State of New Mexico

Michelle Lujan Grisham

Governor

September 25, 2020

Ms. Jillian Aragon, BLM Project Manager

Attn: RMPA Comment Submission
Bureau of Land Management
6251 College Blvd, Suite A
Farmington, NM 87402

Mr. Robert Begay, BIA Project Manager

Attn: RMPA Comment Submission
Bureau of Indian Affairs Navajo Regional Office
P.O. Box 1060
Gallup, NM 87301

Submitted by e-mail to blm_nm_ffo_rmp@blm.gov

Re: Farmington Mancos-Gallup Draft Resource Management Plan Amendment (RMPA) Environmental
Impact Statement (EIS)

Dear Ms. Aragon and Mr. Begay:

On behalf of the State of New Mexico, I am commenting on the Bureau of Land Management’s (BLM)
Farmington Mancos-Gallup Draft Resource Management Plan Amendment Environmental Impact
Statement (RMPA/EIS). I am deeply concerned that the RMPA/EIS does not adequately address the
impacts of the proposed development on either air quality or tribal cultural resources and lacks essential
alternatives. These flaws are in part the result of inadequate tribal consultation, an inadequate public input
process, and an incomplete cultural resources survey. I strongly encourage the U.S. Department of the
Interior to delay consideration of the RMPA/EIS until further consultation, public input, and survey work
is completed and the document is amended to reflect the results of these efforts.

The proposed land development of the planning area includes oil and gas extraction and processing
operations in the New Mexico counties of San Juan, Rio Arriba, McKinley, and Sandoval.  This land
development area is of particular concern as it contains thousands of existing oil and gas wells and other
facilities that cause or contribute to ozone formation and emit greenhouse gases that contribute to climate
change, affect tribal members residing in the area, and impact natural and cultural resources including the
Chaco Cultural Heritage Area.

Five primary alternatives, including a No Action scenario, are described in the RMPA/EIS. The emphasis
on mineral development does not adequately balance effects to human health and the environment or
cultural resources. None of the alternatives the BLM proposes adequately address concerns regarding
negative impacts from oil and gas development to natural resources including sensitive plant species, air

State Capitol • Room 400 • Santa Fe, New Mexico 87501 • 505-476-2200
and water quality, cultural resources, and traditional cultural properties. In addition, the alternatives
currently presented lack a thorough analysis of tribal cultural resources in the planning area.

In January 2019, I issued Executive Order (EO) 2019-003 on Climate Change and Energy Waste
Prevention. The EO requires reductions in methane emissions from the oil and gas sector. Methane makes
up approximately 31% of New Mexico’s greenhouse gas emissions profile. The oil and gas industry is the
largest industrial source of methane emissions in the planning area and produces approximately 64% of
New Mexico’s methane emissions. As identified in the RMPA/EIS, New Mexico is experiencing rising
ozone concentrations in areas of the state with significant oil and gas operations. As acknowledged by
BLM in the report, the proposed alternative must address these rising ozone levels and not continue to
contribute to this issue. None of the BLM’s proposed alternatives adequately address the impacts of oil
and gas development in the planning area in contributing to air pollution and greenhouse gas emissions.
BLM’s preferred alternative, Alternative C, like the no action alternative “would result in a greater
potential for new sources of criteria air pollutants, hazardous air pollutants, and greenhouse gas emissions
into the planning area.”

Further, the planning area contains the Chaco Culture National Historic Park (CCNHP). The CCNHP is
world-renowned for its multi-story buildings and as the ancestral home to the native cultures that have
called New Mexico home for many centuries. The modern Pueblo peoples of New Mexico are the direct
descendants of the residents of Chaco. That is why, for more than a decade, pueblos, tribes, and nations in
New Mexico and Arizona have raised concerns about the proximity of mineral extraction to these
important cultural sites. This area must be given the highest level of protection to ensure the accessibility
of these cultural sites to tribal nations so they may continue culturally significant practices.

I am concerned with the lack of consultation with tribal nations in the development of the RMPA/EIS as
required by NEPA and the National Historic Preservation Act (NHPA) Section 106 process. Adequate
consultation has not occurred, resulting in the absence of alternatives that truly consider the impacts on
the environment, people, and cultural resources. Further, BLM’s process has inhibited the ability of tribes
and their members to provide valuable input on the RMPA/EIS, particularly during the current health
emergency.

Additionally, the RMPA/EIS lacks critical information about cultural resources in the area. Tribes have
requested that the RMPA/EIS be delayed until the BLM can incorporate findings from ethnographic
studies. The BLM has ignored this request in violation of NHPA’s Section 106 process and in spite of the
fact that funding for an ethnographic study of the area’s cultural resources was included in the Further
Consolidated Appropriations Act of 2020 (P.L. 116-94). This study must be completed and its findings
incorporated into a new RMPA/EIS.

I request that the Bureau of Land Management delay adoption of the RMPA/EIS until ethnographic
studies are complete and develop a new alternative, in consultation with tribal nations, that ensures the
protection of natural and cultural resources and preserves and improves air and water quality. This
alternative must also include the proposed fluid mineral leasing closure around the Chaco Culture
National Historical Park along with other protections for the region outlined in the Chaco Cultural
Heritage Protection Act.

Sincerely,

Michelle Lujan Grisham

Governor

State Capitol • Room 400 • Santa Fe, New Mexico 87501 • 505-476-2200