<textarea rows="25" style="font-size: 14px; width: 100%;"><!-- [et_pb_line_break_holder] -->BLM New Mexico State Office<!-- [et_pb_line_break_holder] -->Attention: State Director <!-- [et_pb_line_break_holder] -->301 Dinosaur Trail<!-- [et_pb_line_break_holder] -->Santa Fe, NM 87508<!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->Re:   Protest of Proposed March 2019 Oil and Gas Lease Sale by the Bureau of Land Management’s <!-- [et_pb_line_break_holder] --> Farmington and Rio Puerco Field Offices and Pecos District Carlsbad Office<!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->Dear State Director Spisak:<!-- [et_pb_line_break_holder] --><!-- [et_pb_line_break_holder] -->As a Sierra Club supporter, I protest the lease sale of 37 nominated parcels of public lands in New Mexico managed by the Bureau of Land Management (BLM) at the March 2019 lease sale:<!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->Farmington Field Office parcels: - NM-201903-010, NM-201903-011, NM-201903-012, NM-201903-013,<!-- [et_pb_line_break_holder] -->NM-201903-014, NM-201903-015, NM-201903-016, NM-201903-017, NM-201903-024, NM-201903-025,<!-- [et_pb_line_break_holder] -->NM-201903-026, NM-201903-033, NM-201903-037, NM-201903-038, NM-201903-039, NM-201903-040, <!-- [et_pb_line_break_holder] -->NM-201903-041, NM-201903-042, NM-201903-043, NM-201903-044, NM-201903-045, NM-201903-046<!-- [et_pb_line_break_holder] -->Rio Puerco Field Office parcels: - NM-201903-009, NM-201903-018, NM-201903-019, NM-201903-020, <!-- [et_pb_line_break_holder] -->NM-201903-021, NM-201903-022, NM-201903-023<!-- [et_pb_line_break_holder] -->Pecos District Carlsbad Office parcels: - NM-201903-001, NM-201903-002, NM-201903-003, <!-- [et_pb_line_break_holder] -->NM-201903-004, NM-201903-005, NM-201903-006, NM-201903-007, NM-201903-008<!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->The Farmington Field Office Resource Management Plan amendment and the Rio Puerco Resource Management Plan revision processes are still ongoing. Full analysis of the impacts of horizontal drilling and multistage hydraulic fracturing have yet to be addressed. These processes are meant to ensure that community health and environmental protections are in place before any more drilling occurs.<!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->Interior Secretary Zinke deferred the March 2018 lease sale calling for more cultural consultation and admitted that the Greater Chaco region needs more cultural study. To date, there has not been a single attempt by the BLM to survey over 5,400 cultural resources in the region. Therefore, the BLM is violating the National Environmental Protection Act (NEPA) and the National Historic Preservation Act (NHPA) and is breaking its commitment to consult with tribal governments and impacted communities before these sensitive areas are offered for lease.<!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->Individuals living in the Greater Chaco region experience myriad impacts from existing oil and gas exploitation, including increased levels of asthma and cancer, air contamination due to venting, flaring and leaks of toxic air emissions, destroyed roads and unsafe traveling conditions, dust pollution, the desecration of sacred landscapes, and much more. Continued oil and gas development exacerbates these impacts and undermines the precepts of indigenous rights and consultation as laid out by the United Nations Declarations on the Rights of Indigenous Peoples (UNDRIP) Article 32 and Free, Prior, and Informed Consent (FPIC).  The Navajo Nation, All Pueblo Council of Governors, New Mexico Congressional delegation, New Mexico state legislature, and many NGOs and concerned citizens have called for a moratorium on all new leasing until the Bureau of Land Management has completed management plans that comprehensively address the impacts of horizontal drilling and multistage hydraulic fracturing.<!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->Furthermore, in southeastern New Mexico, oil and gas companies in the Permian Basin are completing wells in the region at an astounding rate, contaminating the air and fueling climate change. The “current” Carlsbad RMP fails to account for the impacts from this scale of development. And, although, the BLM is currently developing a new plan, this plan would be even worse, ultimately opening up 97% of all public lands in this area for oil and gas development. Moreover, up to 50,000 acres of public lands would be sold and privatized. <!-- [et_pb_line_break_holder] -->When the consequences of further leasing across the Carlsbad, Farmington, and Rio Puerco is considered both within the context of individual field offices and in particular as an aggregate whole, it becomes crystal clear that BLM’s oil and gas program in New Mexico contributes significant greenhouse gas pollution exacerbating our climate crisis. This pollution must be accounted for. Yet BLM has never taken a hard look at the aggregate climate impacts of the agency’s oil and gas program on a statewide basis let alone national basis and existing lease-specific analyses are simply inadequate. Rather than meaningfully account for climate change, these analyses paper over the problem and, in the process, worsen it. It is imperative that BLM reduce climate pollution consistent with the agency’s statutory obligations to protect public lands, consider cumulative impacts, and take action that protects, restores, and enhances our public lands and environment in the face of a warming climate. <!-- [et_pb_line_break_holder] --><!-- [et_pb_line_break_holder] -->By going forward with this lease sale, the BLM is failing in its obligation to fulfill the agency’s multiple-use mandate, which requires for the BLM to manage public lands and their numerous natural resources so that they can be used for economic, recreational, and scientific purposes without the infliction of permanent damage. Over 93% of public lands in the San Juan Basin are already leased for oil and gas, and the Permian Basin is already experiencing the negative consequences of intensive oil and gas extraction. It is impossible for BLM to satisfy its multiple use obligations or create balance with nearby communities and the environment where oil and gas is prioritized in this manner.  <!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->In offering to sell the proposed lease parcels, the BLM has also inappropriately and without any public notice rolled back opportunities for public involvement.  Not only has the agency completely eliminated comment periods for draft NEPA analyses, it has stopped allowing people to fax protests and rolled back the protest period from 30 to 10 days, an inordinately short amount of time to meaningfully participate.  Forcing us to rush to document our concerns undermines our right to due process.<!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->Please cancel the March 2019 lease sale for the listed parcels. The U.S. federal government needs to serve all Americans, not just the oil and gas industry.<!-- [et_pb_line_break_holder] --> <!-- [et_pb_line_break_holder] -->Supporting Comment:<!-- [et_pb_line_break_holder] --><!-- [et_pb_line_break_holder] -->Sincerely,<!-- [et_pb_line_break_holder] -->Your printed name (REQUIRED)<!-- [et_pb_line_break_holder] -->Your signature (REQUIRED)<!-- [et_pb_line_break_holder] -->Your mailing address (REQUIRED)<!-- [et_pb_line_break_holder] -->Your email address (optional)<!-- [et_pb_line_break_holder] --></textarea>