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Comment Letter on BLM Waste Prevention Rule

In November, the Bureau of Land Management proposed a regulation to reduce the waste of natural gas on federal lands through venting, flaring, and leakage. In our comment letter, we recommend avenues for BLM to bolster its legal and economic support for the proposal. In particular, we recommend that BLM more expressly disavow its prior position that waste-prevention regulations must benefit regulated industry, more closely evaluate the proposal’s effects to ensure that its analysis fully captures resulting benefits and royalty revenues, and recognize the significance of the rule’s climate benefits.