The Honorable Debra Haaland
Secretary of the Department of the Interior
Department of the Interior
1849 C Street, N.W.
Washington DC 20240

The Honorable Nada Culver
Deputy Director of Policy and Programs
Bureau of Land Management
760 Horizon Drive
Grand Junction, CO 81506


September XX, 2021

Dear Secretary Haaland and Deputy Director Culver,

We write on behalf of our organizations and members in support of new hardrock mining rules, such as those suggested in a recently-submitted petition to the Department of the Interior (DOI).  DOI has ample authority to take action to undertake much needed reform to strengthen and modernize these safeguards.  

A hardrock mining rulemaking does not end generations of mining-inflicted injustice to Indigenous communities nor resolve the injustices the 1872 Mining Law still imposes upon mining-impacted communities. However, new hardrock mining rules are a necessary step to prevent more damage, while we chart a new course for public lands stewardship toward a more sustainable, clean energy economy. They can help more equitably transition to green infrastructure in a way that has tangible benefits for all mining-affected communities and leaves a liveable planet to future generations.

As the Administration develops policies to build back better clean energy infrastructure, the DOI must also transition minerals policies to a modern framework that will prevent unnecessary or undue degradation and enable more responsible sourcing. The current hardrock mining rules are too outdated to facilitate this transition. They are counterproductive to a responsible minerals policy and stand to repeat the tragic mistakes of the 19th century rush for precious metals and the 20th century rush for uranium.

This petition, brought forth by mining-affected communities including Tribes, Indigenous groups, and conservation organizations, asks the Department of Interior (DOI) through the Bureau of Land Management (BLM) to strengthen rules under 43 C.F.R. §§ 3800 et seq. The proposed revisions aim to safeguard critically important lands across the West and Alaska, including sacred lands and cultural resources, vital wildlife habitat, and invaluable water resources. The petition asks:

BLM clarify that it may approve or deny mines;
Strengthen the definition of unnecessary or undue degradation to ensure better protection of important environmental, scientific, historical, cultural, or other public resources;
Ensure that mining plans of operations do not become stale and outdated;
Require a climate change management plan as part of a mining plan;
Ensure that operations cannot adversely affect Treaty rights, including rights to fish, hunt, gather, or otherwise use public land; and,
Require operations prevent impacts to the hydrologic balance that may impair beneficial uses of surface and groundwater.  

This century’s mining must not repeat the mistakes of the past. The Administration must avoid these outcomes by granting this petition and strengthening DOI’s hardrock mining rules.

Thank you for your consideration.

Sincerely,