Re: Comments on Comprehensive Review of Federal Fossil Fuel Programs

Western Colorado Alliance is a grassroots organization dedicated to building and sustaining healthy, just, and self-reliant communities throughout Western Colorado. Our organization includes approximately 800 members living in rural western communities spanning from Jackson to La Plata County. A significant portion of our membership is comprised of farmers and ranchers. Western Colorado Alliance is an affiliate of the Western Organization of Resource Councils.

Western Colorado Alliance’s membership includes persons who live near, recreate in, rely for their livelihoods on, and otherwise use and enjoy federal public lands that are subject to oil and gas leasing, permitting and drilling, including hydraulic fracturing and the infrastructure associated with such oil and gas operations. Members of our Alliance use these public lands, and the rivers, streams and wetlands within them, for outdoor recreation, including hiking, skiing, wildlife viewing, photography, fishing, camping, solitude, and a variety of other activities.

Oil and gas leasing and the subsequent operations can create a variety of adverse environmental impacts, including release of contaminants that pollute air, water and soil. Oil and gas operations can also cause serious habitat fragmentation and destruction as a result of removing functioning ecosystems to create well and infrastructure pads and roads to these locations. These events can impact the health of our members, interfere with their use and enjoyment of these public lands and waters, and harm the plants and animals dependent on these ecosystems. Federal oil and gas development also contributes to climate change, which poses an existential threat to the residents of Western Colorado in the form of devastating wildfires and crippling drought. As such, our Alliance supports the following reforms:

Limiting the quantity and scope of competitive leasing sales. For too long speculative investors have abused the federal leasing process, tying up the public’s use of our federal lands with leases that have little or no promise of yielding oil and gas production, and depriving taxpayers of associated royalties. We seek a more robust vetting process that incorporates transparency and accountability for operators, and ensures leases are purchased in good faith.

Strengthen onshore fiscal policies and financial assurances. Presently, taxpayers are not receiving sufficient compensation from operators for the privilege of drilling and extracting resources from our federal lands. This problem is further compounded by the fact that thousands of orphaned wells across the country have no operator to hold accountable for damage they are causing, and it will fall to taxpayers to cover the cost of their plugging and reclamation. Therefore, we call upon the federal government to strengthen financial assurance requirements before operators are permitted to drill on federal lands, and ensure that taxpayers are not subsidizing the cost of cleanup.

Increase stakeholder participation and ensure oil and gas development on federal lands serves the public’s interests. Under current rules and guidelines, the Bureau of Land Management issues noncompetitive leases that are frequently undeveloped, resulting in millions of acres of federal land being underutilized. The result is difficulty for state and local governments planning land use around such parcels, and the obstruction of conservation designations. Our alliance seeks a more robust policy framework that evaluates the merit of such leases alongside alternative uses, and moves forward with the option that is determined to be the most beneficial to the public from a holistic perspective.

The Biden administration’s temporary pause on oil and gas leasing on federal lands is an important first step toward modernizing the federal oil and gas program, because it provides time to conduct a full programmatic review. Continuing to permit oil and gas leasing and development on federal lands without first modernizing relevant policies invites adverse environmental impacts to the federal lands our members cherish; for this reason, Western Colorado Alliance desires to see oil and gas leasing paused on federal public lands until leasing policy is evaluated for proper control of impacts, with the interests and input of Western Colorado residents considered.

Sincerely,

Western Colorado Alliance Membership