November 10, 2021 Tracy Stone-Manning Director, Bureau of Land Management 1849 C St., NW, Rm. 5665 Washington, D.C. 20240 Re: Request for Extension of Comment Periods on BLM Oil & Gas Leasing Proposals Dear Director Stone-Manning: Congratulations on your recent confirmation as Director of the Bureau of Land Management (BLM). We look forward to engaging with you and your staff, as you work to address the many challenges facing our public lands and waters. One of those challenges involves BLM’s oil and gas leasing program. Because of recent court decisions, BLM is now evaluating at least eight different leasing proposals for over 700,000 acres of public land in ten states1BLM is currently evaluating proposed oil and gas lease sales in Alabama, Colorado, Montana, Nevada, New Mexico, North Dakota, Oklahoma, Utah, and Wyoming and suspended leases in Arizona.. BLM recently released draft NEPA documents for these proposals, and has provided the public with comment periods of just 30 days. Additionally, each comment period expires immediately after the upcoming holiday2All of the comment periods end between Nov. 27 and Dec. 1.. As a consequence, the public will not be able to participate in the decision-making process for these proposals “to the fullest extent possible,” as required by NEPA and FLPMA3W. Watersheds Project v. Zinke, 441 F. Supp. 3d 1042, 1070 (D. Idaho 2020).. Accordingly, we respectfully request that BLM extend the comment periods for all eight of these leasing proposals by at least 60 days. Like many others, we had hoped that if leasing were ever to resume on our public lands, it would be after the Department of the Interior (DOI) had enacted far-reaching reforms that address the long-standing impacts of the oil and gas program on our climate and public lands, waters, and wildlife. However, to date, DOI has yet to advance any meaningful reforms, and has still not issued a much-anticipated report on the federal oil and gas programs. Thus, the need to maximize public involvement on these proposals is heightened by the lack of progress on oil and gas reforms. We are also concerned by an apparent disconnect between these leasing proposals and recent comments from DOI leadership4Michael Doyle & Jennifer Yachnin, Haaland makes COP 26 pitch, E&E News, Nov. 4, 2021.. Last week, DOI publicly stated that the department is “doing whatever [it] can” to address the climate impacts of the oil and gas program. A senior official also publicly acknowledged that DOI has seen “limited public input opportunities” throughout the oil and gas program. To act on these statements, DOI needs to address the climate impacts of these leasing proposals and afford the public ample opportunity to provide meaningful comment. Unfortunately, the roughly concurrent 30-day comment periods for the eight leasing proposals, all of which expire immediately after a federal holiday, do not allow for such meaningful comment. For these reasons, we do hope you will seriously consider granting our request. Sincerely,
Archaeology Southwest
Center for Civic Policy
Citizens Caring for the Future
Coalition to Protect America’s National Parks
Conservation Colorado
Diné Citizens Against Ruining our Environment (CARE)
Environment America
Friends of the Missouri Breaks Monument
GreenLatinos
Hispanic Access Foundation
Hispanics Enjoying Camping, Hunting, and the Outdoors (HECHO)
League of Conservation Voters
League of Oil and Gas Impacted Coloradans
Montana Conservation Voters Education Fund
Montana Wildlife Federation
National Audubon Society
National Parks Conservation Association
National Wildlife Federation
Natural Resources Defense Council
Nevada Wildlife Federation
New Mexico & El Paso Region Interfaith Power & Light
New Mexico Voices for Children
New Mexico Wild
New Mexico Wildlife Federation ProgressNow New Mexico
Public Land Solutions
Rocky Mountain Farmers Union
Rocky Mountain Wild
San Juan Citizens Alliance
Sierra Club
Social Eco Education (SEE-LA)
The Wilderness Society
Upper Missouri Waterkeeper
Western Colorado Alliance
Western Organization of Resource Councils Wild Montana
Wilderness Workshop
Wyoming Outdoor Council
  • 1
    BLM is currently evaluating proposed oil and gas lease sales in Alabama, Colorado, Montana, Nevada, New Mexico, North Dakota, Oklahoma, Utah, and Wyoming and suspended leases in Arizona.
  • 2
    All of the comment periods end between Nov. 27 and Dec. 1.
  • 3
    W. Watersheds Project v. Zinke, 441 F. Supp. 3d 1042, 1070 (D. Idaho 2020).
  • 4
    Michael Doyle & Jennifer Yachnin, Haaland makes COP 26 pitch, E&E News, Nov. 4, 2021.