THE WILDERNESS SOCIETY
AUDUBON ROCKIES * COALITION TO PROTECT AMERICA’S NATIONAL PARKS
* FRIENDS OF THE EARTH UNITED STATES * NATURAL RESOURCES DEFENSE COUNCIL * NATIONAL AUDUBON SOCIETY * POWDER RIVER BASIN RESOURCE COUNCIL * ROCKY MOUNTAIN WILD * WYOMING OUTDOOR COUNCIL
February 15, 2024
SUBMITTED VIA E-PLANNING
Andrew Archuleta
State Director
Wyoming Bureau of Land Management
5353 Yellowstone Road
Cheyenne, WY 82009
Project Contacts:
Erik Norelius en******@bl*.gov
(307) 775-6284
Allen Stegeman as*******@bl*.gov
(307) 775-6259
Re: Scoping Comments on parcels for the Wyoming Bureau of Land Management 2024 Third Quarter Competitive Oil & Gas Lease Sale (DOI-BLM-WY-0000-2024- 0003-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) Wyoming 2024 Third Quarter Oil & 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 appreciate that the Department of the Interior (DOI) 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 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).3See Inflation Reduction Act of 2022, H.R. 5376, 117th Cong. §§ 50262–50263 (2022). 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.
Our scoping comments thus recommend:
- Ensuring that any parcels included in the proposed lease sale comport with the guidance provided in the IMs released on November 21, 2022.
- Prioritizing conservation and climate impacts 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.
- Finalizing the Leasing Rule before holding the proposed sale.
Click here to read the complete letter.