Coalition Joins Comments on the Bureau of Land Management New Mexico 2024 Competitive Oil & Gas Lease Sale Draft Environmental Assessment and Draft Finding of No Significant Impact – The Coalition To Protect America's National Parks

THE WILDERNESS SOCIETY
COALITION TO PROTECT AMERICA’S NATIONAL PARKS * FRIENDS OF THE EARTH US * MONTANA WILDLIFE FEDERATION * NATIONAL PARKS CONSERVATION * ROCKY MOUNTAIN WILD

December 20, 2023

SUBMITTED VIA E-PLANNING

Melanie Barnes
New Mexico State Director
Bureau of Land Management
301 Dinosaur Trail
Santa Fe, NM 87508

Project Contacts:

Catherine Brewster
Bureau of Land Management
cb*******@bl*.gov
(505) 954-2170

David Alderman
da*******@bl*.gov
Bureau of Land Management
(208) 478-6369

Julieann Serrano
js******@bl*.gov
Bureau of Land Management
(505) 954-2149

Re: Comments on the Bureau of Land Management New Mexico 2024 Second Quarter Competitive Oil & Gas Lease Sale Draft Environmental Assessment and Draft Finding of No Significant Impact (DOI-BLM-NM-P000-2023-0002-EA).

Dear State Director Barnes:

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 New Mexico 2024 Second Quarter Oil and Gas Lease Sale. Our organizations and members are deeply invested in sound stewardship of public lands and committed to ensuring that public land management prioritizes the health and resilience of ecosystems, equitably benefits the public, addresses environmental justice, protects biodiversity, and mitigates the impacts of climate change.

We are grateful for both the proposed Fluid Mineral Leases and Leasing Process Rule (Leasing Rule) and the earlier release of several Instruction Memoranda (IMs) beginning to implement program reforms and provisions in the Inflation Reduction Act (IRA).¹ The IRA addressed only some of the needed reforms. The Leasing Rule would codify the IRA’s reforms, address other needed reforms, and update severely outdated bonding requirements.

We urge the BLM to finalize the Leasing Rule expeditiously to ensure deficiencies in the oil and gas leasing program are addressed. Because important measures such as adequately updated bonding requirements are not yet in place, we encourage the agency to consider not proceeding with additional leasing before finalizing the Leasing Rule.

I. The BLM should consistently track EOIs and acreage pursuant to IM 2023-006.

IM 2023-006, released on November 21, 2022, explains that the BLM “will create and periodically update a report to track the acreage of submitted EOIs.” Further, the IM requires the BLM to “place the [EOI acreage] report on the NFLSS Dashboard from the National-Apps Reporting System.” Id. Therefore, the BLM should consistently track EOIs and acreage pursuant to IM 2023-006 and make that information available to the public.

However, while DOI has stated that it is proceeding with new lease sales “to comply with congressional direction on oil and gas leasing through the [IRA],” it has not established how the proposed oil and gas lease sales align with plans to issue rights-of-way (ROWs) for wind and solar development. IM 2023-006 details how the BLM will determine the acreage it must offer for oil and gas leasing in order to issue wind or solar ROWs pursuant to the IRA and defines the period for calculating the acreage requirement as the “year before the wind or solar energy right-of-way is issued.” However, if DOI is going to conduct lease sales to comply with the IRA’s tethering provisions, it should do so as part of a clearly articulated and concerted national strategy rather than holding lease sales piecemeal, state office by state office. Any leases offered as part of this lease sale or related lease sales in the one-year period should indeed be part of a plan to issue wind or solar permits. We urge the BLM to offer for lease the minimum amount of acreage necessary under the IRA to enable it to issue renewables ROWs.

The BLM has significant discretion to determine which EOIs have been properly submitted and, ultimately, to determine whether and how much acreage to lease, if any. We urge the BLM to offer no more acreage than necessary to comply with the IRA’s requirements for allowing issuance of ROWs for responsible and appropriately sited wind and solar development on public lands.

II. The BLM should defer all parcels that do not comport with guidance provided in IM 2023-007.

As an initial matter, parcel NM-2024-06-6828 was removed without the Draft EA or Draft FONSI providing a direct explanation for the removal, and instead merely referencing in a footnote that a parcel was removed due to being a duplicate.² We urge the BLM to clearly state in future draft EAs which parcels are removed and why the parcels are being removed. Transparency allows the public to fully understand decisions made by the BLM and encourages public participation.

We appreciate the BLM screening the parcels in the Draft EA’s Appendix C in accordance with IM 2023-007’s preference criteria. However, proper application of IM 2023-007 calls for deferring the eighteen parcels for which the Pecos District Office assigned a low preference value.³ We strongly urge the BLM to follow its own guidance in IM 2023-007 and defer all the lease parcels in this lease sale for the reasons discussed below.

IM 2023-007 directs deferral of parcels that receive a “low” value leasing preference. Specifically, IM 2023-007 instructs, “The BLM will generally conduct environmental analysis for lease parcels with a high preference value first for potential inclusion in a lease sale and will defer lease parcels with a low preference value.” (emphasis added). The IM 2023-007 further instructs that “[i]f there are no high preference parcels available for the sale,” the office is guided to select “one or more low preference parcels that present the least conflicts based on the criteria.” Indeed, this Pecos District Lease Sale lacks any high preference value parcels in New Mexico. The BLM assigned a low leasing preference for all eighteen parcels based on habitat conflicts, thirteen parcels based on recreation and other resource conflicts, and six parcels based on cultural resource conflicts – meaning all eighteen parcels received a low value leasing preference.⁴ Therefore, the BLM should defer all parcels—or, at minimum, all but one parcel with the least conflicts—in accordance with IM 2023-007.

NEPA generally requires the BLM to conduct an alternatives analysis for “any proposal which involves unresolved conflicts concerning alternative uses of available resources.” 42 U.S.C. § 4332(2)(E). The regulations further obligate BLM to “rigorously explore and objectively evaluate all reasonable alternatives” including those “reasonable alternatives not within the jurisdiction of the lead agency,” so as to “provid[e] a clear basis for choice among options.” 40 C.F.R. § 1502.14. The range of alternatives is the heart of a NEPA document because “[w]ithout substantive, comparative environmental impact information regarding other possible courses of action, the ability of [a NEPA analysis] to inform agency deliberation and facilitate public involvement would be greatly degraded.” New Mexico ex rel. Richardson v. BLM, 565 F.3d 683, 708 (10th Cir. 2009). That analysis must cover a reasonable range of alternatives so that an agency can make an informed choice from the spectrum of reasonable options. A NEPA analysis offering a choice between leasing all proposed parcels, and leasing nothing at all, does not present a reasonable range of alternatives. See, e.g., TWS v. Wisely, 524 F. Supp. 2d 1285, 1312 (D. Colo. 2007) (BLM violated NEPA by failing to consider “middle- ground compromise between the absolutism of the outright leasing and no action alternatives”); Muckleshoot Indian Tribe v. U.S. Forest Serv., 177 F.3d 800, 813 (9th Cir. 1999) (holding that the NEPA analysis failed to consider reasonable range of alternatives where it “considered only a no action alternative along with two virtually identical alternatives”).

To avoid this all or nothing approach, we urge the BLM to consider reasonable alternatives that defer parcels that received a low preference designation. The BLM has previously adhered to IM 2023-007 by deferring parcels found to have a low preference for leasing value. For example, in the Wyoming Q4 2023 Competitive Lease Sale the BLM reviewed three alternatives: a no action alternative; a proposed alternative that offered all 47 parcels for sale; and a modified proposed alternative that deferred 8 parcels in accordance with the criteria of IM 2023-007.⁵

The BLM subsequently chose the modified proposed alternative deferring the 8 parcels. ⁶ We therefore urge the BLM to consider a reasonable alternative that would defer most or all of the parcels that have received a low preference value.

Further, while IM 2023-007 preferences leasing parcels with “[p]roximity to existing oil and gas development,” many of the parcels being offered risk further concentrating and expanding development, exacerbating ongoing and historical degradation to the affected area and the public health of nearby communities. We urge the BLM to prioritize community health and environmental justice, values the Administration has committed to upholding. The presence and availability of a single parcel with high value leasing preference designation urges deferral of all parcels with a low (or moderate) value leasing preference designation.

Furthermore, lease parcels NM-2024-06-6829 and NM-2024-06-6828 are within the medium to “high cave, karst potential” areas, and parcels NM-2024-06-0461, NM-2024-06-6819, NM-2024-06-6820, NM-2024-06-6831, NM-2024-06-6832, NM-2024-06-6835, and NM-2024-06-

6818 are located within the “critical cave, karst potential” area and risk the resources of Carlsbad Caverns National Park. Despite acknowledging the threats of leasing in these areas, the BLM does not recommend deferring any of these parcels.⁷

The landscape around Carlsbad Caverns National Park is characterized by unique and fragile cave and karst systems, extending far beyond the park’s boundaries. As part of the booming Permian Basin, the area contains substantial oil and gas deposits and extreme development pressure. Rampant oil and gas development surrounding the parks can directly impact cave systems connected to caves within the Carlsbad Caverns and also visitors’ enjoyment of the scenic qualities and night skies of these remote lands. Drilling and fracking can also pose risks to groundwater supplies that local communities rely on. This is an opportunity to protect cave structures and delicate formations that have taken millions of years to develop from the impacts of rampant oil and gas development and the contamination and potential seismic activity from fracking by deferring nominated oil and gas leases from areas characterized by cave and karst resources. We urge the BLM to defer all parcels that are within areas with known cave and karst systems.

Due to the reasons stated, we urge the BLM to defer all eighteen parcels in accordance with IM 2023-007.

III. The BLM should provide robust public participation and Tribal consultation as part of the lease sale process.

Public participation and Tribal consultation are critical to an informed NEPA process. DOI has rightfully committed to providing robust and “enhance[d] opportunities for Tribal and environmental justice community engagement in the NEPA and decision-making process.” Secretarial Order 3399, at *3 (Apr. 16, 2021). To honor its commitment to enhanced public participation and Tribal consultation, the BLM should consider providing, in addition to this scoping comment period, one or more listening sessions before issuing any draft NEPA document. Then, the BLM should give the public at least 60 days to review and comment on any draft NEPA document. Doing so would help ensure that the public has an adequate “opportunity to comment upon . . . and participate in, the preparation and execution of” this lease sale, as required by FLPMA and NEPA. 43 U.S.C. § 1738(e); 42 U.S.C. § 4332(C).

The Department must also fully consult and engage Tribal nations, both those recognized by the United States as sovereign nations as well as those not recognized. The United States must recognize the right of Indigenous Peoples to give or withhold “free, prior and informed consent” to projects and policies affecting their lands and people, as stated in the United Nations Declaration on the Rights of Indigenous Peoples, which the United States has supported for more than a decade. The incorporation of these bottom-up principles in this federal process is an important and needed step as we address the history of public lands in the United States.

IV. The BLM must properly analyze and address the reasonably foreseeable greenhouse gas emissions and related climate impacts stemming from this lease sale.

The Draft EA’s discussion of greenhouse gas (GHG) emissions and climate impacts resulting from this lease sale requires additional analysis to take the proper “hard look at environmental consequences” that NEPA demands. Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 350 (1989). On January 9, 2023, the Council on Environmental Quality (CEQ) released updated guidance on how agencies should consider and analyze GHG emissions and climate change in NEPA reviews.⁸ The CEQ climate guidance is effective immediately and directs agencies to “use this guidance to inform the NEPA review for all new proposed actions.”⁹

The guidance reiterates the BLM’s obligation under NEPA to properly consider GHG emissions and climate change. Application of this climate guidance to this lease sale will inform the BLM’s analysis of the impacts related to climate disruption and consideration of alternatives.

Please see Appendix A submitted with this comment letter for a discussion of our recommendations regarding GHG emissions and climate analysis.

V. The BLM must take a hard look at impacts to groundwater from well construction practices and hydraulic fracturing.

The Draft EA violates NEPA because it contains a limited analysis of the reasonably foreseeable impacts to groundwater from drilling on these particular lease sale parcels. The Draft EA contains generic boilerplate about potential water impacts from oil and gas development.¹⁰ These statements could be made about any oil and gas lease anywhere in New Mexico or nearby states – they tell the agency and the public nothing at all about how the development of these leases will impact the region.

NEPA requires the BLM to assess all the potential environmental impacts from oil and gas leases before it offers those leases to operators. That responsibility includes taking a “hard look” at how ensuing development could impact groundwater. WildEarth Guardians v. U.S. Bureau of Land Mgmt., 457 F. Supp. 3d 880, 886–89 (D. Mont. May 1, 2020).

Groundwater is a critical resource that supplies many communities, particularly rural ones, with drinking water. Protecting these resources is imperative to protect human health and the environment, especially because groundwater will become more important as increased aridity and higher temperatures alter water use. The U.S. Environmental Protection Agency (EPA) has noted that existing drinking water resources “may not be sufficient in some locations to meet future demand” and that future sources of fresh drinking “will likely be affected by changes in climate and water use.”¹¹ As a result, the BLM must protect both aquifers currently used for drinking water, and deeper and higher-salinity aquifers that may be needed in coming decades.

Oil and gas drilling involves boring wells to depths thousands of feet below the surface, often through or just above groundwater aquifers. Without proper well construction and vertical separation between aquifers and fractured formations, oil and gas development can contaminate underground sources of water.¹² However, federal rules and regulations do not provide specific direction for the BLM and operators to protect all usable water. Even rules that purport to do so, like Onshore Order No. 2’s requirement to “protect and/or isolate all usable water zones,” are inconsistently applied and often disregarded in practice.¹³

Moreover, industry has admitted that it often does not protect usable water in practice. Western Energy Alliance and the Independent Petroleum Association of America have told the BLM that the “existing practice for locating and protecting usable water” does not measure the numerical quality of water underlying drilling locations, and therefore does not consider whether potentially usable water would be protected during drilling.¹⁴ For example, a report studying a sample of existing oil and gas well records in Montana confirms industry admissions that well casing and cementing practices do not always protect underground sources of drinking water.¹⁵

Similarly, a study of hydraulic fracturing in Pavillion, Wyoming, confirmed that oil and gas drilling had contaminated underground sources of drinking water in that area due to lack of vertical separation between the aquifer and target formation.¹⁶

In light of these risks to a critical resource, the BLM must evaluate potential groundwater impairment. As a threshold matter, the BLM must provide a detailed account of all regional groundwater resources that could be impacted, including usable aquifers that may not currently be used as a drinking water supply. The accounting must include, at minimum, all aquifers with up to 10,000 parts per million total dissolved solids, and it cannot substitute existing drinking water wells or any other incomplete proxy for a full description of all usable or potentially usable groundwater in the region. Second, the BLM must use that accounting to assess how new oil and gas wells might impact these resources. That evaluation must assess the sufficiency of protective measures that will be employed, including wellbore casing and cementing and vertical separation between aquifers and the oil and gas formations likely to be hydraulically fractured. In assessing these protections, the BLM cannot presume that state and federal regulations will protect groundwater, because of the shortcomings and industry noncompliance described above. The BLM may not defer this analysis of groundwater impacts to the APD stage. WildEarth Guardians, 457 F. Supp. 3d at 888. Failure to conduct this analysis would violate NEPA. Id.

VI. We recommend that the BLM conduct additional analysis of the impacts of this lease sale on public health and environmental justice.

We appreciate that the BLM has incorporated some of our provided resources to acknowledge a few of the adverse impacts to public health. However, we urge the agency to address and analyze even more thoroughly the impacts of this lease sale on public health based on our recommendations detailed in our scoping comments.¹⁷

VII. The Draft EA does not properly analyze methane emissions that would result from this lease sale.

Methane is a potent climate pollutant that has contributed about half a degree Celsius to observed global warming.¹⁸ There is now more methane in the atmosphere than at any time in the last 800,000 years, with concentrations increasing at an alarming rate since 2007, largely because of fossil fuel production.¹⁹ Recent findings have amplified the urgent need to curtail oil and gas emissions, demonstrating that methane release from such development has been dramatically underestimated.²⁰ Analysis of pre-industrial ice cores “indicate that anthropogenic fossil [methane] emissions are underestimated by about 38 to 58 teragrams CH4 per year, or about 25 to 40 percent of recent estimates.” This “highlights the human impact on the atmosphere and climate, [and] provides a firm target for inventories of the global [methane] budget.”²¹ The BLM must, in its baseline, properly account for current methane levels and the related climate and resource impacts associated with this and the related lease sales.

The Draft EA fails to take the requisite hard look at the impacts of methane emissions that will result from development of and production on these leases, including the economic, public health, and public welfare impacts of venting and flaring.²² Venting and flaring of gas account for tremendous economic waste and adverse health impacts. In 2019 alone, venting or flaring accounted for roughly 150 billion cubic feet of methane, resulting in the loss of over $50 million in federal royalty revenue – enough to meet the needs of over two million households, nearly as many households as the states of New Mexico, North Dakota, Utah, and Wyoming combined. This waste also means lost royalty revenues for taxpayers and Tribes. A recent analysis conducted by Synapse Energy Economics determined the value of lost gas in the form of: lost royalties; (2) lost state revenue from taxes; and (3) lost revenue from wasted natural gas that could be used for other purposes. The study found that $63.3 million in royalties, $18.8 million in state revenue from taxes (from the top six states), and $509 million in gas value was lost due to venting, flaring, and leaks on federal and Tribal lands.²³ The report found that, in 2019, leaks accounted for 46% and flaring for 54% of lost gas.²⁴

Venting and flaring on Tribal and federal public lands has significant health impacts on frontline and fence line communities.²⁵ Proximity to oil and gas infrastructure creates disproportionate adverse health risks and impacts on Indigenous communities in particular.²⁶ According to an Environmental Defense Fund (EDF) analysis, roughly 1,100 adults with asthma, 800 adults with chronic obstructive pulmonary disease, 700 adults with coronary heart disease, and 400 adults who have experienced a stroke live within a half mile of a flaring well.²⁷ Another study links flaring to shorter gestation and reduced fetal growth.²⁸ Reducing waste from flaring on federal and Tribal lands would lessen these harms and would be consistent with the Administration’s environmental justice commitments. Therefore, the BLM should not issue additional oil and gas leases until the agency addresses waste on Tribal and federal public lands.

Conclusion

Thank you for the opportunity to provide these comments on the Draft EA and Draft FONSI. We look forward to continuing to engage in this decision-making process.

Respectfully,

James Mowdy on behalf of the undersigned parties
Associate Attorney
The Wilderness Society
503 West Mendenhall St.
Bozeman, MT 59715
Ja*********@tw*.org

Mike Murray
Chair
The Coalition to Protect America’s National Parks

Nicole Ghio
Senior Fossil Fuels Program Manager
Friends of the Earth United States

Garrett Titus
Conservation Policy Specialist
Montana Wildlife Federation

Beau Kiklis
Senior Program Manager: Energy Landscape Conservation
National Parks Conservation

Alison Gallensky
Conservation Geographer: Leadership Team
Rocky Mountain Wild

1
See Inflation Reduction Act of 2022, H.R. 5376, 117th Cong. §§ 50262–50263 (2022).
2
See BLM, Pecos District Office Oil and Gas Lease Sale, Environmental Assessment 4 n.1 (Nov. 20, 2023).
3
See Draft EA, App. C Table C.1., 154–55 (Nov. 20, 2023).
4
Id.
5
See U.S. Bureau of Land Mgmt., BLM Wyoming 2023 Fourth Quarter Competitive Oil and Gas Lease Sale FONSI, 3 – 6 (Nov. 2023) (DOI-BLM-WY-0000-2023-0004-EA); See also, U.S. Bureau of Land Mgmt., BLM Wyoming 2023 Fourth Quarter Competitive Oil and Gas Lease Sale EA, 19 – 21 (Nov. 2023) (DOI-BLM-WY-0000- 2023-0004-EA).
6
U.S. Bureau of Land Mgmt., BLM Wyoming 2023 Fourth Quarter Competitive Oil and Gas Lease Sale FONSI, 3 – 6 (Nov. 2023) (DOI-BLM-WY-0000-2023-0004-EA).
7
See BLM, Pecos District Office Oil and Gas Lease Sale, Environmental Assessment, 64–6,155 (Nov. 20, 2023).
8
National Environmental Policy Act Guidance on Consideration of Greenhouse Gas Emissions and Climate Change, 88 Fed. Reg. 1196 (Jan. 9, 2023).
9
Id.
10
Draft EA at 108–10.
11
U.S. Environmental Protection Agency, Hydraulic Fracturing for Oil and Gas: Impacts from the Hydraulic Fracturing Water Cycle on Drinking Water Resources in the United States, EPA/600/R-16/236F, at 2–18 (Dec. 2016) (EPA 2016 Report), www.epa.gov/hfstudy.
12
See, e.g., Gayathri Vaidyanathan, Fracking Can Contaminate Drinking Water, at 8, Sci. Am. (Apr. 4, 2016); Dominic C. DiGiulio & Robert A. Jackson, Impact to Underground Sources of Drinking Water and Domestic Wells from Production Well Stimulation and Completion Practices in the Pavillion, Wyoming Field, 50 Am. Chem. Society, Envtl. Sci. & Tech. 4524, 4532 (Mar. 29, 2016); EPA 2016 Report.
13
See BLM, Regulatory Impact Analysis for the Final Rule to Rescind the 2015 Hydraulic Fracturing Rule, at 44–45 (Dec. 2017), https://beta.regulations.gov/document/BLM-2017-0001-0464.
14
Western Energy Alliance and the Independent Petroleum Association of America, Sept. 25, 2017 comments Re: RIN 1004-AE52, Oil and Gas; Hydraulic Fracturing on Federal and Indian Lands; Rescission of a 2015 Rule (82 Fed. Reg. 34,464) (2017 WEA comments), at 59, https://www.regulations.gov/document?D=BLM- 2017-0001-0412.
15
Dominic Digiulio, Examination of Selected Production Files in Southcentral Montana to Support Assessment of the March 2018 BLM Lease Sale (December 22, 2017), https://eplanning.blm.gov/public_projects/nepa/87551/136880/167234/Earthjustice_Protest_1-12-2018.pdf. (Exhibit D to David Katz and Jack and Bonnie Martinell’s protest of the March 13, 2018 BLM Montana-Dakotas oil and gas lease sales).
16
Dominic C. DiGiulio & Robert A. Jackson, Impact to Underground Sources of Drinking Water and Domestic Wells from Production Well Stimulation and Completion Practices in the Pavillion, Wyoming Field, 50 Am. Chem. Society, Envtl. Sci. & Tech. 4524, 4532 (Mar. 29, 2016), https://pubs.acs.org/doi/10.1021/acs.est.5b04970.
17
See generally New Mexico-Oklahoma Second Quarter 2024 Scoping Letter from TWS et al., to Melanie Barnes, State Director, New Mexico Bureau of Land Management State Office (Sep. 20, 2023) (on file with the Bureau of Land Management New Mexico State Office).
18
Intergovernmental Panel on Climate Change (IPCC), Climate Change 2021: The physical Science Basis, Contribution of Working Group I to the Sixth Assessment Report of the IPCC, Summary for Policymakers SPM-7 (V. Masson-Delmotte et al. eds, 2021) [hereinafter IPCC AR6 WGI], https://www.ipcc.ch/report/ar6/wg1/downloads/report/IPCC_AR6_WGI_SPM.pdf.
19
IPCC, SIXTH ASSESSMENT REPORT, CLIMATE CHANGE 2021: THE PHYSICAL SCIENCE BASIS, TECHNICAL SUMMARY TS-67.
20
B. Hmiel et al., Preindustrial CH4 indicates greater anthropogenic fossil CH4 emissions, 578 NATURE 409, 409–12 (Feb. 19, 2020); S. Pandey et al., Satellite observations reveal extreme methane leakage from a natural gas well blowout, 116 PNAS 52 (2019).
21
Id.
22
See, e.g., EDF, Flaring Aerial Survey Results (2021), https://www.permianmap.org/flaring-emissions/.
23
Olivia Griot et al., Onshore Natural Gas Operations on Federal and Tribal Lands in the United States: Analysis of Emissions and Lost Revenue, Synapse Energy Economics Inc., 3 (Jan. 20, 2023), https://blogs.edf.org/energyexchange/files/2023/01/EMBARGOED_EDF-TCS_Public_Lands_Analysis.pdf.
24
Id at 23.
25
E.g., Jeremy Proville et al., The demographic characteristics of populations living near oil and gas wells in the USA, 44 Population and Environment 1 (2022), https://doi.org/10.1007/s11111-022-00403-2.
26
See, e.g., id. at 2–5.
27
Olivia Griot et al., supra note 24.
28
Lara J. Cushing et al., Flaring from Unconventional Oil and Gas Development and Birth Outcomes in the Eagle Ford Shale in South Texas, 128 ENVIRONMENTAL HEALTH PERSPECTIVES, 077003 (2020).