Earthworks welcomes the opportunity to submit comments for this Resource Management Plan Amendment (RMP-A) and associated Environmental Impact Statement (EIS). These comments regard the full 4.2 million acre planning area and all lands and minerals within it under BLM and BIA’s planning authority. Because the RMP-A is guided by a single EIS that involves both BLM and BIA, we believe scoping should include all affected lands and minerals. The BLM component of this RMP-A was last scoped in 2014. Since then, many conditions on the ground have changed, and the impacts of fracking have become more pronounced. It is inappropriate to segregate scoping by agency under the same EIS because all actions considered in it are connected, and cumulative impacts must be considered for the entire planning area. Therefore, we request that BLM and BIA formally consider these comments as applicable to all lands and mineral estates within the planning area.
These comments will focus nearly exclusively on oil and gas leasing, exploration, development and associated infrastructure.