Grey Hayes
Bratton Online January 23, 2023 https://brattononline.com/ In my last column at BrattonOnline.com, I outlined the tragic history of the 5,600 acre Cotoni Coast Dairies property leading to BLM’s takeover of managing the property and urging readers to pay more attention and to be more active in the evolution of that management. January 30th is an important deadline that provides you an opportunity to help better protect the property: BLM is proposing sweeping regulations that supposedly ‘protect’ this public land, but they are acting prematurely. After reading this, I am hoping that you will write a public comment note suggesting a delay for BLM’s rulemaking until that agency completes its required planning process for protecting Cotoni Coast Dairies as it is supposed to be with its designation as part of a National Monument. If you want to cut this read short and write comments, skip the upcoming critique and go to the last section below for more guidance. Designed to be a Federal Yawner If you were managing BLM and you didn’t want anyone to comment on your oversight of Cotoni Coast Dairies, you’d design public comment period notifications to be filled with confusing jargon, contradictory statements, and pointless direction for commenters. Here’s a link to the current set of rules which would govern Cotoni Coast Dairies in perpetuity and which BLM has published for public review through January 30. Confusing Jargon The press release announcing this public comment period opens with this typically confusing jargon: “The supplementary rule would provide consistency and uniformity for visitors.” Huh? And there’s more confusing jargon – the comment period is about a ‘supplementary rule‘ – supplementary to what, you might ask, aren’t all rules supplementary? This seems either deeply philosophical or something that might better contemplated by Zippy. Contradictory Statements The press release for this public comment period begins with a curious and confusing quote from Acting Central Coast Field Manager Shekeetah Allen Genoway: “We believe this plan will help…” (emphasis mine) Errr…I thought this was a ‘supplementary rule‘ not a plan?? Someone at BLM might be reading this and scoffingly muttering ‘Big Deal!’ ‘What’s the Diff?’ or ‘Who Cares!?’ Well, there is a big difference between a rule and a plan, and it is BLM’s duty to engage with and educate the public about said differences. Pointless Direction Acting Central Coast Field Manager Shekeetah Allen Genoway’s quote goes on to give very narrow advice on what the BLM hopes the public will comment about: “We are seeking public comments to help us clarify language in the rules to ensure they are easily understood by users and public.” (Jargon note: anyone who might visit the property is known to BLM as a ‘user,’ but I’m unclear about the difference between ‘users’ and ‘public’) In short, BLM says that if the rules aren’t clear, then please give them feedback on how to make them clearer. In other words, don’t question the rules…don’t think about why such rules are necessary…don’t suggest better rules or how to improve the rules-making processes, etc. However, the rationale for public comment periods in a democracy is to open up all of those subjects for discussion. The Wizard of Odd Don’t pay attention to the man behind the curtain! If you are brave enough to open the Federal Yawner ‘Supplementary Rule,’ you can get to the root of what I see as the Big Problem by reading the ‘Discussion’ section. There, you will find a profoundly deceptive misstatement: “The BLM completed the Cotoni-Coast Dairies Resource Management Plan (RMP) Amendment on June 23, 2021, to establish land use decisions that protect the objects and values of the Cotoni-Coast Dairies unit of the California Coastal National Monument and support responsible recreation opportunities.” In fact, the RMP did not contain a list of the ‘objects and values’ called out in the Obama Administration’s Monument designation for the property. Therefore, the plan could not and did not ‘establish land use decisions that protect‘ them. Moreover, the RMP’s recreational planning analyses harkened back to pre-WWI-style parks planning with no mention of modern recreational planning principles: social carrying capacity analysis (to avoid overcrowding and user conflicts – for instance, mountain bikers vs. family hikers with small children, or natural resource carrying capacity analysis (to avoid disturbing sensitive wildlife, etc.). So, the plan could not and did not ‘establish land use decisions….{sic}(that) support responsible recreation opportunities.’ In sum, this current proposed “supplementary” rule compounds and builds on the shaky house of cards that has been BLM’s balderdash-based planning for Cotoni Coast Dairies. And, it is on that level that I urge you to give feedback to BLM. What to Do? The best current direction for BLM is to keep the property closed until the requisite planning processes have been completed and there is a credible approach from which to establish regulations for the property. According to BLM’s guidelines for managing National Monument properties (Manual 6220), the agency is required first to undertake studies inventorying the ‘objects and values’ of the Monument and determining how best to protect them. And yet, BLM has been opposing conservationists and the State of California’s natural resource protection agencies in its attempt to avoid such work. The proposed “Supplementary” Rule compounds BLM’s prior mistakes, and in doing so confuses the public into thinking they are embarking on good conservation work by limiting visitor use. You might find it confusing to oppose such a ‘supplementary’ rule when it allows BLM to enforce off-limits areas if what we are looking for is to protect the large swaths of Cotoni Coast Dairies from being ‘loved to death’ by visitors. Perhaps they might need some rules like this, but the BLM’s decision to make these rules is premature. They must first recognize, list, and analyze the human impacts on the ‘objects and values’ protected by Monument designation. For now, if we show BLM we aren’t fooled by their tactics and demand that they do a more complete job of protecting resources, BLM will be forced to follow its own guidelines and get the planning right. And so, I urge you to please write the BLM and let them know that they should complete the planning and analysis outlined in their guidelines for managing National Monuments (Manual 6220) before they create regulations that may or may not be necessary. A short note would suffice: Bureau of Land Management, BLM Central Coast Field Office, 940 2nd Ave., Marina, CA 93933, or emailed to: [email protected] or https://www.blm.gov/ Comments are closed.
|
Categories
All
Archives
March 2024
|