Cat Urbigkit: BLM's Public Comment Process On Sage Grouse & Multiple Use Is Bungled

Columnist Cat Urbigkit writes, "The BLM released thousands of pages detailing six options for public lands management in the western states to conserve sage grouse – but only granted 90 days for the public to read and understand the proposal."

Cat Urbigkit

March 26, 20247 min read

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The Bureau of Land Management released thousands of pages detailing six options for public lands management in the western states to conserve sage grouse – but only granted 90 days for the public to read and understand the proposal.

The agency further complicated this rangewide undertaking by including a shorter comment period (60 days) for a portion of the overall document – that dealing with proposed Areas of Critical Environmental Concern (ACECs).

The Bureau of Land Management is currently accepting public comment on its Greater Sage-Grouse Rangewide Planning Draft Resource Management Plan Amendment and Draft Environmental Impact Statement (DEIS). I’ve reviewed and commented on a lot of agency documents over the last few decades, so I’m familiar with the process and structure, but after spending about 10 hours reviewing this draft environmental impact statement, I feel I’ve just scratched the surface. Still, I’m pleased to report this document is a vast improvement from the Rock Springs Resource Management Plan that was the subject of much public concern last fall.

The public has been granted a 90-day comment period to review and understand this document that will impact 77 BLM Resource Management Plans across 69 million acres in nine western states. The DEIS is spread across three volumes, with the meat of the proposal contained in 661 pages of volume 1, accompanied by 147 pages of maps in volume 2, and more than 1,600 pages of appendixes in volume 3.

It’s well written, supported by science, and well organized. All the glaring flaws of the Rock Springs RMP are absent from this document. The biggest issue I had in reviewing it was simply in terms of scale and trying to decipher the boundaries in various management scenarios in small maps.

The BLM has offered six alternatives for analysis as part of the DEIS, but I’ll focus on the most significant. The BLM’s preferred alternative is Alternative 5, a mix of conservation that avoids and minimizes impacts to grouse habitat while providing local managers the ability to consider site-specific conditions in applying grouse habitat conservation. Importantly, this alternative respects the role of the State Wyoming in managing its grouse population, and the regulatory strength of Wyoming’s sage grouse executive order. This alternative provides for fewer restrictions on resource uses and provides more opportunities for considering compensatory mitigation to reduce impacts on sage grouse and its habitat than other alternatives. It includes disturbance caps, buffer zones, and other protective stipulations to protect priority grouse habitats as well as best management practices for permitted uses.

The preferred alternative seeks to avoid major disturbances in priority grouse habitat but provides for some land uses “where they would minimize their impact (in location and/or intensity) and compensate for residual impacts to achieve no net loss of habitat value—considering both direct and indirect impacts. In achieving the no net loss standard, the BLM would work with the States to apply the tools that work best in those areas to achieve the desired mitigation outcome.”

I appreciate that the BLM’s preferred alternative does prescribe blanket restrictions on other uses of the land but allows land managers some flexibility in allowing uses that do not result in a net loss of grouse habitat.


Here’s where the DEIS gets complicated. Two of the alternatives would designate more than 11 million acres of public lands throughout the western states as Areas of Critical Environmental Concern (ACEC) for sage grouse, including 839,225 acres in Wyoming.

While the preferred alternative does not propose any ACEC designations, two other alternatives do: Alternatives 3 and 6. Alternative 3 is the most restrictive alternative and would close priority habitats to a variety of uses as well as prohibit livestock grazing, rights of way, and mineral entry. In contrast, Alternative 6 is the same as the preferred Alternative 5 with the addition of the ACECs where more restrictions would be imposed.

Under federal law, ACECs are areas “where special management attention is required” to protect and prevent irreparable damage to important resources. The BLM had already considered these ACEC nominations during its 2015 sage grouse plan amendment process and had declined to make the ACEC designation because it determined that the already identified Priority Habitat Management Areas would be sufficient to protect sage grouse.

Now the BLM is back to re-evaluating ACEC designations specifically for sage grouse throughout the western states. The BLM conducted an importance evaluation and narrowed the potential ACECs down to 839,225 acres in Wyoming. Although it’s difficult to tell from the maps, it appears that most of that acreage is in Sublette County.

The Little Sandy area contains some of the highest densities of breeding grouse within the range of the species, establishing the area as "exemplary, rare, unique, and irreplaceable. The potential expansion of liquid and renewable energy development in the nominated area establishes the area as vulnerable to adverse change."

The Sagebrush Focal Areas in South-Central and Southwestern Wyoming with its high densities of grouse is recommended for consideration for ACEC status, as is the Greater South Pass and Upper Green River Basin proposed for ACEC designation.

A small area of Rich County, Utah on Wyoming’s border is also considered for ACEC status.

But as the DEIS points out, the presence of an area that meets relevance and importance criteria does not mean that an ACEC is needed.

“The third component of an ACEC is that the area requires special management to protect and prevent irreparable damage to the given values,” the DEIS states. “Such management would not be present in the absence of the designation.”

The BLM is accepting public comment on the ACEC designations with a shorter timeline than the rest of the DEIS. According to the notice in the Federal Register, public comment on the ACEC portion is scheduled to close on May 14.

The public comment period on the overall sage grouse DEIS is scheduled to close June 13.

Public Meetings:

The BLM is holding 11 in-person open-house and 2 virtual public meetings to provide information on the BLM’s current greater sage-grouse planning effort. All these meetings will include a presentation on the planning effort and opportunities for questions about the planning effort and the Draft RMPA/Draft EIS. The virtual and Wyoming meetings are scheduled for the following days: 

Tuesday, April 9Virtual:  1-3 pm, Mountain Time Zone.  Zoom registration link: 

(Note that both virtual meetings use the same link; attendees can select and register for one or both meetings.)

Monday, April 22, Rock Springs: 5-7 pm, White Mountain Library, 2935 Sweetwater Dr., Rock Springs WY 82901. 

Tuesday, April 23, Worland: 5-7 pm,  Worland Library, 801 Big Horn Ave, Worland WY 82401.

Wednesday, April 24, Casper:  5- 7 pm,  Natrona County Public Library, 307 E 2nd Street, Casper WY 82601 

Thursday, April 25, Virtual : – 6-8 pm Mountain Time Zone. Zoom registration link: 

(Note that both virtual meetings use the same link; attendees can select and register for one or both meetings.)

Cat Urbigkit is an author and rancher who lives on the range in Sublette County, Wyoming. Her column, Range Writing, appears weekly in Cowboy State Daily.

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Cat Urbigkit

Public Lands and Wildlife Columnist