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The following documents are available online or at the Beaverhead County Courthouse: October 2001 BLM RMP Scoping Comments Beaverhead County Resource Use Plan Amendment, July 2001 - July 2001 Resource Use Plan as MS Word DOC file June 2000 Resource Use Plan Draft |
[Previous entry: "Beaverhead Watershed Committee Meeting, Nov 5, 2001, S&R Building"] [Main Index] [Next entry: "Contact Info for BLM DFO RMP"] 11/29/2001 Entry: "Beaverhead Co. BLM RMP Scoping Comments" Beaverhead County Commissioners Mike McGinley and Donna Sevalstad submitted the following scoping comments for the BLM's Dillon Field Office (DFO) Resource Management Plan (RMP) on October 19, 2001: October 19, 2001
Attached please find a letter of submittal and set of comments for consideration in the scoping process. We look forward to working with you to include as many of these and other comments as are appropriate in the final RMP. Sincerely /s/ Donna J. Sevalstad
Donna J. Sevalstad
Michael J. McGinley
October 19, 2001
Beaverhead County would like to take this opportunity to extend its
thanks and recognition to the Dillon BLM office for inviting us to
participate as a coordinating agency in the preparation of the
Resource Management Plan (RMP). This is truly a unique opportunity,
as the BLM planning process, the County’s participation as a
coordinating agency and the County’s Comprehensive Plan’s
Resource Use Plan component are all new. The County looks forward to
participating fully in the BLM’s RMP planning process.
1.)The RMP be legally defensible.
Beaverhead County and its citizens need to have confidence that the
RMP will be legally defensible and will be implemented and monitored
so the County and its citizens may be confident the BLM will fulfill
the legal and management obligations contained in the RMP.
1.)Emerging Issues – Research, Theory and Opinion since the 1979 RMF.
The County is committed to participating fully with the BLM in the
RMP process and has compiled this information as part of our
responsibility as a coordinating agency to surface “emerging
issues” for the scoping process and are not necessarily the
views and/or opinions of the County of Beaverhead and/or any of its
individual citizens. Sincerely,
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EMERGING ISSUES
- How has the archeological theory that Paleo-Indian caused the extinction of North American megafauna with a combination of hunting and alteration of the ecosystem with anthropogenic fire shortly after their arrival on the North American continent affected the BLM/DFO management assumptions? - As man has radically altered the natural environment through hunting and anthropogenic fire for the past 15,000, at what point in time does the BLM/DFO consider to be “natural”? Citations: Williams, Robyn, “Megafauna Extinction”, transcript of radio interview with Tim Flannery, August 9, 2001, pages: 21, http://www.abc.net.au/rn/sciences/ss/stories/s356397.htm Barlow, Connie, “The Ghosts of Evolution: Nonsensical Fruit, Missing Partners, and other Ecological Anachronisms – Megafauna extinction and phenotypic lag”, book review, Basic Books, New York, pages: 2, http://cogweb/english.ucsb.edu/EP/Megafauna.html “Mystery Surrounds the Death of Australia’s Megafauna”, Reuters News Service, August 20, 2001, pages: 4, http://www.enn.com/extras/printer-friendly.asp?storyid=44686 Dunham, Will, “Prehistoric Humans Blamed for Mass Extinctions”, Reuters News Service, June 14, 2001, pages: 4, http://www.enn.com/extras/printer-friendly.asp?storyid=43995 Devlin, Sherry, “Racing from the Past”, Missoulian Online, January 30, 1998, pages: 4, http://www.umt.edu/geograph/edlund/g346/pronghorn.html
- Is an economically wealthy society or an economically poor society better able to protect the environment? - Does an increase in living standards equate to an improved environment? - What negative consequences would a move to organic agriculture have on the environment? Citations: Taylor, Jerry, “Chapter 21, The Growing Abundance of Natural Resources”, presentation at 1992 UN Conference on Environment and Development, pages: 13, http://www.cato.org/pubs/chapters/marlib21.html Hillgren, Sonja, “Environmental Problems in Perspective”, Farm Journal, September 2001, page 68, no URL. “Rebutting the Doomsayers, Human Ingenuity is the Ultimate Resource”, Cato Online Policy Report, Volume XVIII, Number 6, November/December 1996, pages: 2, http://www.cato.org/pubs/policy_report/cpr-18n6-7.html Wade, Nicholas, “Bjorn Lomborg: A Chipper Environmentalist”, New York Times, August 7, 2001, http://forests.org/archive/general/achienv1.htm Avery, Dennis, “Sierra Club Exec Endorses High-Yield Agriculture and Biotech Crops”, Hudson Institute, pages: 3, http://www.hudson.org/averydoc9f.htm Avery, Dennis, “The Organic Farming Threat to People and Wildlife”, Hudson Briefing Paper, March 1994, Number 162, pages: 12, http://www.heartland.org/pdf/04004i.pdf Bailey, Ronald, “David Foreman vs. the Cornucopians”, Reason magazine, August 29, 2001, pages: 4, http://www.reason.com/rb/rb082901.html Livestock Grazing and the Range Resource - How will the BLM/DFO implement livestock grazing necessary to improve range health in “brittle” environments? - How will BLM/DFO use livestock grazing as a tool to achieve management goals without the use of fire, chemicals or machinery. - When will the DLM/DFO review for adoption, the Natural Resources and Conservation Service (NRCS) and Montana Department of State Lands grazing standards to ensure consistency? Citations: Bump, Robert John, “Muddy Creek, forced Montana’s Welborn family to send for the cavalry”, Range Magazine, Fall 2000, pages 53-55, no URL. Kiester, Edwin Jr., “Getting Their Goats, Communities worried about the ravages of wildfires are embracing a four-legged solution”, Smithsonian Magazine, October 2001, pages: 4, http://www.smithsonianmag.si.edu/smithsonian/issues01/oct01/phenomena.html Donovan, Peter, “BLM rents cattle for mine restoration”, pages: 4, http://managingwholes.com/minexco.htm Wood, Wilbur, “Holistic Resource Management”, Sustainability, Late Spring 1990, page 48, pages: 7, http://www.context.org/ICLIB/IC25/Wood.htm “The Hooves Have It”, PERC Reports, December 1999, reprinted from the Albuquerque Journal, page 12-13, pages: 2, Hess, Karl, Jr. & Holechek, Jerry L., “Beyond the Grazing Fee: An Agenda for Rangeland Reform”, Cato Policy Analysis No. 234, July 13, 1995, pages: 29, http://www.cato.org/pubs/pas/pa-234.html Kinze, Perry, “The Ranching ‘Subsidy’”, the Atlantic Online, July 1999, pages: 6, http://www.theatlantic.com/issues/99jul/9907ranchers2.html Kinze, Perry, “Winning the War for the West’”, the Atlantic Online, July 1999, pages: 5, http://www.theatlantic.com/issues/99jul/9907ranchers1.html Kinze, Perry, “Who Owns the West”, the Atlantic Online, July 1999, pages: 7, http://www.theatlantic.com/issues/99jul/9907ranchers3.html Granskopp, Dave & Vavra, Marty, “Improving Forage for Wild Ungulates with Livestock Grazing”, EOARC Eastern Oregon Agricultural Research Center, research brief, pages: 1, http://www.orst.edu/dept/EOARC/researchhome/currentresearch/wildlifeforestry/wild.html
- How has the paleobotanical discovery that as the ice sheets receded, plants moved through the landscape at various speeds affected the BLM/DFO management assumptions? - How does the BLM/DFO define “natural” when nature is always changing? Citations: Trefil, James, “When Plants Migrate”, Smithsonian magazine, September 1998, pages: 5, http://www.smithsonianmag.si.edu/smithosonian/issues98/sep98/phenom_sep98.html
- How are trends in human well-being and environmental quality interlinked? - How will BLM/DFO utilize the tools of high yield agriculture to provide additional wildlife habitat and a healthier environment? Citations: Goklany, Indur M., “Economic Growth and the State of Humanity”, PERC Policy Series, article – pages: 28, http://www.perc.org/ps21.pdf, accompanying tables and figures – pages: 16, http://www.perc.org/ps21_tables.pdf
- How American Indians protected and conserved their natural resources with private property rights? - How did millennia of active usage and management by American Indians shape the landscape prior to European arrival? - How does this usage and management by the American Indian affect the BLM/DFO definition of “natural”? Citations: Williams, John Warren, “Book Review: Bonnicksen, T.M. 2000. America’s Ancient Forests: From Ice Age to the Age of Discovery, Wiley, New York”, The Resilience Alliance, pages: 4, http://www.consecol.org/Journal/vol4/iss2/art2/ Anderson, Terry L., “Conservation-Native American Style”, PERC Policy Series, Issue Number PS-6, July 1996, pages: 19, http://www.perc.org/ps6.htm Boyd, Robert, “Indians, Fire and the Land, in the Pacific Northwest”, Oregon State Press, April 1999, book abstract, pages: 20, http://www.orst.edu/dept/press/IndiansFireIntro.html Anderson, Terry L., “Enviro-Capitalists: Truly Sustainable”, PERC Reports, December 1999, page 19, pages 1, http://www.perc.org/dec99.pdf
- What actions will the BLM/DFO take to protect our food and water supply from international terrorism? - How will the BLM/DFO integrate terrorism prevention into its planning, monitoring and management activities?
- How does direct action affect the BLM/DFO management, monitoring, planning and public interaction? - What will the BLM/DFO do to prevent criminal behavior by direct action groups? Citations: Security Culture: a handbook for activists, 2nd Edition, August 2000, pages: 19, http://www.earthliberationfront.com/library/sec-handbook.pdf The ALF Primer, A guide to direction action and the animal liberation front, North American Animal Liberation Front Support Group, 3rd Edition, pages: 16, http://www.animalliberationfront.com/ALFront/ALFPrimer.htm “Earth Liberation Front.com” website homepage, September 30, 2001, pages: 3, http://www.earthliberationfront.com/main.shtml “No Comprimise.com” website homepage, September 30, 2001, pages: 2, http://www.nocomprimise.org/ Arson Around with Auntie-ALF, Your guide for putting the heat on animal abusers everywhere, by Auntie ALF, Uncle ELF and the Anti-Copyright gang, pages: 20, http://www.earthliberationfront.com/library/arson.pdf Foreman, David; Haywood, Bill, Ecodefense: A Field Guide to Monkeywrenching, 3rd Edition, 1993, Azburg Press, Chico, CA, pages: 350, no URL. Solistice, “A16 – An Analysis of our Tactics”, Earth First! Journal, Volume 20, No. 6, Litha 2000, pages: 4, http://www.earthfirstjournal.org/feature.cfm?ID=50&issue=v20n6 “World Wide Diary of Actions, United States 1999”, Animal Liberation Front website, pages: 5, http://www.animalliberationfront.net/doa/us/99.html Clausen, Barry R., Burning Rage : The Growing Anger Within My Country, Sail Away Press, January 2001, pages: 408, http://www.amazon.com/exec/obidos/ASIN/097000379X/qid=1003195416/sr=1-1/ref=sr_1_0_1/103-2341845-5139033 Randall, Gretchen, “Feds Protect Ecoterrorists, report says”, Environment and Climate News, February 2000, pages: 2, http://www.heartland.org/environment/feb00/ecoterror.htm
- How has the emphasis of national environmental organizations on growth and revenues affected their credibility? - How can the BLM/DFO reduce litigation and the associated costs in time and money? - What effect has the pursuit of short-term goals had on other resources and overall resource health? - How does the environmental movement’s shift to a homegrown style of environmentalism correspond with the BLM’s collaborative community based planning guidelines? Citations: Anderson, Terry L, Editor, “Reinventing Environmentalism in the New Era”, PERC Policy Series, Issue Number PS-2, February 1995, pages: 21, http://www.perc.org/ps2.htm Knudson, Tom, “Fat of the Land, Movement’s prosperity comes at a high price”, Sacramento Bee, Special Report: Environment, Inc., April 22, 2001, pages: 8, http://www.sacbee.com/news/projects/environment/20010422.html Knudson, Tom, “Green Machine, Mission adrift in a frenzy of fund raising”, Sacramento Bee, Special Report: Environment, Inc., April 23, 2001, pages: 8, http://www.sacbee.com/news/projects/environment/20010423.html Knudson, Tom, “Litigation Central, A flood of costly lawsuits raises questions about motive”, Sacramento Bee, Special Report: Environment, Inc., April 24, 2001, pages: 11, http://www.sacbee.com/news/projects/environment/20010424.html Knudson, Tom, “Playing with Fire, Spin on science puts national treasure at risk”, Sacramento Bee, Special Report: Environment, Inc., April 25, 2001, pages: 8, http://www.sacbee.com/news/projects/environment/20010425.html Knudson, Tom, “Seeds of Change, Solutions sprouting from grass-roots efforts”, Sacramento Bee, Special Report: Environment, Inc., April 26, 2001, pages: 9, http://www.sacbee.com/news/projects/environment/20010426.html Knudson, Tom, “Old allies now foes in Alaska oil battle”, Sacramento Bee, Special Report: Environment, Inc., August 19, 2001, pages: 5, http://www.sacbee.com/news/projects/environment/20010819.html Knudson, Tom, “Audubon’s membership at crossroads”, Sacramento Bee, Special Report: Environment, Inc., July 29, 2001, pages: 6, http://www.sacbee.com/news/projects/environment/20010729.html Flodin, Scott “Fund raising: fact and fancy – Gray Wolf”, Sacramento Bee, Special Report: Environment, Inc., April 23, 2001, pages: 2, http://www.sacbee.com/news/projects/environment/graphics/graphic2d.html Knudson, Tom, “Philanthropic report card”, Sacramento Bee, Special Report: Environment, Inc., April 23, 2001, pages: 2, http://www.sacbee.com/news/projects/environment/graphics/graphic2a.html Knudson, Tom, “A century of environmentalism”, Sacramento Bee, Special Report: Environment, Inc., April 22, 2001, pages: 3, http://www.sacbee.com/news/projects/environment/graphics/graphic1b.html “Bringing Back the Salmon: A Former Fisherman Tackles Restoration and Bureaucracy”, PERC Square One, pages: 3, http://www.perc.org/fredmarch/htm Freeman, Allison, “Smarter Tree-Huggers”, Guest Comment on National Review, June 4, 2001, pages: 2, http://www.nationalreview.com/comment/comment-freemanprint060401.html “Ranchers for a ‘radical center’ to protect wide-open spaces”, Smithsonian Magazine, June 1997, pages: 2, http://www.smithsonianmag.si.edu/smithsonian/issues97/malpai.html Haddock, David E., “The Price of Unbalanced Environmental Policy? Check Your Utility Bills”, Pacific Legal Foundation, Op-Ed, pages: 2, http://www.pacificlegal.org/op-ed/ed-enrgy.htm Yandle, Bruce, “Land Trusts or Land Agents? Are they too close to the Government?” PERC Reports, December 1999, page 6-8, pages: 3, http://www.perc.org/dec99.pdf DeWeese, Tom, “Strange Equality, Eco-elitists save private playgrounds in California”, Range Magazine, Fall 99, page 40-43, pages: 9, http://www.rangemagazine.com/stories/fall99/strange_equality.htm
- How will the BLM/DFO meet the challenge of the “New Environmentalism” and its drive to a smaller, community and solutions based process? - What environmental and management lessons can the BLM/DFO learn from state governments, non-profit and for-profit organizations? - Aldo Leopold said that the basis of conservation is husbandry, and that any government can only do certain things. Governments can build great buildings and fight wars, but they are unable to do the myriad of things that constitute husbandry. Additionally, if we make government responsible for conservation, it will do what it can, not what needs doing. Paraphrase of “Land Use Democracy”, Audubon, September 1942. How will the BLM/DFO adopt itself to carry out basic conservation, the myriad of things that constitute husbandry? - How can the BLM/DFO apply the teachings of Aldo Leopold that private efforts would take care of the environment, not public ones? Citations: “Bush touts ‘new environmentalism,’ fewer mandates”, transcript of President Bush speech on CNN.com website, May 30, 2001, pages: 2, http://www10.cnn.com/2001ALLPOLITICS/05/30/bush.sequoia/index.html Scarlett, Lynn, “Conservative Rights and Conservationist Principles Work Together, Says Norton”, Tech Central Station, Transcribed interview with Gale Norton, February 5, 2001, pages: 7, http://www.techcentralstation.com/EnvironLetters.asp?FormMode=EnviroScarletLetters&ID=5 Anderson, Terry L. & Hill, Peter J., “Environmental Federalism: Thinking Smaller”, PERC Policy Series, Issue Number PS-8, December 1996, pages: 26, http://www.perc.org/ps8.htm Scarlett, Lynn, & Ritter, Don, “States can teach the feds”, The Journal of Commerce, July 31, 1998, pages: 3, http://www.newenvironmentalism.org/envrevo.htm Grewell, J. Bishop, “The Sand County Foundation”, Center for Private Conservation, pages: 8, http://www.privateconservation.org/case_studies.php?article_id=4&print=yes Taylor, James M., “A Win for Private Landowners”, Environment & Climate News, September 2001, pages: 6, http://www.heartland.org/environment/sep01/win.htm
- How will the BLM/DFO prepare listings and manage designated species to ensure the designation does not make innocent species the enemy? - What will the BLM/DFO do to meet its contractual obligations to permittees while recovering endanger species? - What management strategies will the BLM/DFO utilize to ensure a designated species is rapidly recovered? - What alternatives would the BLM/DFO recommend to improve endangered species legislation? - How will the BLM/DFO protect the custom, culture and economy of Beaverhead County while recovering endangered species? Citations: Smith, Robert J., “Wildlife Protection and Private Property; The Need for Endangered Species Act Reform”, August 2, 1996, pages: 1, http://www.heartland.org/pdf/23212b.pdf Taylor, Pat, “Court Rules Economic Impact Must Be Tied to ESA”, CNSNews.com, May 18, 2001, pages: 3, http://www.paragonpowerhouse.org/court_rules_economic_impact_must.htm Stroup, Richard L. & Leal, Donald R., “Policy Proposal for Endangered Species”, PERC, Bozeman, MT, pages: 4, http://www.perc.org/esa_propsl.htm Stroup, Richard L., “Endanger Species Act: Making Innocent Species the Enemy”, PERC Policy Series, Issue Number PS-3, April 1995, pages: 15, http://www.perc.org/ps3.htm
- What can the BLM/DFO do to make the nation less dependent on foreign supplies of natural and strategic resources? - How important will environmental concerns be in the event of a national emergency? - What management and planning are necessary to protect the environment in the event of a national emergency? Citations: Baden, John & Stroup, Richard, “Saving the Wilderness”, Reason Magazine, July 1981, pages 28-36, pages: 9, no URL.
- What will the BLM/DFO do to revitalize the mining industry in Beaverhead County? - How will the BLM/DFO ensure mining remains one of many multiple uses? Citations: Gerard, David, “The Mining Law of 1872: Digging a Little Deeper”, PERC Policy Series, Issue Number PS-11, December 1997, pages: 20, http://www.perc.org/ps11.htm
- What will the BLM/DFO do to revitalize Beaverhead County’s forest industry? - How will the BLM/DFO ensure forest industries remain one of many multiple uses? - What actions will the BLM/DFO take to reduce the danger of uncontrollable wildfires in Beaverhead County and how will these actions be coordinated with other agencies and private landowners? Citations: Sedjo, Robert A.,“The National Forests: For Whom and For What? “, PERC Policy Series, Issue Number PS-23, August 2001, http://www.perc.org/ps23.pdf Binkley, Clark S., “Forestry in the Next Millennium: Challenges and Opportunities for the USDA Forest Service”, Resources for the Future, Washington D.C., Discussion Paper 99-15, January 1999, pages: 18, http://www.rff.org/CFDOCS/disc_papers/PDF_files/9915.pdf “New Federal Forestry”, American Forest and Paper Association, pages: 3, http://www.afandpa.org/forestry/NFF/NFF_backgrounder.html “Recent Forest Fires Traded to Reduced Logging”, Environment and Climate News, July 2001, pages: 1, http://www.heartland.org/environment/jul01/logging.htm Randall, Tom, “Alaska’s Forests Left to Die by Government ‘Stewards’”, Environment News, November 1999, pages: 3, http://www.heartland.org/environment/nov99/alaska.htm “Misc. Forest Information”, Montana Wood Products Association, pages: 11, http://www.montanaforests.com/forest_info.htm
- How will BLM/DFO act to support prior existing water rights and Montana water law? - What strategy will the BLM/DFO utilize to recover endangered species while protecting prior existing water rights and supporting Montana water law? - How will the BLM/DFO work with the Bureau of Reclamation and Army Corps of Engineers to maintain irrigated habitat? Citations: Findley, Tim, “Water in the West”, Range Magazine, Fall 2001, page 1W-2W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Findley, Tim, “Caught in the high beams”, Range Magazine, Fall 2001, page 3W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Findley, Tim, “Betrayed by the Feds”, Range Magazine, Fall 2001, page 4W-14W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Findley, Tim, “Basins”, Range Magazine, Fall 2001, page 15W-19W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Findley, Tim, “The Map”, Range Magazine, Fall 2001, page 20W-21W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Findley, Tim, “Aquifers”, Range Magazine, Fall 2001, page 22W-23W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Findley, Tim, “Drought”, Range Magazine, Fall 2001, page 24W-26W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Findley, Tim, “The West”, Range Magazine, Fall 2001, page 27W-29W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Findley, Tim, “The Great Basin”, Range Magazine, Fall 2001, page 30W-34W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Goodson, Jeff, “Big Lone Star Win”, Range Magazine, Fall 2001, page 35W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Goodson, Jeff, “The Texas Water Wars”, Range Magazine, Fall 2001, pages 36W-37W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf Savory, Allan, “Drowning in Albuquerque?”, Range Magazine, Fall 2001, pages 38W-39W, pages: 40, http://www.rangemagazine.com/water/wiw07.01.pdf
- What effect does the BLM/DFO giving away valuable resources have on the economy of Beaverhead County? - Why are state and private land management systems more efficient than federal agencies? Citations: Lippke Fretwell, Holly, “Paying to Play: The Fee Demonstration Program”, PERC Policy Series, Issue No. PS-17, December 1999, pages: 24, http://www.perc.org/ps17.pdf Lippke Fretwell, Holly, “An Unseen Cost of Low Park Fees”, PERC Reports, December 1999, page 20, pages 1, http://www.perc.org/dec99.pdf Leal, Donald R., “Turning a Profit on Public Forests”, PERC Policy Series, Issue Number PS-4, September 1995, pages: 21, http://www.perc.org/ps4.htm
- How does achieving short term goals result in the long-term destruction of habitat? i.e.: logging has been stopped to protect an eagle, instead a wildfire burns the forest, destroying the eagles and their habitat. Citations: Vincent, Bruce, “On the Fire Line”, Environment & Climate News, November 2000, pages: 3, http://www.heartland.org/environment/nov00/vincent.htm Savory, Allan, “Taking a Holistic Approach”, Preventing Wildfires through Proper Management of the National Forests, Oversight Hearing conducted by the House Subcommittee on Forests and Forest Health, August 14, 2000, Albuquerque, New Mexico, pages: 9, http://www.house.gov/resources/1065cong/00aug14/savory.htm LaJeunnesse, William, & Wallace, Robin, “Endangered Fish Policy May Have Cost Firefighters’ Lives”, FoxNews.com, August 2, 2001, pages: 3, http://www.foxnews.com/story/0,2933,31019,00.html
- Is designating an area as special (ACEC, wilderness, etc) the best way to protect the values in that area, or will the designation attract more attention and make protection more difficult? - How do special designations impair the ability of the BLM/DFO to effectively manage the designated area? - How will the BLM/DFO manage specially designated areas to protect the multiple use values inside and outside the specially designated areas? - Are there other management paradigms or designations that would be more appropriate for lands that have a history of multiple use, including logging, mining, road building, motorized recreation and/or grazing than wilderness, ACEC, etc? - Under current funding levels, does the BLM/DFO have the ability to effectively administer the areas currently under special designation? - How will the designation of additional special areas affect the resource values and management of the existing specially designated areas? - What mechanism will the BLM/DFO implement in specially designated areas to protect prior existing water rights and support Montana water law? Citations: Lippke Fretwell, Holly, “Public Lands: Is No Use Good Use?”, PERC, May 2001, pages: 23, http://www.perc.org/pl4.pdf Collins, Clark, “Wilderness is not Good for Recreation, Alternative Designation is Needed”, Blue Ribbon Coalition, pages: 2, http://www.sharetrails.org/bcra1.html “A Designation Whose Time Has Come”, Blue Ribbon Coalition, pages: 6, http://www.sharetrails.org/backcountry.htm Patric, James & Harbin, Raymond, “Whither Wilderness? How Much Is Enough?” Heartland Policy Study, Number 88, December 21, 1998, pages: 45, http://www.heartland.org/studies/patric-ps.htm
- What are the commonalities between Free Market Environmentalism, New Environmentalism, the evolution of Traditional Environmentalism to a community based collaborative effort and the new BLM Planning Guidelines? - How can the BLM/DFO effectively integrate the theories of Free Market Environmentalism to improve environmental quality, reduce costs and improve community “buy in”? Citations: Anderson, Terry L. and Shaw, Jane S., “Is Free Market Environmentalism ‘Mainstream’?”, http://www.perc.org/fmemain.pdf Taylor, James M., “Environmental Protection Through Free-Market Principles”, Environment & Climate News, September 2001, an interview with Kathleen Benedetto, pages: 4, http://www.heartland.org/environment/sep01/benedetto.htm Smith, Robert J. “Resolving the Tragedy of the Commons by Creating Private Property Rights in Wildlife”, the Cato Journal, Volume 1, No. 2, Fall 1981, pages: 24, http://www.cato.org/pubs/journal/cj1n2-1.html Brown, Matthew & Shaw, Jane S., “To Preserve It, Buy It”, Op-Ed by PERC, Tacoma News Tribune, August 13, 1998, pages: 3, http://www.perc.org/oploomis.htm Taylor, James M., “PERC proposes reforms of environmental policy”, Environment & Climate News, September 2001, pages: 5, http://www.heartland.org/environment/set01/perc.htm
- Is the BLM/DFO discriminating against certain minorities based on race, ethnicity or socio-economic status? - How can the BLM/DFO give resources of great value away to one minority group and charge another minority for resources? - What can the BLM/DFO do to reverse the discrimination against minorities and ensure any disaffected minorities can effectively participate in the BLM/DFO processes? - How will the BLM/DFO implement a policy of fair treatment? Fair treatment means that no group of people, including a racial, ethnic, or socioeconomic group, should bear a disproportionate share of the negative consequences resulting from the execution of federal, state, local, and tribal programs and policies. - What will the BLM/DFO do to deal with the perception on some parts of the public that certain minorities are being “cleansed” from the rural areas and/or the west? Citations: Radonovich, George, “Wilson Bridge Watch”, Washington Times Op-Ed, February 6, 2001, pages: 2, http://www.nwi.org/SpecialStudies/WashConsProject/WashTimesFeb06OPED.html “Washington Exempts Itself from the ESA”, Washington (DC) Times editorial, August 15, 2001, pages: 2, http://www.klamathbasincrisis.org/exposed/washingtonexempts.htm Strassel, Kimberly A., “Commentary: Rural Cleansing”, Wall Street Journal, July 26, 2001, pages: 3, http://www.citizenreviewonline.org/july_2001/rural_cleansing_printable.htm Hadley, C.J., “The Political Cleansing of the West”, Range Magazine, Fall 1999, page 11, pages 3, http://www.rangemagazine.com/stories/fall99/political_cleansing.htm Miller, Ted, “Rural Cleansing by Endangered Species”, JeffersonState.com, pages: 2, http://www.jeffersonstate.com/articles/ruralcleansing.html “Rural Cleansing”, Ethan Allen Institute commentary, pages: 2, http://www.ethanallen.org/commentaries/2001/rural.htm
Paige, Sean, “Arnold Pulls Back the Veil of ‘Green’
Tyranny”, Insight Magazine, October 2000, pages: 3, http://www.insightmag.com/archive/200010175.shtml
- Is Ecosystem Management appropriate for use as a guide for public policies, or does use of the concept interject uncertainty, imprecision and arbitrariness? - Are there better management paradigms available to the BLM/DFO than ecosystem management? Citations: Fitzsimmons, Allan K., “The Illusion of Ecosystem Management”, PERC Reports, December 1999, page 3-5, pages: 3, http://www.perc.org/dec99.pdf Fitzsimmons, Allan, K., “Federal Ecosystem Management: A ‘Train Wreck’ in the Making”, Cato Policy Analysis No. 217, October 26, 1994, pages: 31, http://www.cato.org/pubs/pas/pa-217.html Chase, Alston, “Searching for a Past That Never Was”, Chronicles magazine, June 1996, page 17-21, pages: 5, http://www.heartland.org/pdf/23684i.pdf Budiansky, Stephen, “Unpristine Nature”, The American Enterprise, September/October 1995, page 64-67, pages: 4, http://www.heartland.org/pdf/23234g.pdf
- How has the shift from a technical to a functional resource definition changed management paradigms? - Is managing for the “whole” a more balanced approach than managing for one criterion? - Is analyzing how the system as a “whole” captures and processes energy a better indicator of resource health? Citations: Fedwik, John, “New Ideas for Teaching Natural Resource Management”, USDA Forest Service, from Long-Term Realities of National Forest Management, Sept 28, 1998, pages: 11, http://www.fs.fed.us/pub/fedkiw.html Horst, Shannon, “Forest Fire and Scapegoats – Who or what is really to blame for the tragic Cerro Grande fire?”, Albuquerque Tribune, June 3, 2000, pages: 7, http://www.holisticmanagement.org/art_fire.cfm? Hadley, C.J., “The Wild Life of Allan Savory”, Range Magazine, Fall 1999, page 44-47, 55-56, pages: 11, http://www.rangemagazine.com/stories/fall99/allan_savory.htm
- Are education and public relations part of the BLM/DFO’s responsibilities? - What relationship should the BLM/DFO have with the press and advocacy groups? Citations: Davis, Jeffery, “MoJo’s December HELLRAISER”, Mother Jones Magazine, pages: 2, http://www.motherjones.com/mother_jones/ND94/hellraiser.thml Hadley, C.J., “Up Front”, Range Magazine, Fall, 2000, page 3, pages: 1, http://www.rangemagazine.com/stories/fall00/up_front.htm
- What is the appropriate role of science in the creation, implementation and monitoring of BLM/DFO decision making processes? - What is the definition of “best available scientific information” and how is that achieved? - How can the BLM/DFO follow the scientific process carefully and facilitate review of the decisions by the general public and skeptical scientists? Citations: Doremus, Holly, “Listing Decisions Under The Endangered Species Act: Why Better Science Isn’t Always Better Policy”, Washington University Law Quarterly, Volume 75, Number 3, Fall 1997, pages 91, http://www.wulaw.wustl.edu/WULQ/75-3/753-1.html
- How does statistical theory guide the scientific process and data collection? - How can a vigorous statistical methodology be used to verify the validity a scientific process and/or the data collected? - Using verified data, how can statistics be used to determine past trends and forecast future trends? - How can statistics best be used as a management tool? Citations: Elementary Concepts in Statistics, StatSoft online electronic textbook, 1984-2001, pages: 9, http://www.statsoft.com/textbook/esc.html Basic Statistics, StatSoft online electronic textbook, 1984-2001, pages: 27, http://www.statsoft.com/textbook/stbasic.html
- What are the “best practices” for the preparation of an economic analysis or cost-benefit analysis? - How useful are willingness-to-pay (WPT) values in economic analysis? - How will the BLM/DFO prepare economic analyses that represent “real world” on the ground choices and their effects accurately? - How will the BLM/DFO prepare unbiased, economically balanced and acute economic analyses? Citations: “Economic Analysis of Federal Regulations Under Executive Order 12866”, Office of Management and Budget, January 11, 1996, known as “best practices” document, pages: 29, http://wwwwhitehouse.gov/omb/inforeg/riaguide.html Costanza, Robert; D’Arge, Ralph; De Groot, Rudolf; Farber, Stephen; Grasso, Monica; Hannon, Bruce; Limburg, Karin; Naeem, Shahid; O’ Neill, Robert V.; Paruelo, Jose; Raskin, Robert G.; Sutton, Paul; Van Der Belt, Marjan; “Valuing Ecosystem Services: A Response”, a letter in Regulation, 1997, Volume 20, Number 4, pages: 8, http://www.cato.org/pubs/regulation/reg20n4-let.html Fitzsimmons, Allen K., “Clearing Ecosystem Misunderstandings”, a letter in Regulation, 1997, Volume 20, Number 4, pages: 8, http://www.cato.org/pubs/regulation/reg20n4-let.html Carey, Merrick, “Correcting Remedial Measures”, Regulation, 1997, Volume 20, Number 4, pages: 8, http://www.cato.org/pubs/regulation/reg20n4-let.html Shogren, Jason F., “Lessons from the Lab”, Regulation, 1997, Volume 20, Number 4, pages: 8, http://www.cato.org/pubs/regulation/reg20n4-let.html Smith, Kerry V. “Mispriced Planet”, letter in Regulation, Summer 1997, page 16-17, pages: 2, http://www.cato.org/pubs/regulation/reg20n3-per.html Weick, Ed, “Cost Benefit Analysis: Cost benefit analysis and its possible application to the EARP process”, ESAS Inc, March 22, 1999, pages: 13, http://www.members.eisa.com/~ec086636/cost_benefit_analysis.htm Miscellaneous Technical and Process Issues - Trails Closed Unless Open should apply to hikers and horseback riders as those trails were not constructed without significant public involvement or NEPA analysis, and to allow their continued use legitimizes the non-NEPA compliant process that created the trails.
- What mechanisms will the BLM/DFO put in place to gauge the
cumulative effects of its actions on the culture, custom and economy
of Beaverhead County? i.e.: in grazing allotments, the reduction of a
few hundred AUMs on a single allotment is not considered significant.
When these changes are combined on a countywide or resource area
basis, they significantly impact the custom, culture and economies of
the surrounding communities.
- Beaverhead County would suggest that an RMP that could be implemented and monitored with the current staff and budget levels would be appropriate. Everyone would like an increased budget, but these seldom materialize without an incremental increase in workloads. We believe this is an important consideration of any special designations or projects.
- Beaverhead National Forest has a class 10 fire danger rating, the highest. This means the forest has a fire ladder from forest floor to forest canopy. Implicitly, this rating also means much of the Beaverhead National Forest and co-adjacent landowners, including the BLM/DFO, will experience severe wildfires during the lifetime of the new RMP. Beaverhead County is concerned that resources will be diverted from the implementation and monitoring workload of the RMP to fire fighting. As the fire danger is known, Beaverhead County believes a necessary part of the RMP is to develop a mechanism to meet the dual requirements of implementing, managing and monitoring the new RMP and effectively controlling wildfires. To create an RMP that would allow the diversion of management resources to fire fighting when the fire danger is known would not be effective planning.
- What mechanisms will the BLM/DFO put in place to gauge the cumulative effects of its actions on the culture, custom and economy of Beaverhead County? i.e.: in grazing allotments, the reduction of a few hundred AUMs is not considered significant. When these changes are combined on a countywide or resource area basis, they significantly impact the custom, culture and economies of the surrounding communities. Incorporating Knowledge from 1970 RMF into 2001 RMP. - One requirement of effective planning is that past plans be reviewed and the information learned from implementation and monitoring be used to improve the creation, implementation, management and monitoring of the new plan. Beaverhead County believes an important point of the scoping process should involve the following:
1.) A review of the 1979 RMF and the general guidelines it provided. This process should allow the BLM/DFO to incorporate the lessons learned from the 1979 RMF into the 2001 RMP.
- Beaverhead County would recommend that the Resource Advisory
Council (RAC) be given the additional responsibility of reviewing the
ongoing implementation and monitoring to evaluate projects for
success or failure relative to 2001 RMP. Add A New Comment |
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