Understanding BLM's Consistency Requirement: Why County Natural Resource Plans Matter

Micah Christensen
Aug 3
4 min read

Updated: Aug 7

The Bureau of Land Management (BLM) Newcastle Field Office recently released its Final Environmental Impact Statement (FEIS) and Proposed Resource Management Plan (RMP). Among the supporting materials is Appendix C, which documents the BLM's efforts to evaluate consistency with the Natural Resource Plans of three Wyoming counties.

Although neither the Federal Lands Policy and Management Act (FLPMA) nor the BLM's planning regulations require this information to be presented in a standalone appendix, this appendix provides an excellent example of how the agency can document its consistency review with local governments during land use planning. Appendix C describes how the BLM evaluated adopted county policies, worked with county cooperating agencies to identify potential inconsistencies, and documented how those issues were considered and, where possible, resolved before the proposed planning decisions were issued.

High angle view of a public land area with grazing cattle and open fields

Understanding the BLM Consistency Requirement

Under FLPMA (43 U.S.C. § 1712(c)(9)), land-use plans must be consistent with state and local plans to the maximum extent the Secretary finds consistent with federal law and the purposes of FLPMA. The BLM is directed, to the extent practical, to:

remain apprised of state, local, and Tribal land use plans;
ensure that local land use plans germane to the development of BLM land use plans are given consideration;
assist in resolving inconsistencies between federal and local plans; and
provide meaningful opportunities for involvement by state and local governments in the development of land use programs, regulations, and decisions.

What is a County Natural Resource Plan?

Wyoming counties have an important role in representing local interests, conditions, customs, culture, and land-use priorities in federal planning processes. Many Wyoming counties have developed comprehensive Natural Resource Plans through a public process. These plans describe historic and current resource uses within their jurisdictions and establish county policy priorities and goals. Topics commonly include water use, agriculture, mining, access, and energy development.

Because consistency review's are conducted against officially approved or adopted plans, policies, and programs—not general preferences or isolated public comments—the clarity and specificity of a County Natural Resource Plan can directly affect a county’s ability to identify and substantiate inconsistencies during BLM planning.

What Does "Consistency" Mean?

Consistency means that the BLM should make its Resource Management Plan compatible with officially adopted county plans and policies to the maximum extent permitted by federal law. When an inconsistency cannot be resolved, the BLM should identify the conflict, explain why it cannot be reconciled, and document how it was considered. Although county plans are not legally binding on federal land management agencies, Congress has directed the BLM to achieve consistency to the maximum extent consistent with federal law and the purposes of FLPMA.

What is the Purpose of Consistency?

Because public lands are intermingled with private, state, Tribal, and local lands, Congress recognized that effective land management requires coordination across jurisdictions. The consistency requirement encourages the BLM to consider local priorities and, where practical, achieve consistency between federal land use plans and locally adopted policies while still fulfilling its obligations under federal law.

The Benefits of Effective Consistency Reviews

Incorporates local knowledge by considering county expertise on natural resources, infrastructure, economic conditions, and community priorities.
Improves federal decision-making by identifying potential conflicts early and allowing the BLM and local governments to work toward mutually acceptable solutions.
Promotes more durable land use plans by increasing transparency, strengthening the administrative record, and reducing misunderstandings throughout the planning process.
Supports multiple-use management by helping the BLM balance local economic, environmental, recreational, and cultural interests alongside federal responsibilities.
Strengthens government-to-government relationships by encouraging ongoing coordination between counties, states, Tribes, and the BLM throughout the planning process.
Provides greater certainty for communities by helping counties understand how proposed federal decisions may affect local land use, infrastructure, economic development, and natural resource management.

For county commissioners, this means maintaining current, well-supported Natural Resource Plans and actively participating in the BLM planning process. Clear local policies and early coordination give the BLM the information necessary to evaluate consistency and consider county priorities when developing Resource Management Plans.

Eye-level view of a county planning meeting with maps and documents on the table

Practical Tips for County Natural Resource Plans

Maintain an up-to-date County Natural Resource Plan. Clearly adopted policies provide the foundation for meaningful consistency reviews. Counties should periodically update their Natural Resource Plans to address emerging technologies and land uses, changing resource conditions, and evolving county priorities.
Engage early during Resource Management Plan development. Counties should participate during scoping, cooperating agency meetings, and public comment periods. Counties should provide data, maps, economic information, and on-the-ground knowledge that may improve the BLM's analysis.
Coordinate throughout the planning process. Effective consistency reviews are built on ongoing communication throughout plan development rather than a single review conducted near the end of the process. Within the cooperating agency process, counties should identify possible inconsistencies and recommend alternative language or prescriptions that would better align with local plans.
Review proposed plans for policy inconsistencies. Once a draft plan has been published for public review, counties should compare the proposal with their adopted plans and identify specific policy conflicts. As shown by the Newcastle RMP, this review is best done in cooperation with federal partners and can be included in the agency's supporting documents.

Making Consistency Review Meaningful

A legally required consistency review does not guarantee that every county recommendation will be adopted. It does, however, require the BLM to consider officially adopted local plans, address identified inconsistencies, and pursue consistency to the maximum extent consistent with federal law and the purposes of FLPMA. Counties that maintain clear and current Natural Resource Plans, identify specific conflicts, and participate throughout the planning process are better positioned to contribute local knowledge and influence the long-term management direction affecting their lands, economies, and communities.

Appendix C of the Newcastle Proposed RMP demonstrates the value of documenting that process. By clearly identifying county policies, potential inconsistencies, and how those issues were addressed, the BLM can improve transparency, strengthen its relationships with local governments, and create a more durable planning record.