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
U.S. history has shown repeated failure in the care of the natural world. We place
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:
1. Cease throwing away its parts
2. Handle it gently
3. Recognize that its importance transcends economics
4. Don’t let too many people tinker with it.
1. 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.
2. 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.
3. 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.
4. 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 6480 – 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
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-site. 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.