The Honorable Sally Jewell, Secretary
U.S. Department of the Interior
1849 C Street, N.W.
Washington, DC 20240
Re: Oil and Gas Leasing on BLM Lands
Dear Secretary Jewell:
I am writing to you on behalf of over 1,000 members of the Coalition of National Park Service Retirees (CNPSR), who collectively represent more than 30,000 years of national park management experience. CNPSR studies, educates, speaks, and acts for the preservation of America’s National Park System. For some time we have tracked efforts by the Bureau of Land Management (BLM) to move forward on a variety of oil and gas leasing projects near national park areas in Colorado, New Mexico, and Utah. We are concerned that a consequence of some of these projects will be serious harm to the resource values for which many of these parks were established. We have given extensive study to the laws, regulations, court decisions, and internal policies and processes that guide this program. As with many controversial issues, there is, predictably, the challenge of potential conflicts in the respective agency policies and goals. And there are words and terms in the policies that invite differing interpretations. Win/win resolution of these challenges requires strong leadership in Washington and active collaboration between BLM field managers and their National Park Service (NPS) counterparts, the respective park superintendents.
The primary purpose of this letter is to encourage your specific attention to BLM Instruction Memorandum (IM) 2010-117, which introduces the Master Leasing Plan (MLP) as an avenue to assure in-depth planning and analysis crucial to making decisions consistent with protection of important resources and values, including units of the National Park System. We commend the BLM for developing the MLP process. By all accounts, the strong engagement with partners and the level of analyses required to complete an MLP will lead to decisions that provide a balanced approach to oil and gas development and resource conservation, and will better protect parks.
We are pleased to note that a promising MLP process is currently underway in Moab, Utah, capably led by BLM Moab Field Office staff working closely with the NPS staff from Canyonlands National Park to assure that mutual issues and concerns are addressed through preparation of the MLP. We are concerned that proposed leasing near other parks is not following the same planning model that appears to be working well in Moab, resulting in inconsistent and sometimes inadequate levels of collaboration between the respective BLM and NPS staffs. These include the following locations where revisions of BLM Resource Management Plans (RMP), typically a larger scale land use plan, are contemplated or underway:
- Carlsbad (NM) BLM Field Office; Carlsbad Caverns and Guadalupe Mountains National Parks
- Farmington (NM) BLM Field Office; Chaco Culture National Historical Park
- Tres Rios (CO) BLM Field Office; Mesa Verde Nat. Park and Yucca House National Monument
- White River (CO) BLM Field Office; Dinosaur National Monument (CO side)
- Vernal (UT) BLM Field Office; Dinosaur National Monument (UT side)
We believe that the best approach, and one that would ensure effective collaboration as well as consistency and certainty in the planning process, would be for BLM to prepare an MLP whenever proposed (i.e., not pre-existing) leasing has the potential to impact park resources and values. For this reason, we urge that, as appropriate and perhaps highlighting the Moab MLP as a positive model, you direct managers in the respective BLM field offices listed above to assure completion of MLPs in collaboration with park superintendents. Lastly, we understand that, as a practical matter, preparing an MLP is a relatively new and perhaps unfamiliar workload that some BLM field offices may not be adequately funded or staffed to perform and encourage you and DOI to provide BLM with the support necessary to prepare MLPs at these sites.
In closing, we appreciate that oil and gas leasing on Federal lands near national parks is a nationally important activity that must be well planned and managed in order to ensure there is an appropriate balance between energy development and resource conservation. Through consistent use of the MLP process, we are confident that the respective BLM and NPS staffs can collaboratively resolve any concerns about potential impacts to the protected resources and values within units of the National Park System.
Thank you very much for your support.
Sincerely,
Maureen Finnerty
Chair, Coalition of National Park Service Retirees
cc: Director, Bureau of Land Management
Director, National Park Service
