Comment on FR Doc # 2026-12734

I am writing in opposition to the proposed rule revising 43 CFR Parts 3000, 3100, 3110, 3120, 3130, 3140, 3150, 3160, and 3180 (Docket No. BLM-2025-0037; 91 FR 38084). 1. Slashing bond amounts shifts cleanup costs onto taxpayers (43 CFR 3104.1). The rule would return minimum bonds to pre-2024 levels, cutting the per-lease bond from $150,000 back to $10,000 — a roughly 93% reduction. Those older amounts were set decades ago and consistently proved too small to cover actual plugging and reclamation costs, a gap that has already left the public paying to clean up wells abandoned by insolvent operators. Cutting bonds back to that level doesn't reduce burden — it transfers financial risk from industry to taxpayers. 2. Reintroducing noncompetitive leasing undervalues public land (43 CFR Part 3110). Competitive bidding exists to ensure the public gets fair market value when its resources are leased for private extraction. A noncompetitive pathway invites parcels to be leased cheaply with little price discovery, reducing revenue returned to the Treasury and to states that share lease income. 3. Shortening public participation periods weakens oversight (Section 3120.42). Compressing the time available to review proposed lease parcels limits the ability of local governments, Tribes, and affected communities to flag conflicts with water resources, wildlife habitat, or cultural sites before leases are finalized. 4. Eliminating leasing-preference criteria removes a conflict-avoidance tool. The 2024 rule's criteria helped BLM prioritize lower-conflict parcels for leasing. Removing that screen increases the odds that contested parcels reach auction, generating the protests, litigation, and delay the rule claims to be trying to avoid. For these reasons, I urge the BLM to withdraw the proposed reductions to bonding and public participation timeframes, or at minimum to retain bond levels sufficient to cover real reclamation costs and preserve existing comment periods.