THE WILDERNESS SOCIETY
COALITION TO PROTECT AMERICA’S NATIONAL PARKS * FRIENDS OF THE EARTH UNITED STATES * NATURAL RESOURCES DEFENSE COUNCIL * NEVADA WILDLIFE FEDERATION *
ROCKY MOUNTAIN WILD
September 7, 2023
Jon Raby
State Director
Bureau of Land Management, Nevada
Contacts:
Melissa Jennings
Bureau of Land Management
Scott Distel
Bureau of Land Management
Eugene Gilseth
Bureau of Land Management
Jeffrey Kirkwood
Bureau of Land Management
Robert Smith
Bureau of Land Management
Re: Comments on the BLM Nevada 2023 Fourth Quarter Oil and Gas Competitive Lease Sale Draft Environmental Assessment and Draft Finding of No Significant Impact (DOI-BLM-NV- B000-2023-0002-EA)
Dear State Director Sheehan:
On behalf of our organizations, members, and supporters, we thank you for accepting and fully considering these comments on the Draft Environmental Assessment (Draft EA) and Draft Finding of No Significant Impact (Draft FONSI) for the Bureau of Land Management Nevada 2023 Fourth 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.
For the reasons explained in this comment and in our scoping comments, we respectfully request and strongly urge deferring all five parcels for this lease sale. Instruction Memorandum (IM) 2023-007, the Federal Land Policy and Management Act (FLPMA), and analysis under the National Environmental Policy Act (NEPA) counsel these deferrals.
As an initial matter, we applaud the release of the proposed Fluid Mineral Leases and Leasing Process Rule (Proposed Rule)1FLUID MINERAL LEASES AND LEASING PROCESS RULE, 88 Fed. Reg. (proposed Jul. 24, 2023) (to be codified at 43 C.F.R. Parts 3000, 3100, 3110, 3120, 3130, 3140, 3150, 3160, 3170, and 3180) [hereinafter Proposed Rule]., which would codify many of the Inflation Reduction Act’s (IRA’s) reforms and address the critical issue of bonding. Because important measures such as adequately updated bonding requirements are not yet in place, we encourage the Bureau of Land Management (BLM) not to proceed with leasing before finalizing the Proposed Rule.
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