Comment on FR Doc # N/A

I urge the Bureau of Land Management to retain and strengthen Manual 6320 and its requirements for identifying and meaningfully considering lands with wilderness characteristics during land-use planning. The absence of a congressional wilderness designation does not mean that a landscape lacks conservation value or should be treated as available for industrial development. Undeveloped BLM lands can provide irreplaceable wildlife habitat, migration corridors, intact watersheds, climate refuges, solitude, primitive recreation and high-quality hunting and fishing opportunities. BLM should require current, field-verified inventories before adopting or amending a resource management plan and before approving major leasing, mining, road, utility or energy-development decisions. Inventories should not be allowed to become outdated while development permanently changes the underlying landscape. The manual should also clarify that temporary, unauthorized or reasonably restorable disturbances do not automatically eliminate wilderness characteristics. Otherwise, unlawful roads or short-term surface damage could become a means of disqualifying land from further consideration. BLM should evaluate wilderness characteristics alongside habitat connectivity, watershed integrity, climate resilience, natural soundscapes and cumulative landscape fragmentation. Project-by-project review can obscure the combined effects of roads, well pads, transmission corridors, mines and other development across an entire region. Indigenous cultural landscapes must receive meaningful consideration. BLM should consult affected Tribes early enough for consultation to influence inventories and management alternatives—not after decisions have effectively been made. Sensitive information concerning sacred places, traditional cultural properties and archaeological resources must remain protected from public disclosure. The public should receive access to inventory methods, maps, findings and supporting documentation before lands are offered for leasing or development. BLM should clearly explain when it declines to protect identified wilderness characteristics and should evaluate a conservation-focused management alternative in relevant planning decisions. Manual 6320 should not be weakened to favor extraction or administrative convenience. It should ensure that BLM makes informed choices before intact public lands are fragmented and their wilderness qualities are permanently lost. Because BLM has not yet presented specific replacement language, any proposed revision should be published in full for an additional public-comment period before adoption.