Our underfunded and understaffed land management agencies, the Forest Service, Bureau of Land Management and State Divisions of Land are not restoring these degraded lands, wildlife populations and native plant communities, but are continuing unsustainable management without adequate science, regulation, monitoring or accountability.
They are not addressing the true costs of their management as these altered lands lose their productivity and water storage capacity from accelerated erosion, their plant communities shift to invasive or undesirable species, forests and grasslands are prone to severe fires, and fish and wildlife populations are diminished or eliminated.
Y2U continues to participate in the National Environmental Policy Act (NEPA) by submitting science-based comments on many Forest Service (FS) and Bureau of Land Management (BLM) decisions. These include proposed phosphate mining in Southeast Idaho. Y2U provides feedback on agency monitoring protocol and works towards creative solutions to help these underfunded agencies accomplish their stated conservation and restoration goals.
During FY20, Y2U submitted comments on thirteen (13) Draft Environmental Impact Statements and Categorical Exclusions. These include two sets of comments on proposed phosphate mines in Southeast Idaho owned by Bayer/Monsanto and JR Simplot. We submitted comments on a Forest Plan Revision for the Ashley National Forest, comments on a proposed ATV/OHV trail through wilderness and roadless areas of the Uinta Mountains in the Ashley National Forest, comments on proposed “range improvements” in the Manti-La Sal National Forest, six sets of comments on proposed timber projects and federal logging rule changes in the Ashley, Caribou-Targhee and Uinta-Wasatch-Cache National Forests, and two sets of comments on stream restoration projects in the Caribou-Targhee National Forest. We also submitted comments on proposed changes to Roadless Areas in conjunction with a proposed new phosphate mine in the Caribou-Targhee National Forest.
During 2024, Y2U submitted comments on twenty-five (25) Forest Service and Bureau of Land Management (BLM) Environmental Impact Statements, Environmental Assessments and Categorical Exclusions for proposed projects occurring in the Bitterrroot, Boise, Bridger-Teton, Flathead, Helena-Lewis Clark, Lolo, Nez Perce-Clearwater, Shoshone and Uinta-Wasatch-Cache National Forests and BLM managed lands in Idaho, Montana, and Wyoming. The proposed projects included Forest Plan Revisions and Amendments, grazing and grazing improvements, logging, mining, stream rehabilitation, trails and vegetation treatments.
During 2024, Y2U filed nine (9) Objections to Forest Service public land management decisions in the Boise, Caribou-Targhee, Dixie, Flathead, Nez-Perce-Clearwater, and Uinta-Wasatch-Cache National Forests including a pipeline in Southeast Idaho, two regarding a vegetation management projects in Southwest Idaho and Utah, one regarding a Land Management Plan in Idaho, one regarding a vegetation management project in Montana and one regarding a vegetation management project in Utah. We also filed Appeals on two BLM decision regarding a vegetation management project in Montana.
During 2024, four (4) projects were cancelled by the Forest Service or Bureau of Land Management due to our detailed comments, fear of litigation or litigation!
During 2024, Y2U filed five (5) Complaints in U.S. District Courts. These were for vegetation management projects in Utah, Idaho and Montana.
During 2024, Y2U secured legal representation to investigate potential NEPA, NFMA, FLPMA, CWA and ESA violations on eight (8) more project authorizations including one mining and one mining dump project in Southeast Idaho, one pipeline project in Idaho, one vegetation management project in Montana, two vegetation management projects in Utah, one vegetation management project in Wyoming and one on an Elk feedground in Wyoming.
William Pendley/BLM Litigation: On January 19th, 2021, Yellowstone to Uintas Connection, the Center For Biological Diversity, WildEarth Guardians, Western Watersheds Project, and Rocky Mountain Wild filed a lawsuit for declaratory and injunctive relief to challenge Federal Defendants’ unlawful approval of nine Resource Management Plans (“RMP”) and related projects. These RMPs govern the management of more than 6.5 million acres of public lands and minerals, Defendant William Perry Pendley’s exercise of the duties of Acting Director of the U.S. Bureau of Land Management (“BLM”) was unlawful under the Appointments Clause, U.S. Const. art. 2, § 2, cl. 2; the Federal Vacancies Reform Act of 1998, 5 U.S.C. §§ 3345 et seq. (“FVRA” or “Act”); and the Administrative Procedure Act, 5 U.S.C. §§ 701 et seq. (“APA”). The projects include the Dairy Syncline phosphate mining project (See the Mining Section below) and the Gemini Solar project. To view the complaint, see our web page at the following link: https://www.yellowstoneuintas.org/issues/science/item/123-simplot-company-s-proposeddairy-syncline-mine
On June 22nd, 2021, a meeting to discuss potential avenues for resolution of Center for Biological Diversity et. Al. v. U.S. BLM, et. Al. took place. Following that meeting we conferred with the plaintiffs to generate a set of preferred outcomes for the eight RMP-related decisions challenged in our complaint.
On March 19th, 2024, a settlement agreement was reached with the BLM that provided funding for off-site mitigation, sage grouse studies and road density studies. Our opposition of this project started in 2018. This illustrates the length of time that many of these project proposals and the NEPA process take.
Y2U will continue to be the voice for wildlife and habitat connectivity throughout the Corridor. We will continue to advocate for the use of sound science in land management decisions and when necessary, we will support litigation efforts to oppose projects that are projected to have a negative impact on wildlife and habitat.
Work Plan:
- Continue to submit comments on Environmental Assessments (EA), Environmental Impact Statements (EIS), Categorical Exclusions (CE) and other stages of the land management decision-making process.
- Continue to file Objections on Final Decisions issued by these agencies when the issues identified for each proposed project are not satisfactorily addressed.
- Continue to pursue and support litigation when objection resolution is not reached for these proposed projects.
- Continue following up with agency staff as projects develop, and when possible, attend site visits where both agency staff and Y2U staff can discuss project purposes and objectives.
Expected Outcome:
Y2U has formed valuable relationships with several Forest Service and BLM staff over the last couple years, resulting in many positive outcomes including the closure of illegal roads and a reduction or elimination of trespass cattle in several closed allotments. With these positive relationships, we hope to increasingly be viewed as a resource to these agencies for data and feedback. However, Y2U will continue to be the voice for wildlife and habitat connectivity throughout the Corridor. We will continue to advocate for the use of sound science in land management decisions and when necessary, we will support litigation efforts to oppose projects that are projected to have a negative impact on wildlife and habitat.
