I’m tracking how different groups are agreeing on certain points about the Rule. Please send any letters you run across or link them below. It’s kind of mind-boggling to search the comment website for names of groups.
Some groups that disagree on ends agree that this is not a particularly desirable means. And there are similar concerns about conservation leasing and selling carbon credits.
Some groups tend to agree that the BLM already has what it needs to do conservation work, and this may be an unnecessary addition from the employee capacity perspective. Conceivably, employee capacity and morale are still of concern, even when the potential source of the issue is a D administration.
Now PEER clearly sees “drilling, mining, logging, and grazing” as the bad guys.
So to them, one problem is that the Proposed Rule
Would allow oil and mining interests to lease vacant land as an “offset” against adverse climate and other damage they are wreaking on their original holdings.
But don’t wind and solar also “wreak damage” to habitat? Especially considering their (much) larger footprint.
And some mining (strategic minerals) is actually good for climate, right? The old order of good guys and bad guys seems to be breaking down before our eyes.
And “Giving BLM more regulatory discretion to issue more leases may, especially under future administrations, simply trigger a new corporate land grab, leaving little to ensure they are managed to provide real conservation value or public benefit.”
So in a sense they share my and others’ concerns about NGOs and corporations sitting around the table and divvying up the federal estate. Maybe it’s also about trust in the sense that setting up something new to help one Admin’s buddies could be used by the next Admin’s buddies.
And while I think “BLM is doing a pretty good job but this is just extra paperwork that confuses everyone and is unlikely to help” PEER thinks “BLM is doing a really bad job and this will make more work for employees and be unlikely to help.”
PEER wrote a very thoughtful comment letter and here’s part of the section on capacity. I recommend reading the whole section if you are interested, in the interest of space I left parts out.
I. BLM Lacks the Capacity to Implement the Proposed Rule
We believe BLM lacks the staff and resources to implement the proposed rule. Specifically, we are concerned that without a significant addition of resources and the development of staff expertise, BLM will be unable to:
1. Conduct meaningful and scientifically defensible land health assessments;
2. Accurately assess the environmental impacts of land use decisions, including those in the conservation and restoration leases proposed in this rule; and,
3. Adequately engage the public in its decision-making processes.
Therefore, we recommend that BLM conduct a workforce analysis to specifically address the staffing and resource needs to implement this rule and share the information publicly. This will help BLM prioritize the agency’s conservation programs based on those that will deliver the most cost-effective results.
Without addressing workforce issues and agency priorities, we are concerned that:
1. Existing programs will suffer;
2. BLM will be unable to provide adequate oversight for the innovative programs in this proposed rule: and,
3. BLM will outsource important government functions to contractors and non-governmental organizations resulting in further capture of BLM by special interest groups that have an interest in obtaining leases.
Understaffing is already a genuine issue at BLM. …
They also agree with me on offsets, although they expressed it much better. Again, this is only a part, so those interested should read the whole section.
III. The Rule Should Expressly Prohibit the Use of Conservation Leases to Generate Carbon Offset Credits
We also question whether offsets generated on BLM lands can be real, additional, permanent, and verifiable. One problem with carbon offsets on BLM lands is that BLM should already be managing these lands for conservation purposes if they are not being used for grazing or resource extraction, such as mining. The problems of additionality would be significant on the land management by BLM. If BLM decides to allow the generation of carbon credits on the lands it manages, BLM must first propose a separate rulemaking that specifically addresses the legal, environmental and compliance issues associated with the offset program it is proposing.