We submitted two sets of comments to the Bureau of Land Management (BLM) in response to their Draft Resource Management Plan (RMP), which focuses on mineral development potential in the Carlsbad region of New Mexico. Our comments recommend that BLM not offer more lands for fossil fuel leasing, but instead consider alternatives with the greatest amount of conservation and wildlife protection. In particular, we focus on shortcomings in the RMP’s analysis and its failure to monetize climate damages.
BLM’s preferred development alternative leaves 98% of the Carlsbad region open to leasing. Their analysis, however, does not account for the public’s valuable option to delay selling development rights to private actors. Our comments suggest that the RMP consider option value, as well key uncertainties and risks that accompany fossil fuel leasing – including variable energy markets, negative effects on the local environment, and climate damages. We also point out that BLM has not applied the Social Cost of Greenhouse Gases to its analysis, and in turn has not adequately assessed the impacts of carbon dioxide, methane, and nitrous oxide emissions.