THE WILDERNESS SOCIETY
COALITION TO PROTECT AMERICA’S NATIONAL PARKS * FRIENDS OF THE EARTH * NATURAL RESOURCES DEFENSE COUNCIL * NORTHERN PLAINS RESOURCE COUNCIL * ROCKY MOUNTAIN WILD * WILD MONTANA

June 26, 2023

Sonya Germann
State Director
Bureau of Land Management, Montana-Dakotas

Project Contacts:
Tessa Wallace
Bureau of Land Management

Re: Comments on the Bureau of Land Management Montana-Dakotas 2023 Third Quarter Oil and Gas Lease Sale Draft Environmental Assessment and Draft Finding of No Significant Impact (DOI-BLM-MT-0000-2023-0002-EA)

Dear State Director Germann:

On behalf of our organizations, members, and supporters, we thank you for accepting and fully considering these comments on the Draft Environmental Assessment (EA) for the Bureau of Land Management (BLM) Montana-Dakotas 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 are concerned about the BLM’s consideration to move forward with the Proposed Alternative B in the Draft EA for this lease sale. 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 (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.

Read the entire submission here.