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Comments to BLM on Environmental Impacts of Federal Oil and Gas Leases

In response to a District Court order, the Bureau of Land Management (BLM) recently prepared a Supplemental Environmental Assessment (EA) for five federal oil and gas leasing decisions issued in 2015 and 2016. We submitted comments that focus on the agency’s failure to adequately quantify greenhouse gas emissions and monetize their climate impacts.

The U.S. District Court for D.C., in WildEarth Guardians v. Zinke, asked BLM to prepare a supplemental EA. Our comments detail the ways BLM must correct problems in its new analysis. BLM’s quantification of greenhouse gas emissions is flawed and often unexplained. We ask the agency to improve or clarify its analysis related to global warming potentials, direct and fugitive methane emissions, sensitivity analysis, and substitution effects. Our comments also discuss the monetization of climate damages as a means of assessing the intensity and significance of the environmental effects of the oil and gas leases in the case. We recommend that BLM use the Interagency Working Group’s 2016 estimates of the Social Cost of Greenhouse Gases, which reflect the best available data and methodologies.