Public Comments on Proposed Federal Rules
Here's a look at public comments on proposed Federal Register rules
Featured Stories
America Outdoors Association Urges Bureau of Land Management to Revise Conservation Rule Instead of Rescinding
Carter Struck
WASHINGTON, Nov. 3 -- The America Outdoors Association, Knoxville, Tennessee, has submitted a public comment letter to the Bureau of Land Management expressing its concerns over the proposal to rescind the 2024 Conservation and Landscape Health Rule. The association, which represents over 1,000 outfitters, guides, and outdoor recreation service providers across the country, emphasizes the critical need for reliable federal permitting processes that are vital for small businesses reliant on public lands.
In its letter, the group highlights that many of its members, which include small businesses
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WASHINGTON, Nov. 3 -- The America Outdoors Association, Knoxville, Tennessee, has submitted a public comment letter to the Bureau of Land Management expressing its concerns over the proposal to rescind the 2024 Conservation and Landscape Health Rule. The association, which represents over 1,000 outfitters, guides, and outdoor recreation service providers across the country, emphasizes the critical need for reliable federal permitting processes that are vital for small businesses reliant on public lands.
In its letter, the group highlights that many of its members, which include small businessesserving over three million Americans annually, depend on the efficiency and transparency of BLM's permitting system. While the organization acknowledges certain deficiencies in the 2024 Rule, it firmly believes that a complete rescission would eliminate important tools and create further uncertainty in a sector that already faces significant challenges.
The letter outlines that the 2024 Rule was designed to promote a balanced approach to land management that aligns with the Federal Land Policy and Management Act (FLPMA). The association insists that rescinding this framework would not solve the fundamental legal requirements BLM must adhere to but would instead strip away mechanisms that enhance the decision-making process for special recreation permits (SRPs).
In advocating for a balanced approach, the association suggests targeted revisions that would address both the BLM's concerns and the needs of outdoor recreation businesses. These revisions include clarifying the compatibility of outfitting and guiding as legitimate use within conservation leases and establishing realistic timelines for permit processing to avoid delays.
The organization expresses its commitment to ensuring that conservation efforts do not come at the expense of recreational access. The association argues that outfitting and guiding contribute positively to land stewardship, fostering local constituencies that care deeply about the health of public lands. A middle-ground strategy is deemed necessary to avoid broad policy shifts that may disrupt the livelihoods of small business owners and negatively impact conservation outcomes.
Furthermore, the group urged BLM to improve stakeholder consultation processes moving forward to foster more collaborative, stakeholder-based reforms. In conclusion, the association requests that the agency reconsider the full rescission of the 2024 Rule, advocating instead for a framework that retains its effective elements while addressing known shortcomings. Through these collaborative efforts, the group aspires to cultivate both robust conservation policies and a thriving outdoor recreation economy.
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The letter was signed by:
Aaron Lieberman
Executive Director, America Outdoors Association
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Read full text of letter here: https://www.regulations.gov/comment/BLM-2025-0001-9743
University at Buffalo Opposes Proposed Rule Limiting Student Duration of Stay
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WASHINGTON, Nov. 3 -- Nojin Kwak, Vice Provost, Office of International Education at the University at Buffalo, State University of New York, has submitted a public comment letter to the U.S. Department of Homeland Security expressing objections to the proposed rule that would end the Duration of Status for international students.
The change would impose a four-year limit on admission for F-1 and J-1 students, a move that the university claims would have dire consequences for its academic programs, student body, and the economy of Western New York.
According to Kwak, many of its programs, particularly
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WASHINGTON, Nov. 3 -- Nojin Kwak, Vice Provost, Office of International Education at the University at Buffalo, State University of New York, has submitted a public comment letter to the U.S. Department of Homeland Security expressing objections to the proposed rule that would end the Duration of Status for international students.
The change would impose a four-year limit on admission for F-1 and J-1 students, a move that the university claims would have dire consequences for its academic programs, student body, and the economy of Western New York.
According to Kwak, many of its programs, particularlyPhD and professional degrees, require more than four years to complete due to the nature of their curricula, which often include clinical internships and research components. Statistics from the National Center for Education Statistics indicate the average time to complete a bachelor's degree is approximately 4.3 years, while PhD candidates at UB average nearly 6.3 years. The university warns that limiting the duration of stay would discourage international students from pursuing their studies and lead to increased requests for extensions as they strive to complete their academic requirements.
The letter highlights that such a requirement could result in a significant decline in international student enrollment, which would subsequently impact tuition revenue, staffing, and research capabilities at UB. This decline could exacerbate local economic hardships, as international students not only contribute to university budgets but also support local businesses and services. Currently, international students enrolled at UB generate substantial economic activity, contributing over $223 million annually and supporting nearly 2,000 jobs across the region.
Kwak also raised concerns over the administrative burden the proposed changes would impose on institutions, suggesting that the added complexities surrounding Extension of Stay applications may lead to higher costs that could affect tuition rates and student services. Moreover, the university expressed alarm that the rule would allow DHS adjudicators to influence academic decisions, potentially leading to inconsistent evaluations of students' academic progress.
The proposal, which could add hundreds of thousands of extension requests to the already existing USCIS backlog, further complicates an already strained processing system. The university argues that any modifications to the current policy should maintain the flexibility essential for students' academic success.
In conclusion, Kwak emphasizes the importance of preserving the existing Duration of Status policy, which not only aligns with educational needs but also bolsters the economic fabric of the local community. The university calls for DHS to withdraw or revise the proposed rule to safeguard the interests of students and the broader economic health of Western New York.
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The letter was signed by:
Nojin Kwak, Ph.D.
Vice Provost, Office of International Education
University at Buffalo, State University of New York
vpinted@buffalo.edu
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Read full text of letter here: https://www.regulations.gov/comment/ICEB-2025-0001-21913
IT For Change Urges USTR to Reconsider Trade Barrier Characterization
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WASHINGTON, Nov. 3 -- IT for Change, a not-for-profit organization based in India, has submitted a public comment letter to the U.S. Trade Representative urging the agency to reassess its characterization of India's digital economy regulations as "significant trade barriers." This submission comes as the USTR prepares for the National Trade Estimate Report (NTE Report) 2026, which seeks to identify foreign trade barriers that may affect the United States and its trading partners.
The letter argues that the Indian regulations in question are essential for protecting citizens' rights and promoting
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WASHINGTON, Nov. 3 -- IT for Change, a not-for-profit organization based in India, has submitted a public comment letter to the U.S. Trade Representative urging the agency to reassess its characterization of India's digital economy regulations as "significant trade barriers." This submission comes as the USTR prepares for the National Trade Estimate Report (NTE Report) 2026, which seeks to identify foreign trade barriers that may affect the United States and its trading partners.
The letter argues that the Indian regulations in question are essential for protecting citizens' rights and promotingfair competition within the digital economy. IT for Change highlights that these policies, which include provisions for cross-border data flows and digital market regulations, mirror similar legislative measures in the U.S. The organization insists that dismissing such policies as trade barriers undermines the sovereign right of nations to govern their digital ecosystems in a manner that prioritizes public interest.
IT for Change contends that the USTR's reliance on what they describe as industry biases in the NTE Report 2025 obscures the genuine public interest justifications for India's regulatory measures. The letter emphasizes that the adoption of such an adversarial stance towards foreign regulations risks exacerbating biases toward large technology firms, potentially destabilizing the market dynamics essential for fair competition.
The organization specifically urges the USTR to exclude particular Indian laws and policies from the 2026 NTE Report. These include regulations governing cross-border data flows, measures that promote competition in digital markets, and taxation of digital services. IT for Change argues that these provisions are designed to protect consumer interests and ensure equitable distribution of data dividends within India's digital landscape.
In its submission, IT for Change underscored the importance of embracing frameworks that respect the regulatory rights of nations, particularly in light of ongoing global discussions about digital taxation and consumer protection regulations. The organization asserts that a more constructive approach by the USTR can build towards equitable global trade and allow for the preservation of necessary policy space for individual countries to navigate their digital economies effectively.
IT for Change concludes by calling for a balanced approach in the upcoming NTE Report that echoes the U.S. Administration's commitment to upholding domestic regulatory standards while recognizing the rights of other nations to create policies that reflect their unique challenges and needs in the digital era.
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Read full text of letter here: https://www.regulations.gov/comment/USTR-2025-0016-0026
Dolores River Boating Advocates Urge Bureau of Land Management to Retain 2024 Public Lands Rule
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WASHINGTON, Nov. 3 -- Rica Fulton, advocacy and stewardship director at the Dolores River Boating Advocates, Colorado, has issued a public comment letter to the U.S. Department of the Interior and the Bureau of Land Management (BLM) urging the agency to retain the 2024 Public Lands Rule. This organization represents a variety of stakeholders across the West who emphasize the importance of balanced land management.
In its commentary, DRBA highlighted that the Public Lands Rule supports the health of landscapes while accommodating various uses. With a focus on the conservation, recreational, and
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WASHINGTON, Nov. 3 -- Rica Fulton, advocacy and stewardship director at the Dolores River Boating Advocates, Colorado, has issued a public comment letter to the U.S. Department of the Interior and the Bureau of Land Management (BLM) urging the agency to retain the 2024 Public Lands Rule. This organization represents a variety of stakeholders across the West who emphasize the importance of balanced land management.
In its commentary, DRBA highlighted that the Public Lands Rule supports the health of landscapes while accommodating various uses. With a focus on the conservation, recreational, andeducational values of the Dolores River and surrounding public lands, the organization advocates for a land management strategy that serves a wide array of interests, including ranching, boating, and wildlife preservation.
The letter underlined that successful ranching relies on careful management of grazing practices and long-term considerations for land health. Similarly, it posits that recreational activities require forward-thinking plans that incorporate other land uses, such as maintaining wildlife habitats. This approach aligns with the philosophy of multiple-use, which seeks to balance diverse interests for current and future generations.
The DRBA's correspondence emphasized that the 2024 Public Lands Rule is consistent with the Federal Land Policy and Management Act (FLPMA). This act promotes the concept of "sustained yield," which aims for the continuous availability of renewable resources on public lands. The organization asserts that effective land management must prioritize conservation and long-term planning to sustain these resources.
Furthermore, the letter pointed out that FLPMA recognizes watershed health as a fundamental use of BLM-managed lands. The health of watersheds is critical not only for recreation and wildlife habitats but also for the provision of drinking water to millions of people in the West. The DRBA posited that conserving these vital ecosystems supports a plethora of community needs.
In conclusion, the Dolores River Boating Advocates implored BLM to uphold the Public Lands Rule, stressing that using the best available science to prioritize ecosystem health and biodiversity is crucial for sustainability. The organization affirmed that responsible management today is essential for maintaining resources for future generations.
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The letter was written by:
Rica Fulton
Advocacy and Stewardship Director
Dolores River Boating Advocates
rica@doloresriverboating.org
PO Box 1173
Dolores, CO 81323
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Read full text of letter here: https://www.regulations.gov/comment/BLM-2025-0001-9141
Cumberland Law Students Challenge BLM Proposed Rescission of 2024 Conservation Rule
Carter Struck
WASHINGTON, Nov. 3 -- Russell Burt and Joshua Wright, third year law students at Cumberland School of Law in Birmingham, Alabama, have submitted a public comment letter to the U.S. Department of the Interior Bureau of Land Management regarding its proposed rescission of the 2024 Conservation and Landscape Health Rule.
The letter was submitted as a part of a classroom research assignment for an Administrative Law Course, and it critiques the existing regulatory framework and advocates for shifts in management practices that align with the Federal Land Policy and Management Act of 1976.
The Bureau
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WASHINGTON, Nov. 3 -- Russell Burt and Joshua Wright, third year law students at Cumberland School of Law in Birmingham, Alabama, have submitted a public comment letter to the U.S. Department of the Interior Bureau of Land Management regarding its proposed rescission of the 2024 Conservation and Landscape Health Rule.
The letter was submitted as a part of a classroom research assignment for an Administrative Law Course, and it critiques the existing regulatory framework and advocates for shifts in management practices that align with the Federal Land Policy and Management Act of 1976.
The Bureauhad initially implemented the 2024 Rule to enhance conservation efforts on public lands, promoting areas traditionally viewed as "non-use" to a status of "productive use." Critics, however, argue that this alteration contradicts the Bureau's primary mandate of regulating the "use, occupancy, and development" of public lands. The letter outlines concerns that the 2024 Rule's requirements have created unnecessary complexities in regulatory processes, hindering the Bureau's ability to effectively manage public resources.
The students' analysis emphasizes that the 2024 Rule has resulted in both regulatory redundancy and potential administrative overreach, making it more challenging for the Bureau to meet its multiple-use mandate. They suggest that these entanglements lead to a protracted leasing process, thereby restricting economic productivity in sectors like grazing, mining, and energy production.
The commentary raises issues with the process for designating Areas of Critical Environmental Concern (ACECs), arguing that such nominations have been exploited by outside groups to impede legitimate land use applications. The proposed rescission aims to minimize these twenty-first-century challenges, allowing for a more balanced approach between conservation and productive usage.
In discussing a cost-benefit analysis of the rescission, the students argue that while conservation organizations may oppose the repeal due to the loss of rapid ACEC protections, industries dependent on land access, like grazing and recreational activities, would see substantial benefits, including reduced permitting delays and costs. Historical data presented in the letter suggests that the Bureau's actions prior to the 2024 Rule generated significant economic output and supported numerous jobs across various regions.
To address the concerns voiced in the letter, the Bureau is encouraged to consider alternatives, such as a "graduated response protocol" for ACEC nominations, which would allow for ongoing activities until a merit-based evaluation is concluded. Moreover, integrating conservation efforts with other uses through a "conservation plus use" framework is proposed as a potential way forward.
As public comments are evaluated, the outcome of this proposed rescission continues to draw interest, highlighting the ongoing debate over land management practices in the U.S. and the balance between conservation and economic development.
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Read full text of letter here: https://www.regulations.gov/comment/BLM-2025-0001-7687
