Several letters sent during the comment period for the American Conservation and Stewardship Atlas said the 30×30 initiative—known as America the Beautiful initiative—fails to clarify how the federal government defines “conservation” and what lands would be considered part of the initiative.
In January, the Department of the Interior (DOI) announced it was taking public comments and holding listening sessions to develop the Atlas, which will reflect baseline information on the lands and waters that are “conserved or restored.” The department announced the Atlas would “reflect a continuum of conservation actions, recognizing that many uses of lands and waters can be consistent with the long-term health of natural systems and contribute to addressing climate change.”
Montana
In a letter dated March 7, Montana Gov. Greg Gianforte (R) stated the initiative is “long on philosophy and short on detail” and asserted the federal government does not have the authority and funding to execute the proposal.
Gianforte’s letter stated the DOI lacks authority to define “conservation” and determine what state and private lands constitute the definition. The letter cited two court rulings that stated the federal government lacks authority to undertake President Joe Biden’s executive order directing DOI to solicit input, and Congress should grant such authority.
“Attributing undefined characteristics like ‘conservation’ or ‘wildlife habitats and corridors’ to private lands influences property values, may lead to promulgation of land restrictions, and raises a number of property ‘taking’ concerns pursuant to U.S. Constitution (Amendment) V,” the letter reads.
The letter questions the government’s recent effort to propose “vague action” followed by a public comment period that “inappropriately shifts the burden to stakeholders and opens the door to illogical outgrowth of the initial proposal.” The letter cites the Atlas as an example of the approach and questions what constitutes “conservation,” whether 30 percent applies to all lands and waters in the U.S., and what “permanent protection,” “nature-deprived” and “stewardship action” mean.
“Montana has done its job insofar as conserving natural areas and resources,” the letter continues, citing the state’s work with environmental groups, private landowners and stakeholders to ensure the protection of open space. “Montana asks that the DOI allow this work to continue, unencumbered by federal attempts to ‘help.’”
Both the Montana Farm Bureau and the Montana Stockgrowers Association (MSGA) echoed the same concerns expressed in Gianforte’s letter, stating the initiative lacks detail, and in order for the “ambitious proposal” to achieve success, they must have farmers and ranchers at the table.
“In defining ‘conservation,’ there must be an accounting for what is already done: conservation easements, utilization of federal conservation practices, adoption of the innovative approaches that support healthy ecosystems and more,” MSGA said in a statement. “The administration should also take a broad view of conservation so that good practices are rewarded (by being counted) and are encouraged in the future—as part of this proposal, or during the normal course of daily activities.”
PLC
Echoing concerns about what defines “conservation,” the Public Lands Council (PLC), National Cattlemen’s Beef Association and American Sheep Industry sent a joint letter on the administration’s request for information on the development of the Atlas.
The trio is recommending a clarification of the distinction between “conservation” and “preservation” and between “conserve” and “protect.” They are asking the administration to define what “counts” in the Atlas—whether it is just federal lands or state lands and if multiple-use lands are allowed to be considered “conserved.” They ask the administration to recognize existing conservation, including the routine stewardship of farmers and ranchers.
“As a baseline, farmers and ranchers have often stewarded and conserved landscapes for decades, some for generations, and have done so with great success,” the letter reads. “Ranchers’ and farmers’ viability depends on their ability to match the needs of their operations with the health of the landscape and watersheds, building on the biodiversity and ecological potential for future generations.”
Additionally, the letter asks the Biden administration not to seek new federal authority to complete conservation objectives in the initiative, “particularly those that would allow the agencies greater latitude to infringe on private property rights because the administration will not be successful in regulating additional landscapes into conservation.”
The livestock associations are asking the DOI not to consider the U.S. Geological Survey’s (USGS) Protected Areas Database as a baseline—which states only 12 percent of lands are considered permanently protected—or use its system of Gap Analysis Project (GAP) codes.
USGS classifies GAP 1 and 2 areas as those “having permanent protection from the conversion of natural land cover and a mandated management plan in operation.” They ask to include lands where conservation practices like grazing are implemented alongside multiple uses.
ASL
Since the Biden administration’s 30×30 announcement, American Stewards of Liberty (ASL), a nonprofit founded in 1992 by Western ranchers to protect property rights, has led a grassroots effort in counties to pass resolutions opposing the initiative.
In a letter submitted by ASL and several counties, they are calling on the Biden administration to conduct a National Environmental Policy Act (NEPA) analysis for the Atlas and the 30×30 program.
ASL contends that an environmental impact statement under NEPA would require the administration to explain the definition of “conservation” and disclose any “substantive details that provide necessary information to the public and decision-makers.”
Margaret Byfield, ASL executive director, stated NEPA compliance is required on smaller projects than the 30×30 initiative, and the administration should comply with the regulation.
Like Gianforte’s letter, ASL stated, “A presidential order to act, as with the exercise of any governmental power, must stem either from an act of Congress or from the Constitution itself, or a combination of the two.”
An outdoor group known as the Hunt Fish 30×30 coalition, which comprises 45 recreational groups, sent comments on the 30×30 initiative, asking for the clarification of “conservation” to support the active management and sustainable use of our nation’s public trust fish and wildlife resources.
They urged the Biden administration to identify the lands and waters considered “conserved” based on conservation outcomes rather than arbitrary criteria. The groups also highlighted the importance of working with state fish and wildlife management agencies, regional fish and wildlife management authorities, Tribes, conservation-focused nongovernmental organizations and private landowners “who are most knowledgeable and best equipped to advance pragmatic and successful conservation efforts throughout the U.S.” — Charles Wallace, WLJ editor
