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Comments to BLM on Draft SEIS for Willow Master Development Plan

In 2020, the Bureau of Land Management approved an extraction plan known as the Willow Master Development Plan, which would authorize oil giant ConocoPhillips to drill in Alaska’s North Slope for 30 years. But a federal court blocked the Plan from going into effect because BLM failed to account for several important environmental considerations, and in June, BLM released a draft supplemental environmental impact statement that improves upon the agency’s analysis and now finds that the Project will cause billions upon billions of dollars in climate damage.

We submitted comments recognizing the significance of those climate damages and arguing that BLM continues to undervalue climate costs while overvaluing economic benefits. In particular, our comments focus on limitations in BLM’s substitution analysis that cause the agency to underestimate net greenhouse gas emissions. Our comments, submitted jointly with Earthjustice and the Wilderness Society, follow prior comments that we submitted on this proposal in 2019 and early 2022.

In October 2022, we filed an additional comment letter presenting our original economic modeling that further evinces the flaws in BLM's substitution analysis. That modeling provides detailed evidence that BLM should revise its substitution modeling to account for long-term changes in the energy sector. This would enable the agency to better estimate net greenhouse gas emissions from federal fossil-fuel production.