Comment on FR Doc # 2026-12738

Opposition to BLM-2025-0235: Elimination of Methane Waste Prevention Standards Dear Secretary Burgum and BLM, I oppose the proposed revisions to the Waste Prevention Rule (renamed "Royalty for Oil and Gas Lost from Onshore Federal and Indian Leases"). These changes systematically eliminate oversight of methane emissions while directly harming Indian tribes through lost royalty revenue. The rollbacks are indefensible. 1. Eliminating Waste Minimization Plans Removes the Primary Incentive to Reduce Methane Emissions. The 2024 rule required operators to submit waste minimization plans with permit applications, creating accountability for flaring and venting decisions. Removing this requirement eliminates the strongest driver for operators to invest in gas capture instead of release. This isn't "streamlining"—it's abandoning a core conservation mechanism that costs operators almost nothing to comply with but reduces methane emissions substantially. The proposed rule offers no analysis of how much additional methane will be released by eliminating these plans. 2. Expanding "Unavoidable Losses" Reduces Royalties Without Justification. By broadening the definition of "unavoidable" losses, the rule allows operators to claim more gas was lost "unavoidably" and thus doesn't owe royalties. This transfers public wealth directly to private operators. The rule provides no technical or economic justification for the expansion. Given that modern capture technology can economically capture ~40% of vented/flared gas, this definitional change is arbitrary. 3. This Rule Violates DOI's Fiduciary Duty to Indian Tribes. Tribal nations receive a portion of oil and gas royalties from leases on Indian lands. Reducing the royalty base by eliminating waste minimization requirements and expanding unavoidable-loss definitions directly reduces tribal revenue. This is a violation of DOI's fiduciary responsibility under the Mineral Leasing Act. 4. Eliminating Leak Detection and Repair (LDAR) Programs Increases Benzene and Other Hazardous Emissions. LDAR requirements ensure that operators find and repair methane leaks on an ongoing basis. Eliminating LDAR removes the mechanism that prevents chronic emissions from operational failures. Methane is not the only gas released—benzene and other volatile organic compounds (VOCs) also escape during flaring and venting, causing respiratory harm to communities near wells. Reject this rule. The 2024 Waste Prevention Rule should remain in place and be enforced fully. Sincerely, Joshua Goldberg