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AUGUST 2017

Recommendations for BLM Streamlining Planning & NEPA
Published August 3, 2017


A. Focused Analysis: How can the BLM reduce duplicative and disproportionate analyses?

  1. Solution #1 – Develop Guidance that Broadly Interprets Plan Conformance to Reduce the Need for Plan Amendments - Provide for a broader interpretation of “plan conformance” to reduce the need for plan amendments. Pursuant to current regulation (43 C.F.R. § 1601.0-5(b)), plan conformance means that an action is either “specifically provided for in the plan” or “if not specifically mentioned, [] clearly consistent with the terms, conditions and decisions of the approved plan or plan amendment.” The term “clearly consistent” with respect to “terms, conditions and decisions of an approved plan or plan amendment” could be broadly interpreted (via written policy) to reduce the need for plan amendments.
  2. Solution #2 – Provide Enhanced Staff Training - BLM must provide its staff specific training to strictly follow the current planning regulations and manage third party contractors assisting the agency with their analysis. Analysis should focus on the truly significant impacts and minimize discussion and consideration of nominal effects for the sake of coverage of every conceivable impact. Recommendations for BLM Streamlining Planning & NEPA

Docket No. DOI–2017–0002, Review of Certain National Monuments Established
Published August 3, 2017


Re: Docket No. DOI–2017–0002, Review of Certain National Monuments Established Since 1996


Dear Secretary Zinke:


The Arizona Mining Association (AMA), Arizona Rock Products Association (ARPA), AMIGOS, and the Southern Arizona Business Coalition are jointly submitting comments for the four national monuments located in the state of Arizona that meet the criteria for review as established in Executive Order 13792 issued on April 26, 2017. These are the Sonoran Desert, Vermillion Cliffs, Ironwood Forest and Grand Canyon-Parashant National Monuments. - AZ Mining Industry Group Comments on National Monuments – July 6


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