Conservation and Landscape Health Rule, RIN 1004-AE92, OMB Control No. 1004-0NEW (88 Fed. Reg. 19583)

The Clean Air Task Force (CATF) supports the BLM's proposed Conservation and Landscape Health rule, arguing that conservation leases are a valid tool for implementing the Federal Land Policy and Management Act (FLPMA) mandates. CATF recommends that the rule be structured to avoid hindering the buildout of electric transmission and renewable energy, specifically suggesting a two-mile buffer around energy corridors where leases are restricted to permittees. The document also advocates for integrating carbon sequestration and climate resilience into the 'fundamentals of land health' and strongly advises against allowing conservation leases to generate marketable carbon offset credits due to a lack of permanence in the proposed 10-year lease terms.

• CATF supports the use of conservation leases as a mechanism to restore landscapes, satisfy mitigation requirements, and promote climate resilience on public lands, asserting they are consistent with the Federal Land Policy and Management Act (FLPMA).
• To prevent conflicts with clean energy deployment, CATF proposes that conservation leases within two miles of designated renewable energy leasing areas or energy right-of-way corridors be issued only to permittees using those areas for mitigation.
• CATF recommends that the BLM explicitly allow conservation leases to satisfy mitigation requirements imposed by other entities, including state or local governments, Tribes, and other federal agencies.
• The document argues that the BLM should integrate carbon sequestration into the 'ecosystem processes' factor of land health and add 'climate resilience' as a fifth fundamental of land health.
• CATF strongly advises the BLM to prohibit the use of conservation leases for generating voluntary or marketable carbon offset credits, citing a mismatch between the proposed 10-year lease term and the permanence required for high-quality offsets.
• To streamline the siting of linear infrastructure, CATF suggests that the BLM should only extend conservation leases in designated energy corridors if the extension does not impede the corridor's purpose.
• Regarding valuation, CATF suggests using a formula based on a percentage of the statewide average value for non-irrigable acres from the National Agricultural Statistics Services (NASS) to determine fair market value for leases.
• CATF recommends allowing in-kind payments (such as volunteer work or direct restoration expenditure) to count toward rental and lease fees for voluntary restoration leases, but not for compensatory mitigation leases.

APA

Clean Air Task Force (2023). Conservation and Landscape Health Rule, RIN 1004-AE92, OMB Control No. 1004-0NEW (88 Fed. Reg. 19583). https://cdn.catf.us/wp-content/uploads/2024/09/03161724/catf-comments-conservation-landscape-health-rule.pdf

Chicago

Clean Air Task Force. Conservation and Landscape Health Rule, RIN 1004-AE92, OMB Control No. 1004-0NEW (88 Fed. Reg. 19583). 2023. https://cdn.catf.us/wp-content/uploads/2024/09/03161724/catf-comments-conservation-landscape-health-rule.pdf.

Wikipedia

{{cite press release |author=Clean Air Task Force |title=Conservation and Landscape Health Rule, RIN 1004-AE92, OMB Control No. 1004-0NEW (88 Fed. Reg. 19583) |date=5 July 2023 |url=https://cdn.catf.us/wp-content/uploads/2024/09/03161724/catf-comments-conservation-landscape-health-rule.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{cleanairtaskforce2023conservation, author = {{Clean Air Task Force}}, title = {{Conservation and Landscape Health Rule, RIN 1004-AE92, OMB Control No. 1004-0NEW (88 Fed. Reg. 19583)}}, publisher = {Clean Air Task Force}, year = {2023}, month = jul, url = {https://cdn.catf.us/wp-content/uploads/2024/09/03161724/catf-comments-conservation-landscape-health-rule.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }