Comment on FR Doc # N/A

Docket ID: BLM-2026-0068-0001 Subject: Opposition to Potential Updates Regarding "Lands with Wilderness Characteristics" and Proposal for Innovative Land Use I. Introduction I am writing to express my strong opposition to any updates or revisions to BLM Manual 6320 that would expand the agency’s ability to designate or manage "lands with wilderness characteristics" (LWC). These internal policies create de facto land-use restrictions that bypass the formal, congressionally mandated process for wilderness designation, undermining the "multiple-use" mandate established by FLPMA. II. Lack of Statutory Authority and Compliance with Loper Bright The BLM’s authority is bounded by the clear intent of Congress. Following the Supreme Court’s decision in Loper Bright Enterprises v. Raimondo, the agency cannot rely on administrative discretion to expand its regulatory reach. The creation of secondary, administrative-only wilderness protections is an unauthorized expansion of its mandate, especially when those designations restrict the use of lands that could otherwise address pressing national needs. III. The Need for Productive Land Use: Housing and Accessibility Instead of unilaterally restricting lands under the guise of "wilderness characteristics," the BLM should evaluate its land holdings to address the national housing affordability crisis. Housing Development: The BLM should identify parcels that could be responsibly disposed of or utilized to increase the availability of affordable housing. Homesteading for Vulnerable Populations: As a specific caveat to current management practices, the agency should explore a modern framework to grant limited, suitable land parcels to seniors and individuals with disabilities. This would provide a vital safety net and contribute to the social welfare of these populations, serving a far more direct "national interest" than current restrictive LWC designations. Failure to Consider Alternatives: By prioritizing restrictive, conservation-only management, the BLM is failing to perform a rigorous analysis of whether these lands could serve more urgent public purposes, such as community expansion. Under the Administrative Procedure Act (APA), such a narrow, exclusionary approach is arbitrary and capricious. IV. Conclusion and Recommendations I urge the BLM to abandon the expansion of LWC management and instead pivot to a land-management strategy that supports the American public's need for affordable housing and accessibility. If the agency chooses to proceed with updates, it must: 1. Analyze Alternative Uses: Conduct a formal, transparent review of how public lands could be repurposed for affordable housing or community expansion. 2. Evaluate Social Impact: Perform a comprehensive economic and social impact study on how restrictive land designations harm seniors and disabled individuals who could benefit from alternative land-use models. 3. Respect Congressional Authority: Limit its administrative actions to those explicitly granted by FLPMA, and stop using internal manuals to create permanent, restrictive wilderness-like designations without legislative approval.