Defend wild BLM lands that aren't yet wilderness

What the public could have raised, from the agency’s own document

• I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
• The manual makes wilderness characteristics inventory a hollow exercise by declaring that inventory findings carry no substantive weight in management outcomes. Section 1.6.A states that inventory and management are separate activities and that the Bureau has full discretion to disregard wilderness characteristics once identified, so the extensive data-gathering, mapping, and factor analysis required elsewhere in the manual produces no binding consequence. The agency should explain why field offices should invest planning resources in wilderness characteristics inventories if the outcome is entirely discretionary regardless of what the inventory finds, or revise the policy to give inventory results actual weight in the final decision.
• The manual lowers the substantive protection standard for wilderness characteristics without justifying why mere consideration of mitigation satisfies FLPMA's unnecessary and undue degradation standard. Under Section 1.6.A, when a planning decision prioritizes other multiple uses, BLM is not required to adopt any measures to avoid or minimize impacts to wilderness characteristics and need only consider mitigation measures. The agency should justify how this reduced obligation is consistent with FLPMA's degradation standard and should analyze the cumulative effect of applying this reduced standard across land use plans nationwide.
• The final decision requirement uses non-mandatory language that undercuts accountability for decisions that decline to protect wilderness characteristics. Section g. Final Planning Decision says BLM 'should' state whether it adopted practicable means to avoid or minimize impacts, or provide a rationale if not, rather than requiring it. Given that this is the only accountability mechanism identified for decisions that forgo protection, the agency should convert this to a mandatory requirement and specify what constitutes an adequate rationale under 40 CFR 1505.2(a)(3).
• The manageability factor for external impacts sets an undefined and unworkable standard. Section 1.6.A.1.a.4 states that visible or audible incompatible activities should not determine manageability 'unless these impacts are pervasive and omnipresent,' but the manual never defines pervasive or omnipresent, nor provides a threshold, metric, or example. This vagueness invites arbitrary and inconsistent application across field offices. The agency should define these terms with specific criteria or examples before finalizing this guidance.