated that if the consequences are high enough, you can always find an expert to testify on your behalf. This rule is simply not needed and will again remove the ability for users to participate in substantive comments.

Economic effects must be considered and analyzed. BLM needs to more fully analyze the effects that would result from the proposed rule. Recreation is a huge economic driver across BLM managed lands as well as other uses such as grazing and mining. These changes could greatly affect access in general for all users on public lands and that analysis and data needs to be available to the public to submit thoughtful comments. The BLM also needs to fully understand the depth of the effects from the proposed rule.

Every time motorized routes are closed, people with disabilities that require the use of motorized means to access public lands are barred from those areas forever. In the past, there has been little resource available to people with disabilities because the American with Disabilities Act does not require public land management agencies to consider disproportionate effects on the disabled community, requiring only that there is equality of opportunity. This has resulted in the BLM’s historical failure to give any real impact to the effects on the disabled community.

On his first day in office, President Biden issued an “Executive Order on Advancing Racial Equity and Support for Underserved Communities Through the Federal Government” This changed the equation, now requiring focus on equality of outcome rather than the prior equality of opportunity. Allowing closures of public lands through any of the methods outlined in the Rule will further the longstanding discrimination towards American with disabilities within federal land management agencies. The entire rule should be eliminated from consideration entirely because it will adversely impact disabled users in their outcome of enjoying public lands.

It is also likely that this rule will be utilized as a tool for socioeconomic class discrimination. It is already common for conservation easements to be used by wealthy landowners in gateway Western communities to prevent development and turn these communities into enclaves for billionaires. The subject of this as a tool for wealthy or prospective landowners has even reached media in the hit television series “Yellowstone”. Conservation leases can be used as a tool to keep the middle classes and working classes away from what eventually become private nature preserves for the wealthy. To spread this toxic outcome across the hundreds of millions of acres of BLM land is completely misguided.

The Federal Government already has enough protections available to protect our available resources, reject this Rule in it’s entirety. 

Please submit your comments to prevent this rule from taking place with these sweeping changes. We encourage you to submit your detailed comments in either of 2 ways.

  1. Use the BlueRibbon Coalition’s Action Alert. Please edit to include your personal concerns in your comments.
  2. Federal eRulemaking Portal: Click on this link to take you directly to the Comments page for this action. If this link does not work, go to https://www.regulations.gov. In the Searchbox, enter “1004-AE-92” and click
    the “Search” button. Follow the instructions at this website.

Thanks in advance for your support in taking action against this proposal.

Remember,

Together We Can Win,
But We Can’t Do It Without You

Loren Campbell
President

Learn How You Can Help Us Achieve our Mission at http://www.UtahPLA.com/help




BLM Warner Valley Land Exchange Resolution

Thank You For Helping

Save Sand Mountain!

When we come together, we can accomplish great things. The proposed BLM Sand Mountain Land Exchange posed a serious threat to both the OHV community and Dispersed Campers that used Warner Valley. When we raised a Call to Action to the Community, nearly a thousand of you turned up at the St George Library for BLM’s scoping meeting with only 4 days notice. Hundreds of you submitted scoping comments, including some of the most substantive comments I’ve ever seen. Your response set the stage for how committed the OHV community was in protecting Sand Mountain and helped us immensely in negotiating with BLM, Washington County Water Conservancy District (DISTRICT), and the City of Washington.

The team that negotiated on behalf of the OHV community consisted of Jeff Bieber from DRATS, Ben Burr from BlueRibbon Coalition, Milt Thompson from Dixie 4 Wheel Drive, Steve Jacobs from Tri State ATV, Steve Maxfield and Casey Lofthouse. I had the pleasure of leading the team as the representative from Utah Public Lands Alliance. Together, we spent many hours, weeks, and months strategizing and meeting with 4 different government agencies to find a mutually agreeable solution.

I must recognize the leaders of the agencies for taking the time and effort to understand our needs and respond to them. Jason West, BLM Field Manager was always quick to respond to our inquiries and set up our initial meetings with the DISTRICT. Mayor Nanette Billings from the City of Hurricane setup our first meeting with the City of Washington, Mayor Kress Steheli. General Manager Zach Renstrom and Attorney Morgan Drake from the DISTRICT spent many hours working with us and refining the agreement and working document. Both Mayor Steheli and Jason West went on field trips with Jeff Bieber and I to tour to affected parts of Sand Mountain, and to show them the work the OHV Community has done on Sand Mountain. Morgan Drake and Zach Renstrom organized a field trip in UTVs for DISTRICT staff and Board members to view the mountain for themselves. They got a first hand experience of why we’re so proud and protective.

Last night, the DISTRICT Board passed a Resolution unanimously that identified the protections the OHV Community needed, as well as limited protection for Dispersed Camping until we can find another option. The Resolution, Map and Press Release can be seen here.

As stated in the Board Meeting last night by Morgan Drake and Mayor Kress Steheli from the City of Washington, this has been an excellent example of how difficult land use decisions can best be worked out when everyone sits at the table and work together to find a solution.  Is it a solution that everybody got everything they wanted? No, that only happens in fairy tales. Is the work over? No, there’s still work to be done in the coming months-but this was a very important milestone for us because BLM will insert these conditions into the terms of the Land Exchange if it is approved.

We still have several review processes to complete with the NEPA process, and we’ll be asking you to reengage as those came up. But a sincere thank you to everyone that participated in this effort for a successful outcome.

Remember this for the future…

Together We Can Win,

But We Can’t Do It Without You

Gratefully and with Sincere Appreciation,

Loren Campbell
President
Utah Public Lands Alliance

Learn How You Can Help Us Achieve Our Mission




Watch our Youtube Update on the BLM Sand Mountain Land Exchange




Sand Mountain Land Exchange Questions and Answers

Join UPLA and DRATS for an update about the Sand Mountain Land Exchange, and get your questions answered. Loren Campbell from UPLA and Jeff Bieber will be taking your questions via chat during the call.

We are getting great comments being submitted, but like anything of great importance, there are lots of rumors that we want to do our best to answer.

This Zoom event is limited to the first 100 people, but you must preregister. Register Here

If the event fills up, we will either post the recording or reschedule a repeat session.




Updated Scoping Comments April 7, 2023

Scoping is underway for the proposed Land Exchange for the Washington County Water Conservancy District to obtain 1050 acres of land from the Western portion of Sand Mountain OHV area near Warner Valley. Part of this may be to provide land for the new reservoir, to which we have no objection, but we are in opposition to the addition of the land east of Warner Valley Rim which would affect West Rim and Ridgeline Trails. We are also opposed to the loss of disbursed camping in both Warner Valley and on the Pipeline Road. The camping on Pipeline Road is incomparable for the remote locations and incredible views, and is truly irreplaceable. You can learn more about the latest details at www.UtahPLA.com

What is Scoping? The National Environmental Policy Act (NEPA) requires the Bureau of Land Management (BLM), to involve the public in the planning process and seek their input through a scoping process, which is one of the first steps of the process. It will be followed by BLM’s preparation of a draft Environmental Assessment (EA) , and you will have another opportunity to add substantive comments. Effective NEPA scoping comments for BLM should ask these kind of questions, some thought starters have been included in italics, but come up with your own questions, please don’t just copy this list, put it into your own words.

  1. Provide specific information about the proposed action, including its location, purpose and need, and potential environmental impacts.
    1. We understand the purpose of the reservoir use, but what is the purpose of the large acquisition east and north of the reservoir?
    2. We asked the Water Conservancy District and City of Washington what they plan to use the land for, and their response has been they have no plans or it’s too early to have thought about it. BLM should demand a clear direction from the City of Washington as to their involvement and precise plans for the future.
    3. My understanding is that the exchange has only the purpose of providing for the acquisition of the designated critical habitat for the Mojave desert tortoise. Although there has been much talk about the reservoir, it is my understanding that the proposal for the reservoir is only speculative, and it is not even mentioned in your public scoping notice. It is also my understanding that the BLM has determined in their EA that all 1047 acres of BLM land proposed for the exchange is also suitable for the desert tortoise population. Simple math would indicate that giving up 1047 acres of land proposed to be speculatively used for a reservoir in exchange for 89 acres would result in a net loss of 960 acres of tortoise habitat, which might actually hurt the desert tortoise population. This might be a simplistic view,  explain the science behind this exchange on how much the net effect of this exchange will be on the desert tortoise population.
    4. How specifically will it affect visitors and their economic impact to the region?
    5. Adjoining lands that are managed by different agencies often cause conflicts because of differences in rules governing that use, and law enforcement. If the “disbursed” camping is eliminated at Washington Dam, law enforcement issues may rise with those people desiring free camping will arise in other areas, i.e. our Waddy’s Corral staging area may have people trying to camp there, especially after we pave the road to it. Last weekend there were probably 250-300 people camping in the valley. Hurricane Area RV parks are expensive, starting around $75 and going up to $158 per night for the new Jellystone Park. Sand Hollow State Park RV camping is often full. Where are the people that have enjoyed free camping for many years in Warner Valley going to go, or will they be unable to continue the recreation they have enjoyed? This seems that it may severely impact low income communities. Provide your analysis of this problem, and the mitigations you suggest to solve it.
    6. Much of the increase in OHV recreation has come from UTV/ATV users that need staging areas to unload and park their machines. Where do they go if Washington Dam is closed? What will you need to do to prevent users from parking in unsafe or unauthorized areas? What law enforcement agency will be responsible for this?
    7.  What will be the Visual Resource Impacts of the exchange. Currently, most of Sand Mountain is classified as Class 2, but it appears from Map 2.14 in the BLM St George Field Office 1999 Recreation Management Plan that the West Rim is classified as Class 3. How will you ensure that the basic characteristics and visual appearance will be maintained if the exchange is approved?
    8. In the Agreement to Initiate a Land Exchange, BLM agreed not to encumber the land without first notifying WCWCD and giving them an opportunity to comment. This will affect all future  the consent of WCWCD. This affects all Special Recreation Permits to limit their term from the standard 10 year period to only 2 years. This further burdens the applicants and the BLM in the processing and review of new permits. What steps can BLM take to ensure this burden is not passed on to Applicants in extra paperwork, expense, and potential delays?
  2. Identify any alternatives that the BLM should consider, including no action, and explain why they would be preferable or less impactful.
    1. What other locations have been considered for the exchange located north and east of the reservoir? Explain why you came to the conclusion that this is the best of those alternatives.
    2. I have been told the reason for the expansion of 169 acres to the original proposed exchange was because a survey had already been done. How much would it actually cost to survey a better defined area?
    3. What alternatives have been considered that eliminate portions of the 1047 acres?.
    4. Have you considered replacing our area of concern with land to the south of the proposed reservoir location, where WCWCD is planning for recreation already.
    5. What other alternatives have you considered for acquiring the 89 acre Non Federal parcel?. Did you apply for a grant from the Land and Water Conservation Fund? What were the results of that application?
    6. If no action is recommended as an alternative, please provide precise details what that means.
  3. Highlight any potential significant impacts that may result from the proposed action and suggest ways to mitigate or avoid them.
    1. Without knowing what the new use will be, how will you clearly analyze potential impacts or mitigations.
    2. How do you propose to resolve impacts such as user conflicts between OHV and development, noise or traffic concerns.
    3. Although WCWCD does not want to manage the area for recreation, they indicated that their intent is that recreation would be allowed and managed by another agency. What types of commitments would bind these other managers to abide by the terms of any agreement with the OHV/Disbursed camping communities?
    4. Although a State Park, California’s Oceano Dunes OHV users have been attacked by new residents building communities adjacent to the Dunes because of User Conflicts. What consideration have you given that the transfer could lead to even further losses if undetermined future users complain about current OHV use such as noise, traffic, or blowing sand.
    5. Open OHV areas like Sand Hollow are rare. Even though OHV use has been increasing dramatically, it seems that more areas are being closed to OHV use than opened. Please provide your analysis of the land currently available, what it was  5 years ago, and any projections in the next 5 years in Utah for each of the following designations:
      1. Open OHV use
      2. Open for Use on Existing Roads and Trails
      3. Open for Use on Designated Roads and Trails
      4. Closed to OHV Use
      5. Change in OHV Registration Data Over the same period
  4. Provide relevant scientific data, studies, or other sources of information to support the comments.
    1. Oceano Dunes is a great example of how user conflicts were created that led to further losses to OHV. In many communities, airports have come under attack from new communities built around them that complain about the noise, ultimately resulting in the closure of 378 airports since 1990, almost 7% of the total. Explain what measures you are taking to ensure that OHV does not suffer a similar fate.
    2. Explain how you quantify the value of land used for recreation, including significant factors that influence that valuation?
  5. Address the scope of the proposed action, including any indirect or cumulative effects that may result from the action.
    1. How will continued access to the public lands on top of Warner Ridge and West Rim be accomplished.
    2. What will be the impact of the loss of staging and dry camping in the area?
    3. What will be the impact on OHV traffic patterns from the recently constructed Waddy’s Corral Staging area and other Sand Mountain trails?
    4. Why are you giving more land than needed for the reservoir?
    5. Where will the people that use the disbursed camping sites on Pipeline Road go to?
    6. Where will the campers using Washington Dam free camping area go?
    7. There are often many conflicts when different land managers are in charge of adjacent areas, who is going to manage the acquired land, and what is their experience working in conjunction with BLM?
    8. How will the view sheds from the West Rim trail and above be impacted by the change?
    9. The OHV Area loss from this is 1050 acres, plus an additional loss of almost 400 acres if the reservoir project proceeds in a future request. This is in addition to the indirect and direct cumulative effects from various options from the 2016 Lake Powell Project proposal, ranging from 60 to 290 additional acres of land being closed to OHV use. This brings the total OHV loss to 1740 acres from the Sand Mountain SMRA. What other options have you considered?
  6. Identify any potential environmental justice concerns that may arise from the proposed action, such as impacts on low-income or minority communities.
    1. Explain your scientific analysis of the impact of potentially losing the free and disbursed camping affect users of lower income?
  7. Discuss any potential cultural or historical impacts on Native American tribes or other affected communities.
    1. What cultural, anthropological, and historical impacts will result from this Proposed Exchange, and how will they be mitigated?
  8. Offer specific suggestions for how the BLM can address public concerns and incorporate feedback into the decision-making process.
    1. While we appreciate the extension for comments of 6 days, there are many visitors that come at different times of the year, and it will take time to get the word out to people interested in the outcome. Have you collected user data by month to see what the most frequent periods the land is used? What do you need to justify an extended comment period for future comments?

 

Scoping is not about stating opinions or venting, it’s about developing the questions that should be answered in the EA or EIS. Framing your comments into questions are the best way to elicit consideration for that question to be addressed in future evaluations. No comment is worthless, but comments that are very broad such as “I don’t want this exchange to happen” are not very helpful if not supported by specifics. If you have detailed and specific comments, I encourage you to submit comments using Option 1 below. If are limited in time and want to make quick comments, I suggest you make your comments using the Blueribbon Action Alert Option 2, it has an excellent set of comments that cover a wide range of subjects. When you submit using the Blueribbon Action Alert, copies will be sent to BLM and Congress. The best option is to submit them both ways.

We have received many excellent copies of comments already submitted, but one from the Capital Trail Vehicle Association from Helena, MT is very well written and may give you more ideas. You can see their comments here….

Now is the time to submit your comments, visit www.UtahPLA.com for the very latest information.  

Comment Period Closes at Midnight on April 19, 2023

You can submit comments as often as thoughts arise, but start submitting today!




Read these Tips Before Sending Your Comments to Stop the Sale

Scoping is underway for the proposed Land Exchange for the Washington County Water Conservancy District to obtain 1050 acres of land from the Western portion of Sand Mountain OHV area near Warner Valley. Part of this may be to provide land for the new reservoir, to which we have no objection, but we are in opposition to the addition of the land east of Warner Valley Rim which would affect West Rim and Ridgeline Trails. You can learn more about the latest details at www.UtahPLA.com

What is Scoping? The National Environmental Policy Act (NEPA) requires the Bureau of Land Management (BLM), to involve the public in the planning process and seek their input through a scoping process, which is one of the first steps of the process. It will be followed by BLM’s preparation of a draft Environmental Assessment (EA) , and you will have another opportunity to add substantive comments. Effective NEPA scoping comments for BLM should ask these kind of questions, some thought starters have been included in italics, but come up with your own questions, please don’t just copy this list, put it into your own words.

  1. Provide specific information about the proposed action, including its location, purpose and need, and potential environmental impacts.
    1. We understand the purpose of the reservoir use, but what is the purpose of the large acquisition east and north of the reservoir?
    2. We asked the Water Conservancy District and City of Washington what they plan to use the land for, and their response has been they have no plans or it’s too early to have thought about it. BLM should demand a clear direction from the City of Washington as to their involvement and precise plans for the future.
    3. How will it affect visitors and their economic impact to the region?
    4. Adjoining lands that are managed by different agencies often cause conflicts because of differences in rules governing that use, and law enforcement. If the “dispersed” camping is eliminated at Washington Dam, law enforcement issues may rise with those people desiring free camping will arise in other areas, i.e. our Waddy’s Corral staging area may have people trying to camp there, especially after we pave the road to it. Much of the increase in OHV recreation has come from UTV/ATV users, who need staging areas to unload and park their machines. Where do they go if Washington Dam is closed?
    5.  What will be the Visual Resource Impacts of the change. Currently, most of Sand Mountain is classified as Class 2, but it appears from Map 2.14 in the BLM St George Field Office 1999 Recreation Management Plan that the West Rim is classified as Class 3. How will you ensure that the basic characteristics and visual appearance will be maintained if the exchange is approved?
  2. Identify any alternatives that the BLM should consider, including no action, and explain why they would be preferable or less impactful.
    1. What other locations may have been considered for the exchange located north and east of the reservoir?
    2. Have you considered alternatives that eliminate the areas east of the reservoir.
    3. Have you considered replacing our area of concern with land to the south of the proposed reservoir location, where WCWCD is planning for recreation already.
    4. What other alternatives have you considered for acquiring the 89 acre Non Federal parcel.
    5. If no action is recommended as an alternative, please provide precise details what that means.
  3. Highlight any potential significant impacts that may result from the proposed action and suggest ways to mitigate or avoid them.
    1. Without knowing what the new use will be, how can you clearly analyze potential impacts or mitigations.
    2. How do you propose to resolve impacts such as user conflicts between OHV and development or noise or traffic concerns.
    3. Although a State Park, California’s Oceano Dunes OHV users have been attacked by new residents building communities adjacent to the Dunes because of User Conflicts. What consideration have you given that the transfer could lead to even further losses if undetermined future users complain about current OHV use such as noise, traffic, or blowing sand.
  4. Provide relevant scientific data, studies, or other sources of information to support the comments.
    1. Oceano Dunes is a great example of how user conflicts were created that led to further losses to OHV.
    2. In many communities, airports have come under attack from new communities built around them that complain about the noise, ultimately resulting in the closure of 378 airports since 1990, almost 7% of the total.
    3. How will the appraisal reflect the value of Recreation?
  5. Address the scope of the proposed action, including any indirect or cumulative effects that may result from the action.
    1. How will access to the public lands on top of Warner Ridge and West Rim be accomplished.
    2. What will be the impact of the loss of staging and dry camping in the area?
    3. What will be the impact on OHV traffic patterns from the recently constructed Waddy’s Corral Staging area.
    4. Why are you giving more land than needed for the reservoir?
    5. Where will the people that use the disbursed camping sites on Pipeline Road go to?
    6. Where will the campers using Washington Dam free camping area go?
    7. There are often many conflicts when different land managers are in charge of adjacent areas, who is going to manage the acquired land, and what is their experience at working with BLM?
    8. How will the view sheds from the West Rim trail and above be impacted by the change?
    9. The OHV Area loss from this is 1050 acres, plus an additional loss of almost 400 acres if the reservoir project proceeds in a future request. This is in addition to the indirect and direct cumulative effects from various options from the 2016 Lake Powell Project proposal, ranging from 60 to 290 additional acres of land being closed to OHV use. This brings the total OHV loss to 1740 acres from the Sand Mountain SMRA. What other options have you considered?
  6. Identify any potential environmental justice concerns that may arise from the proposed action, such as impacts on low-income or minority communities.
    1. How will the loss of free and disbursed camping affect users of lower income?
  7. Discuss any potential cultural or historical impacts on Native American tribes or other affected communities.
    1. What cultural, anthropological, and historical impacts will result from this Proposed Exchange?
  8. Offer specific suggestions for how the BLM can address public concerns and incorporate feedback into the decision-making process.
    1. While we appreciate the extension for comments of 6 days, there are many visitors that come at different times of the year, and it will take time to get the word out to people interested in the outcome. Have you collected user data by month to see what the most frequent periods the land is used? What do you need to justify an extended comment period for future comments?

 

Scoping is not about stating opinions or venting, it’s about developing the questions that should be answered in the EA or EIS. Framing your comments into questions are the best way to elicit consideration for that question to be addressed in future evaluations. No comment is worthless, but comments that are very broad such as “I don’t want this exchange to happen” are not very helpful if not supported by specifics. If you have detailed and specific comments, I encourage you to submit comments using Option 1 below. If are limited in time and want to make quick comments, I suggest you make your comments using the Blueribbon Action Alert Option 2, it has an excellent set of comments that cover a wide range of subjects. When you submit using the Blueribbon Action Alert, copies will be sent to BLM and Congress. The best option is to submit them both ways.

 

Now is the time to submit your comments, visit www.UtahPLA.com for the very latest information.  

Comment Period Closes at Midnight on April 19, 2023

Start Now, and Get your Comments Submitted!