Taxpayers for Common Sense (TCS) appreciates the opportunity to submit comments on the Bureau of Land Management’s (BLM) Proposed Rule, National Petroleum Reserve in Alaska Production Site Development and the associated Draft Chapters 1 and 2 of the Environmental Impact Statement (Draft EIS, DOI-BLM-AK-0000-2026-0012-EIS).

Since 1995, TCS has served as a nonpartisan budget watchdog dedicated to ensuring that federal resources are managed responsibly and that taxpayers receive a fair return on public assets we own and do not shoulder the costs and liabilities of industry operations.

TCS supports efforts to improve efficiency that would better support the responsible management of publicly owned assets. However, the Proposed Rule would expose federal taxpayers and local communities to long-term risks and liabilities of oil and gas infrastructure and operations without allowing the public to provide input on such projects. By replacing site-specific reviews with a standardized, 60-day administrative rubber stamp across up to 17.9 million acres of sensitive Arctic landscapes, this Proposed Rule would expose federal taxpayers and local communities to the long-term financial and environmental risks and liabilities, limit public participation, and negatively affect local subsistence, hunting and angling economies.

For these reasons, TCS opposes the Proposed Rule as currently drafted (analyzed as Alternative B in the Draft EIS) as well as Action Alternatives C and D. TCS urges BLM to withdraw the Proposed Rule and select Alternative A in the Final EIS to protect taxpayers from long-term costs and liabilities.