Saying No to Oil and Gas Leasing
What do you do when you learn that the Bureau of Land Management anticipates leasing 8,860 acres of northern New Mexico for oil and gas drilling? You have less than 30 days to submit a comment. You don’t know the landscape. Whatever you say may be ignored.
Well, actually that’s kind of freeing. Say what you have to say as if you were talking to a fellow crew member on Spaceship Earth. Think of it as art. After you’ve collected your submission ID number, share your work with anyone capable of caring. In the spirit of collaboration I’ll share this comment with groups that protested BLM New Mexico oil and gas leasing in 2023.
Comment Submitted to the Bureau of Land Management
By Jon Biemer, February 23, 2025
Project: DOI-BLM-NM-F010-2025-0011-EA – Q4 2025 Competitive Oil and Gas Lease Sale – Farmington and Rio Puerco Field Offices
Submission ID: Q42025-1-500746655 (comments due March 3, 2025; website: https://eplanning.blm.gov/eplanning-ui/project/2035973/510.)
Issues Relevant to the Proposed Action
Climate change and its cost are relevant to the proposed extraction of fossil fuels. See new technical or scientific information below.
The responsibility for carbon being released into the atmosphere is shared by the lessor of the land where fossil fuels are extracted.
Reasonable Alternatives
Not issuing oil and gas leases is a reasonable alternative. There is no compelling need.
Renewable energy is a reasonable alternative to extracting and burning fossil fuels. Below are responses to typical critiques of renewable energy.
- The variability of solar and wind generation is being addressed with batteries, hydro storage, time of day electricity pricing, incentivized demand control, new transmission lines, and emergency generation in critical facilities. Most of these are seasoned technologies.
- Solar and wind can be built in a wide range of scales and financing arrangements – thus increasing the market and minimizing the risk of technological surprises and cost overruns.
- Large-scale renewable energy is maturing. According to Canary Media, “Across the U.S., 10 states currently generate half or more of their electricity supply from renewables, with Iowa and South Dakota leading thanks to abundant wind power. In Texas, solar generated more electricity than coal for the first time in March [of 2024].” Renewables are good business for rural America.
- Energy efficiency is effectively a renewable resource. Successful efficiency measures over the years include LED lights, efficient industrial motors, the Energy Star program, and LEED buildings. With efficiency we thrive economically while decreasing our per-capita power consumption. Between 2022 and 2027, the Northwest Power Planning Council recommends that utilities and established institutions in the Pacific Northwest acquire between 750 and 1000 aMW of power (which will power 600,000 to 800,000 homes) through energy efficiency.
- Demonstrated efficiencies in electric vehicles, concrete and steel making and air travel will continue to reduce U.S. demand for fossil fuels.
- Technology advances in deep geothermal drilling will likely make that renewable resource widely available – using the infrastructure of retired power plants.
The Extent to Which the Issues and Impacts Should Be Analyzed
Use a computer model to translate estimated fossil extraction into projected impact on the population of the United States. Include the following steps:
- Estimate fossil fuel extraction from this lease sale, and from the aggregate of all lease sales anticipated for 2025.
- Derive CO2 equivalent releases from that extraction once it is combusted or made into end products
- Derive the impact of that CO2 release from these leases on the aggregate CO2 in the atmosphere
- Ascertain from historical data the impact on weather from the increase in CO2 atmospheric concentration derived in step 3 above.
- Derive the fiscal (dollar) impact of weather extremes due to increasing the CO2 concentration in the atmosphere – on the United States and on New Mexico (where the fossil fuel is extracted).
- Compare the financial impact of drilling derived above with renewably generated energy (especially wind, solar energy and energy efficiency).
Assess the lessor’s shared liability for climate change relating to leasing of lands for extraction of oil and natural gas. Legal principles used in the prosecution of John Demjanjuk and Oskar Grӧning as accessories in extermination camps may apply.
New Technical or Scientific Information to be Considered
2024 was the warmest year for our planet since human record keeping began. 2023 was the warmest year before that. January 2025 was the warmest January on record since human record keeping began.
According to NOAA’s Adam Smith, “2024: An active year of U.S. billion-dollar weather and climate disasters,” January 10, 2025:
“NOAA’s National Centers for Environmental Information (NCEI) has updated its 2024 Billion-dollar disaster analysis. In 2024, there were 27 individual weather and climate disasters with at least $1 billion in damages, trailing only the record-setting 28 events analyzed in 2023. These disasters caused at least 568 direct or indirect fatalities, which is the eighth-highest for these billion-dollar disasters over the last 45 years (1980-2024). The cost was approximately $182.7 billion.
“This total places 2024 as the fourth-costliest on record, trailing 2017 ($395.9 billion), 2005 ($268.5 billion) and 2022 ($183.6 billion). Adding the 27 events of 2024 to the record that begins in 1980, the U.S. has sustained 403 weather and climate disasters for which the individual damage costs reached or exceeded $1 billion. The cumulative cost for these 403 events exceeds $2.915 trillion.”
The 2024 hurricanes included: Helene, September 24-29: 219 deaths, $79.6 billion; Milton, October 9-10: 32 deaths, $34.3 billion; and Beryl, July 8: 46 deaths, $7.2 billion.
Thanks to reporter Alison Sandoval of the Sierra Sentinel in Truth or Consequences, NM for helping make us aware of pending BLM actions.
Jon Biemer is author of Our Journey to Sustainability (2024) and Our Environmental Handprints (2021). He is a member of the Society of Environmental Journalists and a registered Professional Engineer (California).
