THE WILDERNESS SOCIETY
AUDUBON ROCKIES * THE COALITION TO PROTECT AMERICA’S NATIONAL PARKS * NATIONAL AUDUBON SOCIETY * NATIONAL PARKS CONSERVATION ASSOCIATION * NATURAL RESOURCES DEFENSE COUNCIL * POWDER RIVER BASIN RESOURCE COUNCIL * WYOMING OUTDOOR COUNCIL * WYOMING WILDERNESS ASSOCIATION
July 12, 2023
Wyoming Bureau of Land Management
5353 Yellowstone Road
Cheyenne, WY 82009
Re: Scoping Comments on Parcels for the Wyoming Bureau of Land Management 2024 First Quarter Competitive Oil & Gas Lease Sale (DOI-BLM-WY-0000-2023- 0005-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) 2024 First 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).3See Inflation Reduction Act of 2022, H.R. 5376, 117th Cong. §§ 50262–50263 (2022). TWS et al. 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.
Our scoping comments thus recommend:
- Ensuring that any parcels included in the proposed BLM Wyoming Oil and Gas Competitive Lease Sale comport with the guidance provided in the IMs released on November 21, 2022.
- Immediately issuing additional guidance on other important reforms to steer all leasing decisions before a final rule is in place.
- Releasing a proposed rule to revise the BLM’s fossil fuel leasing and permitting regulations before holding the proposed sales to ensure the rulemaking moves forward expeditiously.
- Prioritizing conservation and climate by exercising the agency’s considerable discretion to defer parcels to protect public lands, waters, and wildlife, cultural resources and sacred sites, and community health and safety.
- Properly analyzing and mitigating the impacts of leasing.
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- 1U.S. DEP’T OF THE INTERIOR, REPORT ON THE FEDERAL OIL AND GAS LEASING PROGRAM 3 (Nov. 2021) [hereinafter DOI REPORT].
- 3See Inflation Reduction Act of 2022, H.R. 5376, 117th Cong. §§ 50262–50263 (2022). TWS et al.