Aug. 24, 2026
U.S. Bureau of Land Management
Director Steve Pearce
1849 C Street NW
Washington, DC 20240
CC:
Interior Secretary Doug Burgum
Dear Director Pearce,
We, the undersigned, write to you as concerned elected officials across the United States, to express our opposition to the proposed revisions to the 2024 Bureau of Land Management Oil and Gas Rule, and urge BLM not to adopt them.
Our communities rely on our federal public lands, whether they sit at the edge of town or far away. They sustain livelihoods and local economies, as well as provide clean water, wildlife habitat, and recreational access. As local elected officials, we understand that public lands are a shared asset that offers broad economic benefits, protects our natural heritage, and enhances quality of life for all our communities, regardless of proximity to the land itself. As such, we have a shared stake in responsible stewardship.
This proposed rule would not only allow the oil and gas industry to develop our publicly owned resources for pennies on the dollar, but also drastically diminish the public’s voice in leasing decisions, put sensitive wildlife habitat and cultural sites at risk, offload well cleanup costs to taxpayers, and undermine private property rights.
Limiting public engagement
America’s public lands are one of our country’s best ideas: owned by all of us, and open to everyone. They also support a vast range of uses, including agriculture, ranching, hunting, fishing, camping, hiking, and renewable energy development, as well as extractive resource industries. As a publicly owned resource where so many work and play, the public is entitled to an active, participatory role in decisions that affect these lands, particularly as the BLM plans to open up millions of additional acres to drilling.
We oppose the elimination of the longstanding 30-day scoping period and 30-day comment period for the environmental review, the reduction of the lease sale notice period from 60 to 45 days, the reduction of the protest period from 30 to 10 days, and the addition of a $1 per page fee for detailed protests. By imposing a fee and limiting overall public participation to a mere 10 days, the rule hamstrings meaningful public participation in the oil and gas lease sale process. The law is clear that the BLM must offer meaningful public engagement opportunities in lease sales. Public participation isn’t bureaucracy for bureaucracy’s sake – it’s transparent governance and democratic decision-making. It builds public trust, and it produces better outcomes for our communities.
This provision is also out of step with what our constituents want. In the American West, where the vast majority of BLM lands are located, 74 percent of voters oppose overriding local concerns to advance oil and gas development. This sentiment holds true across party lines; the same poll found that 76 percent – including a majority of Republicans, Democrats, and Independents – would prefer their Members of Congress place more emphasis on protecting resources on these lands over maximizing energy production.
Shifting cleanup costs to taxpayers
The Environmental Protection Agency estimates there are about 3.9 million abandoned oil and gas wells in the U.S., many of which are on public lands. By reducing bonding requirements back to rates established in the 1950s and 60s ($10,000 for individual lease bonds and $25,000 for statewide bonds – drastically below market rate), this fiscally irresponsible provision would ensure that our taxpaying constituents – not oil and gas companies – are responsible for cleanup after a well’s productive life ends.
Eliminating preference criteria
Preference criteria established through the 2024 rule ensure that leasing is directed away from lands with critical fish and wildlife habitat, culturally significant resources, economically valuable outdoor recreation opportunities, low oil and gas potential, and no existing oil and gas infrastructure. At a time when the BLM is conducting mandatory and increasingly larger quarterly and replacement lease sales on public lands based on outdated resource management plans, these criteria are a critical guardrail. They ensure the agency complies with its statutory mandate to manage those lands for multiple use and sustained yield, and they prevent unnecessary or undue degradation. Without these criteria, sensitive habitat, cultural sites, water resources are at risk, and other land uses are obstructed.
Reducing the lease application fee
At the same time the BLM proposes to charge the public for participating in the leasing process, the agency also proposes to reduce the lease application fee from $3,100 to $155. When combined with the reinstatement of noncompetitive leasing, which enables companies to acquire lands that don’t receive bids at auction for only $3 per acre, as well as replacement sales, reduced bonding rates, the elimination of expression of interest fees, and BLM’s separate effort to lower the royalty rate, this rule will make it much easier and cheaper for oil and gas companies to drill on public lands than almost all state or private lands – all at the expense of taxpayers and the lands they own.
Eliminating surface owner notification requirements
The BLM owns approximately 57 million acres of split-estate lands: lands where the BLM owns the subsurface mineral rights, while someone else (like a private landowner) owns the above-ground property. By eliminating the requirement to notify these landowners – like farmers, ranchers, or other private landowners – about proposed leases on their lands, BLM is opening the door to drilling without even offering a courtesy notice to those most impacted.
The split-estate issue has already become prevalent in the past year. For example, in Colorado, leases were sold adjacent to the Aurora Reservoir (which supplies drinking water to more than 400,000 people), underneath two State Wildlife Areas, and on privately owned ranchland where conservation easements exist to support wildlife habitat. In the past year, community members, state agencies, hunters, and ranchers submitted comments opposing leasing on these split-estate lands. It would be unfair and negligent to deny these stakeholders due notice about proposed leases beneath their land.
In conclusion, BLM’s proposed rule holds harmful implications for our taxpaying constituents, countless industries, and millions of acres of land that belong to Americans – who made their support for the 2024 rule clear. The 2024 rule had broad public support – it received more than 260,000 public comments, over 99 percent of which were in favor of adopting the rule as written. In addition, for the 2024 rule, the BLM held five public meetings during the 60-day comment period. It would be unjust to revoke most of the 2024 rule’s provisions without offering public meetings during this comment period.
BLM’s proposal, as written, undermines democratic values by cutting the public out of the lease sale process, denies private property owners fair notice, undercuts taxpayers, and opens the door to all the environmental, social, cultural, and economic impacts that come with unfettered development of federal public lands. On behalf of our constituents and communities, we urge you not to adopt the provisions outlined in this letter, and instead support a balanced approach to public lands management.
Thank you for your time and consideration.
Sincerely,
Arizona
Lauren Kuby
State Senator, District 8
Patty Contreras
State House Representative, District 12
Brian Garcia
State House Representative, District 8
Betty Villegas
State House Representative, District 20
Patrice Horstman
Coconino County Supervisor
Anna Hernandez
Phoenix City Councilor
Nieves Riedel
Mayor, City of San Luis
Corey Woods
Mayor, City of Tempe
Miranda Schubert
Tucson City Councilor
Colorado
Judy Amabile
State Senator, District 18
Cathy Kipp
President Pro Tempore, State Senate, District 14
Mike Weissman
State Senator, District 28
Tracey Bernett
Former State House Representative, District 12
Monica Duran
State House Majority Leader, District 23
Cecelia Espenoza
State House Representative, District 4
Karen McCormick
State House Representative, District 11
Jacque Phillips
State House Representative, District 31
Naquetta Ricks
State House Representative, District 40
Lesley Smith
State House Representative, District 49
Elizabeth Velasco
State House Representative, District 57
Jenny Willford
State House Representative, District 34
Yara Zokaie
State House Representative, District 52
Emma Pinter
Adams County Commissioner
Carrie Warren-Gully
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Shawna Ambrose
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Ruth Stanley
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Hannah Berman
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Elise Jones
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Claire Levy
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Marta Loachamin
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Taishya Adams
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Laurie Anderson
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PT Wood
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Flor Alvidrez
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John Clark
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Polly Kroger
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Thomas McCracken
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Scott Fetchenhier
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Anne Brown
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Galena Gleason
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Lance Waring
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Karn Stiegelmeier
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Regina Lopez-Whiteskunk
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Amber Hott
Westminster City Councilor
Idaho
Carrie Semmelroth
State Senator, District 17
Monica Church
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John Gannon
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Suzanne Wrede
Bellevue City Councilor
Muffy Davis
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Angenie McCleary
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Hayden Paulsen
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Montana
Christopher Pope
State Senator, District 33
Bob Carter
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Shelly Fyant
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Jamie Isaly
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Eric Matthews
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Debo Powers
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Jane Weber
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Emma Bode
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Juanita Vero
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Sean McCoy
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Nevada
Lisa Schuette
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Tick Segerblom
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Debra March
Former Mayor, City of Henderson
Devon Reese
Reno City Councilor
New Mexico
Randall Vicente
Pueblo of Acoma Former Governor
Mimi Stewart
Senate President Pro Tem, District 17
Carrie Hamblen
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Natalie Figueroa
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Pamelya Herndon
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Marian Matthews
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Andrea Romero
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Angelica Rubio
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Liz Thomson
State House Representative, District 24
Tammy Fiebelkorn
Albuquerque City Councilor
Sierra Asamoa-Tutu
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Alicia Edwards
Former Grant County Commissioner
Beverly Michael
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Randall Ryti
Los Alamos City Council Chair
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Anna Hansen
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Hank Hughes
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