Energy

Texas congressional delegation wants federal oil & gas leasing to fire up in the state

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From the Forest Service scoping notice:

The National Forests and Grasslands in Texas (NFGT) is initiating the preparation of an environmental impact statement (EIS). The EIS will analyze and disclose the effects of identifying areas as available or unavailable for new oil and gas leasing. The proposed action identifies the following elements: What lands will be made available for future oil and gas leasing; what stipulations will be applied to lands available for future oil and gas leasing, and if there would be any plan amendments to the 1996 NFGT Revised Land and Resource Management Plan (Forest Plan).

The Forest Service withdrew its consent to lease NFGT lands from the Bureau of Land Management (BLM) for oil and gas development in 2016. The reason for the withdrawal of consent was due to stakeholder concerns, including insufficient public notification, insufficient opportunity for public involvement, and insufficient environmental analysis. There is a need to analyze the impacts of new oil and gas development technologies on surface and subsurface water and geologic resources; air resources; fish and wildlife resources; fragile and rare ecosystems; threatened and endangered species; and invasive plant management. There is also a need to examine changed conditions since the Forest Plan was published.

These leasing availability decisions are forest plan decisions that were most recently made in 1996.  The action proposed by the Forest Service would result in changes in the stipulations and would therefore require a forest plan amendment.  The changes would shift about 11,000 acres from “controlled surface use” to “no surface occupancy,” and remove timing limitations from about 35,000 acres.

A letter from five Republican members of the delegation disagrees with the premise that the 1996 analysis was inadequate, and is unhappy with the pace of the amendment process.

The published timeline anticipated a Draft EIS in the winter of 2019 with the Final EIS expected in the fall of 2020. We are concerned that this timeline is no longer achievable given current pace of progress.

We request that USFS end the informal comment period, issue a Draft EIS this spring and ultimately approve the Final EIS that reinstates BLM’s ability to offer public competitive leases of National Forest and Grasslands in Texas for oil and gas leases before the end of 2020. While USFS is required by law to respond to eligible comments received within the public comment window (CFR218.12), the Forest Supervisor also has the authority to declare the available science sound, conclude the public comment period, and proceed with the issuance of the scoping comments and alternative development workshops as the next steps ahead of a Draft EIS (CFR219.2.3, 219.3) (sic).

That last sentence got my attention as the kind of congressional attention to Forest Service decision-making that might cause them to cut a legal corner here or there (especially when there is an election coming).  I also noticed the absence of any reference to the new requirements for amendments, and maybe the delay could have something to do with this becoming evident to them as a result of scoping.  36 CFR §219.13(b)(6):

For an amendment to a plan developed or revised under a prior planning regulation, if species of conservation concern (SCC) have not been identified for the plan area and if scoping or NEPA effects analysis for the proposed amendment reveals substantial adverse impacts to a specific species, or if the proposed amendment would substantially lessen protections for a specific species, the responsible official must determine whether such species is a potential SCC, and if so, apply section §219.9(b) with respect to that species as if it were an SCC.

I found nothing in the EIS for the 1996 revision about effects of oil & gas development on at-risk wildlife species.  You’d think the new information since 1996 might have something to do with effects on climate change, too.

Batteries vs. Buckwheat: Mining for Lithium on Federal Lands

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Photo of rare buckwheat from CBD via AP.

This AP story has all the challenges of the “good industry” versus “bad industry” philosophical conundrum. We know that electric cars are good, at least if they are run off all carbon-free sources. Unfortunately, they require (as almost everything does) mining minerals to build them.

CBD says “not where they occur on federal land in Nevada, due to an endangered buckwheat.”

The company acknowledges Tiehm’s buckwheat hasn’t been documented anywhere else on earth, but denies the mine would lead to its extinction.

Company officials say they’ve been researching the plant since 2016, going to great lengths to ensure its protection and examining how it’s fared during previous mining operations at Rhyolite Ridge, near the small town of Tonopah, over the past 80 years.

They recently spent $60,000 for a yearlong study at the University of Nevada, Reno. Scientists there are growing hundreds of seedlings in a greenhouse to determine whether it’s feasible to transplant them into the wild to bolster the limited population, an estimated 43,000 plants covering a total of 21 acres (8.5 hectares).

“We have always been aware of the buckwheat. It didn’t come as a surprise,” Ioneer President Bernard Rowe told The Associated Press in a phone interview from Australia.

All site activity has been undertaken with the “protection of the buckwheat first and foremost in mind,” Rowe said. He added the company’s mitigation strategy “will ensure protection and, in fact, the expansion of the buckwheat population.”

“We’re seeing evidence of that at the greenhouse at UNR,” Rowe said. “We’ve got a reasonably high degree of confidence we can successfully propagate these plants and protect them.”

But what I thought was most interesting about this article, given our discussions about abstraction, are quotes from the scientists involved (caveat, they may have been misquoted, but I’m taking this at face value).

Leger, who also serves as director of UNR’s Museum of Natural History, said those who dismiss the flowers as weeds unworthy of all the fuss don’t understand the value of biodiversity.

“Weed is a human construct. A weed is a plant that grows anywhere a human doesn’t want it,” she said, adding biodiversity is “magic” and a safeguard against future loss.

Biodiversity is actually a human construct, as is the idea of species, especially when we get to telling closely related species apart.

I’m a little concerned with a scientist saying that that biodiversity is “magic”, though. Anyway, it’s interesting what it means to potentially lose “a species” of buckwheat that grows on 21 acres as opposed to losing “biodiversity”. Is it more compelling, or magic, or less compelling or magic?

Meanwhile, Donnelly of CBD (not a scientist) says:

He acknowledged a difference between transplanting plants and growing them from seeds, but said it’s “beside the point, really.”

“A species is more than a set of genetic material. A species is inextricable from its habitat,” Donnelly said. “To allow a species’ habitat to be wiped out and put it someplace else, is functionally allowing it to go extinct.”

I always thought ESA was about “sets of genetic material” but maybe CBD intends to raise the bar.

Failed planning for power lines on the Coconino

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(Modoc National Forest photo)

The Coconino National Forest Plan was revised in 2018.  They have just announced that a proposed powerline requires a forest plan amendment because, “The proposed power line and associated roads would not comply with the following forest plan guidance after all reasonable stipulations to minimize impacts are applied: ‘Management activities and permitted uses should be designed and implemented to maintain or move toward the desired SIOs.'” “SIOs” are “Scenic Integrity Objectives, which are forest plan components.  It also appears to conflict with several plan guidelines for special uses (though the letter doesn’t directly acknowledge that).  Nobody saw this coming during the recent plan revision?  Did the forest plan include things that really weren’t that important?  (Scenery doesn’t seem to often rise to the level of litigation.)  Is this just more “energy dominance” from the Trump administration?  The scoping letter doesn’t attempt to answer these kinds of questions.

This article includes a link to the scoping documents.  From the map, it looks like the power lines are needed as a shortcut, and is often the case, conservation lands are the easiest target.  All of the action alternatives would violate the forest plan.  A compliant alternative seems like an obvious omission.  (And there is a requirement for special use permits that locations off of the national forest be not feasible.)  While the Forest discusses burying  the line, it’s not clear that they are considering an alternative that would bury all of it in areas where it is not consistent with the scenery objectives, or whether doing so would meet them.  Of course we can’t actually tell exactly where it would violate those objectives because the scoping letter doesn’t distinguish between the areas where the objectives are “high” or “moderate,” but maybe it’s the entire route.  While the amendment would be “project specific,” meaning it wouldn’t affect future projects, does that make any sense if the landscape would no longer meet the objectives in the forest plan?  ( Some of the scenery management science is not intuitive to me.)  At least they included the amendment in scoping for the project (some have popped that out at the last minute).

This summary dismissal of the forest plan unfortunately suggests a lack of respect given to forest plans and the effort put into them.  I don’t know anything about the scenery here, or who looks at it, but if it was important enough to put into a forest plan a couple of years ago, it seems like it should be important enough to take a little more seriously now.

2016 election consequences for Colorado federal lands

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The Forest Service and Bureau of Land Management over the last several years have been developing long-term Resource Management Plans for more than 3 million acres of BLM lands in Eastern Colorado and the Uncompahgre Plateau and in the Rio Grande National Forest.  According to this article, the state and local communities are not happy.

The Trump-driven shift toward more oil and gas development on public lands worries Colorado politicians and conservation groups that are steering the state toward increased protections. Agencies within the same department seem in conflict. Long-studied plans are changing between between draft and final reports, with proposed protections fading away and opportunities for extraction growing…

“What we are seeing is the full effect — in proposed actions — of the 2016 election at the local level,” Ouray County Commissioner Ben Tisdel said.

The article goes into detail about the effects on the Uncompahgre Field Office’s proposed plan:

County commissioners from Gunnison, Ouray and San Miguel counties have filed protests with the BLM over the Uncompahgre Field Office’s proposed plan. The counties have been involved with the planning for eight years. In 2016, the counties submitted comments on the plan outlining concerns for the Gunnison sage grouse and listing parcels the agency should protect and retain as federal lands.

“Alternative E proposed doing all the things we specifically asked them not to do,” said Tisdel, the Ouray County commissioner, adding that lands his county wanted protected were listed in the 2019 plan for possible disposal by the agency. “We thought we had a pretty good product in 2016 and now we have this new alternative, Alternative E, that goes way beyond anything we had seen before and is awful in ways we never thought of before.”

With regard to the Rio Grande National Forest revised forest plan:

The move from that September 2017 Draft Environmental Impact Statement to the final version released in August has riled conservationists and sportsmen. Goals established for air quality, designated trails, fisheries management, fire management, wildlife connectivity and habitat were scaled back in between the draft and final versions.

Colorado’s governor has weighed in on the BLM plan (in language consistent with the Western Governors Association policies):

The resource management plan’s “failure to adopt commitments consistent with the state plans, policies and agreements hinders Colorado’s ability to meet its own goals and objectives for wildlife in the planning area,” Polis wrote.

The BLM had an interesting response:

“There is room to adjust within the RMP, which has a built-in adaptive management strategy,” he said. “We are ready to respond as the state’s plans are complete.”

So they plan to do whatever the state wants them to do later?  “Room to adjust within the RMP” appears to mean that they don’t have to go through a plan amendment process with the public, which seems unlikely to be legal for the kinds of changes the state appears to want.  (It definitely wouldn’t work for national forest plans.)

The Western Energy Alliance blames the governor for being late to the game:

It doesn’t get a complete do-over just because something new happens, like Gov. Polis issues a new order.”

But it does apparently get a complete do-over because a new federal government administration says so.  There may still be some legal process (e.g. NEPA) questions this raises.

Increasing Wind and Solar on Public Lands: Outside Magazine Article

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I first heard about this idea from something on Jared Polis’s (Colorado’s now-governor) website. The fundamental idea is that public lands should not be used for oil and gas production, but should be used for more wind and solar production.

It is conceivable that different uses could co-exist on public lands (at least wind, and oil and gas, and grazing) as they do on private lands in Kansas and Colorado (and no doubt elsewhere). But the case being made seems to be that one group should be removed from public lands (oil and gas) and another group increased (solar and wind). It seems that it is framed as “either/or” and not “both/and.” And yet, oil and gas production has some commonalities with solar and wind.

First, solar and wind also have environmental impacts. Second, they can also be unaesthetic, and thereby potentially incompatible with recreation. Third, they tend to impact a greater surface area of land (than oil and gas), and fourth, they may require transmission lines instead of roads. I don’t know the relative impacts, but I do know that many environmental groups don’t seem to like new roads or transmission lines on public lands. fourth, solar and wind generate electricity which can’t substitute for fuel currently used in heating and transportation immediately, so there would be a transition during which fossil fuels will come from elsewhere. For me, these are all considerations.

BLM has much information on their solar and wind programs, solar and wind.

What’s interesting about this Outside story is that it takes for granted the idea that carbon is emitted by production on federal lands, and that stopping it will simply reduce carbon emissions. If we import oil and gas from other countries and use the same amount, it is difficult for me to see that that makes a positive difference to the environment (while making a negative difference to state coffers). If importing increases prices and decreases energy security, then it might not be a good thing at all for folks who depend on oil and gas products for heating and transportation, and are on the poor end of the financial spectrum.

Here’s the link to the Outside story.

Federal lands hold tremendous untapped potential for unleashing a renewables boom and sucking down the carbon dioxide that’s warming the globe, Huntley and other energy-policy experts say. While federal lands hold significant oil, gas, and coal reserves, they also have some of the nation’s best solar and wind resources. Yet TWS estimates that less than 5 percent of U.S. power from renewables is generated on federal land. The BLM alone manages more than 20 million acres with wind-energy potential in the 11 western states. Largely because of renewable-energy pushes from previous administrations, the BLM has approved about 11,000 megawatts worth of solar, wind, and geothermal projects.

But with some significant exceptions, such as the Ivanpah megasolar facility on BLM lands in California, which went online in 2014 and now powers 140,000 homes around the West, the renewable potential of the vast open landscapes of the federal estate is underdeveloped. And if oil and gas development is phased out under a Green New Deal bill—or any other legislation that tamps down greenhouse-gas emissions—renewables development on federal lands will be crucial to replace that energy.

Renewable-energy development is not without its own environmental consequences, though. The massive Ivanpah solar-thermal project, for example—at the time the largest solar facility in the world—disturbed habitat for the desert tortoise, blue-gray gnatcatcher, and other wildlife and forever changed the scenery in the Mojave Desert. Bird and bat deaths from encounters with wind turbines are well-documented. But conservation groups say that much has been learned from Ivanpah and other renewable-development projects about how to plan, develop, and monitor them in a way that reduces their impacts. Measures adopted through legislation could ensure that new projects avoid the mistakes of the past, they say.

It’s also interesting that conservation groups think that the renewable energy industry can reduce their impacts through improved monitoring and so on. I am curious as to why some industries seem to get the benefit of the doubt with regard to the environment and public lands (solar, wind) but others do not (timber, grazing, oil and gas).

Oh, and forests are mentioned in the article as well.

New Technology Grants: 79 Mill from DOE, Including Improving Wood Heating

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What NOT to do in fire country.

 

Whatever the  color of the Administration, the relatively obscure  wheels of scientific research and development continue along well-worn paths (whether the wording of the day is “low carbon” or “affordable, reliable and secure”). As I recall from my time in R&D, scientists readily change the title, and perhaps some introductory paragraphs, and voila! Thanks to the Forest Business Network for this link.

The U.S. Department of Energy (DOE) is providing up to $79 million in funding for bioenergy research and development including biofuels, bioproducts, and biopower. This funding supports DOE’s goal of providing consumers and businesses with a range of domestic energy options that are affordable, reliable, and secure.

Topics areas for the biofuel funding opportunity include the following:

  • Cultivation Intensification Processes for Algae: Develop technologies for outdoor algae systems that increase the harvest yield, reliability and quality of algae.
  • Biomass Component Variability and Feedstock Conversion Interface: Research to lower the cost and improve the reliability of biomass handling and preprocessing.
  • Efficient Wood Heaters: Develop technologies to reduce emissions and increase efficiency of wood heaters for residential heating.
  • Systems Research of Hydrocarbon Biofuel Technologies: Integrate new technologies and processes in experimental prototype systems to improve and verify real-world performance and lower the cost of drop-in biofuels.
  • Optimization of Biomass-Derived Jet Fuel Blends: Identify and develop cost-competitive drop-in renewable jet fuel with improved energy density and lower particulate matter emissions.
  • Renewable Energy from Urban and Suburban Wastes: Support academic research and educational programs that focus on strategies to produce bioenergy and bioproducts from urban and suburban waste feedstocks.
  • Advanced Bioprocessing and Agile BioFoundry: Reduce the time and cost of developing biological processes for biomanufacturing fuels and products through the use of synthetic biology, low capital intensity methods, and continuous production systems.
  • Plastics in the Circular Carbon Economy: Develop biobased plastics with improved performance and recyclability and lower the cost and energy-intensity of recycling  existing plastics through enhanced degradation.
  • Rethinking Anaerobic Digestion: Develop anaerobic processes or alternative strategies to enhance carbon conversion efficiency and lower costs of smaller scale wet waste systems.
  • Reducing Water, Energy, and Emissions in Bioenergy: Identify biofuels or bioproducts technologies with the greatest potential for reducing water consumption, energy consumption, and/or emissions relative to existing conventional fuels or products.

This FOA also supports the Water Security Grand Challenge, a White House initiated, DOE-led framework to advance transformational technology and innovation to meet the global need for safe, secure, and affordable water. In particular, this funding will support research and development focused on anaerobic digestion, a technology that can help achieve the Grand Challenge’s goal to double resource recovery from municipal wastewater.

 

I particularly like the “wood heaters” project because there are many low-income people already use this as a primary heating source. New cool technologies are cool, of course, but making old uncool but widely used wood heat work better is also important.

Center for Western Priorities: Pushing the Boundaries of Partisan-Hood

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John Persell raised an interesting question here. It was pretty “out there” for me to say that folks like the Center for Western Priorities are “not of our world”. Certainly I can’t speak for everyone who read on The Smokey Wire.

But most of us have been involved in federal lands issues for years.  When new groups come on the scene, claiming to be non-partisan but funded by the New Venture Fund and staffed by people who worked as political staff for D candidates…er… it does raise some questions.

My experience on the Hill as a staff person, and having briefed many Congressional staff people over the years, is that some are political animals,who may not be as interested in resolving an issue as getting opportunities for their party to look good and win. That’s not to be critical, it’s just their world.  I don’t think anyone who reads what the current Congress is up to, or not up to, would disagree with this. You can’t look to Congress for technical knowledge, accuracy in their statements, nor humility about their own views. That’s not what we select them for.

This is from the Hewlett Foundation’s website:

This renewal grant will continue support for the New Venture Fund’s Center for Western Priorities. The Center is a West-wide communications effort designed to educate the media, public, and decision makers about the impacts of fossil energy development on public lands. The Center builds relationships with reporters, draws from the best polling to craft persuasive messages, rapidly responds to arguments advocating for the elimination of public land protections, steadily generates reports and news, and enlists a broad array of westerners as spokespeople. The Center also works closely with conservation organizations across the West to fill gaps in communications capacities.

Here’s what the Center for Western Priorities says about themselves:

The Center for Western Priorities is a nonpartisan conservation and advocacy organization that serves as a source of accurate information, promotes responsible policies and practices, and ensures accountability at all levels to protect land, water, and communities in the American West.

Based in Denver, Colorado, the Center advances responsible conservation and energy practices in the West. We encourage open, public debate and work to advance those discussions online, in the media, and throughout Western communities by promoting responsible solutions and original research.

Have they changed what they do since their 2015 grant from the Hewlett Foundation? That sounded like a propaganda machine with a certain end in mind. Their own description sounds more like The Smokey Wire.

I do think they do a super job of generating information. I wish The Smokey Wire had those kind of bucks to investigate things, do FOIA’s, hire journalists, develop relationships with reporters, and all that. Nevertheless, we need to ask what kind of slant they put on what they do report, and how careful they are about checking facts that support their narrative. So I think it’s fair to say “communication campaigns run by political operatives” are not the usual federal lands policy suspects. I think of them as newsfeed generators. That’s definitely not like our environmental group friends, who often are seen in the trenches participating in the various policy processes, or even our litigatory environmental group friends, whom I all consider to be “part of our world.”

The New Venture Fund organizations (Center for Western Priorities and the Western Values Project) also came upon the federal lands policy scene recently (since campaign finance reform?) and seem to be mostly about oil and gas (and, of course, denouncing all things Trump Administration.)  One wonders whether their interest in public lands policy will go away in 2020 if a certain event occurs..

Your not-so-friendly neighborhood oil and gas industry

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There sometimes seems to be an undercurrent here of the idea that environmental groups are rich bullies, and extractive industries are working for the common good, or at least are benign.   Here’s some evidence otherwise regarding the latter.

One of the industry tactics is SLAPPs, Strategic Lawsuits Against Public Participation, wherein corporations try to intimidate their opponents by filing truly frivolous lawsuits – that they can afford but the defendant can’t. Matthew posted about one involving a forest products company here.

But your friendly oil and gas industry seems to be a leader in this field. Meaning that when you pay for your heat and transportation you’re also paying for this; “Using lawsuits to shut people up has long been a part of the oil industry’s playbook…”  They lost a notable case recently when they sued youth groups (among others) after the groups won protections against neighborhood oil drilling in Los Angeles.

Many states have passed legislation to prevent this kind of intimidation of free speech, and a proposal is pending in Colorado, as described here, by an anti-drilling activist who has been SLAPPed:

I accept the urgency of climate change, and I am a proud advocate for our public lands. Many here agree with me, and together we have stood up to limit oil and gas development from expanding across the national forest and BLM lands.

The particulars of my case are unimportant here, although they can be easily researched. And I have already been found by a Colorado District Court to not have committed any actionable offense, and also awarded attorney fees for the “frivolous” and “vexatious” complaint made against me.

But all that is under appeal, and so I am still, over two years later, unduly burdened by and defending myself against this action.

Free speech is protected in our republic for good reason. Citizen input is grist for the mill of representational democracy. Dialogue and debate is a plus in pluralistic society. And this value is shared by Americans across the political spectrum. Free Speech allows people to participate robustly in government, speak truth to power, and to challenge the status quo.

Pellet Exports from California and the Northwest? Interim Findings and a Blast From the Past

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Figure 3 Chip/Pellet Facilities – Pacific Northwest from Forest2Market article linked below.

It seems like pellets and chip markets might be useful for places like California which have 1) extra small trees to think for fuel treatments (conceivably without “industrial logging”, however that is defined, and 2) access to ports.  BC seems to be taking advantage of these opportunities.

Again logically there are two options if the use is bioenergy (conceivably this material also could be used for higher-value products). The first is to burn this material for bioenergy in California (not developed well due to pollution standards) or sell to others (which as Matthew points out, involves use of (more) fossil fuels currently for transport.)  This might raise all kinds of questions about Asia, for example, and their bioburners’ pollution and climate change calculations.

Anonymous hypothesized here that maybe the answer is availability of supply.  If this sounds like a blast from the past, some of us remember the mountain pine beetle infestation in the 80’s in Central Oregon and trying to do something with the dead trees (forty years ago).  One idea was to get a waferboard plant in Chiloquin, Oregon.  This idea foundered on the shoals of .. supply dependability.  It seems like a bit of a theme.  I think it’s important not to just conflate this with “litigation about projects”, although that may be a piece of the puzzle.  Again logically, a deal could be reached to say (if material x is removed, in y kinds of places, with practices such that z does not happen, to a total amount of a per acreage b, then we will not litigate).  Even so, if I were considering investing, I would be very dubious, given our track record.  It is interesting to think how Canada can provide adequate assurances for investment but we cannot.

I haven’t yet found an expert on this topic, and am still searching, but a forest economist friend pointed me to this piece that compares the Pacific Northwest to the US south and other sources. First, the authors note that a preponderance of forest land is public compared to the Southern U.S..

One notable difference between the US South and the Northwest is the seasonal (but frequent) occurrence of severe, large-scale wildfires. This is related to a combination of climatic conditions in the PNW, ownership/management intensity and harvest restrictions, all of which have allowed for the build-up of excessive fuel loads in many forest stands. One method proven to be effective in reducing wildfire loss is through the use of fuel-reduction thinning operations, especially on public lands.

Due to this lack of forest management, one analysis estimated that up to 12 million green tons of biomass could be harvested via fuel-reduction thinning over the course of a decade. If this management practice is promoted and implemented, the increase in small log and residual material availability could spur a growth in both wood chip and pellet production.

 

Ownership/Supply Chain Characteristics

With forestland ownership being primarily public (federal, state and municipal), the fiber supply chain in the US Northwest is somewhat different than in other regions. Public land management is governed by different sets of rules and procedures, and harvesting is conducted at a reduced level compared to private land.

A large portion of private forestland is owned by timber investment management organizations (TIMOs), real estate investment trusts (REITs), and other large landownerships that supply a majority of the timber in the region. Because of the TIMO/REIT influence in the region, tract sizes are generally much larger and small tracts (under 20 acres) are less prevalent than in other regions. There are small-scale landowners as well, but they comprise a much smaller piece of the available volume.

As a result of this fragmented ownership situation, there is not a robust timber dealer/broker network. Large landowners generally negotiate delivered contracts directly with the mills, and they then pay loggers for harvesting services and transportation from the woods to the mill. While there are some stumpage sale contracts in the region, it is not a common practice as it is in the US South.

 

So there are structural problems compared to the US South (not a robust dealer/broker network) which makes it more difficult to get this material from private land, but this article doesn’t mention the “relatively assured supply” problem from public lands. Seems like if it were a good idea to sell material removed from fuel treatments that California economic development would be on it. Maybe they are.

Forest Service and BLM Processes for Oil and Gas Development 101- 2- Further Questions Answered

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This is in Wyoming.

Despite a general seeming lack of interest in this topic, I’m going to continue because this might be good basic information to have accessible when the next controversy comes up. Many thanks to a helpful individual in the Colorado BLM State Office for answers to these questions.

If there is no or little potential, as in the RFD, then why does it come to the FS in the first place (and make them do all that analysis)?
The Forest Service is responding to a lease nomination from the BLM.  Where does that come from? The BLM gets nominations from folks who are interested in getting leases.  BLM checks on some things,  including, if it is on Forest Service land, whether the area is leasable according to the Forest Service decisions, If it is, BLM forwards the lease nomination to the Forest Service. (Reasonable Foreseeable Development) RFDs do not always keep pace with changes in the industry. An area with low potential might become commercially viable due to changes in drilling and fracking technology, or the discovery of new reserves.
Note that an RFD is an analysis associated with a NEPA decision such as an RMP (Resource Management Plan), somewhat along the lines of a forest management plan.
Which leaves us necessarily with the question:
How often are RMP’s updated?
RMPs typically are in place for 20-30 years in between plan revisions. RMPs are updated from time to time to address maintenance actions or specific issues that were not adequately addressed in the plan.  (very similar to forest management plans).
Why would a company nominate a lease parcel and then not bid on it?
Nominations are anonymous until after the lease sale. Why a company would nominate a parcel and then not bid would be a question better answered by the private sector. (Maybe I can find someone from the industry to answer this, but if it takes a while to nominate, forward, analyze and put out the lease,  it could be changes to the nominators own conditions or analysis.)
How long does a no-leasing decision (such as the decision described for the Ruby Mountains) last?
 The Forest Service can decide to concur or not concur with a private sector nomination that is being handled by the BLM. If the Forest Service does not concur with leasing, the nomination in questions would not be offered. Unless the USFS changes the forest plan, that area is still open to leasing and future nominated parcels would still be processed by the BLM and potentially presented to the USFS for the concurrence.
What’s the overall timeframe for the nomination to be processed by the BLM and sent to the FS?
It can vary quite a bit based on BLM workload and the complexity of the parcel request. Anywhere from a few weeks to a few months.
What is the timeframe for the FS to make the leasing availability decision?  In the Ruby Mountains example, the nomination was received in 2017, they issued an EA in 2018 and the final decision was March 2019.
***********************************************************************
What were some things in the forest plan specifically about oil and gas leasing? (from the 2018 EA here).
Forest Plan Desired Conditions:
*The number of leases, permits and operating plans is expected to increase slightly throughout the life of
the plan. Withdrawals and legislative requirements will restrict mineral development on 356,888 acres.
*The Forest will expedite the processing of oil and gas lease applications and locatable mineral proposals.
*Leasable mineral/energy applications will be evaluated on an individual basis. The decision to lease and
site-specific stipulations will be determined on a site-by-site basis. Development activities will be
addressed by an interdisciplinary field analysis and environmental assessment.
Forest Plan Goals:
Goal #36- Administer the mineral resources of the Humboldt National Forest to provide for the needs of
the American people and to protect and conserve other resources.
Goal #38- Expedite oil/gas and geothermal activities.
Goal #39- Reduce the backlog of oil and gas lease applications.
Goal #40- Integrate the exploration and development of mineral and energy resources with the use and
protection of other resources. Use special stipulations identified in Appendix H (of the Forest Plan) for
mineral leases.
**************************************
Two years seems pretty, fast as FS NEPA analyses go, so it looks like the HT is following the forest plan.  As an observer of other NEPA processes, though, it seems that the nominator of the parcel gets much NEPA work done and then can simply not bid on the parcel with no loss to them, unlike examples of other kinds of proponents funding “third party NEPA.”  While it is understandable that technical and economic conditions can change, it seems like the FS has more skin in the game than the nominator or the BLM, analysis-work wise. Perhaps nominators should have to front a certain amount of the analysis money as their contribution?