My main comment on this Resource Management Plan is the integrity of this document and what it should be. Will the taxpayer and residents of the affected counties be confident with this document? Upon further examination, I find that many things were not completely done in regard to the fairness for the people who live in the Valley County area.
A comparative analysis should be done to insure that this document does not infringe upon anyone’s individual civil rights, and that it preserves the cultural identity, heritage and well being of the Valley County residents.
There is nothing in this RMP document to indicate that there was a Consistency Review done, comparing this RMP to any land plans or growth policies that are in place and pertinent to Valley County, the city of Glasgow, the towns of Opheim, Nashua or Fort Peck, or any of the town sites located in Valley County. This would, and should be, a basic priority to any RMP that has such far reaching consequences.
Oil production projections in this RMP are based on what was known prior to 2006, not on what are current knowledgeable facts. The many layers of oil production capabilities are an evolving technology and can change significantly every few months. Many things are very different today, and are not properly addressed in the RMP by what the new technology can and cannot do. Changing the land to “No Surface Occupancy” on the BLM land that was acquired under the Bankhead-Jones Act deprives Valley County of the opportunity to capitalize on the 6.25 percent royalty that was part of the selling price when the land was sold to the United State government in 1937. It could also have far reaching effects on the roads that cross this property, as well as the public utilities and easements that cross these lands.
Valley County was assured that these rights-of-way would remain intact and No Surface Occupancy would greatly change land values and access to private holdings. The current RMP has set the No Surface Occupancy designation on 282,062 acres of land. The preferred alternative in the RMP raises that number to 1,711,378 acres of land. This is an increase of over six times the previous amount. Many acres of that land are located in north Valley County, and will deprive Valley County of gas and oil revenues.
As it turns out, Valley County was in the process of negotiating a mineral lease with a company looking at exploring oil on some Valley County land. That company just informed the commissioners that they are backing out on any leasing. They stated that unfortunately, because of sage grouse habitat issues involving federal lands, it will be extremely difficult to conduct exploratory operations. The offer to lease the mineral interest in Valley County has been withdrawn.
The preferred alternative also promotes an area that could be separated later from agriculture production and become an “Area Of Critical Concern,” and later be more restrictive than even now. It has yet to be proven that it will significantly change sage grouse numbers because all detriments to the sage grouse are not addressed, such as predators, West Nile disease, and uncontrollable weather patterns such as hail and heavy snow falls, let alone the mere fact that sage grouse migrate from Canada. The Canadian government does not have plans that are consistent with Montana’s efforts to protect these birds.
Vested and accrued water and grazing rights have not been approached in a clear and concise manner, informing the public that much of the federal land could be a split estate with joint ownership on many kinds of rights. No attempts have been made to explain the Bankhead-Jones acquired property, leaving the public believing that these properties are totally owned by the federal government, when they are not.
Fire management in Valley County is not done by the BLM, but by Valley County. This was not properly addressed, because in most cases, fires are put out by Valley County’s Long Run Fire Department, not BLM fire units.
Management of BLM roads does not fit within the requirements for county roads, and maintenance and upkeep is almost non-existent on some of these BLM roads. Many of the roads pose a threat to public use and public safety.
Petitioned roads and public rights-of-way on the federal land are not adequately addressed on the BLM, even though the Valley County Commissioners have informed the RMP working group that we had no intention of closing any of these roads on the range, as they provide access for fire suppression, etc.
Many reservoirs are in need of repair and pose a threat to county residents if they should wash out during the rainy season, causing additional water to flow into the flood plain. Example: Triple Crossing Access Road and Reservoir. Many of these reservoirs were built with monies from livestock producers, and those producers are more than vested in the use of the reservoirs.
I feel that projected management plans lean more towards wildlife recovery than to multiple uses with livestock operations. Absolutely nowhere do I find ranching and farming described as our cultural heritage, which has been fostered by as many as six generations of occupancy in many Valley County families. Many, if not all, of Valley County residents have irrevocable ties to ranching and farming and most feel that federal agencies are not respecting their civil rights.
Many rights, such as water and grazing rights, are not recognized yet. The BLM knows that they exist in many cases. In the past the BLM has entered into MOUs with the CMR on water use, and has yet to consult with any of the ranchers that use the range or Valley County through coordination/cooperation, as is federally mandated in an executive order.
It would be to the best interest of the residents of the counties affected by this RMP if it was re-addressed through a legitimate coordination effort that would allow new data and legitimate input from local governments and other political subdivisions. This document sets some far reaching policies that are not going to help the people that live in this Hi-Line region, and could very well deprive us of some very basic civil rights.