COALITION TO PROTECT AMERICA’S NATIONAL PARKS * CONSERVATION COLORADO * EARTHJUSTICE * ENVIRONMENTAL DEFENSE FUND * FRIENDS OF THE EARTH * LEAGUE OF CONSERVATION VOTERS * MONTANA WILDLIFE FEDERATION * NATIONAL PARKS CONSERVATION ASSOCIATION * NATURAL RESOURCES DEFENSE COUNCIL * PUBLIC CITIZEN * ROCKY MOUNTAIN WILD * SIERRA CLUB * WILD MONTANA * THE WILDERNESS SOCIETY * WILDERNESS WORKSHOP
March 23, 2022
U.S. Bureau of Land Management
1849 C Street NW
Washington, DC 20240
RE: Request for Supplemental National Environmental Policy Act Analyses for the Proposed Quarter One 2022 Lease Sales.
Dear Director Stone-Manning:
Our organizations recommend that BLM reconsider its National Environmental Policy Act (NEPA) reviews of the onshore quarter one 2022 lease sales in light of two recent developments.
First, since BLM posted the draft Environmental Assessments for the lease sales, the Intergovernmental Panel on Climate Change (IPCC) released a devastating report on the climate crisis, documenting widespread, pervasive impacts to ecosystems and people. Second, the Interagency Working Group (IWG) on the Social Cost of Greenhouse Gases (SC-GHG) is scheduled to release its final update to the SC-GHG estimates in the near future.
BLM should strongly consider delaying further action on the lease sales until the IWG is able to release final updated SC-GHG estimates and BLM can incorporate the estimates into the NEPA documents. After that time, we respectfully request that the agency evaluate both the new IPCC report and the updated estimates and issue draft supplemental NEPA analyses on climate impacts for each lease sale, with a subsequent 60-day comment period, to allow adequate opportunity for community groups to participate, or, at the least, a 30-day comment period. We believe robust analyses will demonstrate that moving forward with onshore sales is incompatible with BLM’s legal obligations under the Federal Land Policy and Management Act (FLPMA) and NEPA, climate science, and the Administration’s climate priorities and commitments.
Read the full document (PDF) here.