Stop rollback of safeguards on public lands drilling

What the public could have raised, from the agency’s own document

• I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
• In the section proposing to cut bond minimums by 93-95 percent, BLM itself states that lower bonds could reduce operators' incentive to reclaim wells and increase risk to public lands and ecosystems. The agency's proposed fix is to rely on the same periodic bond-adequacy-review policy that existed before this admission, without showing that policy is sufficient to offset the specific risk it just identified. BLM should analyze and disclose how bond adequacy reviews alone will prevent the increased default and non-reclamation risk it acknowledges.
• BLM explicitly states the new per-page protest fee is not meant to recover its $2,470 average processing cost per protest, but rather to change protester behavior by discouraging long filings. At the same time, the agency's own data show that protests are the norm, not the exception, occurring on more than 70 percent of parcels and 100 percent of parcels in fiscal year 2022. A fee designed to suppress a form of public participation that the agency's own statistics show is the standard practice, rather than an aberration, needs stronger justification than administrative convenience. BLM should justify the fee against its actual chilling effect on this widely used comment mechanism or drop it.
• BLM proposes to eliminate the 30-day scoping and 30-day comment periods during NEPA review, but justifies this in the same discussion by asserting that the agency 'already conducts thorough environmental reviews and assessments that include opportunities for public input at various stages.' This directly undercuts the removal, since the scoping and comment periods being eliminated are themselves among those very opportunities for public input. BLM should identify with specificity what public input opportunities will remain equivalent to the eliminated periods, or restore them.
• For the change to the combined hydrocarbon lease royalty rate under Subpart 3140, BLM admits it performed no analysis of the financial effect on the three remaining pending applications, dismissing the issue solely because the number of applications is small. A change that alters the royalty obligation on pending applications from 16.67 percent to 12.5 percent has a direct, calculable revenue effect on both the applicants and the Treasury regardless of how few applications remain, and the agency should quantify it rather than waive analysis based on scope alone.