Develop a new BLM Planning Handbook or Secretarial Order that institutes transparency measures without violating the CRA ban.
Use Interior’s administrative tools to standardize earlier disclosure and clearer public engagement in BLM planning without triggering the CRA “substantially similar” trap described here. Focus on practical process upgrades—handbook updates, guidance, and orders—that require publishing key materials earlier and in more usable formats. This path is fastest when a legislative fix is uncertain and transparency needs to improve before the next plan cycle closes.
Why this works
- Easier and faster than going through Congress; can be tailored flexibly.
- Could achieve much of Planning 2.0’s intent informally.
Public Citizen
AdvocacyChampioning consumer rights and accountable government
Mechanism
About LobbyingHow Public Citizen uses funding
- Define the minimum transparency and engagement standards the guidance must require.
- Draft handbook or order language that improves disclosure without mirroring barred rule text.
- Consult stakeholders and internal BLM staff to identify workable implementation steps.
- Publish guidance and supporting templates so regions can apply it consistently.
- Track adoption, surface bottlenecks, and iterate to improve usability over time.
Milestones
Checkpoints and the expected timing for each step
- 1
Guidance scope and CRA constraints mapped
Near-termRequired transparency steps are defined alongside clear legal guardrails.
- 2
Draft handbook or order language completed
EarlyConcrete text and implementation templates are ready for review and iteration.
- 3
Guidance issued and rollout launched
During an administrative decision windowInterior publishes guidance and regions receive clear adoption expectations.
- 4
Early implementation checkpoints published
Post-issuanceA trackable set of adoption signals shows whether disclosure is happening earlier.