Stop geothermal leasing on Carson City public lands

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.
• The EA defers detailed analysis of site-specific impacts until later NEPA reviews, claiming that 'Potential impacts are analyzed in a general sense because information on components such as specific information is not available at this time' and 'These types of site-specific elements would be analyzed under future NEPA' (Section 3.2.3). This violates the rule against segmented NEPA review. The agency should either conduct a programmatic analysis addressing the range of foreseeable impacts, or acknowledge that the current EA cannot support a reasoned decision and prepare an EIS that addresses the full scope of likely development scenarios across all parcels.
• The ranching impact analysis (Section 3.2.5) acknowledges that lease parcels could represent '0.7 and 24 percent of the total area of each of the affected grazing allotments' yet states 'It is important to note that the entirety of the lease parcel area is not likely to be developed under the RFD scenario, but the extent of potential development is currently unknown.' This is circular reasoning: if the extent of development is unknown, the agency cannot estimate impacts to grazing. The document should either quantify the probable acreage of development per parcel based on the stated RFD, or acknowledge the analysis is inadequate and prepare an EIS with reasoned estimates of development intensity.
• The cultural resources section relies on a Class II survey of only 205 acres (or approximately 0.6 percent) of the 32,175.71 acres nominated, yet concludes that survey is sufficient for a leasing-stage decision (Section 4.3 and Section 3.2.6). The document states 'Approximately 11.04% of the total parcel acreage has been surveyed at the Class III level to date; un-surveyed areas are likely to contain additional resources.' This means 89% of the parcels remain unsurveyed at project stage resolution. The agency should either conduct Class III surveys on all parcels before leasing or explain in the decision record why incomplete cultural resource information is acceptable for a 10-year lease commitment.
• The document relies on general mitigation measures and Best Management Practices (BMPs) without verifying their effectiveness or enforceability. For example, dust control is described as 'water dirt roads during periods of high use to reduce fugitive dust emissions' (Section 3.2.1) and the document states emissions 'would not be expected to cause a discernible change to existing air quality,' yet provides no monitoring protocol or enforcement mechanism if BMPs fail. The agency should explain how it will ensure BMPs are implemented and what recourse exists if air quality impacts exceed estimates.