February 27, 2023

The Honorable Deb Haaland
Secretary of the Interior
1849 C Street NW
Washington, D.C. 20240

RE: Recommendations for the Rulemaking to Revise Existing Regulations for the Federal Onshore Oil and Gas Leasing Program

Dear Secretary Haaland:

Thank you for your leadership in recently issuing guidance on the important federal onshore oil and gas program reform provisions that were included in the Inflation Reduction Act (IRA). While new regulations for the federal oil and gas program are not yet in place, the Bureau of Land Management’s (BLM’s) adherence to the Instruction Memoranda (IMs) issued on November 21, 2022, is critical for ensuring that leasing decisions on federal public lands and minerals are consistent with all applicable laws and do not perpetuate program deficiencies.

We write now to strongly urge the Department of Interior (DOI) to finalize new regulations for the federal onshore oil and gas program. Completing this rulemaking is of paramount importance, both to ensure durable, holistic reform and to avoid discrepancies between codified regulations and the law. Additionally, there are many other needed reforms that DOI has yet to address and should prioritize in its rulemaking, such as strengthening the onshore program’s bonding and reclamation framework, limiting participation by speculators and bad actors that result in wasteful leasing of public lands, and allowing for the BLM to more strategically identify lands that may be nominated for leasing.

We, the undersigned organizations, therefore provide the attached appendix to outline essential elements of an updated federal onshore leasing program rule. We call on DOI to act expeditiously to issue its proposed rule to reform the onshore oil and gas leasing and permitting regulations and implement the IRA’s onshore leasing-related provisions. The appendix is not an exhaustive list – rather, it includes immediate and tangible suggestions for the rulemaking at hand. We also urge you to utilize all available discretion to pursue additional changes that will move the BLM’s stewardship of our public lands and minerals closer in line with the public’s interest in protecting and preserving public lands, waters, and wildlife.

Thank you for considering these recommendations and others you may receive that build in further critical reforms designed to ensure DOI and its agencies can steward our shared public lands equitably and sustainably. We look forward to continued engagement on how DOI can better protect our public lands, waters, climate, and wildlife, and better serve our communities.

Archaeology Southwest
Coalition to Protect America’s National Parks
Colorado Fiscal Institute
Colorado Wildlife Federation, Inc.
Environmental Defense Fund
Hispanic Access Foundation
League of Conservation Voters
Montana Wildlife Federation
National Audubon Society
National Parks Conservation Association
National Wildlife Federation
Natural Resources Defense Council
Nevada Conservation League
Nevada Wildlife Federation
New Mexico Voices for Children
New Mexico Wild
New Mexico Wildlife Federation
Northern Plains Resource Council
Nuestra Tierra Conservation Project
Public Citizen
Rocky Mountain Farmers Union
Rocky Mountain Wild
The Wilderness Society
Trout Unlimited
Upper Missouri Waterkeeper
Western Colorado Alliance
Western Organization of Resource Councils
Wild Montana
Wilderness Workshop
Wyoming Outdoor Council

Tommy Beaudreau, Deputy Secretary, Department of the Interior
Laura Daniel-Davis, Principal Deputy Assistant Secretary – Land and Minerals Management,Department of the Interior
Steve Feldgus, Deputy Assistant Secretary – Land and Minerals Management, Department of the Interior
Tracy Stone-Manning, Director, Bureau of Land Management
Nada Culver, Deputy Director of Policy and Programs, Bureau of Land Management Nicholas Douglas, Assistant Director – Office of Energy, Minerals, and Realty Management, Bureau of Land Management

Click here to read the attached Appendix.