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

As the Bureau of Land Management (BLM) considers opening Alaska’s Arctic National Wildlife Refuge for oil and gas leasing, pursuant to language in the 2017 Tax Act, our comments explain that development of oil and gas in the Arctic Coastal Plain would pose serious threats to this delicate, pristine ecosystem. In preparing an Environmental Impact Statement (“EIS”) for this potential lease sale, BLM must consider the many factors that weigh strongly against any leasing or development in the Refuge. These include the long history of bipartisan support for the pristine refuge; the threat of oil spills, pollution, and infrastructure effects; threats to endangered and threatened species; and climate change effects from oil and gas development. Given these myriad, serious effects, BLM must analyze and consider a “no leasing alternative” in its EIS. In addition to the no leasing alternative, BLM must consider a delayed lease sale alternative that would require waiting for more information on environmental risks, resource prices, and more, in order to account for the option value (or informational value of delay) of irreversible drilling within the Refuge.

Our joint comments with Environmental Defense Fund, Montana Environmental Information Center, Sierra Club, and the Union of Concerned Scientists encourage BLM to quantify and monetize the climate effects of the potential leasing program by using the Social Cost of Greenhouse Gases.