Dec. 24, 2023
I am writing in strong opposition to the creation of NACs in this current rule. Under current law, it extends rights and privileges to an NAC that are unavailable to individual property owners. For instance, mineral rights are almost never transferred on any ownership claim of even large properties. Water rights are also difficult to obtain for new buyers and generally rely on a series of grandfathered provisions. This is unacceptable favoritism in business practices. Further, it's logical that local control over these lands is the best option, since the people who live and work next to them are usually the most incentivized to manage them with the intent to cause the least damage and maximize outputs. An organization that could feasibly be headquartered thousands of miles away that manages millions of acres does not have a similar incentive. The idea that an NAC can manage any collection of lands better than an individual or state government does not seem to be defensibly true in most situations. There are plenty of examples from the federal government where mismanagement occurred due to the lack of understanding local environments and conditions that surround decision making; for example the release of toxins into the Animas River in Colorado. The only difference is that NACs are private and therefore totally unaccountable to voters. This unaccountability is also unacceptable. I'm also strongly opposed to NACs because if rights federal lands are being sold to private companies, access by citizens will necessarily be curtailed. This is unacceptable since federal lands were bought into this program for the very reason of providing access to generations of Americans. Selling these lands (or rights to certain aspects of them in the form of a lease) appears to be a violation of that tenet. If the federal government can no longer manage all the lands it has acquired, then ownership should be passed to the state and local governments where they are located. This is an anathema to the entire idea of federal lands and the reason they were created. I will be reaching out to my local government and representatives to see how they can prevent ownership being passed into the hands of NACs.