Congress should eliminate the ability of ranchers to use public lands as collateral for private loans. My request is to modify Subpart 4130.9 Pledge of permits or leases as security for loans so that it reads: 1) Grazing permits or leases that have been pledged as security for loans from lending agencies shall be NOT be renewed. 2) Grazing permits or leases may NOT be pledged as security for loans from lending agencies, this does not exempt these permits or leases from the provisions of these regulations. Background The current policy under 43 CFR Part 4100 Subpart 4130 (part of the Taylor Grazing Act of 1934) allows ranchers granted grazing leases to use public lands defined in that agreement as collateral for private lending encumbrance. There are roughly 18,000 grazing leases and permits across 155 million acres of public land in 13 states Bureau of Land Management (BLM) has permitted a substantial portion of public lands to be used by an elite, wealthy few as loan collateral. The removal of the right to use public land as collateral in private lending under 43 CFR Part 4100 Subpart 4130 should be an easy WIN-WIN for both near term risk reduction and improving the sustainability of public lands. Position Statement: We strongly advocate for the removal of the provision in 43 CFR Part 4100 Subpart 4130 that allows for the use of public land as collateral in private lending transactions. This policy presents several significant concerns: Environmental Degradation: The primary focus on private financial gain can incentivize unsustainable land use practices. Landowners may prioritize short-term profits over long-term environmental health, leading to increased resource extraction, habitat destruction, and pollution. Social Equity: This policy disproportionately benefits large landowners and corporations, while potentially displacing or harming local communities and Indigenous populations who rely on these lands for subsistence and cultural practices. Government Accountability: The use of public land as collateral shifts the primary responsibility for land management towards private entities, potentially undermining the government's ability to ensure the sustainable use and conservation of these valuable resources. Increased Risk: If a borrower defaults on their loan, the government may be left with the responsibility of managing potentially environmentally damaged land, incurring significant costs for remediation and restoration. Conclusion: Removing the right to use public land as collateral in private lending is crucial for safeguarding our environment, promoting social equity, and ensuring the long-term sustainability of our public lands. By implementing alternative financing mechanisms and strengthening government oversight, we can better balance economic development with environmental protection and social justice.

It is imperative that Congress takes action to address the use of public lands as collateral for private loans. Currently, the policy allows ranchers to leverage grazing permits or leases for loans from lending agencies, which poses significant risks to the environment, social equity, and government accountability. By modifying Subpart 4130.9 to prohibit the renewal of permits or leases used as loan collateral, and disallowing their use as security for loans, we can protect our public lands and ensure their sustainable management for future generations. The existing practice incentivizes unsustainable land use practices, prioritizes short-term profits over environmental health, and disproportionately benefits large landowners at the expense of local communities and Indigenous populations. Moreover, the reliance on private financial gain undermines government oversight and places public lands at increased risk of damage if borrowers default on their loans. In order to safeguard our environment, promote social equity, and enhance the long-term sustainability of public lands, we must advocate for the removal of the provision allowing public land to be used as collateral. Through alternative financing mechanisms and strengthened government oversight, we can strike a better balance between economic development, environmental conservation, and social justice. Together, let's work towards a future where our public lands are protected and preserved for the benefit of all.

It is imperative that Congress considers amending Subpart 4130.9 to prevent ranchers from using public lands as collateral for private loans, which has raised various concerns including environmental degradation, social equity issues, government accountability, and increased risks associated with land management. Our proposed modifications to Subpart 4130.9 aim to address these concerns by prohibiting the renewal of grazing permits or leases pledged as loan collateral and disallowing the pledging of such permits or leases for loans. By removing the provision that allows public lands to be used as collateral, we can better protect these valuable resources, promote social equity, and ensure sustainable land management practices. As advocates for land conservation and responsible stewardship, it is crucial that we take action to safeguard our environment, support local communities, and uphold the integrity of public lands. Through alternative financing mechanisms and enhanced government oversight, we can work towards a more balanced approach that prioritizes environmental protection, social justice, and long-term sustainability.

Congress should consider amending Subpart 4130.9 Pledge of permits or leases as security for loans in the following manner: 1) Grazing permits or leases that have been offered as collateral for loans from lending institutions should not be eligible for renewal. 2) Grazing permits or leases should not be allowed as collateral for loans from lending agencies, with these permits or leases still subject to the regulations in place. Context: The current regulation outlined in 43 CFR Part 4100 Subpart 4130 permits ranchers holding grazing leases to utilize public lands outlined in the agreement as collateral for private loans. There are approximately 18,000 grazing permits and leases spanning across 155 million acres of public land in 13 states, with a substantial portion of these lands authorized by the Bureau of Land Management (BLM) to be leveraged as loan collateral by a select few affluent individuals. Eliminating the authorization to use public lands as collateral for private loans as per 43 CFR Part 4100 Subpart 4130 is a viable solution with multiple advantages, including mitigating immediate risks and enhancing the sustainable management of public lands. Stance: We advocate fervently for the removal of the provision in 43 CFR Part 4100 Subpart 4130 that permits the utilization of public lands as collateral in private loan agreements. This policy raises significant apprehensions, including: Environmental Impacts: The primary focus on private financial gains may encourage unsustainable land management practices, potentially leading to resource depletion, habitat destruction, and pollution. Social Inequity: This regulation tends to favor bigger landowners and corporations, potentially disadvantaging local communities and Indigenous groups that rely on these lands for their sustenance and cultural practices. Government Integrity: Using public lands as loan collateral shifts the primary responsibility for land management to private entities, which could compromise the government's ability to ensure sustainable utilization and conservation of these valuable resources. Increased Risks: In scenarios where a borrower defaults on their loan, the government may be left to manage environmentally impaired lands, incurring substantial costs for remediation and rehabilitation. Conclusion: Revoking the privilege of utilizing public lands as collateral in private loan scenarios is essential to safeguarding our environment, upholding social equity, and ensuring the long-term sustainability of our public lands. By adopting alternative financing mechanisms and fortifying governmental oversight, we can strike a better balance between economic progress, environmental conservation, and egalitarian principles.