ACEC Toolbox

1. A well thought-out advocacy campaign for ACEC designation that includes strategies for influencing specific BLM decision-makers is essential.
2. Likelihood of success is highest when you submit ACEC nominations early.Under the new rules the ideal time is during the Planning Assessment Phase or during the Scoping phase at the latest.
3. A comprehensive, science-based ACEC nomination package is essential. You need to build a strong case that area has values that meet the criteria for designation, and back that case up with as much scientific data and other relevant information as possible. Including specific management recommendations is also essential. Unlike wilderness designation, ACEC designation does not come with any specific required management.   You must propose specific management prescriptions that you want to accompany the designation. Throughout the process, it is important to give as much attention in comments, advocacy etc. to the management as to the designation.
4. It is critical to start meeting with BLM and doing advocacy as soon as possible after submitting your nominations. If BLM determines that your ACECs don’t meet the criteria when they prepare their ACEC Evaluation Report (after the Scoping Comment Period and before the Release of Preliminary Alternatives) you will face an uphill battle.
5. Interacting with BLM staff and decision-makers regularly throughout the process is essential. You are highly unlikely to be successful if you rely solely on submission of a written ACEC nomination package and submission of comments during the various comment periods.
6. It may be important to prioritize a small number of nominated ACECs for an intensive campaign. It can be more difficult to design an effective campaign around a large number of potential ACECs.
7. You will be more successful if you can generate significant public support for designation. Target groups and individuals who are influential with the relevant BLM decision-makers. It is also important to build support from traditional allies who are likely to be interested in the significant values in the ACEC. For example: native plant societies, local birding organizations or Audubon chapters, state natural heritage programs, wildlife conservation organizations, botanic gardens conservation departments, zoo conservation departments, archaeological societies and clubs, cultural heritage groups, amateur naturalist organizations, etc.
8. Gaining support for ACEC designation from experts and agencies that BLM respects will significantly increase your odds of success. Bringing in experts when identifying potential ACECs is a good way to get experts invested in the potential ACECs. (For example: If your ACEC protects rare plants, gain support from your state’s Natural Heritage Program)
9. It is possible to make a strong case that many different types of values meet the criteria for ACEC designation. Be creative. For example, if your goal is to protect big game, it might be difficult to get BLM to designate general habitat for big game, but you could make a strong case that crucial migration corridors or calving grounds meet the criteria.
10. It’s important to carefully consider whether potential ACECs will make sense to BLM from a management perspective. Potential ACECs with boundaries that don’t make sense to BLM from a management perspective are less likely to be designated. Examples include:

• ACECs whose boundaries extend across boundaries between Field Offices or other areas not covered by the planning process in question
• ACECs whose boundaries include private inholdings, particularly when the landowner(s) harbor anti-federal government sentiments
• ACECs where BLM is committed to extractive uses that they view as inconsistent with ACEC designation (e.g. areas covered with existing oil and gas leases will be more difficult to get designated than areas with no existing leases, ACECs where major development projects are proposed in a preferred alternative in an ongoing EIS may be unlikely to be designated etc. )
• ACECs that will inadvertently increase risk of damage to sensitive values – for example, BLM may not want to designate an ACEC drawn around a small area with archaeological resources due to concern that it will make the location public and increase the risk of theft and vandalism.

Download a PDF version of the recommendations here.

Starting Prior to BLM Planning Assessment to Prepare for a New Resource Management Plan (RMP)*

• Identify Areas that Meet Criteria for ACEC Designation (relevance and importance, need for special management)
  • Start as early as possible in the planning process
  • Use a science-based process to identify potential ACECs
  • Identify and interview relevant experts
  • Identify existing data on potentially significant values
  • Talk to BLM field office staff with relevant expertise
  • Use GIS tools to identify potential ACECS, draw boundaries, make maps
  • Draw boundaries that make sense from a management perspective
  • Determine how the area is currently managed
  • Determine special management needed to protect significant values
  • Visit potential ACECs – on the ground knowledge is very helpful
  • Develop draft maps of potential ACECs and get feedback from experts and BLM staff
  • Refine boundaries based on feedback from experts and BLM staff
• Prepare a formal ACEC nomination package
  • Include formal nomination language
  • Describe each potential ACEC
  • Include maps of each potential ACEC
  • Provide a solid rationale for why the areas meet the criteria for ACEC designation (relevance and importance criteria, need for special management)
  • Include specific management recommendations for each potential ACEC
  • Include photos
  • Indicate interest in meeting with BLM to discuss nominations
  • Take care not to show exact locations of sensitive resources if doing so will put them at risk
• Start building relationships with key BLM staff
• Develop a strategy for influencing relevant BLM decision-makers
  • Potential elements of a strategy include:
    • Conduct targeted outreach to gain support from individuals and groups influential with decision makers
    • Use a creative communications strategy to generate support from the general public and get the public engaged in the process
    • Organize public events in potential ACECs (e.g. hikes, BioBlitz events)
    • Figure out how to respond to and neutralize opposition
    • Demonstrate support in the media
• Monitor other plans, projects, and activities that might impact potential ACECs throughout the planning process (e.g. oil and gas lease sales).

Starting When BLM Begins Planning Assessment to Prepare for a New Resource Management Plan (RMP)*

• During BLM Planning Assessment to Prepare for a New Resource Management Plan (RMP)*
  • Submit the formal ACEC nomination package to BLM
  • Organize an initial meeting with BLM:  the goal at this stage is to help BLM get familiar with your proposal, answer questions, address any initial concerns etc.
  • Communicate with BLM frequently
  • Visit the potential ACECs with BLM staff
  • Listen to BLM staff feedback and adjust the proposal based on BLM staff feedback
  • Listen to expert feedback and adjust the proposal based on expert feedback
  • Keep track of any relevant new information and adjust the proposal based on new information if needed
  • Start implementing your strategy to influence relevant BLM decision-makers

Starting When BLM Initiates RMP Planning Process

• During 30-Day Scoping Period
  • Re-Submit the formal nomination package to BLM
    • Include any adjustments based on feedback (from BLM or experts)
    • Include any adjustments based on new information
    • Add language as needed to strengthen rationale for designation
    • Highlight changes from the original package in a cover letter
  • Meet with BLM:  the goal at this stage is to convince BLM that the potential ACECs meet the relevance and importance criteria and should be included in at least one alternative in the plan.
  • Continue to implement your strategy to influence BLM decision-makers
    • At this stage, one element of the strategy should be organizing supporters to engage in the scoping process.
  • Note that there is no time to spare between submitting the ACEC nomination and getting in to meet with BLM and doing advocacy.  At the next stage (ACEC Evaluation Report) BLM will decide whether the potential ACECs meet the criteria.  It’s critical to meet with BLM and do advocacy before the next stage.
• BLM May Release an ACEC Evaluation Report
  • Look for the Evaluation Report to see if BLM found that the potential ACECs meet the relevance and importance criteria.  Note that if your ACEC doesn’t make the cut as meeting the criteria at this point, it is a MUCH more uphill battle.

Starting When BLM Releases Preliminary Resource Management Alternatives*

• During Comment Period on the Preliminary Resources Management Alternatives
  • Review the preliminary management alternatives
  • Make sure your nominated ACECs are included in at least one alternative
    • If potential ACECs are proposed for designation in at least one alternative
      • Submit comments supporting the decision to include the potential ACECs in the range of alternatives
      • Meet with BLM and thank them for including the potential ACECs in the range of alternatives
      • Continue implementing your strategy to influence BLM decision-makers – goal at this stage is to ensure that the potential ACECs are included in the range of alternatives in the draft plan.
        • At this stage, the strategy should include organizing supporters to submit additional letters of support
    • If potential ACECs are not proposed for designation in at least in one alternative
      • Determine why potential ACECs were not included within the range of alternatives
      • Submit comments that make a strong case for potential ACECs to be included in at least one alternative in the draft plan – this may require making a stronger case that potential ACECs meet the criteria for designation.
      • Meet with BLM to make a case for designation, gather information about their perspective and try to address concerns.
      • Determine whether a new strategy is needed to change the minds of BLM decision- makers, and if so, develop and implement a new strategy.
        • If you are facing opposition from Field Office decision-makers, a new strategy might include:
          • Targeting state and national decision-makers
          • Intensifying efforts to organize supporters
          • Working to determine if BLM concerns about designation can be addressed

Starting When BLM Releases Draft Resource Management Plan and Environmental Impact Statement

• During 60-Day Comment Period on Draft Resource Management Plan and Draft EIS **
  • Review the draft Resource Management Plan and Draft EIS
  • Determine whether potential ACECs are in at least one alternative in the draft plan
    • If potential ACECS are proposed for designation in at least one alternative:
      • Submit comments strongly supporting the decision to include the potential ACECs in the range of alternatives
      • Meet with BLM and thank them for including the potential ACECs in the range of alternatives and continue to advocate for designation
      • Continue implementing your strategy to influence BLM decision-makers: goal at this stage is to ensure that the potential ACECs are included in the range of alternatives in the draft plan.
      • At this stage, your strategy should include organizing supporters to engage during the comment period and submit additional letters of support
      • This may also be a good time to demonstrate support in the media
    • If potential ACECs are not proposed for designation in at least in one alternative:
      • Determine why potential ACECs were not included within the range of alternatives
      • Submit comments that make a strong case for potential ACECs to be included in at least one alternative in the draft plan.  This may require making a stronger case that potential ACECs meet the criteria for designation, or addressing specific concerns BLM has about designation
      • Meet with BLM to make a case for designation, gather information about their perspective and try to address concerns.
      • Determine whether a new strategy is needed to change the minds of BLM decision- makers, and if so, develop and implement a new strategy
        • If you are facing opposition from Field Office decision-makers, a new strategy might include:
          • Targeting state and national decision-makers
          • Intensifying efforts to organize supporters
          • Working to determine if BLM concerns about designation can be addressed
          • Demonstrating concern about lack of consideration of ACEC designation in the media

Starting When BLM Releases the Proposed Resource Management Plan and Final EIS

• During 30-Day Protest Period (and concurrent 60-day Governor’s Consistency Review Period)
  • Review the proposed RMP and Final EIS
  • If potential ACECs are proposed for designation:
    • Demonstrate support for the proposed plan in the media
    • Organize your supporters to thank BLM
    • Track whether protests are filed in opposition to designation, if so prepare to intervene in future legal challenges if necessary
  • If potential ACECs are not proposed for designation:
    • Demonstrate public outcry over failure to designate ACECs in the media
    • Advocate for changes to the plan before the final is issued with high level decision makers in BLM, Interior Dept. and Congress
    • If state or local governments support designation, ask them to push for designation through the governor’s consistency review
    • Formally protest the plan during the 30 day protest period

BLM Issues Final Decision on Protests

• Decide whether to challenge the decision in court

BLM Issues Final Resource Management Plan and Final Environmental Impact Statement

• Celebrate if your ACECs are designated!
• Assess what went wrong and determine lessons learned to apply to future efforts if you ACECs are not designated

* New steps in the RMP planning process described in BLM’s recent proposed changes to the planning regulations (as part of planning 2.0).
** Current 90-day comment period reduced to 60 days in BLM’s recent proposed changes to the planning regulations (as part of planning 2.0).

For more information contact Megan Mueller, Senior Conservation Biologist, Rocky Mountain Wild: megan@rockymountainwild.org

Download a PDF version of the checklist here.