The Bureau of Land Management (BLM) is currently considering the Miller Mountain Land Exchange in Wyoming, which proposes to trade away 1,802 acres of pristine mountain riverfront public land to a private corporation in exchange for lower quality desert lands along a separate river. On top of that, BLM will be paying the private corporation to acquire the pristine public land. This proposal raises serious concerns for the outdoor recreation community.

We are asking the public to comment against this against proposal, which can be done with the form at the end of this article. While the proposal began in 2015, BLM seems to have recently acted in haste to get this proposal approved. As such, the comment period closes this Wednesday, June 11th! So, don’t delay in submitting comments below.

Miller Mountain Land Exchange Overview

The Bureau of Land Management Wyoming offices in Pinedale, Kemmerer, and Rock Springs have proposed the exchange, a federal action involving a land swap between the BLM and Fort Hill, LLC, a private landowner in Big Piney, Wyoming. As currently written, the Environmental Assessment (EA) fails to adequately protect public access to incredible parcels and undervalues the exceptional land the public stands to lose.

  • Federal Lands Conveyed (Area 1): 1,802 acres of BLM-managed surface estate in forested, mountainous terrain with riparian areas is currently mostly landlocked and difficult to access or manage. These lands are Area 1 in the map below.
  • Non-Federal Lands Acquired (Areas 2 & 3): 2,275 acres offered by Fort Hill, strategically located along the Big Sandy River and scattered throughout the Miller Mountain area to improve public access and ecological connectivity. These lands are Areas 2 and 3 in the map below.
  • Equalization Payment: A cash payment of $160,000 will be made to Fort Hill to equalize appraised values under 43 CFR 2201.6

Maps of proposed Exchange Parcels

A Pristine River Parcel the Public Deserves to Access

At the heart of this exchange is a river parcel (Area 1 in the map below) currently managed by the BLM. This is a stretch of pristine mountain land with incredible recreational potential. Instead of trading this valuable land away, BLM should prioritize providing public access to it. Constructing a road to reach this parcel would open up significant opportunities for motorized recreation, fishing, camping, and other outdoor activities that serve a wide spectrum of public interests. The proposed Environmental Analysis should include an alternative that analyzes establishing access through the creation of new roads to the parcel in Area 1.

It is worth noting that one of the reasons the BLM wants to dispose of the parcel in Area 1 is because it is landlocked by private property, and the BLM can’t access the property. It is accessed by private landowners who own the surrounding private lands, who then get to enjoy this public land as if it was an extension of their private property where they don’t have to bear any of the costs of ownership.

Landlocked BLM Parcel

While it is true that the parcel is landlocked, a recent decision out of the 10th Circuit Court of Appeals in March 2025 has set a precedent that private landowners are prohibited from denying access to public land that is accessible by crossing the corner of adjacent public lands. As you can see from the map above, the State of Wyoming owns land that would allow for a corner crossing access point to the landlocked BLM parcel. This would require that the BLM coordinate with the Sate of Wyoming to construct a road that would connect to the corner crossing point.

A road already exists according to satellite imagery for the lower half of the route proposed below. This means we could get public access to this high-value BLM land if the State of Wyoming worked with its local officials and the recreation community to build a primitive road less than .5 miles in length to the corner crossing point of the BLM parcel. It would likely take public pressure to encourage the State of Wyoming to consider this alternative, but this should at least be considered before we pay taxpayer dollars to a private landowner to take this parcel out of public hands.

Screenshot

Regulatory Compliance Concerns

Land transfers are a regular part of land management, and several existing federal laws allow for land sales and exchanges. This proposal has been in the works since 2015. The BLM’s Pinedale and Rock Springs Resource Management Plans (RMPs) govern this transaction. The Pinedale RMP, set strict standards for land exchanges and sales in this area:

  • Exchanges must involve lands of similar value or character.
  • Disposal must serve an overriding public benefit.
  • Wetlands and riparian areas should be retained unless long-term protection is guaranteed.

It is questionable that these conditions are met in this exchange. In fact, the justification for disposal under the Rock Springs RMP is compromised by the likelihood that this RMP will be rescinded by the budget reconciliation legislation that has already been passed by the U.S. House of Representatives. If it is rescinded in the coming weeks, it is likely that the regulatory basis for this exchange will no longer be in effect. This might explain why after being stalled for 10 years they decided to complete this plan in a hurry.

Land Valuation Doesn’t Add Up

This deal doesn’t pass the smell test. It appears that the appraisals used for this exchange are from 2015, when this proposal was originally started under the Obama Administration. A lot has changed in the real estate market over 10 years, and it isn’t reasonable that analysis that started 10 years ago should still be used in a realty action now. Fortunately, current market data is available for comparable parcels right now, so we can assess if the public is being treated fairly in this exchange.

Parcel 1 Valuation Comparison

Parcel 1 Comps

The property currently listed on Zillow for $5.75 million in the screenshot above is directly comparable to the public land that BLM is proposing to pay a private landowner to take off of their hands. It is worth noting that the BLM property is located further upstream in a higher alpine ecosystem that is arguably more valuable and pristine. The BLM parcel is also 1802 acres where the property listed here is only 520 acres. This means acre for acre if the BLM land was valued at the same level it would be worth $11,000 per acre. At that rate the BLM parcel should be worth $20 million. Even with these comps, you could make the case that $20 million is still too low of a valuation for the BLM parcel.

Here is how this property is described in the real estate listing:

This 520 acre property offers everything Wyoming has to offer. Sitting at the base of the Wyoming Range and North Piney Creek running thru it. Originally homesteaded in 1904, the land has traditionally been used for grass, hay and livestock production. Water rights date back to 1905 for 365 acres. There is a estimated mile of North Piney Creek running thru the property with a fish count of 50-299 lbs. per mile according to the Wyoming Game and Fish website. Land is very desirable for fish pond construction or irrigation pivot’s. Seller estimates the aum’s for cattle at 350 for four months. Wildlife is abundant on the property during certain times of the year which include deer, moose, antelope, eagles, hawks and elk in the winter months. Mountain and valley views are breath taking. Property is accessible by a County maintained road. There are no conservation easements on the property. Fish found in North Piney Creek are Colorado Cutthroat, Brook Trout and Snake River Cutthroat. This is truly a one-of-a-kind property.

Parcel 2 Valuation Comparison

Area 2 Parcel Comps

The property currently listed on Zillow for $350k in the screenshot above is in direct proximity to the scattered parcels of private property that would be traded to the BLM in this exchange. The listed parcel is 71 acres, so here the public is getting land valued at $5,000 an acre according to nearby comps.

Parcel 3 Valuation Comparison:

Area 3 Parcel Comps

The Zillow listing in the screenshot above for $8.5 million is located in a similar area to the private land that will be traded to the BLM along the Big Sandy River. According to the listing this ranch contains numerous structures and public land grazing leases. As such, even though the property is roughly 42,000 acres, only 3,610 of these acres are deeded land. If we assume the structures are worth roughly $1 million dollars, then the 3,610 deeded acres would be valued at $2,077 per acre. Even though this is a rough estimate, it comes nowhere close to the value of the mountain property that is valued at over $11,000 per acre.

Based on these valuations, the public should be getting comparably valued land… or we should be getting up to 5 acres of private land in exchange for the high value land we’re losing. Instead, BLM is proposing to pay a private entity $160,000 to take this pristine mountain acreage out of the public’s hands. These valuations must be made publicly available, and the agency must be transparent about how this deal serves the public interest.

The public deserves to know the true value of the lands being traded. From all appearances, the parcel the BLM is proposing to relinquish holds far more recreational and ecological value than the scattered, often disconnected “orphan” parcels they would receive in return. A fair and transparent valuation process is not just best practice, it’s a requirement for maintaining public trust. Those valuations must be made publicly available and subject to scrutiny.

Vague Promises on Recreation Are Not Enough

If the BLM proceeds with this land exchange, the EA must include hard, enforceable language that outlines exactly how the agency will protect and enhance recreational access on any newly acquired parcels. Anything less leaves too much room for broken promises and diminished public access. Right now, the EA lacks the clarity and commitment necessary to ensure recreation remains a priority in this exchange. They have basically committed to recognize access routes to the new parcels during the next travel management planning process. Remember, they first proposed this ten years ago and the travel planning process hasn’t occurred during those ten years. How the BLM plans to establish public access to acquired parcels should be documented in this exchange proposal – not a separate proposal at a later date since it is a state purpose of this action to expand public access to the acquired parcels.

We are especially concerned that anti-access organizations like Western Watersheds Project are on record supporting this project, even though this organization is running current campaigns to aggressively oppose any sell-off of public lands.

Compliance with the EXPLORE Act Is Not Optional

Under the newly enacted EXPLORE Act, the BLM is required to improve and expand motorized access to public lands. This mandate is entirely absent from the current EA. BLM must revise the analysis to clearly demonstrate how this exchange supports the goals of the EXPLORE Act—not sidesteps them.

BRC’s Bottom Line

BlueRibbon Coalition strongly urges the BLM to pause the Miller Mountain Land Exchange until the agency:

  • Analyzes options for providing public access to the current river parce in Area 1, including the construction of an access road in partnership with the State of Wyoming;
  • Publicly discloses land valuations to ensure the public is not getting shortchanged;
  • Includes firm language in the EA committing to enhancing recreational access on any acquired lands;
  • And demonstrates clear compliance with the EXPLORE Act’s requirements to increase opportunities for motorized access.

Add Your Voice to Defend Our Public Lands