Memorandum:
To: BLM All
From: Stan Olmstead –
Natural Resource Specialist
Date: September 28, 2012
Re: Last
Formal Comment on the Commitment to the Mission.
Never looking through “rose colored glasses” it is obvious
that we have monumental environmental concerns both in the nation and on the planet
and are in need of serious solutions. The U.S. government has all the abilities
to perform state-of-the-arts environmental
management and yet we continue to fail. The land management agencies have hard-working
people and they put in sincere time to perform their work. However if the Vernal
Field Office is representative, there is concern in the implementation of the
BLM mission. The Vernal Office has placed priority on the exploitation of
public land for commodities. This effort is because of a focus on development
of energy, due to a fossil-fuel fixation, politics, Energy Policy Act (2005), Vernal
Field Office RMP (2008), and office managers that do not understand their
purpose. A quarter of the employees of the Vernal Office have a personal
interest, academic knowledge, and intent to serve the American public in the
performance of the mission. The mission and natural resource knowledge is their
prime reason for working with the Bureau. The intent of the natural resource
professional is to wisely manage habitat and fauna of public land for our
citizens.
U.S. history has shown repeated failure in the care of the
natural world. We placed the exploitation of natural resources and profits from
these resources ahead of wisdom. In the past we mined, logged, grazed and
exploited the natural world. Pressure on our political officials to reverse
this attitude and stop deterioration of natural systems was necessary and
resulted in excellent environmental laws. The U.S. has lost numerous species and
yet we do not act for their ethical protection and subsequently in defense of
our own healthy environment. At the Vernal Office little concern has been shown
to care for sensitive species (mountain plover, sage grouse, hookless cactus).
We promote energy development without stop and continue to measure natural
resources by dollar value.
The mission of the BLM is to sustain the health, diversity and productivity of public lands for the
use and enjoyment of present and future generations. As civil servants we are
obligated to all Americans to perform the BLM mission. Yet our elected,
appointed and agency administrators ask us to focus on commodities and
economics as opposed to environmental health. Commodities and economic gains
are easier to measure. We work with our elected officials but we work for our citizens. Outside
influences that lead us away from our required service to the American citizen and
the BLM mission, should be repelled by the servant. Our service to the American
people is to fulfill the mission through science, law, regulations and “team
work”. Our fellow civil servants that administer the Bureau should insist that
we work together in a common goal to fulfill the intent of the mission. Yet the
Vernal Office does not work together as a professional team, instead the office
works as fragmented groups, individually following bureaucratic requirements catering
to the exploiter and political antagonist.
There is little thought for the future by those in charge for real land
health.
Health and diversity of public lands are natural entities. They
do not include oil wells, livestock, crested wheatgrass nor guzzlers. These are
developments and tools to exploit and have nothing to do with health and
diversity. Productivity is not synonymous with commodities. Protection of
healthy soils, vegetation, clean air & water and a natural fauna are the
true products, which we should diligently promote before commodity extraction. Science
teaches us to not act until we know that harm will not occur to the natural
system. Whereas development asks for proof of damage to the natural system before
you restrict. The natural environment and subsequently the human environment will
be injured seriously if balance is not restored. U.S. federal land management
agencies have it in their power to be the best land stewards anywhere in the world.
We fail not in ability but in our attitude, a lack of understanding, lack of futuristic
thinking and our implementation. Our actions are based on outside forces
inconsistent with the intended mission and wisdom.
The BLM employee that did not study for a career in natural science
frequently works for the Bureau for different reasons than the natural resource
professional and it appears from experience that those who work for these
different reasons are unable to visualize the intended mission. Knowing environmental
health, diversity and the true customer must be known by the team before we can
fulfill our service. Without a personal interest for the health of the land it
is difficult to implement a professional understanding. If as some have said incorrectly
that “their job was to promote oil & gas” they fail in the mission and
service to the people.
Aldo Leopold had four
requisites for land-health:
- Cease throwing away its parts
- Handle it gently
- Recognize that its importance transcends economics
- Don’t let too many people tinker with it.
However Vernal:
- Lost the mountain plover; the only known population in Utah while at
the same time the species is in decline throughout its range. Little
effort to prevent this loss was implemented and is a serious mission departure.
- Plugging and abandonment of well sites have not been a priority.
Numerous oil & gas wells have not produced for more than 15 years and
yet these sites remain un-reclaimed. Notable
of these is Seep Ridge #1; Lease #U-6616 & Seep Ridge #3; Lease
#U-10178-A. Why is it that after more than 20 years of non-production these
two wells remain idle and un-reclaimed? Federal regulation for well
abandonment (Title 43 CFR 3162.3-4) requires abandonment.
- Land reclamation after use still appears difficult to solve.
What’s the problem? The user wishes to profit from the land and the land
is owned by the citizens. Insist that the user fulfills the reclamation requirement
before permitting additional use. Our only task is to identify need and
confirm success.
- Animal Unit Months; we have grazing allotments, allotments have
specified AUM’s and grazing occurs. Yet we disturb large percentages of our
allotments located in oil & gas fields and AUMs remain the same. If
you lose 30% of the forage in a specific allotment it is logical to reduce
the AUMs by 30%.
In the Vernal Field Office we have shown no concern for the
cumulative impact of the developed area and provide in NEPA documents little
quantitative analysis. We fragment habitat extensively in energy areas
resulting in ecosystem damage not unlike that which occurred from over grazing and
other historic land exploitation. It took decades for government to stop over
grazing and move toward land health. Today scars remain from time before the
Taylor Grazing Act. We have lost the only population of mountain plover in the
state of Utah, contrary to science, ethics, and policy (BLM Manual 6840 – Special
Status Species Management). We have watched as direct and indirect impacts have
literally killed individuals of a federally listed plant species with only a
token effort to prevent future actions and not an apology for our failure. Analysis
of water depletion associated with endangered fish of the Colorado River system
is accomplished through a series of documented explanations that have no attempt
to monitor the quantity of depletion and is inconsistent with critical habitat
for the species. The air within the Uintah Basin continues to be fouled in our
effort to maximize energy and economic gain. Climate change receives but token language
in our NEPA documents. Socio-economics are measured on dollar values gained without
analysis showing measurement of “degradation/benefit” to the community. Air
quality causes respiratory ailments, traffic within the community is industrial
and large sums of money leave the community to outside corporations. A myriad
of other community related issues are in need of detailed analysis.
We need to alter our bureaucratic method of operation. Focus
on our mission and team implementation as professional civil servants. Work
together as a unified team of professionals to implement the science, law, and
regulations for service to the American people. Discontinue our practice of
placing our budget on projects that in truth are developments in disguise and termed
mitigation. We should utilize the budget on monitoring and over sight. The use of
the public land is the burden of the user to minimize injury and restore to its
natural state.
Without serious fulfillment of the mission we continue to
harm public land as it has been harmed so frequently in our historic past. Be
honest about what is happening. It is easier to break something than to fix it,
so let us stop breaking the land.
“Our Quest, is to see
that we are connected to all things, that there is no separation, only in the
mind”- John Mayers; Geologist.
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