By Scott Jones Esq

The Bureau of Land Management is entering a process develop a  completely new  planning process, which the BLM is calling  their Planning2.0 initiative and the first two public meetings have recently occurred on the proposal.  The proposal seeks to speed up the planning process and would expand planning from just the field office level to landscape level plans (similar to the current Sage Grouse efforts), combined with continued field office level planning and expand localized planning for particular issues.   After attending the Denver, Colorado meeting some concerns have arisen on this process.  These concerns are: 1. Where is the money coming from for the extensive new multi-level planning sought to be developed; 2.  Partner involvement in the process appears very limited;  3. There appears to be limited protections of multiple use in the planning process; and 4. BLM is seeking to accept citizen science in planning without identifying how that relates to best available science.

The Planning2.0 proposal seeks to develop new landscape level plans, similar to the BLM Sage Grouse plans, to guide field office level plans.  I have been reasonably involved in the BLM Sage Grouse planning and I think it might be a little early for BLM to be declaring that plan a success and the model for a new planning process.  The Western Governors Association just aptly summarized state and local participation in the landscape  Sage Grouse planning process as an “afterthought” as often stakeholders in the Sage Grouse process were not meaningfully engaged and input was not discussed in detail.    Our experiences with the landscape level Sage Grouse plans found that management standards were overly specific and failed to address impacts to other multiple uses beyond the usage specifically identified and failed to integrate plans being developed or that were already in place.  As part of the landscape level plans, no explanation was provided  on how recreational usage of habitat areas was identified as not a threat in landscape level plans but roads and trails in habitat areas were identified as a threat to the Grouse.  How does recreational usage of habitat occur without roads and trails to access these areas.  These are issues that will make implementation difficult at best and minimize any long term savings.

Identifying funding for planning has been a significant issue for field office and localized planning and one that BLM appears to continue to struggle with.   While the new planning process may look great on paper, it still must be applied on the ground.  This takes money.  When this funding question was posed in the Denver meeting, BLM asserted that the new planning process would be so streamlined and efficient that there would be more planning and more money for implementation.  I thought the response was really optimistic and failed to incorporate the experiences of the USFS with their new planning rule, who had sought to achieve the same goal but are finding that goal difficult to achieve. Anytime I speak with a BLM person about funding a project or trail repair there is a single answer to the discussion, there is no funding for projects. This will remain a major hurdle to applying any planning on the ground.

Partner involvement at the Denver meeting was surprisingly limited and experiences with the Sage Grouse have shown that engaging partners  will be a major key to success moving forward.  Engaging partners is often difficult as many partners and users have exceptionally busy schedules.  The meeting was well attended by environmental organizations, but traditional partners with BLM such as State and local government agencies and user groups were almost non-existent. Clearly the resolution to this issue partially depends on having more than two meetings and make them at times when the public can attend.   Most of the public is working on Wednesday afternoons and cannot attend these types of meetings no matter how concerned they might be on the issue. When partners are publicly stating their input is an afterthought, that is an indication that partner involvement probably has not gone well. Unfortunately this is an issue that remains unresolved in the planning 2.0 process.

Balancing of multiple usage in the new landscape level planning process is also a concern. This concern is based more on the examples already in place rather than any discussions at the meeting.  While the California desert solar plan was recently released, recreation was only protected in this plan as a result of ORBA involvement, rather than a statutory mechanism that brought all uses to the table.   Similar plans, such as the recently released San Luis Valley/TAOS plateau solar plans and the various rapid ecological response plans that have been developed are very targeted to particular issues and often fail to include the recreational community in these plans.   If management could be effectively addressed to only particular issues, that would be nice, but experience has taught us that this is often difficult and made more complex when all multiple users are not at the table. This is a major concern moving forward.

BLM repeatedly stated that expanded incorporation of citizen science in the planning process would be  a benefit of the new planning process.  This is admirable but at no point was the relationship between statutory requirements of best available science and citizen science explained. In a troubling development citizen science was not even defined in the Denver meeting.  Incorporating legally insufficient research into the planning process will simply result in more litigation and bad plans being developed that attempt to manage concerns in a manner that will simply never address the problems to be managed. While integration of best available science will streamline planning, this process is very different than accepting citizen science.

While I welcome the BLM efforts in the new planning process, I question if the goals are achievable and where is the money coming from.  Even the best plans do not work if the management is never applied to the ground and stakeholders to not support the process as they have not been involved. My experiences have taught me that developing an effective management plan is often far more cost and result efficient in the long run than a plan that is quickly developed and is the results of proper research not being done.

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