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Comments to BLM on Lease Sales on Oklahoma and New Mexico

We recently submitted joint comments to the Bureau of Land Management (BLM) about environmental assessments for three planned oil and gas lease sales in Oklahoma and New Mexico. BLM estimates and quantifies some direct, upstream, and downstream greenhouse gas emissions from the leasing plans, but fails to include a monetized estimate or meaningful assessment of the real-world climate damages those emissions will cause.

The Bureau of Land Management’s Oklahoma Field Office, Rio Puerco Field Office, and Pecos District Office released environmental assessments for September 2019 competitive oil and gas lease sales. Each EA attempts to defend why BLM has opted against applying the social cost of greenhouse gases to monetize the action’s emissions. We explain how the agency’s reasoning is flawed. For example, the accompanying resource management plans monetize a number of the benefits of the oil and gas leases, including royalties and labor income. Climate impacts must be given the same consideration. BLM should monetize the costs of greenhouse gas emissions using the federal Interagency Working Group’s 2016 social cost of carbon and social cost of methane estimates, which reflect the best available data and methodologies.