CWF Comments on Oil Shale RD&D Program

Oil shale and tar sands development poses a huge threat to wildlife, including species that already are on the verge of disappearing. Hundreds of thousands of acres of vital wildlife habitats for big game and sage-grouse may be œoccupied by oil shale and tar sands projects to the exclusion of all other uses, including wildlife, perhaps for generations. Tremendous quantities of water will be required to extract and produce oil from shale and tar sands. In the arid environs of the Rocky Mountain West, the dedication of scarce water to oil shale and tar sands development poses significant risks to other important water uses including fish and wildlife.

The Wildlife Federations support Secretary Salazar’s decision to withdraw the second round of research, development and demonstration (RD&D) oil shale leasing that the Bush Administration proposed in January 2009. The critical question the Department of the Interior (DOI) must now address is whether a second round of RD&D leases should be issued at this time, and if so under what terms and with what goals. The Wildlife Federations assert that no additional federal public lands should be dedicated to this oil shale œexperiment, at least until more is known about the success or failure of the RD&D projects already authorized.


The Wildlife Federations note that DOI is under no legal obligation to issue additional leases. The Energy Policy Act of 2005 (EPAct) contained several provisions aimed at analyzing the future potential of oil shale and tar sands. EPAct does specifically direct BLM to make limited areas of land available for RD&D projects. That congressional directive has been met. In 2006, BLM issued six leases for RD&D projects in Colorado and Utah. Ground has yet to be broken on any of these projects. Further, we do not believe access to more federal public lands for oil shale RD&D is necessary. Billions of tons of oil shale are privately held, much of it by the very same companies that nominated parcels in BLM’s last round of RD&D leasing. Federations suspect that the push for additional leasing of federal oil shale resources is less about serving the public’s interest in researching new sources of energy and more about these companies’ private interests in securing control over potentially valuable public mineral reserves.

Finally, while the Wildlife Federations recognize that the extraction of energy fuels is an important component of federal public lands management, these multiple-use lands must be managed for other values as well. BLM has a duty to protect the diversity of all  native wildlife on public lands.  Protecting biological diversity can only be dealt with appropriately at the programmatic or planning level. This is the only way to ensure biological diversity is preserved and that ecosystem attributes are not œnickel and dimed to death by individually small but cumulatively significant site-specific projects. The project level is simply too small a scale for adequate exploration of impacts to the health of large ecosystems. Yet, this is precisely the course of action pursued thus far with respect to leasing for oil shale RD&D.

The Wildlife Federations remain concerned about any commitment of public lands and resources to oil shale development without a full awareness on the part of both DOI and the public of the environmental consequences of doing so. Late last year BLM released its final programmatic environmental impact statement on proposed oil shale and tar sands Resource Management Plan amendments. See BLM, Proposed Oil Shale and Tar Sands Resource Management Plan Amendments to Address Land Use Allocations in Colorado, Utah, and Wyoming and Final Programmatic Environmental Impact Statement, (September 5, 2008) [hereinafter PEIS].  The PEIS, which professes to open millions of acres of federal lands to oil shale and tar sands extraction, was “programmatic” in name only.  Its examination of environmental impacts was limited to a discussion of what one oil shale extraction project might entail.  Before DOI dedicates additional public resources, DOI must have a much better understanding of the broader public costs of developing oil shale on a commercial scale.




National Wildlife Federattion

Rocky Mountain Regional Center

2260 Baseline Road, Suite 100

Boulder, Colorado 80302



Here are excertps of the text of the comments submitted on May 28, 2009 to the BLM by National Wildlife Federation, Colorado Wildlife Federation and the Wyoming Wildlife Federation re the OIl Shale Research, Development and Demonstration Program and request for Public Comment.

MAY 28, 2009

Bureau of Land Management

Attn: Nick Douglas

Minerals and Realty Management

Mail Stop: LS 807

1849 C Street, NW

Washington, DC  20240

Dear Mr. Douglas:

The following comments on the Bureau of Land Management’s (BLM) Withdrawal of the Call for Nominations – OIl Shale Research, Development and Demonstration (RD&D) Program and Request for Public Comment (RD&D Comments) are submitted on behalf of the National Wildlife Federation and its state affiliates, the Colorado Wildlife Federation and the Wyoming Wildlife Federation [hereinafter Wildlife Federations].  As an organization, the National Wildlife Federation (NWF) represents the power and commitment of four million members and supporters joined by affiliated organizations in 47 states and territories.  NWF and its affiliates have a long history of working to conserve the wildlife and wild places on federal public lands in the West. Many members of NWF and its affiliates use the lands and resources that could be impacted by oil shale and tar sands extraction on federal public lands in Colorado, Utah, and Wyoming. The Wildlife Federations appreciate this opportunity to submit these comments to the Bureau of Land Management.