RV Industry Association Comments On Bureau Of Land Management’s Proposed Rule

On April 3, 2023, the Bureau of Land Management published in the Federal Register a proposed rule that, in accordance with the Federal Land Policy and Management Act of 1976, would advance the Bureau’s mission to manage public lands for multiple uses, including outdoor recreation, grazing, energy development, and more by prioritizing the health and resiliency of ecosystems across those lands.

To ensure health and resilience, the proposed rule states that the Bureau will protect intact landscapes, restore degraded habitat, and make wise management decisions based on science and data.

In response to the Proposed Rule, the RV Industry Association submitted comments that highlight the need for outdoor recreation to be on an even playing field with other land uses to protect RV camping access and safeguard the current and future health of the $862 billion outdoor recreation industry and the local economies dependent on outdoor recreation access. The Association drew attention to the following four areas:

1. The RV Industry Association agrees that outdoor recreation is consistent with the Bureau’s goal of creating resilient public lands and ecosystems. The Association understands the importance of maintaining the resilience of ecosystems across the Bureau’s lands. We agree that the term “multiple use” includes outdoor recreation access and sustainable management of public lands to meet current and future needs of the American people.
2. The RV Industry Association agrees that outdoor recreation does not degrade landscapes. The Association supports balanced policies that maintain federal lands so that they can be accessed and enjoyed today and by future generations of Americans. During the planning process, we encourage the Bureau to coordinate with local communities and outdoor recreation stakeholders so that the areas being restored can benefit and maximize the public’s use of them. The Association also agrees that the Bureau should work with communities and outdoor recreation stakeholders to identify and safeguard geographic areas important to their strategic growth and development.
3. The RV Industry Association believes coordination with local communities and recreation partners will be critical to developing reasonable restoration objectives. The Association understands the Bureau’s imperative to steward public lands and maintain functioning ecosystems. Restoration is not inconsistent with outdoor recreation and camping. As the Bureau enters into restoration planning, programs, and permitting, the Association encourages the agency to consider limits on the acreage or areas that can be closed via conservation leases at any one time in order to achieve stated objectives or, alternatively, to try pilot programs first. Coordination with local communities and recreation partners will be critical to developing timely and reasonable restoration objectives.
4. The RV Industry Association believes that the “casual use” definition related to conservation leases should not preclude the public from accessing public lands for camping and other outdoor recreation activities. The Association cites two items of concern related to the Bureau authorization of conservation use on public lands. First, any temporary closures should be clearly defined, limited, and publicly noticed so as not to impact outdoor recreation indefinitely. Second, we encourage public lands leased for conservation purposes under the proposed rule to remain open. When considering applications for conservation leases, it is important for the Bureau to closely review the proposed uses and activities. Additionally, the Final Rule must include the Bureau’s imperative “This provision is not intended to preclude other uses such as grazing, mining and recreation” when describing what actions conservation leases may allow.

The outdoor recreation economy is dependent on responsible and sustained use of our nation’s public lands and waters. The conservation lease proposals must allow, where appropriate, outdoor recreation and camping. RV camping provides the public with opportunities to take part in America’s iconic outdoor recreation experiences, and encourages stewardship, conservation, and enjoyment of our beloved federal lands.