Ray Trejo <district1@lunacountynm.us>; Chris Brice <cbrice@lunacounty.gov>; Christie Ann Harvey <district3@lunacountynm.us>; jenifer.jones@nmlegis.gov <jenifer.jones@nmlegis.gov>; Colette Chandler <district2@lunacountynm.us>
Subject:
Re: DOI-BLM-NM-L000-2026-0002-EA – Q2 2026 Competitive Geothermal Lease Sale
Submitted to: Bureau of Land Management, Las Cruces District Office
Re: DOI-BLM-NM-L000-2026-0002-EA – Q2 2026 Competitive Geothermal Lease Sale
Public Comment Period: April 27 – May 11, 2026
Contact: BLM Natural Resource Specialist Cody McCullah, 505-954-2027
I am a resident of Luna County, New Mexico, and I am submitting this comment in support of responsible geothermal development in our region, with specific requests that the BLM strengthen provisions in this lease sale to protect Luna County's long-term economic and environmental interests.
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I. LUNA COUNTY'S ECONOMIC CONTEXT DEMANDS COMMUNITY ACCOUNTABILITY
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Luna County has a poverty rate of 26% — more than double the national average — and over 20% of our residents are 65 or older, many living alone on fixed incomes. Any development of public lands in our county must be evaluated against this backdrop. Geothermal development has real potential to benefit our community: lease bids, annual rents, and royalties directed to Luna County represent a meaningful and recurring revenue stream. Unlike solar development, geothermal plants also pay property taxes — estimated at approximately $10,000 per megawatt per year — which could directly fund local schools and services over a 30-50 year plant lifetime.
However, the employment benefits require scrutiny. While the geothermal industry generates approximately 34 jobs per megawatt over a full project lifecycle, permanent on-site operations jobs amount to only 1.17 to 1.7 per megawatt. Construction jobs — numbering around 6 per megawatt — are temporary. In a community with a predominantly Hispanic workforce and limited technical training infrastructure, the highest-paying permanent jobs risk going to workers recruited from outside the county without deliberate planning to prevent it.
The BLM's own 2024 Renewable Energy Rule established a precedent for workforce accountability by providing fee reductions to solar and wind developers who used Project Labor Agreements. We ask that the BLM apply the spirit of that precedent to geothermal development in Luna County.
Request 1a: The EA should explicitly analyze the local economic benefit to Luna County residents — not just regional or statewide economic impacts — including a realistic assessment of how many permanent jobs would likely be filled by local residents given current workforce skill levels.
Request 1b: The BLM should require that any lessee submitting a Utilization Plan for development within Luna County address, as part of that plan, how it intends to engage local workforce development institutions — including community colleges and vocational programs — in recruiting and training local workers. This is not a lease stipulation but a reasonable condition of Utilization Plan approval, consistent with BLM's authority to require plans that serve the public interest.
Request 1c: The BLM should notify Luna County commissioners of any approved Utilization Plan affecting county lands, and provide the county an opportunity to negotiate a Community Benefits Agreement with the lessee prior to construction commencement. Several states and counties have established this practice in connection with large-scale energy development on public lands, and Luna County's economic vulnerability makes such an agreement especially warranted here.
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II. THE TRACK RECORD OF BIDDERS WARRANTS SCRUTINY
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A review of the 2021 BLM New Mexico geothermal lease sale registered bidders reveals that of the six participants, only one — Raser Power Systems — has actually constructed geothermal power plants, and that company filed for Chapter 11 bankruptcy following the failure of its flagship Thermo 1 project in Utah. Other registered bidders included land administration companies, a royalty investment firm, and entities with no documented geothermal development experience. Notably, Federal Abstract Company — a Santa Fe-based oil and gas title firm — won the only competitive bid in a prior New Mexico geothermal sale, paying $6 per acre for a Hidalgo County parcel, generating just $9,135 in total receipts for public benefit.
This pattern suggests that geothermal leases in New Mexico are routinely bid on by speculators with no intent to develop. Of the BLM's 800+ current geothermal leases nationally, only approximately 50 are in production — roughly 6%. Meanwhile, held leases provide surface access and subsurface geological data that may be valuable for purposes well beyond geothermal energy, including mineral prospecting.
Federal regulations confirm that other parties may file mineral claims on the same lands as a geothermal lease under the Mining Law of 1872, and that geothermal exploration drilling inherently generates subsurface geological data useful for locating hard-rock minerals. Luna County and the surrounding region — including adjacent Grant and Hidalgo counties — contain known deposits of copper, silver, and molybdenum. The risk that geothermal leases in this region serve primarily as a vehicle for mineral reconnaissance rather than energy development is not speculative; it is consistent with the documented profile of prior bidders.
Request 2a: The BLM should include robust diligent development requirements in all leases issued from this sale, with clear milestones for exploration, drilling, and production, and enforceable provisions for lease cancellation where no good-faith development activity occurs within defined timeframes.
Request 2b: The BLM should require bidder qualification disclosures that include prior geothermal development experience and financial capacity to develop, not merely financial capacity to bid.
Request 2c: The BLM should monitor for and publicly disclose any overlapping or subsequent mining claims filed by geothermal lessees or their affiliated entities on the same or adjacent parcels, and report such activity to the affected county.
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III. WATER RESOURCES REQUIRE SPECIAL PROTECTION
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Luna County is an arid, high-desert environment with existing water scarcity. Geothermal power plants — particularly flash steam systems — can consume significant quantities of water for cooling. Binary cycle plants, which are more appropriate for the low-temperature resources found in this region (as demonstrated at the Lightning Dock facility near Animas), use substantially less water. However, the current EA does not appear to provide parcel-level water consumption analysis, nor does it establish binding water use limits as a condition of leasing.
In a county where agricultural water rights are already contested and municipal water supplies are constrained, any geothermal development that draws on the same aquifer systems could have serious consequences for existing users — including elderly residents on fixed incomes and small farmers.
Request 3a: The EA should include a parcel-level water use analysis for each of the 68 nominated parcels, comparing projected geothermal water consumption against existing aquifer capacity and current permitted water uses in the affected watershed.
Request 3b: Where water resources are demonstrably constrained, the BLM should require binary cycle technology as a lease stipulation, consistent with its authority to attach conditions necessary to prevent unnecessary or undue degradation of public lands and resources.
Request 3c: Any Utilization Plan approved for Luna County parcels should require the lessee to obtain all applicable New Mexico state water rights prior to construction, and to demonstrate that geothermal operations will not impair existing water rights holders.
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IV. SUPPORT FOR DEVELOPMENT WITH ACCOUNTABILITY
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I want to be clear: I support geothermal energy development in Luna County. It is a renewable, baseload resource that generates local tax revenue, creates jobs, and aligns with New Mexico's energy future. The Lightning Dock resource near Animas has demonstrated viability, and this sale represents a genuine opportunity for our community to benefit from the responsible development of public lands.
But that opportunity is only realized if lessees are genuine developers, if local residents share meaningfully in the economic benefits, and if our scarce water resources are protected. The BLM has both the responsibility and the authority to ensure these conditions are met before and after leases are issued.
The eight requests outlined above are grounded in existing BLM authority, supported by documented evidence, and tailored to the specific economic and environmental circumstances of Luna County. I respectfully urge the BLM Las Cruces District Office to incorporate them into the final EA, the FONSI, and any lease stipulations attached to parcels in this sale.
Respectfully,
Mary Meade
419 S. Silver Ave
Deming, NM 88030
850-890-6511
One Response:
Inbox
Christie Ann Harvey
To: me, and 4 others · Mon, May 4 at 12:43 PM
Thank you Mary for submitting your well-crafted request to the BLM.
Christie Ann Harvey
Chair, Luna County Board of Commissioners
District 3