Date: 10/20/25 10:06 am From: Jeffrey Short <bashman...> Subject: Re: Opportunity for Public Comment - Rescission of Public Lands Rule
Hi Kevin,
Excellent comments!
Were these also CC’d to our Congressional representatives, too?
(I have been having difficulty sending emails to Boozman RE: USDA on a completely unrelated matter.)
Best,
Jeff Short
From: The Birds of Arkansas Discussion List [mailto:<ARBIRD-L...>] On Behalf Of Kevin Krajcir
Sent: Sunday, October 12, 2025 8:17 PM
To: <ARBIRD-L...>
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!
