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PLAN's read: high threat

Stop oil and gas leasing on 13,000 acres in New Mexico

Q4 2026 Competitive Oil and Gas Lease Sale - Carlsbad Field Office

Bureau of Land Management· Carlsbad Field Office (CFO) administered lands, Farmington Field Office (FFO) administered lands, Oklahoma Field Office (OFO) administered landsBLM NEPA Register DOI-BLM-NM-P020-2026-1065-EA ↗

BLM ePlanningWe track this on the agency’s own system of record, where most on-the-ground decisions live.

Pronghorn in sagebrush steppe
Pictured: Pronghorn in sagebrush steppe

The groups on this fight

4 groups predicted likely to care in New Mexico and Oklahoma

Predicted likely to care is a guess from footprint in New Mexico and Oklahoma, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.

  • Greater Chaco Coalition

    Predicted likely to care · a guess

    Works New Mexico: the coalition of Diné and Pueblo communities fighting drilling around Chaco.

  • Intertribal Buffalo Council

    Predicted likely to care · a guess

    Works Oklahoma: on the ground in Oklahoma.

  • New Mexico Wild

    Predicted likely to care · a guess

    Works New Mexico: led the community campaign for the 2014 designation and executive director Mark Allison spoke at the June 2025 Las Cruces rally against monument reductions and the Senate public land sell-off provisions.

  • Western National Parks Association

    Predicted likely to care · a guess

    Works Oklahoma: on the ground in Oklahoma.

Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.

BLM plans to hand drilling rights on 13,453 acres of federal land to oil and gas companies.

What’s at risk

Over 13,000 acres of public land in Eddy and Lea Counties, New Mexico are at risk of industrial oil and gas development. Leasing these 53 parcels would lock in exclusive drilling rights for at least 10 years, and potentially far longer if production begins.

If this goes through

Once leased, companies gain exclusive rights to explore and drill across all 53 parcels, and those rights can extend indefinitely as long as oil or gas is produced.

Our plain-English read of the official notice ↗. Check it against the agency’s own words below.

By the numbers, from the agency’s own document

Total federal acres proposed for leasing across three field offices
13,453.263 acres
Project Description

“Farmington Field Office (FFO), and Carlsbad Field Office (CFO), covering 13,453.263 acres”

Open the document ↗
Total nominated parcels in the lease sale
53 nominated parcels
Project Description

“The Proposed Action is to lease 53 nominated parcels of federal minerals”

Open the document ↗
Carlsbad Field Office parcels by county
10 in Eddy County and 4 in Lea County
Project Description

“The parcels for the CFO include 10 in Eddy County and 4 in Lea County.”

Open the document ↗
Initial lease term, then perpetual while producing
10-year initial term, then continues as long as oil or gas is produced
Project Description

“issued for a 10-year period and continue for as long thereafter as oil or gas is produced in paying quantities”

Open the document ↗
Number of field offices with separate EAs for one sale
3 offices
Project Description

“This is one of 3 offices involved in this lease sale.”

Open the document ↗

Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.

The agency’s own analysis

What the notice says, and what it leaves out

The strongest findings read from the agency’s own document, each quoted word for word. Each one is a point a letter can put on the record.

  • What's New

    The agency says

    “the draft Environmental Assessment (EA) and Finding of No Significant Impact (FONSI) documents specific to this Field Office”

    The What's New section confirms BLM posted the draft EA and an unsigned Finding of No Significant Impact simultaneously for the same public comment period.

  • Project Description

    The agency says

    “This is one of 3 offices involved in this lease sale.”

    The Project Description states this is one of three offices involved in the sale and directs the public to separate e-Planning pages for each office's EA.

  • Project Description

    The agency says

    “A permit to drill would not be authorized until site-specific NEPA analysis is conducted.”

    The Project Description acknowledges that no drilling permit will be authorized until a separate site-specific NEPA analysis is conducted at the APD stage.

  • Project Description

    The agency says

    “the lease purchaser has the exclusive right to use as much of the leased lands as is necessary”

    The Project Description grants every lease purchaser the exclusive right to use as much of the leased surface as is necessary, with no surface-disturbance limit established at the leasing stage.

  • Project Description

    The agency says

    “issued for a 10-year period and continue for as long thereafter as oil or gas is produced in paying quantities”

    The Project Description states leases run for 10 years and then continue indefinitely for as long as oil or gas is produced in paying quantities.

8 holes in the agency’s own analysis

Make these points, in your own words

  • I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
  • The What's New section confirms BLM posted the draft EA and an unsigned Finding of No Significant Impact simultaneously for the same public comment period. A FONSI is the conclusion that environmental review produces after the agency considers public input, not a document issued alongside the review it is supposed to evaluate. Releasing both at the same time renders the comment period structurally hollow: the agency cannot credibly remain open to a significance finding it has already rejected in writing. BLM should withdraw the unsigned FONSI, complete a genuine review of public comments, and issue any significance determination only after that review. If the full scale and perpetual duration of these leases cannot be shown to have no significant impact, BLM should prepare an EIS.
  • The Project Description states this is one of three offices involved in the sale and directs the public to separate e-Planning pages for each office's EA. That structure means no single NEPA document ever analyzes the combined footprint of all 53 parcels and 13,453.263 acres. Splitting one lease sale into three separate EAs obscures cumulative impacts on groundwater, wildlife habitat, air quality, and traffic that cross administrative boundaries. BLM should prepare a single consolidated NEPA document covering all 53 parcels across all three field offices, or at minimum explain in this document precisely how cumulative impacts across the full sale are accounted for and where a reader can find that analysis.
  • The Project Description acknowledges that no drilling permit will be authorized until a separate site-specific NEPA analysis is conducted at the APD stage. This concession means the EA supporting the FONSI contains no analysis of actual wells, roads, reserve pits, pipelines, surface disturbance, or emissions that the leases will authorize. A no-significant-impact conclusion drawn from an analysis that defers every measurable impact to a later document is not a conclusion the record supports. BLM should analyze a reasonably foreseeable development scenario, including estimated well count, road miles, and surface disturbance per parcel, before issuing a FONSI on any parcel in this sale.
  • The Project Description grants every lease purchaser the exclusive right to use as much of the leased surface as is necessary, with no surface-disturbance limit established at the leasing stage. Without a bounded disturbance cap, the EA has no defined scenario to evaluate, and a FONSI on an unbounded development right covering 13,453 acres cannot be defended analytically because the agency has never specified what level of development it is calling not significant. BLM should establish maximum surface-disturbance stipulations for each parcel as a condition of leasing, analyze impacts at those defined limits, and demonstrate in the EA that those limits prevent significant impacts.
Show every point from the document
  • The Project Description states leases run for 10 years and then continue indefinitely for as long as oil or gas is produced in paying quantities. A commitment of potentially unlimited duration conveying exclusive surface rights over 13,453 acres was evaluated at only the EA level. The combination of perpetual duration, exclusive surface access, and complete deferral of site-specific impact analysis presents the hallmarks of a decision requiring an EIS rather than an EA with a FONSI. BLM should explain with specificity how a no-significant-impact determination applies to a right of indefinite length, or prepare an EIS that accounts for the full potential duration and cumulative development trajectory of the lease sale.
  • All 53 parcels are described in the Project Description as nominated, with no description of any parcel screening, deferral, or any alternatives BLM evaluated. NEPA requires a meaningful alternatives analysis, including a reduced-acreage alternative and a genuine no-action alternative. An EA composed entirely of industry-nominated parcels, with no visible agency screening, does not satisfy that requirement. BLM should describe what alternatives were considered, explain why each nominated parcel was retained over competing public resource concerns, and analyze at minimum a reduced-parcel alternative that removes the most environmentally sensitive tracts from the sale.
  • The Project Description references Surface Management Agency stipulations that apply if applicable but says nothing about government-to-government tribal consultation under NEPA, NHPA Section 106, or the federal trust responsibility. The parcels sit in Eddy and Lea Counties, New Mexico, within the traditional territories of multiple tribes. The complete silence on consultation is a gap in the public record that must be closed before the sale proceeds. BLM should disclose which tribes were consulted, when consultation occurred, and what each consultation found, and should defer the sale of any parcel for which consultation is incomplete or unresolved.
  • The Project Description states the CFO parcels include 10 in Eddy County and 4 in Lea County, but the Project Location table in this notice lists only Eddy County entries with no entry for Lea County. An incomplete project location record can result in Lea County residents, local governments, and cooperating agencies missing formal notice of this action entirely. BLM should correct the Project Location table to include all counties in which parcels are located and confirm that all required notices were delivered to Lea County officials and to surface owners whose land overlies the four Lea County parcels.
  • Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
Every point is checked against the agency’s own decision document ↗. 8 findings verified against the text, word for word.

In the agency’s own words

The Proposed Action is to lease 53 nominated parcels of federal minerals administered by the Bureau of Land Management (BLM) Oklahoma Field Office (OFO), Farmington Field Office (FFO), and Carlsbad Field Office (CFO), covering 13,453.263 acres. Standard terms and conditions as well as lease stipulations listed in the relevant BLM OFO, FFO, and CFO Resource Management Plan(s) (as amended) and Surface Management Agency stipulations (if applicable) for Federal Oil and Gas Lease Offerings would apply. Once sold, the lease purchaser has the exclusive right to use as much of the leased lands as is necessary to explore…

BLM NEPA Register DOI-BLM-NM-P020-2026-1065-EA ↗

On the record for this fight

2 people have filed on this fight through PLAN. The official record is still catching up.

  1. Karen W.49 seals
  2. and 1 more steward

Ranked on letters found on the agency’s record, then letters filed. Readers appear as first name and last initial, or as a steward in their state; switch yours off in your record. All boards

Did the agency answer?

8 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.

Issues on the record, awaiting the decision

  • PendingThe Project Description acknowledges that no drilling permit will be authorized until a separate site-specific NEPA analysis is conducted at the APD stage.

    The Project Description acknowledges that no drilling permit will be authorized until a separate site-specific NEPA analysis is conducted at the APD stage. This concession means the EA supporting the FONSI contains no analysis of actual wells, roads, reserve pits, pipelines, surface disturbance, or emissions that the leases will authorize. A no-significant-impact conclusion drawn from an analysis that defers every measurable impact to a later document is not a conclusion the record supports. BLM should analyze a reasonably foreseeable development scenario, including estimated well count, road miles, and surface disturbance per parcel, before issuing a FONSI on any parcel in this sale.

    A hole PLAN found in the agency’s own notice, quote verified against the text

  • PendingThe Project Description states the CFO parcels include 10 in Eddy County and 4 in Lea County, but the Project Location table in this notice lists only Eddy County entries with no entry for Lea County.

    The Project Description states the CFO parcels include 10 in Eddy County and 4 in Lea County, but the Project Location table in this notice lists only Eddy County entries with no entry for Lea County. An incomplete project location record can result in Lea County residents, local governments, and cooperating agencies missing formal notice of this action entirely. BLM should correct the Project Location table to include all counties in which parcels are located and confirm that all required notices were delivered to Lea County officials and to surface owners whose land overlies the four Lea County parcels.

    A hole PLAN found in the agency’s own notice, quote verified against the text

  • PendingThe Project Description states this is one of three offices involved in the sale and directs the public to separate e-Planning pages for each office's EA.

    The Project Description states this is one of three offices involved in the sale and directs the public to separate e-Planning pages for each office's EA. That structure means no single NEPA document ever analyzes the combined footprint of all 53 parcels and 13,453.263 acres. Splitting one lease sale into three separate EAs obscures cumulative impacts on groundwater, wildlife habitat, air quality, and traffic that cross administrative boundaries. BLM should prepare a single consolidated NEPA document covering all 53 parcels across all three field offices, or at minimum explain in this document precisely how cumulative impacts across the full sale are accounted for and where a reader can find that analysis.

    A hole PLAN found in the agency’s own notice, quote verified against the text

  • PendingThe Project Description grants every lease purchaser the exclusive right to use as much of the leased surface as is necessary, with no surface-disturbance limit established at the leasing stage.

    The Project Description grants every lease purchaser the exclusive right to use as much of the leased surface as is necessary, with no surface-disturbance limit established at the leasing stage. Without a bounded disturbance cap, the EA has no defined scenario to evaluate, and a FONSI on an unbounded development right covering 13,453 acres cannot be defended analytically because the agency has never specified what level of development it is calling not significant. BLM should establish maximum surface-disturbance stipulations for each parcel as a condition of leasing, analyze impacts at those defined limits, and demonstrate in the EA that those limits prevent significant impacts.

    A hole PLAN found in the agency’s own notice, quote verified against the text

  • PendingThe Project Description states leases run for 10 years and then continue indefinitely for as long as oil or gas is produced in paying quantities.

    The Project Description states leases run for 10 years and then continue indefinitely for as long as oil or gas is produced in paying quantities. A commitment of potentially unlimited duration conveying exclusive surface rights over 13,453 acres was evaluated at only the EA level. The combination of perpetual duration, exclusive surface access, and complete deferral of site-specific impact analysis presents the hallmarks of a decision requiring an EIS rather than an EA with a FONSI. BLM should explain with specificity how a no-significant-impact determination applies to a right of indefinite length, or prepare an EIS that accounts for the full potential duration and cumulative development trajectory of the lease sale.

    A hole PLAN found in the agency’s own notice, quote verified against the text

  • PendingThe Project Description references Surface Management Agency stipulations that apply if applicable but says nothing about government-to-government tribal consultation under NEPA, NHPA Section 106, or

    The Project Description references Surface Management Agency stipulations that apply if applicable but says nothing about government-to-government tribal consultation under NEPA, NHPA Section 106, or the federal trust responsibility. The parcels sit in Eddy and Lea Counties, New Mexico, within the traditional territories of multiple tribes. The complete silence on consultation is a gap in the public record that must be closed before the sale proceeds. BLM should disclose which tribes were consulted, when consultation occurred, and what each consultation found, and should defer the sale of any parcel for which consultation is incomplete or unresolved.

    A hole PLAN found in the agency’s own notice, quote verified against the text

  • PendingThe What's New section confirms BLM posted the draft EA and an unsigned Finding of No Significant Impact simultaneously for the same public comment period.

    The What's New section confirms BLM posted the draft EA and an unsigned Finding of No Significant Impact simultaneously for the same public comment period. A FONSI is the conclusion that environmental review produces after the agency considers public input, not a document issued alongside the review it is supposed to evaluate. Releasing both at the same time renders the comment period structurally hollow: the agency cannot credibly remain open to a significance finding it has already rejected in writing. BLM should withdraw the unsigned FONSI, complete a genuine review of public comments, and issue any significance determination only after that review. If the full scale and perpetual duration of these leases cannot be shown to have no significant impact, BLM should prepare an EIS.

    A hole PLAN found in the agency’s own notice, quote verified against the text

  • PendingAll 53 parcels are described in the Project Description as nominated, with no description of any parcel screening, deferral, or any alternatives BLM evaluated.

    All 53 parcels are described in the Project Description as nominated, with no description of any parcel screening, deferral, or any alternatives BLM evaluated. NEPA requires a meaningful alternatives analysis, including a reduced-acreage alternative and a genuine no-action alternative. An EA composed entirely of industry-nominated parcels, with no visible agency screening, does not satisfy that requirement. BLM should describe what alternatives were considered, explain why each nominated parcel was retained over competing public resource concerns, and analyze at minimum a reduced-parcel alternative that removes the most environmentally sensitive tracts from the sale.

    A hole PLAN found in the agency’s own notice, quote verified against the text

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