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Comments to BLM on 2022 First Quarter Lease Sales

The Bureau of Land Management (BLM) recently released several environmental assessments (EAs) for oil and gas lease sales taking place in the first quarter of 2022, which together could contribute over $4 billion in climate damages. We submitted comments on the EAs for Colorado, Montana and North Dakota, New Mexico, Utah, and Wyoming. In our comments, we applaud BLM for taking the important step of considering climate impacts by monetizing greenhouse gas emissions with the social cost of greenhouse gases tool.

We then make recommendations for how BLM should improve its decisionmaking by better incorporating the social cost values into its final determination, including by monetizing other effects of the proposed action and comparing the overall costs and benefits, using the social cost values as a point of comparison between alternatives, and considering the cumulative climate impacts of concurrent lease sales. We also advise BLM to consider the informational value of delaying leasing known as option value and we urge BLM to conduct more robust environmental justice analyses to inform its decisionmaking.