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Comments on Environmental Impact Statement for Changes to Bears Ears Monument

The Bureau of Land Management and U.S. Forest Service recently released a Draft Environmental Impact Statement (EIS) on their land management proposal for the Bears Ears National Monument. The EIS does not consider the environmental impacts of shrinking the monument’s boundaries. We submitted comments explaining why the agencies are responsible for providing detailed environmental analysis of their proposal to alter the Bears Ears planning area.

The agencies claim that they are unable to conduct analysis on the larger, unaltered Bears Ears area because it would violate a recent Presidential Proclamation, which shrunk the size of the monument. We point to the National Environmental Policy Act (NEPA), which explains that Environmental Impact Statements should guide ultimate decisionmakers, like Congress. Only an act of Congress can legally alter the boundaries of a monument, so the EIS should provide the information needed to assess the impacts of altering Bears Ears’ boundaries. NEPA also requires agencies to assess incremental and cumulative impacts of an action. The agencies’ EIS, however, does not adequately discuss how shrinking Bears Ears might have incremental and cumulative impacts through oil and gas development and greenhouse gas emissions.