HELP! There’s an RMP. What should I do?
The following information will guide you through the RMP engagement process.
Resource management plans (RMPs) are strategic processes employed by the Bureau of Land Management (BLM) to guide the management of public lands and resources. They involve comprehensive planning that determines the best use of land and resources such as minerals, grazing, water, wildlife, recreation, and areas designated for conservation. This guidance directs BLM staff in their land use decisions. The goal of an RMP is to balance various land uses while ensuring sustainable practices that protect the environment and meet public needs. This process includes stakeholder input, environmental assessments, and legal considerations, resulting in a plan that directs land management activities, typically over a period of 15-20 years. Because of the length of time these plans normally stay in place, and the nature of the plans themselves, decisions in the plan are often larger brush strokes than fine points. A plan will not authorize a specific oil and gas well on a specific site, but rather authorize where oil and gas could be approved within the planning area.
The National Environmental Policy Act (NEPA) plays a critical role in RMPs by ensuring that environmental impacts are thoroughly considered during the planning process. NEPA requires federal agencies, including the BLM, to assess the environmental effects of their proposed actions through Environmental Impact Statements (EIS) or Environmental Assessments (EA), depending on the nature of the RMP. In RMPs, the NEPA process ensures that a range of alternatives is evaluated, public input is considered, and decisions are made transparently. While there have been recent attacks on NEPA regulations, NEPA is still a statutory requirement to which agencies must adhere.
- NEPA fact sheet: how regulatory changes impact RMP development and how to rely on the statutory language
- While the Public Lands Rule has been rescinded, BLM’s conservation mandate remains. It is still critical for BLM to implement this mandate, and you can help by incorporating elements of the Rule into your comments.
RMPs are an exciting, once-in-a-decade opportunity to weigh in on management of our most treasured landscapes, and it’s incredibly important to understand the process and encourage your communities to engage. This document outlines the process for EISs, but keep in mind that the EA process can feel more truncated. Dig in and get started below.
- See an overview of the planning process here
- Campaign checklist
Pre-Scoping and Analysis of Management Situation
BLM will sometimes conduct a pre-scoping process to glean insights from key interest groups within a planning area and conduct an analysis of the management situation. This is an excellent time to build your coalition, develop a community alternative, educate the community about the landscapes, connect with BLM field staff, and submit Area of Critical Environmental Concern (ACEC) nominations.
Scoping
The scoping period in resource management planning is one of the first phases where the public, Tribes, stakeholders, and agencies provide input on the issues and concerns that should be addressed in the plan. This phase is crucial for identifying the scope of environmental analyses and alternatives to be considered. The purpose is to ensure that the planning process is comprehensive and considers diverse perspectives, leading to more informed and effective management decisions. The scoping period is the first time the agency will be formally asking the public for things to include in the plan. Don’t expect the agency to have anything constructive to provide to the general public regarding alternatives or information on what may be included in the final plan or what will be excluded. This is a great time to engage your community more broadly on the process, scope, planning area, writing substantive comments, and encouraging engagement while beginning to build a list of advocates in the community you can keep engaged during future periods of the process.
Due to the wide nature of commenting during this period, all comments are helpful. Scoping periods are typically 30 days. If community members miss the scoping period deadline, encourage them to submit a comment anyway. They may be restricted in the future from submitting a protest if they miss the scoping comment deadline, but that will likely only matter if they plan on filing a lawsuit. Arguments from scoping comments are often great to re-use in communications tactics like op-eds and letters to the editor. Encourage your community members to submit a comment, provide a copy to your organization, and save it for their own records and future use.
- Scoping comment checklist
- List of designations to consider requesting in scoping comments - coming soon
- Campaign checklist
Draft RMP/Draft EIS (or EA)
Draft resource management plans (RMPs) and draft environmental impact statements (EISs) are key documents released during the planning process. These draft RMPs/EISs outline proposed management strategies for public lands and evaluate the potential environmental impacts of those strategies. The draft will often identify the agency’s “preferred alternative.” These drafts should be made available for public review and comment, allowing stakeholders to provide feedback before final decisions are made. This ensures that the final plans are balanced and well-informed. This is the show! From a community engagement perspective, this is the period you want to be working towards. It’s where you should spend the most time organizing around, and likely the portion of the process where the community can have the biggest impact. Go back to those people who commented during scoping and encourage similar comments, now tied to specific alternatives identified by the BLM.
Get creative! Host comment writing workshops, hikes to important landscapes, or anything else that will encourage community participation. In an ideal world, the priorities and issues you care about will be included in the agency-preferred alternative. But if they aren’t, that’s okay! The agency will often pick and choose issues from different alternatives to craft a proposed plan. Getting a lot of people to comment for a certain ACEC or wild and scenic river or protection of a plant species is the best way to influence the outcome.
Proposed RMP/Final EIS (or EA)
The release of the proposed RMP and Final EIS kicks off the opportunity for individuals or groups to formally object to, or protest, the proposed RMP before it is approved. It also triggers a 60-day Governor's Consistency Review (43 CFR § 1610.3-2(e). State agencies review the proposed RMP against official state/local resource management plans, wildlife priorities, air/water quality laws, and land-use policies. This is an opportunity to examine whether the plan is consistent with state laws and policy. This part of the planning process also ensures that previous commenters have a chance to voice concerns about potential impacts or legal issues, promoting transparency and accountability in land management decisions. Protesting a proposed plan is difficult and more time consuming than commenting during scoping or the draft periods. It involves referencing past comments and then documenting where the agency did not incorporate your feedback in their planning process.
The release of the proposed RMP and Final EIS kicks off the opportunity for individuals or groups to formally object to, or protest, the proposed RMP before it is approved. It also triggers a 60-day Governors Consistency Review (43 CFR § 1610.3-2(e). State agencies review the proposed RMP against official state/local resource management plans, wildlife priorities, air/water quality laws, and land-use policies. This is an opportunity to examine whether the plan is consistent with state laws and policy. This part of the planning process also ensures that previous commenters have a chance to voice concerns about potential impacts or legal issues, promoting transparency and accountability in land management decisions. Protesting a proposed plan is difficult and more time-consuming than commenting during scoping or the draft periods. It involves referencing past comments and then documenting where the agency did not incorporate your feedback in their planning process.
Approved RMP/Record of Decision (ROD)
The signing of the record of decision (ROD) marks the final step in the RMP process. It officially approves the proposed land management strategy outlined in the RMP, solidifying the decisions made regarding land use, resource allocation, and environmental protections. The ROD is signed by the authorized agency official, signifying that all legal and procedural requirements, including public input and environmental review, have been met. This decision sets the course for future implementation of the plan and all future land management actions.
Litigation
After the Record of Decision (ROD) is signed, interested parties who remain dissatisfied with the outcome have the option to further challenge the decision by elevating their concerns to the Interior Board of Land Appeals (IBLA) or through litigation. The IBLA provides an administrative forum where disputes over land management decisions can be reviewed, potentially leading to revisions or reversals of the ROD. Alternatively, stakeholders can pursue legal action in federal court to address legal violations. These avenues ensure that there are checks and balances in place, allowing for continued oversight and the opportunity to rectify contested decisions.
- Litigation success story: Uncompahgre Field Office Resource Management Plan
