THE WILDERNESS SOCIETY
AUDUBON ROCKIES (WY, CO, UT) * COALITION TO PROTECT AMERICA’S NATIONAL PARKS * FRIENDS OF THE EARTH * NATIONAL AUDUBON SOCIETY * NATURAL RESOURCES DEFENSE COUNCIL * POWDER RIVER BASIN RESOURCE COUNCIL * ROCKY MOUNTAIN WILD * WYOMING OUTDOOR COUNCIL
April 10, 2023
SUBMITTED VIA E-PLANNING
Andrew Archuleta
State Director Wyoming Bureau of Land Management
5353 Yellowstone Road
Cheyenne, WY 8200
Project Contacts:
Allen Stegeman
astegeman@blm.gov
(307) 775-6259
Erik Norelius
enoreliu@blm.gov
(307) 775-6284
Re: Comments on the Wyoming Bureau of Land Management 2023 Third Quarter Oil and Gas Lease Sale Draft Environmental Assessment and Draft Finding of No Significant Impact (DOI-BLM-WY-0000-2023-0003-EA)
Dear State Director Archuleta:
On behalf of our organizations, members, and supporters, we thank you for accepting and fully considering these comments on the Draft Environmental Assessment (EA) and Draft Finding of No Significant Impact (FONSI) for the Wyoming Bureau of Land Management 2023 Third Quarter Oil and Gas Lease Sale. Our organizations and members are deeply invested in sound stewardship of our public lands and committed to ensuring that they equitably benefit all people, address environmental justice, protect biodiversity, and serve as a solution to – not a cause of – climate disruption.
We appreciate inclusion of Alternative 3 (Modified Proposed Action) in the Draft EA for this lease sale. However, for the reasons explained in this comment and in our scoping comments, we respectfully request and strongly urge deferring many of the remaining parcels. Instruction Memorandum (IM) 2023-007, the Federal Land Management Policy Act (FLPMA), and analysis under the National Environmental Policy Act (NEPA) counsel additional deferrals, as discussed in Section III.
As we did in our scoping comments, we continue to strongly urge the Department of the Interior Department (DOI or Interior Department or Interior) to begin both seriously addressing the structural deficiencies that it has identified in its Report on the Federal Oil and Gas Leasing Program and durably implementing the Inflation Reduction Act’s (IRA’s) requisite leasing program reforms through the fossil fuel rulemaking process.
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