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Comments to BLM on the Coastal Plain Supplemental Environmental Impact Statement

The 2017 Tax Act directed Bureau of Land Management (BLM) to conduct two sales in the Arctic National Wildlife Refuge (ANWR) area known as Coastal Plain totaling at least 400,000 acres by 2024. BLM released a final environmental impact statement in September 2019 considering the over 1.5 million-acre area in the ANWR and held the first lease sale in January 2021. Later in 2021, the agency placed a moratorium on all activities relating to BLM’s Coastal Plain leasing program, announced that the analysis conducted in 2019 was legally deficient, and began to prepare a supplemental environmental impact statement. The EIS, which reflects this supplemental analysis, demonstrates considerable improvement from the agency’s 2019 analysis. Yet there remains room for improvement. Specifically, to ensure the complete and balanced presentation of climate costs and economic benefits, BLM should:

  • Recognize that its energy-substitution model, EnergySub, produces an underestimate of net greenhouse gas emissions and update the model to incorporate the likelihood of substantial long-term changes in the energy sector;
  • Recognize that its social cost of greenhouse gases estimates are conservative and consider applying newer federal valuations in line that reflect expert consensus; and
  • Update its economic benefits analysis to ensure consistency with its presentation of climate costs.