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March 28, 2007
Bureau of Land Management
Las Vegas Field Office
4701 North Torrey Pines Drive
Las Vegas, Nevada 89130
Las Vegas Field Office
4701 North Torrey Pines Drive
Las Vegas, Nevada 89130
Dear Bureau of Land Management:
The National Rifle Association would appreciate having this letter entered in the public comment record for the proposed closure to target shooting on certain lands in Nye County, Nevada as announced in the Federal Register dated March 2, 2007.
Nearly a decade ago, in the face of increasing loss of access and opportunity on public lands for target shooting, national hunting and wildlife conservation organizations formed a partnership with the BLM and other federal land management agencies called the Public Lands Shooting Sports Roundtable. The objective of the Roundtable was to protect the future of the shooting sports on public lands by working together to resolve the kinds of issues that BLM cites in this notice as its reasons for the proposed closure.
The Roundtable partnership was renewed and strengthened in August, 2006 when a Memorandum of Understanding (MOU) was signed by 40 hunting, fishing and wildlife conservation organizations with the BLM, the Forest Service, and the Fish and Wildlife Service.
The purpose of the Federal Lands Hunting, Fishing and Shooting Sports Roundtable MOU is to "develop and expand a framework of cooperation among the Parties at the national, regional and local levels for planning and implementing mutually beneficial projects and activities related to hunting, fishing and shooting sports conducted on federal lands."
The purpose of the Federal Lands Hunting, Fishing and Shooting Sports Roundtable MOU is to "develop and expand a framework of cooperation among the Parties at the national, regional and local levels for planning and implementing mutually beneficial projects and activities related to hunting, fishing and shooting sports conducted on federal lands."
In that document, the federal agencies agreed to certain things. One, for example, states:
when sites used by shooting sports enthusiasts on federal lands are unsafe or in unsuitable locations (such as where urbanization or public pressures threaten a target range or hunting or shooting areas); are in need of environmental or trash cleanup; are not meeting best management practices; or are in need of maintenance, reconstruction, or modernization, work with the Private Organizations to resolve these issues in a mutually satisfactory manner and consistent with applicable laws, regulations, and Agency policies.
In spite of this MOU and the previous efforts to work with the BLM, issues are not being resolved in a mutually satisfactory manner and land continues to be closed to target shooting.
As a signatory to the MOU, we have no knowledge that the Las Vegas Field Office or any office within the BLM contacted the NRA or any other MOU organization about issues related to target shooting on public lands in Nye County. To our knowledge, there was no opportunity extended to any MOU organization to work with the BLM in resolving these issues.
We are also unaware of any contact the BLM may have made to local target shooters, who are in the BLM's words "traditional public land users," to solicit their assistance in resolving the issues. Nor do we believe they were given advance notice that BLM was contemplating a closure. Thus, the process leading to this notice of closure is contrary to the intent and spirit of the MOU to which the BLM is a party.
The notice says that the closure "merely imposes certain rules on recreational use on a limited portion of public lands in Southern Nevada in order to protect human health and safety." We are certain that the traditional public land users would not view this closure as a mere imposition. Rather, the closure forces them off of their public land, permanently.
Most people living in western states are dependent upon access to public land to enjoy the benefits of recreational shooting, to practice safety and marksmanship skills, and to introduce their family members to the shooting sports. It has been NRA's experience that when public land is closed to recreational shooting, no alternative sites are opened, meaning a net loss in recreational opportunities.
Hunters are also affected by the closure, even though the notice states that it does not apply to hunting. Hunting is more than the act of hunting game. Hunting is also about the preparations that lead up to opening season; that is, being a safe and humane hunter. Closing access to public lands for target shooting has an adverse effect on hunting in that the opportunity to hunt safely and enjoyably is restricted to the seasoned hunter, to those who belong to private gun clubs, and those who live elsewhere in the state or country. Hunters are not separate and distinct from target shooters. Hunters also need a place to practice, and to sight in their hunting guns.
With respect to the closure restrictions, the notice appears to go beyond BLM's authority. The notice does not just address the restriction on the discharge of firearms, it also addresses illegal possession of firearms. It is not clear why "b" through "e" are necessary since illegal possession is the purview of local, state and federal law enforcement. The notice is duplicative of existing laws and regulations.
The NRA and other shooting sports organizations have the technical expertise to assist the BLM in resolving recreational use conflicts in a manner that promotes continued use of public lands for the traditional public land users, protects the natural and cultural resources of the land, accommodates other users of the public land, and protects private property.
Numerous times the NRA has offered to work with the BLM to resolve target shooting issues. That is why we signed the MOU. It is our good faith commitment to the partnership. We trust that the BLM will begin to act in like fashion.
The NRA respectfully urges the Las Vegas Field Office to withdraw this notice and address target shooting issues in Nye County within the framework of the MOU.
Sincerely,
Susan Recce
Director
Conservation, Wildlife and Natural Resources
National Rifle Association
Director
Conservation, Wildlife and Natural Resources
National Rifle Association
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