On March 13, the Bureau of Land Management (BLM) proposed to create a new categorical exclusion under the National Environmental Policy Act (NEPA) that would allow up to 10,000 acre projects to mechanically remove pinyon pine and juniper trees on public lands with no environmental analysis. The BLM justifies the proposed categorical exclusion on the need to improve mule deer and sage grouse habitat. Other than that, the BLM is essentially without restraints in carrying out these projects.
Ignoring the harmful environmental effects of past mechanical pinyon pine and juniper removal on public lands, the BLM plans to remove all public input and oversight from future projects of this nature, claiming that this “streamlining” will have no significant environmental consequences.
Please click here to submit comments on the BLM's web portal. Please consider the following. Please do not cut and paste, but share these concepts in your own words. And please add your own stories and points as to why it's important to you.
Deadline: April 13. Please Act Today.
When writing your comments, please consider the following points:
- 10,000 acre projects are an extremely unreasonable size to categorically exclude from NEPA and public review. This area is larger than many cities. Congress in the past has called for agencies to establish categorical exclusions for some projects up to 4,500 acres in size. BLM’s proposed categorical exclusion is more than double that, with very few limitations on where, when, and how treatments can be conducted.
- The best available science shows that these projects do have significant environmental effects, making any blanket determination that future projects need not go through the NEPA process because there are no significant environmental effects wildly inappropriate.
- BLM has misrepresented available scientific research on the effects of these projects in its categorical exclusion proposal, erroneously concluding they have a net positive effect on the ecosystem. This completely excludes science showing that mechanical pinyon pine and juniper removal is overall very harmful for woodland-dependent species, including migratory birds whose populations are already in drastic decline.
- BLM should not be able to categorically exclude any projects in National Monuments, Areas of Critical Environmental Concern, Wilderness Study Areas, or other special-status public lands. There are many proposed vegetation removal projects in recent years that were removed from these sensitive areas because of public input and engagement. It is improper for BLM to be able to plan, approve, and execute projects using heavy machinery to clearcut native forests in these special management lands with no public oversight and without robust, site-specific environmental analysis.
- These projects help accelerate climate change by causing large-scale surface disturbance that increases desertification, contributes to atmospheric dust levels, and removes valuable forest carbon sinks. Numerous studies show clearly that deforestation decreases water retention in both arid and wet regions. In the arid Great Basin, we should be seeking to retain water by enlarging our forested areas, not cutting them back. Healthy forests sequester carbon dioxide. Deforestation releases it to the atmosphere. BLM must continue to do project-specific, public, NEPA analysis for pinyon pine and juniper removal projects because of their potential contributions to climate change.
- BLM has not demonstrated that it has adequately monitored past vegetation removal projects to ensure that the treatments do not cause significant, long-term damage to overall ecosystem health by disturbing and destroying biological soil crust or spreading invasive species like cheatgrass. BLM must provide long-term monitoring data from past projects to demonstrate their success before categorically excluding future projects from NEPA. BLM must make this data publicly available.
- BLM has not provided any criteria or guidelines in the proposed CX to determine what qualifies as sage-grouse or mule deer habitat, and because there will be no public process, the BLM will not need to justify these determinations. Therefore, the BLM could ostensibly use the proposed CX to remove 10,000 acres of forest wherever it wants with no public accountability. Distressingly, the public may not even know these large-scale projects were happening until after they were completed and the deforestation was irreversible.
- Indigenous tribes consider pinyon pine to be culturally important to their way of life and survival. Local tribes must be consulted on all proposed pinyon-juniper treatments.
~Thank you SUWA for help with the wording.