Comments on the Proposed Rescission of the Conservation and Landscape Health Rule

Bureau of Land Management

U.S. Department of the Interior

1849 C St. NW, Room 5646

Washington, DC 20240

Attn: 10044-AF03

Re: Comments on the Proposed Rescission of the Conservation and Landscape Health Rule (Docket No. BLM-2025-0001-0001)

Bureau of Land Management,

The undersigned organizations and businesses value watershed health, clean water, and healthy freshwater systems and are writing to urge the Bureau of Land Management (BLM) to retain and fully implement the Conservation and Landscape Health Rule (referred to throughout these comments as “the Public Lands Rule” or “the Rule”). The Public Lands Rule codifies critical freshwater restoration and protection tools BLM can use to protect intact lands and waters; improve the resilience of public lands in the face of extreme events such as droughts, wildfires, and floods; and restore freshwater resources on America’s public lands.

BLM adopted the Public Lands Rule in 2024 to help it achieve its multiple-use mission and

safeguard the health and resilience of the lands it manages. The Rule implements the Federal Land Policy and Management Act, which requires BLM to manage its vast lands for extractive uses like oil and gas, logging, livestock grazing, and mining, and for conservation-focused uses, including watersheds, fish and wildlife, recreation, and natural scenic values. The Public Lands Rule recognizes that balancing uses to meet the American people’s present and future needs is a core responsibility of public land management.

The Public Lands Rule helps BLM manage its freshwater resources and meet its obligations under the Federal Lands Policy and Management Act. The Rule achieves this by:

• Requiring BLM to identify priority landscapes for protection and restoration and to prepare restoration plans for those priority landscapes.

• Establishing the framework for restoration and mitigation leases to improve the health of public lands and waters, and prevent degradation.

• Requiring BLM to conduct watershed condition assessments to inform land use planning, restoration planning, and other management actions. Watershed condition assessments help BLM meet its sustained yield mandate, ensuring that it sustains resources for future generations by assessing and synthesizing watershed-scale drivers that impact the condition of soil, water, aquatic and terrestrial habitats, and ecological processes within watersheds.

• Applying BLM’s well-established fundamentals of land health to all BLM lands and program areas to further its ability to protect healthy intact landscapes, restore degraded habitat, and help inform all decision-making.

• Promoting more equitable and informed decision-making by requiring meaningful consultation with Tribal Nations and using the best available science, including Indigenous knowledge. It also advances opportunities for Tribal co-stewardship of public lands.

• Providing clear direction to ensure BLM is appropriately managing important water, cultural, wildlife, and scenic resources and complying with Congress’s direction to prioritize the protection and designation of Areas of Critical Environmental Concern.

Healthy landscapes and resilient ecosystems are essential to multiple use and sustained yield

management. For the last several decades, despite the ecological importance of BLM’s 245 million acres, BLM’s on-the-ground implementation of its mission has been unbalanced, tilting substantially toward extractive uses while discounting sustained yield. For example, approximately 81 percent of BLM’s lands are open to oil and gas extraction, more than 60 percent are open to livestock grazing, and more than 4 percent have active mining claims. [1] BLM’s own data indicate that one of every five acres it manages fails to meet its own land health standards, which consider the health and functionality of watersheds, ecological processes, water quality, and wildlife habitat. [2] A sampling of BLM’s aquatic habitat shows that only 25 percent of its floodplain area is healthy, active, and connected to rivers and streams [3] – indicating a clear need for management actions that restore these and other critical freshwater systems.

BLM has a critical role to play in protecting and restoring freshwater resources. It manages more than 20,000 acres of wetlands and more than 250,000 miles of perennial and intermittent streams and rivers which serve as the source of drinking water for 1 in 10 people in the West. [4] Additionally, BLM manages 81 designated wild and scenic rivers in the West and Alaska. Importantly, BLM-managed lands are significant to many Tribal Nations and Indigenous communities given the high number of wetland-dependent cultural resources and ancestral ties to the lands and the waters and wildlife they support.

Freshwater habitats are disproportionately important parts of the landscape in arid and semi-arid landscapes where communities and wildlife are already confronting water insecurity, and persistent drought. These ecosystems in the West—including wetlands, streams and their connected floodplains, and wet meadows—are regional hot spots of biodiversity and exhibit high rates of biological productivity. For example, they provide essential habitat for fish and other aquatic species, support 70–80 percent of terrestrial wildlife during some part of their life cycle, and can sustain species richness for migrating birds that is 10-14 times higher than adjacent uplands. [5] These resources provide many additional public benefits, including cleaning and filtering water supplies, absorbing floodwaters, and buffering against drought.

Water resources on BLM-managed lands also are a critical part of wildfire management. When in healthy condition, the saturated soils, braided stream channels, and vegetation associated with these freshwater systems do not readily burn. Thus, they can slow fire movement, provide refuge for wildlife and wildland firefighting crews, serve as natural firebreaks, decrease the amount of post-fire sediment that ends up in reservoirs and water treatment facilities, and provide cleaner water for downstream fish and other aquatic organisms after fires.

[6] BLM needs new tools to increase the health of its freshwater resources and expand the many benefits they can provide to communities and nature. For the reasons outlined above, we respectfully ask BLM to retain and fully implement the Public Lands Rule.

Thank you for considering our comments.

Respectfully,

National

Beaver Institute

Center for Water Security and Cooperation

Defenders of Wildlife

GreenLatinos

Latino Outdoors

League of Conservation Voters

Natural Resources Defense Council

Public Employees for Environmental Responsibility

Sierra Club

Spatial Informatics Group - Natural Asset Laboratory (SIG-NAL)

The Center for Biological Diversity

Waterkeeper Alliance

Regional

Association of Northwest Steelheaders (Oregon, Washington)

Greater Yellowstone Coalition (Idaho, Montana, Wyoming)

Northwest Sportfishing Industry Association (Northwest)

Project Eleven Hundred (Arizona, California, Colorado, New Mexico, Oregon, Utah)

Save Our Wild Salmon Coalition (Pacific Northwest)

Tahoe Area Group Sierra Club (California, Nevada)

Waterkeepers Chesapeake (Chesapeake Bay)

Winyah Rivers Alliance (North Carolina, South Carolina)

Arizona

Upper Agua Fria Watershed Partnership

Xplore Outside

California

1000 Grandmothers for Future Generations

Bay Area System Change not Climate Change

Benici Good Neighbor Steering Committee

Blackhawk Environmental, Inc.

CactusToCloud Institute

California Environmental Voters

California Land Watch

California Native Plant Society

Californians for Western Wilderness

CalWild

Central Valley Bird Club

Ecologistics, Inc.

Endangered Habitats League

EPIC (Environmental Protection Information Center)

Fresnans against Fracking

Friends of the Amargosa Basin

Palomar Audubon Society

Preserve Calavera

San Diego Bird Alliance

Sierra Nevada Alliance

Southwest Wetlands Interpretive Association

Colorado

Dolores River Boating Advocates

Eagle River Coalition

High Country Conservation Advocates

Western Slope Conservation Center

Wilderness Workshop

Connecticut

Farmington River Watershed Association

Idaho

Idaho Conservation League

Idaho Outfitters and Guides Association

Idaho Rivers United

Iowa

Iowa Environmental Council

Michigan

Yellow Dog Watershed Preserve

Montana

Clark Fork Coalition

Montana Freshwater Partners

Montana Trout Unlimited

New Jersey

Great Egg Harbor Watershed Association

New Mexico

Amigos Bravos

Gila Resources Information Project

New Mexico Wild

Rio Grande Return

Oregon

Friends of the Kalmiopsis

Let's Get Out Adventures

Oregon Natural Desert Association

Oregonians for Wild Utah

Utah

Utah Physicians for a Healthy Environment

Washington

350 Seattle

Friends of the San Juans

Washington Wild

Thurston Climate Action Team—Tree Action Group

Wyoming

Snake River Fund

Wyoming Wilderness Association

https://www.regulations.gov/document/BLM-2025-0001-0001