Date: 10/12/25 6:18 pm From: Kevin Krajcir <kjkrajcir...> Subject: Opportunity for Public Comment - Rescission of Public Lands Rule
Good evening,
At tonight's board meeting, the Arkansas Audubon Society approved the
submission of a comment opposing the Bureau of Land Management's proposal
to rescind the "Public Lands Rule," which allows conservation uses of land
to be considered as equally important as other consumptive land uses like
logging, mining, oil/gas development, etc. Without this rule, conservation
uses/activities on BLM lands would not be considered a priority any longer.
The AAS opposes this decision due to the ramifications for birds, habitats,
and ecosystems protected by conservation of these lands. You can read more
about the issue here
<https://wildlife.org/blm-seeks-to-deemphasize-conservation-on-public-lands/> .
To serve as an example of the type of comment you can provide, here is what
the AAS Conservation Committee has drafted and submitted (again, with AAS
Board approval). Please use this to inspire your own writing, rather than
as a template, as you draft your own comment/opinion on this issue.
"I am writing on behalf of the Arkansas Audubon Society, an all-volunteer,
statewide organization committed to fostering a greater knowledge of the
natural history of Arkansas and promoting conservation of the state’s
natural resources. We oppose the proposal to rescind the Conservation and
Landscape Health Rule (aka, the Public Lands Rule), which currently allows
conservation practices to be considered as equally relevant and important
as land uses such as ranching, grazing, timber, energy extraction, etc.
Conservation of our public lands through protection and restoration should
remain a priority of the Bureau of Land Management (BLM), because these
types of land use ultimately benefit humans, wildlife, and the health of
our planet.
This proposal expresses concerns that conservation results in “no-use” of
land or that the BLM has exceeded its authority by overemphasizing
conservation in favor of “multiple-use” scenarios; however, conservation of
public lands allow for uses and ecological processes that benefit human and
wildlife health, the economy, and our natural resources. Protected lands
create safe holds for America’s wildlife, many of which are in decline.
Considering birds as an example, nearly 30% of North America’s birds have
been lost since 1970, largely due to habitat loss and conversion for
agriculture, urbanization, and energy extraction. Proper protection,
management, and restoration of public lands can help to slow or reverse
these extraordinary declines.
Protecting wildlife and their habitats ultimately benefit humans in
countless ways. Lands held under the goal of conservation should not be
considered “no-use” as hunters, anglers, bird watchers, and numerous other
groups use many of these areas for various forms of outdoor recreation. The
outdoor recreation industry contributes billions of dollars and millions of
jobs to the nation’s economy each year, and lands held in conservation are
a critical piece of that industry. Beyond the economic impact of protected
lands, maintaining protected lands decreases instances of human-wildlife
conflict and disease transmission when wildlife have sufficient habitat
free of human disturbance. Furthermore, properly managed wildlands can help
reduce the likelihood or severity of wildfires.
As of 2022, only approximately 13% of US land and 19% of US waters were
protected under conservation at some level, whether federal, state, or
private. We do not believe that these numbers can afford to be reduced as
we see the acceleration of the loss of biodiversity, the increasing
frequency and severity of natural disasters, and the general degradation of
America’s wild spaces. We urge the BLM to consider using other technologies
or land use strategies on lands that have already been disturbed as a means
to meet our country’s growing energy and material needs. Conservation is a
valid use under federal law, on equal footing with other uses of public
lands. Americans support this–during the original rulemaking process, 92%
of public comments supported the proposed public lands rule that is
currently the law.
Thank you for accepting this comment. We hope that the BLM will act in the
best interest of this nation’s public lands by allowing their conservation
to remain a top priority."
Thank you for joining us in taking the time to speak up for the birds and
their habitats!
