Comments on Applications for Permit to Drill in the Bakersfield Field Office

Earthjustice and several partner organizations request that the BLM defer approval of oil and gas drilling permits in Kern County, California. They argue the BLM has violated the National Environmental Policy Act (NEPA) and other laws by failing to provide public comment periods on Environmental Assessments (EAs). The statement highlights severe public health risks to environmental justice communities in Kern County, including high rates of asthma and cancer, and argues that the BLM's air emissions estimates are unrealistically low and violate the Clean Air Act. It further demands a 'hard look' at water scarcity, groundwater contamination from unlined waste pits, and the climate impacts of carbon-intensive California crude. Finally, it asserts that new drilling threatens the critically imperiled Temblor legless lizard.

• The BLM's process for issuing APDs violates public participation requirements of NEPA, FLPMA, and the MLA by approving permits without providing draft EAs for public comment or decision records until after approval.
• Kern County is identified as a significant environmental justice community where 65 percent of residents are people of color and 47 percent are considered low-income.
• Oil and gas operations in Kern County contribute to severe respiratory issues; by 2035, drilling is expected to account for 40 percent of fine particulate matter (PM2.5), 70 percent of nitrogen oxide, and 97 percent of sulfur dioxide emissions county-wide.
• The BLM's per-well emission estimates for the San Joaquin Valley are argued to be unrealistically low; for example, the BLM's 2020 average NOx estimate for one well in the development stage was 0.357 TPY, whereas Kern County Zoning EIR estimates were 2.79 TPY.
• The BLM has allegedly failed to perform required Clean Air Act conformity determinations for APDs in the San Joaquin Valley, which is designated as 'extreme' nonattainment for ozone.
• Kern County faces severe water scarcity and pollution, with the second highest number of community water systems in California relying on contaminated groundwater.
• The use of unlined waste pits for wastewater in California is a major threat to groundwater; over 200 unlined pits in the Central Valley were operating without permits as of April 2015.
• California crude oil is highly carbon-intensive, with three-quarters of production having GHG emissions comparable to Canada's tar sands crude.
• The document argues that the BLM must adopt a 'managed decline' of federal oil and gas production, reducing production by 10 percent annually from 2021 to 2029 and 3 percent thereafter to align with 1.5 degrees Celsius warming targets.
• The Temblor legless lizard (Anniella alexanderae) is a critically imperiled microhabitat specialist whose range is primarily threatened by oil and gas development.

APA

Earthjustice (2022). Comments on Applications for Permit to Drill in the Bakersfield Field Office. https://earthjustice.org/wp-content/uploads/2022-8-29_comments_bakersfield_apds.pdf

Chicago

Earthjustice. Comments on Applications for Permit to Drill in the Bakersfield Field Office. 2022. https://earthjustice.org/wp-content/uploads/2022-8-29_comments_bakersfield_apds.pdf.

Wikipedia

{{cite press release |author=Earthjustice |title=Comments on Applications for Permit to Drill in the Bakersfield Field Office |date=29 August 2022 |url=https://earthjustice.org/wp-content/uploads/2022-8-29_comments_bakersfield_apds.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{earthjustice2022comments, author = {{Earthjustice}}, title = {{Comments on Applications for Permit to Drill in the Bakersfield Field Office}}, publisher = {Earthjustice}, year = {2022}, month = aug, url = {https://earthjustice.org/wp-content/uploads/2022-8-29_comments_bakersfield_apds.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }