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Comments to BLM on Oil and Gas Leasing in the Arctic National Wildlife Refuge

The Bureau of Land Management (BLM) recently prepared a Draft Environmental Impact Statement (DEIS) for an oil and gas leasing plan within the Arctic National Wildlife Refuge (ANWR) Coastal Plain. We submitted comments explaining how fossil fuel extraction in ANWR would pose serious threats to a delicate ecosystem and would contribute significantly to climate change. Our criticism of the DEIS focuses on the methodological flaws in BLM’s analysis and their failure to consider viable leasing alternatives.

ANWR, including its Coastal Plain, has been off limits for oil and gas development for almost 60 years. Many of the same characteristics that made it a prime candidate for protection decades ago are just as compelling, if not more so, today. Drilling for oil or natural gas would pose significant risks of environmental damage. Despite the Coastal Plain’s ecological sensitivity, BLM does not consider alternative development scenarios that would best reduce environmental and social harms, nor does it analyze an alternative that would account for the option value of irreversible drilling. BLM also provides an energy substitution analysis that grossly underestimates downstream greenhouse gas emissions from the proposed leasing. We encourage BLM to better analyze leasing alternatives, substitution effects, and the value of the ANWR ecosystem.

We also submitted joint comments on the agency’s failure to monetize climate damages in the DEIS. BLM does not include a monetized estimate of any of the actual real-world climate damages that oil and gas leasing would produce, instead claiming that climate impacts are the same across all alternatives. We explain that the scenarios proposed by BLM, compared to the no-action alternative, would result in hundreds of millions of dollars in annual climate impacts. The agency should apply social cost of greenhouse gases estimates in its DEIS.