The Coalition requested that a 15-day public comment period on an oil and gas lease sale near Great Sand Dunes National Park and Preserve be extended to a more reasonable 30 days. BLM denied the request, stating it was following “current administration guidance” to streamline the NEPA process.
March 24, 2018
Mr. Keith Berger
Manager, BLM Royal Gorge Field Office
3028 East Main Street
Cañon City, CO 81212
Subject: Request for Extension of Comment Period on DOI-BLM-CO-F020-2018-0003-EA
Proposed September 2018 Oil & Gas Lease Sale, Royal Gorge Field Office
Dear Mr. Berger:
I am writing to you on behalf of over 1,500 members of the Coalition to Protect America’s National Parks (Coalition). Our membership is composed entirely of retired, former, or current salaried employees of the National Park Service (NPS). As a group, we collectively represent more than 35,000 years of national park management experience.
We are quite concerned about the proposed September 2018 Competitive Oil and Gas Lease Sale by the Bureau of Land Management (BLM), Royal Gorge Field Office and its potential impacts on Great Sand Dunes National Park & Preserve. We plan to submit comments on the environmental assessment (EA) that was released on March 22, 2018. However, after conducting a preliminary review of the EA, it is quite apparent that the 15-day public comment is unreasonably brief and should be extended.
DISCUSSION
Given the nature and complexity of the proposal, which encompasses potential leasing on 28 parcels totaling approximately 22,175 acres of federal oil and gas leases in eastern Colorado, the 15-day public comment period for the EA is unreasonably brief. The 15 days is inconsistent with the 30-day comment period previously allowed for public scoping on the same project. Furthermore, it is also inconsistent with the past precedent of 30-day public comment periods for numerous previous lease proposal EAs issued by BLM’s Colorado Office[1]. These include:
* December 2017 lease sale EA open for public comment May 10 – June 9, 2017
* September 2017 lease sale EA open for public comment February 10 – March 13, 2017
* June 2017 lease sale EA open for 30-day public comment November 9 – December 12, 2016
* March 2017 lease sale EA open for 30-day public comment August 9 – September 8, 2016
* December 2016 lease sale EA open for 30-day public comment May 12 – June 13, 2016
* May 2016 lease sale EA open for 30-day public comment November 12 – December 14, 2015
We could go on listing examples, but you get the point. An abbreviated 15-day public comment period on a complex, potentially controversial oil and gas lease proposal near one of America’s national parks is not reasonable. Nor has BLM provided any explanation or justification in the EA (see Section 1.4.3) for such a short comment period. Allowing the public an unreasonably short period to review and comment on the EA violates the spirit and intent of public participation in NEPA. And, frankly, BLM’s decision to limit the comment period to 15 days appears designed to inhibit meaningful public review and comment on the proposal.
We hereby request an immediate 15-day extension of the public comment deadline to allow a total of 30 days for public comment. In fairness to all parties interested in commenting on the EA, such an extension, if granted, should be announced as soon as possible.
Thank you in advance for your consideration of this request.
Sincerely,
Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks
[1] https://www.blm.gov/programs/energy-and-minerals/oil-and-gas/leasing/regional-lease-sales/colorado
In Reply Refer To:
1680 (COF020) maa
Mr. Phillip A. Francis Jr.
Coalition to Protect America’s National Parks
201 I Street, NE #805
Washington, DC 20002
Subject: Lease Sale Comments, DOI-BLM-CO-F020-2018-0003-EA
Dear Mr. Francis:
Thank you for your letter dated March 24, 2018, in which you expressed concerns about the length of the comment period, and requested a general extension of time for all public comments regarding this lease sale.
After reviewing the information and the request, Colorado BLM will continue to follow current administration guidance, and will not extend the current 15-day comment period. You indicated that in the past, BLM has allowed different lengths of time for comments. That approach has currently changed as we work to streamline our NEPA process.
The decision to allow a 15-day comment period complies with the legal requirements outlined in the National Environmental Policy Act, and CEQ guidance, as codified at 40 CFR 1500 – 1508.
Sincerely,
Keith E. Berger
Field Manager
Royal Gorge Field Office
March 30, 2018
Mr. Keith Berger
Manager, BLM Royal Gorge Field Office
3028 East Main Street
Cañon City, CO 81212
Subject: Lease Sale Comments, DOI-BLM-CO-F020-2018-0003-EA
BLM Reply Reference: 1680 (COF020) maa
Dear Mr. Berger:
Thank you for your letter received March 29, 2018 regarding our request for an extension of the 15-day public comment period on DOI-BLM-CO-F020-2018-0003-EA.
In your letter denying our request, you state, “Colorado BLM will continue to follow current administration guidance, and will not extend the current 15-day comment period.”
We hereby request an electronic copy of the “current administration guidance” regarding the length of the comment period that is referred to in your denial.
Thank you in advance for your consideration.
Sincerely,
Philip A. Francis, Jr., Chair
Coalition to Protect America’s National Parks