Printer Friendly

Bureau of Land Management National Conservation Areas: legitimate conservation or Satan's Spawn?

In the last third of the twentieth century, Congress saw fit to designate ten Bureau of Land Management ("BLM") national conservation areas ("NCAs") in eight western states. Unlike Wilderness or national parks or national wildlife refuges, Congress has never enacted general, uniform guidance to direct the creation and management of NCAs. There is no "National Conservation Area System." (1) Although there are similarities in the legislation establishing NCAs, each is the result of local politics and Congressional compromise.

Congress cites a multitude of reasons for creating NCAs, but two unstated motives almost always bear on the decision to designate a new area. The first has been to elevate the status of environmentally significant BLM lands (and sometimes their protection) to avoid transferring them to another, more conservation-oriented federal agency. A second unspoken reason Congress creates NCAs is that they are considered a political alternative to Wilderness designation. (2)

The enabling legislation designating each NCA establishes the management scheme and lists the permissible uses for that particular area. Table 1 depicts the NCAs Congress has designated to date. By analyzing the columns from left to right one can see the differences between NCAs. Analyzing the rows yields trends in both the levels and types of protection legislated for each area.

Congress addresses resource protection, or the lack thereof, in the purposes for which each NCA was designated, the values each area is intended to conserve, the statutory uses that are permitted in each area, or with specific provisions regarding particular uses. Only a few generalities can be made for NCAs. These areas are usually withdrawn from location, leasing and sale under federal mining and geothermal development laws; motorized vehicles are generally limited to designated roads and trails; and as public lands grazing has become more controversial, where grazing privileges have predated NCA designation Congress has acted to specifically preserve them in the enabling legislation. (3) In most cases Congress has authorized acquisition of inheld or adjacent state or private lands through purchase, donation or exchange to consolidate or expand NCAs. Which political party controls what branch of government appears to have little effect on the form or substance of NCA designation. (4)

NCAs are potentially helpful in the conservation, protection and restoration of BLM lands. Since there is no underlying statutory basis (including minimum protections) for NCAs, each area Congress creates is essentially concocted to meet the political opportunities or realities of the moment. For example, the Clinton Administration was so bold as to develop a list of minimum protections for NCAs proposed during its tenure; Congressional sponsors of NCA legislation were advised to meet the standards or suffer the President's veto. (5) Similarly if conservationists have a strong political hand, they can help craft good NCAs. If they do not, they will not.

The history of NCAs teaches us that they should be considered when it is determined that transfer of the environmentally significant (usually threatened) landscapes to another federal agency is not preferred or politically practical. However, there are standards that conservationists should enforce when Congress seeks to designate a new area. NCAs should not be a substitute for Wilderness designation, rather they should encompass larger landscapes with important natural and other public values and include Wilderness and Wild and Scenic River designations for all qualifying rivers within them. Also, conservationists should reject any NCA that, at a minimum: does not declare environmental conservation as its primary purpose, to which all other exploitative or recreational uses are subordinate; fails to withdraw the entire area from all forms of mineral and geothermal development; does not prohibit off-road vehicle use; or "releases" wilderness study areas from further consideration as BLM wilderness. (6) Where livestock grazing is an issue, conservationists should also advocate for voluntary or compulsory grazing permit retirement. (7) If, as NCA legislation winds its way through the political process, it takes a turn for the worse, then conservationists may need to kill it, fight harder to win the necessary protections, or strategically withdraw and regroup so that stronger protection can be obtained for the area in the future.
TABLE 1. COMPARISON OF BUREAU OF LAND MANAGEMENT NATIONAL
CONSERVATION AREAS

NATIONAL
CONSERVA-
TION AREA King Range Steese El Malpais

ESTABLISHED Oct. 21, 1970 Dec. 2, 1980 Dec. 31, 1987

PUBLIC LAW 91-476 96-487 100-225

AREA (ACRES) 60,000 1,220,000 262,690

STATE California Alaska New Mexico

WHITE HOUSE Republican Democrat Republican

CONGRESS Democrat Democrat Democrat

STATUTORY "[C]onserving "[P]rovide for "[P]rotect for
PURPOSES and develop- the immediate the benefit and
 ing, for the use and future enjoyment of
 and benefit of protection of future genera-
 the people of the lands in tions (this)
 the United Federal owner- area contain-
 States, the ship within the ing the La
 lands and framework of Ventana Natu-
 other a program of ral Arch and
 resources multiple use the other
 therein under and sustained unique and
 a program of yield and for nationally
 multiple usage the mainte- important ...
 and sustained nance of envi- resources of
 yield." ronmental the public
 quality ..." lands sur-
 rounding
 Grants Lava
 Flows ..."

STATUTORY "[N]atural "[C]aribou "[U]nique and
VALUES resources range and nationally
 including but Birch Creek" important geo-
 not limited to (Wild and logical, archeo-
 the soils, bod- Scenic River logical,
 ies of water (designated as ecological, cul-
 including the wild)). tural, scenic,
 shorelines scientific and
 thereof, forest wilderness
 growth includ- resources ..."
 ing timber,
 vegetative
 cover including
 forage, fish,
 and other
 wildlife, and
 geological
 resources
 including min-
 erals."

STATUTORY "[I]ncluding None stated. Managed to
USES but not limited "protect the
 to ... scenic resources spec-
 enjoyment, ified (above)"
 hunting, fish- in accordance
 ing, hiking, with FLPMA
 riding, camp- and "other
 ing, picnicking, applicable pro-
 boating and visions of law,
 swimming, all including those
 uses of water provisions
 resources, relating to
 watershed grazing on
 management, public lands";
 production of hunting and
 timber and trapping per-
 other forest mitted in
 producers, accordance
 grazing and with New
 other agricul- Mexico state
 tural uses, fish law, except
 and wildlife zones estab-
 management, lished for pub-
 mining, preser- lic safety,
 vation of eco- administration
 logical or public
 balance, scien- enjoyment.
 tific study,
 occupancy and
 access."

WATER No provision. No provision. Enough
RIGHTS PRO- reserved to
VISION fulfill purposes
 of the NCA.

LAW No provision. No provision. No provision.
ENFORCEMENT
PROVISION

HYDROELEC- No provision. No provision. No provision.
TRIC DEVEL-
OPMENT
PROVISION

Motorized No provision. No provision. No provision.
Vehicles
Provision

WOOD PROVI- Expressed use No provision. Commercial
SION (see "Uses" sale of dead or
 above). green wood
 prohibited.

MINERAL Prospecting Withdrawn All lands with-
WITHDRAWAL and patents from location, drawn from all
PROVISION are subject to entry and pat- forms of entry,
 "reasonable ent; leasing appropriation
 regulation" as and sale con- or disposal
 the Secretary tinued. Secre- under the pub-
 may issue. tary may lic land laws;
 classify lands from location,
 as open to entry and pat-
 entry, location ent under the
 and patent. All mining laws;
 valid claims and from dis-
 subject to position under
 "reasonable all laws per-
 regulations ... taining to min-
 to assure that eral and
 mining will, to geothermal
 the maximum leasing. Also
 extent practi- includes provi-
 cable, be con- sion for
 sistent with exchanges of
 the scenic, sci- mineral inter-
 entific, cultural ests.
 and other
 resources ..."
 Patents for
 minerals only.

WILDERNESS No provision. No provision. Wilderness
PROVISION NCA overlaps designated
 existing Wil- within NCA;
 derness. new Wilder-
 ness Study
 Area desig-
 nated.

LAND ACQUI- Donation, No provision. Donation,
SITION PROVI- purchase, or purchase,
SION exchange. exchange,
 transfer from
 another fed-
 eral agency.

LIVESTOCK Express use No provision. "[S]hall be
GRAZING PRO- (see "Uses" permitted to
VISION above). continue, pur-
 suant to appli-
 cable Federal
 law, including
 this sub-
 chapter, and
 subject to such
 reasonable
 regulations,
 policies and
 practices as
 the Secretary
 deems neces-
 sary."
NATIONAL
CONSERVA- San Pedro Red Rock Gila Box
TION AREA Riparian Canyon Riparian

ESTABLISHED Nov. 18, 1988 Nov. 16, 1990 Nov. 28, 1990

PUBLIC LAW 100-696 101-621 101-628

AREA (ACRES) 56,431 195,780 20,767

STATE Arizona Nevada Arizona

WHITE HOUSE Republican Republican Republican

CONGRESS Democrat Democrat Democrat

STATUTORY [P]rotect the "[C]onserve, "[C]onserve,
PURPOSES riparian area protect and protect and
 ... of the enhance for enhance the
 public lands the benefit riparian and
 surrounding and enjoyment associated
 the San Pedro of present and areas ..."
 River ..." future genera-
 tions ... the
 area ... con-
 taining and
 surrounding
 the Red Rock
 Canyon ..."

STATUTORY "[A]quatic, "[U]nique and "[A]quatic,
VALUES wildlife, arche- nationally wildlife,
 ological, pale- important geo- archaeological,
 ontological, logic, archeo- paleontologi-
 scientific, cul- logical, cal, scientific,
 tural, educa- ecological, cul- cultural, edu-
 tional and tural, scenic, cational,
 recreational scientific, wild- scenic, and
 resources ..." life, riparian, other
 wilderness, resources and
 endangered values ..."
 species, and
 recreation
 resources ..."

STATUTORY "The Secretary "The Secretary "The Secretary
USES shall only shall only allow shall allow
 allow such such uses of only such uses
 uses ... [that] the conserva- ... [that] will
 will further the tion area as he further the
 primary pur- finds will fur- purposes for
 poses for ther the pur- which the con-
 which the con- poses for which servation area
 servation area the conserva- is established."
 is established." tion area is
 established";
 nothing shall
 preclude the
 Secretary from
 taking mea-
 sures to pre-
 vent devastating
 fire or infesta-
 tion of insects
 or disease with-
 in the NCA;
 hunting permit-
 ted in accord-
 ance with
 Nevada state
 law, except
 zones estab-
 lished for pub-
 lic safety,
 administration or
 public enjoy-
 ment.

WATER Enough Enough Enough
RIGHTS PRO- reserved to reserved to reserved to
VISION fulfill purposes fulfill purposes fulfill purposes
 of the NCA. of the NCA. of the NCA.

LAW Fines and No provision. Fines and
ENFORCEMENT imprisonment imprisonment
PROVISION authorized. authorized.

HYDROELEC- No provision. No provision. No provision.
TRIC DEVEL-
OPMENT
PROVISION

Motorized "[O]nly ... Limited to "[P]ermitted
Vehicles allowed on designated only on roads
Provision roads specifi- roads and specifically
 cally desig- trails. designated for
 nated for such such use...."
 use...."

WOOD PROVI- No provision. No provision. No provision.
SION

MINERAL All lands with- All lands with- All lands with-
WITHDRAWAL drawn from all drawn from all drawn from all
PROVISION forms of entry, forms of entry, forms of entry,
 appropriation appropriation appropriation
 or disposal or disposal or disposal
 under the pub- under the pub- under the pub-
 lic land laws; lic land laws; lic land laws;
 from location, from location, from location,
 entry and pat- entry and pat- entry and pat-
 ent under the ent under the ent under the
 mining laws; mining laws; mining laws;
 and from dis- and from dis- and from dis-
 position under position under position under
 all laws per- all laws per- all laws per-
 taining to min- taining to min- taining to min-
 eral and eral and eral and
 geothermal geothermal geothermal
 leasing. leasing. leasing.

WILDERNESS No provision. Wilderness No provision.
PROVISION Study Areas
 expressly unaf-
 fected.

LAND ACQUI- Donation, Donation, Donation,
SITION PROVI- purchase or purchase, purchase or
SION exchange. exchange, exchange.
 transfer from
 another fed-
 eral agency, or
 limited con-
 demnation.

LIVESTOCK No provision. No provision. No provision.
GRAZING PRO-
VISION

NATIONAL
CONSERVA- Snake River Gunnison Colorado
TION AREA Birds of Prey Gorge Canyons

ESTABLISHED Aug. 4, 1993 Oct. 21, 1999 Oct. 24, 2000

PUBLIC LAW 103-64 106-76 106-353

AREA (ACRES) 484,873 57,725 122,300

STATE Idaho Colorado Colo./Utah

WHITE HOUSE Democrat Democrat Democrat

CONGRESS Democrat Republican Republican

STATUTORY "[C]onserva- "[P]rotect the "[C]onserve,
PURPOSES tion, protec- resources of protect, and
 tion and the Conserva- enhance for
 enhancement tion Area in the benefit of
 of raptor accordance present and
 populations with (1) this future genera-
 and habitats Act; (2) the tions the
 and the natu- Federal Lands unique and
 ral and envi- Policy and nationally
 ronmental Management important val-
 resources and Act of 1976 ues ..., includ-
 values ... ...; and (3) ing geological,
 [and the] sci- other applica- cultural, pale-
 entific, cul- ble provisions ontological,
 tural, and of law." natural, scien-
 educational tific, recrea-
 resources and tional,
 values ..." environmental,
 biological, wil-
 derness, wild-
 life education
 and scenic
 resources ..."

STATUTORY Densest "[R]ecognized "The areas ...
VALUES known nesting for offering contain unique
 populations of exceptional and valuable
 raptors in multiple use scenic, recrea-
 North opportuni- tional, multiple
 America; his- ties ... natural, use opportuni-
 torical, cultural cultural, ties (including
 and archaeo- scenic, wilder- grazing), pale-
 logical ness, and rec- ontological,
 resources; mill- reational natural, and
 tary training resources ..." wildlife com-
 area; World ponents
 Center for enhanced by
 Birds of Prey; the rural west-
 Raptor ern setting
 Research and ..."
 Technical
 Assistance
 Center;
 domestic live-
 stock grazing;
 hydro-electric
 facilities.

STATUTORY "[T]he Secre- Motorized "[O]nly such
USES tary shall allow vehicles (see uses ... [that]
 only such uses below); hunt- will further the
 of lands in the ing, trapping purposes for
 conservation and fishing in which the
 area as ... accordance Conservation
 will further the with Colorado Area is estab-
 purposes for law, except lished," includ-
 which the zones estab- ing livestock
 Conservation lished for pub- grazing (see
 Area is estab- lic safety, below); and
 lished," except administration hunting, trap-
 for National or public ping and fish-
 Guard training enjoyment. ing in
 and livestock accordance
 grazing (see with Colorado
 below). and Utah law,
 except zones
 established for
 public safety,
 administration,
 or public
 enjoyment.

WATER Expressly no Expressly no Expressly no
RIGHTS PRO- reserved water reserved water reserved water
VISION right to fulfill right to fulfill right. Allows
 purposes of purposes of for establishing
 the NCA. the NCA. new water
 Allows for right under
 establishing Colorado law.
 new water Adjacent seg-
 right under ment of Colo-
 Colorado law. rado River
 specifically
 excluded as
 part of the
 NCA.

LAW No provision. No provision. No provision.
ENFORCEMENT
PROVISION

HYDROELEC- Expressly No provision. Prohibits fed-
TRIC DEVEL- allowed. eral govern-
OPMENT ment from
PROVISION developing
 new "water
 resource
 facili(ties)" in
 the NCA,
 including
 "hydropower
 projects."

Motorized No provision. "In addition to Limited to
Vehicles the use of designated
Provision motorized roads and
 vehicles on trails.
 established
 roadways, ...
 [they are also]
 allowed to the
 extent the use
 is compatible
 with off-high-
 way vehicle
 designations as
 described in
 the manage-
 ment plan in
 effect on the
 date of enact-
 ment."

WOOD PROVI- No provision. No provision. No provision.
SION

MINERAL All lands with- All lands with- All lands with-
WITHDRAWAL drawn from all drawn from all drawn from all
PROVISION forms of entry, forms of entry, forms of entry,
 appropriation appropriation appropriation
 or disposal or disposal or disposal
 under the pub- under the pub- under the pub-
 lic land laws; lic land laws; lic land laws;
 from location, from location, from location,
 entry and pat- entry and pat- entry and pat-
 ent under the ent under the ent under the
 mining laws; mining laws; mining laws;
 and from dis- and from dis- and from dis-
 position under position under position under
 all laws per- all laws per- all laws per-
 taining to min- taining to min- taining to min-
 eral and eral and eral and
 geothermal geothermal geothermal
 leasing; except leasing. leasing.
 "sale" (able)
 minerals from
 existing sites
 allowed "to
 the extent
 compatible
 with the pur-
 poses ..."

WILDERNESS Wilderness Wilderness Wilderness
PROVISION Study Areas designated designated
 expressly within NCA; within NCA.
 released. Wilderness
 Study Area
 released.

LAND ACQUI- Donation, No provision. Donation,
SITION PROVI- purchase, purchase or
SION exchange, exchange.
 transfer from
 another fed-
 eral agency.

LIVESTOCK "So long as the No provision. "[T]he Secre-
GRAZING PRO- Secretary deter- tary shall issue
VISION mines that and administer
 domestic live- any grazing
 stock grazing is leases or per-
 compatible with mits in the Con-
 the purposes for servation Area
 which the con- ... in accor-
 servation area is dance with the
 established, the same laws
 Secretary shall (including regu-
 permit such use lations) and
 of public lands Executive
 within the con- orders followed
 servation area, by the Secretary
 to the extent in issuing and
 such use of such administering
 lands is compat- grazing leases
 ible with such and permits on
 purposes." Live- other land
 stock grazing is under the juris-
 managed accord- diction of the
 ing to Taylor Bureau of Land
 Grazing Act and Management."
 related laws.

 Black Rock
 Desert-High
NATIONAL Rock Canyon
CONSERVA- Emigrant
TION AREA Trails

ESTABLISHED Dec. 21, 2000

PUBLIC LAW 106-554

AREA (ACRES) 797,100

STATE Nevada

WHITE HOUSE Democrat

CONGRESS Republican

STATUTORY "[C]onserve,
PURPOSES protect, and
 enhance for
 the benefit of
 present and
 future genera-
 tions the
 unique and
 nationally
 important his-
 torical, cul-
 tural,
 paleontologi-
 cal, scenic, sci-
 entific,
 biological,
 educational,
 wildlife, ripa-
 rian, wilder-
 ness,
 endangered
 species, and
 recreational
 values and
 resources asso-
 ciated with the
 Applegate-
 Lassen and
 Nobles Trails
 corridors ..."

STATUTORY Segments of
VALUES historic Cali-
 fornia emi-
 grant Trails;
 wilderness
 landscape;
 absence of
 development;
 Great Basin
 plant and
 animal species;
 cultural, arche-
 ological, pale-
 ontological,
 and geographi-
 cal resources;
 domestic live-
 stock grazing.

STATUTORY "[O]nly such
USES uses ... [that]
 will further the
 purposes for
 which the con-
 servation area
 is established,"
 except live-
 stock grazing
 (see below);
 "large-scale
 permitted
 events in
 defined, low
 impact areas
 of the Black
 Rock Desert
 playa" (Burn-
 ing Man); and
 hunting, trap-
 ping and fish-
 ing in
 accordance
 with Nevada
 law.

WATER No provision.
RIGHTS PRO-
VISION

LAW No provision.
ENFORCEMENT
PROVISION

HYDROELEC- No provision.
TRIC DEVEL-
OPMENT
PROVISION

Motorized Limited to
Vehicles designated
Provision roads and
 trails.

WOOD PROVI- No provision.
SION

MINERAL All lands with-
WITHDRAWAL drawn from all
PROVISION forms of entry,
 appropriation
 or disposal
 under the pub-
 lic land laws;
 from location,
 entry and pat-
 ent under the
 mining laws;
 and from dis-
 position under
 all laws per-
 taining to min-
 eral and
 geothermal
 leasing.

WILDERNESS Wilderness
PROVISION designated
 within NCA.

LAND ACQUI- No provision.
SITION PROVI-
SION

LIVESTOCK "Where the
GRAZING PRO- Secretary of
VISION the Interior
 currently per-
 mits livestock
 grazing in the
 conservation
 area, such
 grazing shall
 be allowed to
 continue sub-
 ject to all
 applicable
 laws, regula-
 tions, and
 executive
 orders."


(1.) In 2000, former Interior Secretary Bruce Babbitt drew together the NCAs and other BLM reservations, including Wilderness, Wild and Scenic rivers, national monuments, the Steens Mountain Cooperative Management and Protection Area and the California Desert Conservation Area into a "National Landscape Conservation System" ("NLCS"). An associate director was promoted to manage a small NLCS office in Washington, D.C., to develop guidance and policy for the NLCS, but the agency promised that no new legal protections or restrictions would be imposed on BLM reservations in the new system. It remains to be seen whether the new Bush Administration will abolish the NLCS.

(2.) Some NCAs overlap existing Wilderness, while others are designated in conjunction with new Wilderness areas. But in every case NCAs are larger than the Wilderness areas within them to allow for otherwise incompatible uses to continue in the non-Wilderness parts of each NCA.

(3.) In three of the last four NCAs established, livestock grazing has been listed as a statutory value as well as a statutory use of the area. See National Parks, Military Parks, Monuments, and Seashores: Snake River Birds of Prey National Conservation Area, 16 U.S.C. [section] 460iii-3(f) (2001); Colorado Canyons National Conservation Area and Black Ridge Canyons Wilderness Act, Pub. L. No. 106-353, [section] 6(g), 114 Stat. 1374 (2000); Black Rock Desert-High Rock Canyon Emigrant Trails, H.R. REP. No. 106-1033, 106th Cong., at 638 (2000). For two NCAs, Snake River Birds of Prey National Conservation Area and Black Rock Desert-High Rock Canyon Emigrant Trails, Congress stated that grazing is important to local communities and that livestock have not been proven to be harmful to the environment. 16 U.S.C. [section] 460iii (11); H.R. REP. No. 106-1033, 106th Cong. at 636-37. For three NCAs, grazing was specifically reserved in Wilderness designated within the NCA. See Colorado Canyons National Conservation Area and Black Ridge Canyons Wilderness Act, Pub. L. No. 106-353, [section] 6(g)(1)-(2), 114 Stat. 1374 (2000); Black Rock Desert-High Rock Canyon Emigrant Trails, H.R. REP. No. 106-1033, 106th Cong. at 640 (2000); National Parks, Military Parks, Monuments, and Seashores: El Malpais National Monument and National Conservation Area, 16 U.S.C. [section] 460uu-32(b) (2001).

(4.) Sometimes the politics of what an area will be called result in the most dramatic and contentious discussions regarding the area's designation. For example, although the pride of the Oregon Congressional delegation, the recently established Steens Mountain Cooperative Management and Protection Area ("SMCMPA") is a political bastard. Pub. L. 106-399, 114 Stat. 1655 (2000). As the delegation deliberated the future for the area managed by the BLM in southeastern Oregon, local resource users warned that they would not tolerate Steens Mountain being legislated as a "national conservation area" due to the land use restrictions implied by such a designation. The delegation therefore dutifully avoided any reference to NCAs in naming the area. Nevertheless, despite its unusual name, the SMCMPA affords strong protections for the Steens, including our country's first legislated livestock, free wilderness area. See id; see also Mark Salvo & Andy Kerr, Congress Designates First Livestock-free Wilderness Area, WILD EARTH 10, 55 (2000).

(5.) Testifying in favor of the Colorado Canyons National Conservation Area and Black Ridge Canyons Wilderness Act of 2000, former Bureau of Land Management Director Tom Fry recounted the Clinton Administration's minimum standards for NCAs.
 The Administration has testified before Congress several times this year on
 special protective legislation for public lands managed by the Bureau of
 Land Management (BLM). While each NCA or BLM-managed National Monument is
 unique, there are certain common elements, and we have set a standard for
 what these special areas must include. Critical components of a Monument or
 NCA include: a land, mining and mineral withdrawal; off-highway vehicle
 (OHV) use limitations; and language which charges the Secretary to allow
 `only such uses' as further the purposes for which the monument or NCA is
 established. In addition, we cannot consent to any language that represents
 a step backward from current management.


Colorado Canyons National Conservation Area and Black Ridge Canyons Wilderness Act of 2000, S. REP. No. 106-460, 106th Cong, at 6.

(6.) Pursuant to the Federal Land Policy and Management Act of 1976, Congress will eventually "release" all wilderness study areas not designated as Wilderness. See 43 U.S.C. [section] 1782(a), (c). Wilderness study areas were released in the Snake River Birds of Prey and Gunnison Gorge National Conservation Areas. See National Parks, Military Parks, Monuments, and Seashores: Snake River Birds of Prey National Conservation Area 16 U.S,C. [section] 460iii-5(b) (2001); Black Canyon on the Gunnison National Park and Gunnison Gorge National Conservation Area Act of 1999, Pub. L. 106-76 [section] 8(a)(2), 113 Stat. 1126.

(7.) For a discussion of federal grazing permit retirement, and how it could rid our national parks and Wilderness areas of domestic livestock, see Andy Kerr & Mark Salvo, Livestock Grazing in the National Park and Wilderness Systems, WILD EARTH 10, 45-52 (2000).

Andy Kerr is principal of the Larch Company and Director of the National Public Lands Grazing Campaign. He can be reached via email at: andykerr@andykerr.net.

Mark Salvo serves as Grasslands and Deserts Advocate for American Lands in Portland, Oregon. He endeavors in matters of the BLM, including Wilderness designation, grazing permit retirement, and the conservation and restoration of sage grouse and their habitat across the West. He may be reached via email at: mark@americanlands.org.
COPYRIGHT 2002 University of California at Los Angeles, School of Law
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 2002 Gale, Cengage Learning. All rights reserved.

Article Details
Printer friendly Cite/link Email Feedback
Author:Kerr, Alex A.; Salvo, Mark
Publication:UCLA Journal of Environmental Law & Policy
Geographic Code:1USA
Date:Jun 22, 2002
Words:3901
Previous Article:The failure of EPA's water quality reforms: from environment-enhancing competition to uniformity and polluter profits.
Next Article:Continued cartographic chaos, or a new paradigm in public land reconfiguration? The effect of new laws authorizing limited sales of public land.
Topics:


Related Articles
Budget battleground.
Our sedimentation boxes runneth over: public lands soil law as the missing link in holistic natural resource protection.
THE TORTOISE AND THE CATTLE RANCHER.
Fish, game find refuge at roads' end.
Conservation tools workshops in Georgia.

Terms of use | Privacy policy | Copyright © 2019 Farlex, Inc. | Feedback | For webmasters