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 * WYOMING WILDERNESS ASSOCIATION
April 17, 2023
SUBMITTED VIA E-PLANNING
Andrew Archuleta
State Director
Wyoming Bureau of Land Management
5353 Yellowstone Road
Cheyenne, WY 82009
Re: Scoping Comments on Parcels for the Wyoming Bureau of Land Management 2023 Fourth Quarter Competitive Oil & Gas Lease Sale (DOI-BLM-WY-0000-2023- 0004-EA).
Dear State Director Archuleta:
Thank you for the opportunity to submit these scoping comments on parcels under consideration for the Bureau of Land Management’s (BLM’s) 2023 Fourth Quarter Oil & Gas Lease Sale. Our organizations and members are deeply invested in sound stewardship of our public lands and committed to ensuring they equitably benefit all people, address environmental justice, protect biodiversity, and serve as a solution to—not a cause of—climate disruption.
We appreciate that the Department of the Interior (DOI or Interior Department or Interior) has acknowledged the federal oil and gas leasing program’s significant “deficiencies”1U.S. DEP’T OF THE INTERIOR, REPORT ON THE FEDERAL OIL AND GAS LEASING PROGRAM 3 (Nov. 2021) [hereinafter DOI REPORT]. and is taking strides to address them. In its Report on the Federal Oil and Gas Leasing Program, DOI recognized that, among other issues, the oil and gas program “inadequately accounts for environmental harms to lands, waters, and other resources; fosters speculation by oil and gas companies”; “extends leasing into low potential lands that may have competing higher values”; “leaves communities out of important conversations about how they want their public lands and waters managed”; and “fails to provide a fair return to taxpayers, even before factoring in the resulting climate-related costs.”2Id. The report highlighted the “urgent” need for tackling long “overdue reform” of the program.
We were grateful to see the BLM release several Instruction Memoranda (IMs) beginning to implement program reforms and provisions in the Inflation Reduction Act (IRA).3 The IRA, however, addressed only some of the needed reforms, and we are concerned that DOI is proceeding with leasing before initiating a rulemaking to revise the BLM’s fossil fuel leasing and permitting regulations.
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