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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 issued a notice of intent to complete a Supplemental Environmental Impact Statement (EIS) for an oil and gas leasing plan within the Arctic National Wildlife Refuge (ANWR) Coastal Plain. We submitted comments explaining how BLM’s previous EIS fell short of the agency’s obligation to assess the effects of oil and gas leasing and to consider reasonable alternatives. 

As Policy Integrity has repeatedly noted in comments to BLM, drilling in ANWR would pose significant risks of environmental damage. Our comments explain how BLM’s EIS mischaracterized the environmental effects of leasing by using flawed methodologies, not quantifying numerous harms, and disregarding tools like the social cost of greenhouse gases to assess climate impacts. BLM also failed to sufficiently analyze alternatives that would reduce environmental and social harms from oil and gas development.  Furthermore, the EIS understated the environmental impacts of oil and gas leasing in the area by assuming that any forgone development in the Coastal Plain will be almost entirely offset by oil and gas production elsewhere—an assumption that has been discredited by economists and that is inconsistent with the agency’s treatment of economic benefits in the EIS.

Owing in large part to these analytic oversights and mistakes, BLM previously selected a development plan that allows for drilling in the entire program area and imposes the fewest restrictions on leasing activities in America’s largest wildlife refuge. We encourage BLM to correct the deficiencies in its analysis and reconsider whether its chosen alternative best serves the public interest.