BLM DIRECTOR’S 1990 MEMO EXPANDING ON INTERIOR SECRETARY HODEL’S 1988 POLICY STATEMENT ON RS 2477 MANAGEMENT
This memo expands on the 1988 Policy Statement of Interior Secretary Donald Hodel on RS 2477 rights-of-way. It gives the State Directors (SD’s) of the BLM more specific examples and interpretations of that policy statement. Like the Hodel memo, it is of value both because it reflects the long-standing position of the BLM in dealing with these rights of way and also illustrates what a radical departure from that policy Interior attempted in issuing its draft regulations in 1994.
This is the text of the memorandum approved by Interior Secretary Donald Hodel in 1988. It is significant for two reasons. First, it summarizes the status of RS 2477 interactions with the public lands states and counties and reflects both past administrative actions and many court decisions. Second, as such, it illustrates how extreme the draft regulations issued by the Department of Interior just six years later really were and just how far they departed from previous policy and precedents.