Coalition Comments on Parcels Under Consideration for Inclusion in the BLM Montana-Dakotas 2025 Fourth Quarter Oil and Gas Lease Sale – The Coalition To Protect America's National Parks

ELECTRONIC TRANSMISSION – NO HARD COPY TO FOLLOW

Submitted on-line via: https://eplanning.blm.gov/eplanning-ui/project/2036978/595/8021033/comment

April 1, 2025

Bureau of Land Management
Montana/Dakotas State Office
Attention: Hattie Payne
5001 Southgate Drive
Billings, MT 59101

Re: Scoping comments on parcels under consideration for inclusion in the BLM Montana-Dakotas 2025 Fourth Quarter (October) Oil and Gas Lease Sale (DOI-BLM-MT-0000-2025-0003-EA)

To whom it may concern:

Thank you for the opportunity to submit these scoping comments on parcels under consideration for inclusion in the Bureau of Land Management’s (BLM’s) Montana-Dakotas 2025 Fourth Quarter (October) Oil and Gas Lease Sale. The Coalition to Protect America’s National Parks (Coalition) is comprised of more than 3,700 members, all of whom are retired, former or current National Park Service (NPS) employees or volunteers who collectively represent more than 50,000 years of national park management experience. The Coalition studies, educates, speaks and acts for the preservation of America’s National Park System. The Coalition and our members are deeply invested in the protection of national parks, including in the management of public lands surrounding the parks, so that they can survive for generations to come.

As the BLM prepares for this lease sale and evaluates which parcels to offer for lease, we wish to remind the agency of its obligations under existing law and policy, including the final Fluid Mineral Leases and Leasing Process Rule (Leasing Rule) implementing program reforms and provisions in the Inflation Reduction Act.¹ In carrying out this lease sale, the BLM must comply with all applicable federal, state, and local laws and regulations.

Of the 7 parcels covering 3,001.31 acres, for the reasons discussed below, we recommend designating as low preference and deferring at least 3 parcels, one of which borders and two of which are in close proximity to, Theodore Roosevelt National Park (TRNP):

- ND-2025-10-0782
- ND-2025-10-6882
- ND-2025-10-6884

I. Oil and gas development is not compatible with the sensitive and valuable recreational, historical, and wildlife habitat resources that are conserved within Theodore Roosevelt National Park.

Established as Theodore Roosevelt National Memorial Park² by act of Congress in 1947, the site preserves the landscape that inspired Theodore Roosevelt to adopt a conservation ethic. As president, he set aside more than 230 million acres of public land for future generations. In 1978, the area was given national park status when President Carter signed Public Law 95-625 that changed the memorial park to Theodore Roosevelt National Park (TRNP). This same law placed 29,920 acres^[1] of the park under the National Wilderness Preservation System.

Under NPS planning guidelines, every unit of the National Park System is to have a foundational document that will provide basic guidance for planning and management decisions. The core components of a foundation document include a brief description of the park as well as the park’s purpose, significance, fundamental resources and values, other important resources and values, interpretive themes, and resource-related concerns including threats to park resources. The 2014 Foundation Document^[1] (Document) for TRNP identifies oil and gas development surrounding the park as TRNP’s “most significant parkwide issue.” The Document also identifies the park’s “fundamental resources and values” that are essential to protect, which include night skies, clean air, and wilderness qualities. These offer exceptional beauty, silence, and solitude, and encourage personal growth, inspiration, and healing, just as they did for Theodore Roosevelt in the 1880s. Specifically, protecting wilderness values is central to the purpose of the park and is a reflection of the conservation ethic advocated by Roosevelt. In addition to the designated wilderness, the park’s remote setting, natural soundscape, and rugged topography create a sense of solitude for visitors throughout the park’s three units.

Seventy-five (75) percent of the lands available for leasing in the Little Missouri National Grassland that borders TRNP on all sides have already been leased for oil and gas development.³

The Document repeatedly identifies “oil development on private, state, and federal lands around the park” as a significant threat to park resources and values. Specific statements of concern include the following:

- Hydraulic fracturing technology has unleashed a wave of oil development on private, state, and federal lands around the park. This energy boom is expected to continue for decades. Many new people have moved into western North Dakota, bringing traffic, permanent and temporary residential developments, and social problems. Consequently, this boom is creating significant challenges for the park. (p. 5)
- Widespread and Severe Impacts of Encroaching Energy Development and Associated Industrial Infrastructure. Oil and gas development in the surrounding area is the most significant parkwide issue. (Emphasis added) North Dakota is experiencing rapid oil and gas development in the Devonian-Mississippian Bakken Shale using hydraulic fracturing technology. The state now ranks second in the nation in total oil production, accounting for nearly 10% of all U.S. production. As of early 2014, there were approximately 10,000 producing wells in the state. McKenzie and Billings counties—where the park is located—account for roughly 25% of this total. It should be noted, however, that the number of producing wells in this region changes constantly. Other oil and gas deposits near the park are likely to become economically viable in the near future, including the Devonian Three Forks Formation and Pennsylvanian Tyler Formation. Altogether, North Dakota estimates another 40,000 wells will be drilled in the state during the coming decades. The implication is that oil and gas wells and infrastructure will continue to proliferate across the landscape surrounding the park.
- The direct and indirect impacts on park resources and the visitor experience during seismic, drilling, and production activities include air emissions, increased noise, night sky degradation, and operations intruding upon the viewshed. Most notably, oil and gas wells, flares, and infrastructure are already present within the viewshed in all three park units. Infrastructure build-out and transportation issues—for example, each new well requires an average of 2,000 trucking events—create impacts well beyond the areas of drilling and production and affect the local communities, park visitors, and park staff.
- The socioeconomic impacts of the “Bakken Boom” on the park and surrounding communities are already substantial. The population in the area has grown rapidly as people from across the United States have migrated to the region. For example, in McKenzie County, the population officially grew by nearly 60% between 2000 and 2012, from 5,737 to 7,987 people. However, there are currently more than 9,500 people living within a three-mile radius of the North Unit’s gateway town of Watford City, a town that consistently had approximately 1,700 people for many years. Currently, homeowner vacancy rates in the county are 0.4% and rental vacancy rates are 0%. Rapid development of rural and agricultural areas; increased semi-truck traffic on local roads; increased crime; increased costs for housing, goods, and services; strain on infrastructure such as storm and wastewater systems; and additional impacts to soil, water, and air resources affect areas adjacent to all three of the park’s units and its gateway communities. Housing availability and high costs have already affected the recruitment and retention of park staff, and very high occupancy rates and high prices in hotels prohibit many park visitors from staying near the park.
- Identifying and responding to the effects of oil and gas development is highly taxing on the park’s managers and staff. For example, building cooperative relationships with adjacent landowners and federal and state agencies requires a substantial investment of staff resources. Participating in the public hearings held by local and state agencies is another vital, but time-consuming activity. Case-by-case mitigation of individual wells—which is typically accomplished by negotiating directly with drilling permit holders—has produced positive results, but is not sustainable. The potential demands on park staff become even more pronounced when the expected increase in the number of wells is considered. (pp. 14-15)
- Scenic Views and Clean Air. Theodore Roosevelt National Park’s night skies, clean air, and wilderness qualities offer exceptional beauty, silence, and solitude, which encourage personal growth, inspiration, and healing, just as they did for Theodore Roosevelt in the 1880s… At the boundaries of the park, energy development is negatively impacting viewsheds and air quality. Oil and gas wells, storage tanks, drill rigs, flares, and related infrastructure outside park boundaries are visible from all three units of the park… oil and gas development and the associated flares, wells, rigs, and road/highway noise are expected to continue for the next 20–30 years.Drilling activity is expanding and is currently affecting park resources and values in all three park units. Infrastructure build-out and transportation issues create impacts well beyond the areas of drilling and production and are affecting the local communities, park visitors, and park staff. Due to budget reductions and the associated staffing impacts, the park may lose its capacity to effectively evaluate the impacts of new oil and gas proposals and take proactive steps to mitigate impacts… Continued energy and industrial development around the park could degrade the park’s air quality, which would in turn degrade visibility of scenery, wildlife health, and visitor experience. Continued energy and industrial development around the park will continue to degrade park viewsheds and soundscapes. Direct and indirect impacts on park resources and visitor values during seismic, drilling, and production activities include air emissions, night sky degradation, and operations intruding upon the viewshed. (pp. 23-24) (Emphasis added to underlined sections)
- The Theodore Roosevelt Wilderness and Wilderness Qualities Throughout the Park. Theodore Roosevelt National Park’s night skies, clean air, and wilderness qualities offer exceptional beauty, silence, and solitude, which encourage personal growth, inspiration, and healing, just as they did for Theodore Roosevelt in the 1880s… At the boundaries of the park energy development is negatively impacting soundscapes. Pump jack noise and diesel generators are audible at locations in the South Unit, both in wilderness and nonwilderness areas. Semi-truck and railroad noise are clearly audible at multiple sites within the park, especially in the South Unit… Oil and gas development is increasing in the areas surrounding the park. It occurs in multiple locations and will continue for the foreseeable future… Energy development outside the park threatens the wilderness character of the Theodore Roosevelt Wilderness as well as the quiet and chance for solitude in other areas of the park such as the Elkhorn Ranch. These threats impact the whole park but may be seen as especially damaging to designated wilderness because the National Park Service is legally required to manage for the preservation of wilderness character. The designated wilderness is relatively small and extends right to the boundary of the park in many places, which makes it especially susceptible to energy development impacts (energy development could be located a very short distance from, and within view of designated wilderness). The character of the natural landscape (generally open, with few trees) also makes it susceptible to these impacts. (pp. 26-27) (Emphasis added)

In addition to the many concerns expressed in the Foundation Document, a 2017 study ⁴ prepared on behalf of the National Park Service (NPS) found that “the damaging effects of [encroaching oil and gas development] on viewscapes, soundscapes, and air quality” contrast with the “solitude, quiet, and isolation of the prairie, the sense of vast openness, and the experience of black, starlit night” that characterize the park. NPS has also previously described development taking place around the park as “widespread,” “severe” and “the most significant parkwide issue.”

II. The BLM has ample authority to defer leases proposed for this sale.

The BLM has substantial authority over whether to lease agency managed lands for oil and gas development and production, and is not mandated to lease any particular parcel for those purposes. Under the Mineral Leasing Act (MLA), lands “known or believed to contain oil or gas deposits may be leased” by the Interior Department.⁵ If DOI chooses to lease lands, sales are held only “where eligible lands are available.⁶” For nearly a century, the U.S. Supreme Court and federal circuit courts have consistently recognized this “broad” and “considerable” discretion over the federal onshore leasing program.⁷ The BLM recently affirmed this plain reading of the MLA in the final Leasing Rule, clearly stating that “[a]ll lands eligible and available for leasing may be offered for competitive auction.”⁸

Thus, the BLM is not obligated to lease any specific parcel of public land for oil and gas development. The agency retains the authority to defer all lease sale parcels, even after bidding has concluded.⁹

III. The BLM must analyze the conservation and multiple use conflicts and environmental impacts associated with the proposed lease parcels, along with evaluating the deferral of parcels based on such conflicts.

The BLM must evaluate the environmental impacts of this proposed lease sale under the National Environmental Policy Act (NEPA). NEPA fosters informed decision making by federal agencies and promotes informed public participation in government decisions.¹⁰ To meet those goals, NEPA requires that the BLM “consider every significant aspect of the environmental impact of a proposed action” and inform the public of those impacts.¹¹ The BLM must take a “hard look” at the environmental effects before making any leasing decisions, ensuring “that the agency, in reaching its decision, will have available, and will carefully consider, detailed information concerning significant environmental impacts.”¹² Environmental “[e]ffects are reasonably foreseeable if they are sufficiently likely to occur that a person of ordinary prudence would take [them] into account in reaching a decision.”¹³

Where conflicts with other uses exist, the BLM must analyze the deferral of lease parcels. Under the Federal Land Policy and Management Act (FLPMA), the BLM must manage public lands for “multiple use”¹⁴ in order to “best meet the future needs of the American people” and make “the most judicious use of the land,”¹⁵ including by preventing unnecessary or undue degradation of the lands.¹⁶ In considering the environmental effects of leasing the proposed parcels, the BLM must also consider whether to defer the parcels based on conservation or other use conflicts.

IV. The BLM must determine the preference with which the proposed lease parcels should be given for lease and defer parcels found to have “low” preference for lease.

The BLM must apply leasing preference criteria, now codified in regulation, ¹⁷ to parcels being scoped for lease. While the regulations preference leasing parcels on lands “upon which a prudent operator would seek to expand existing operations”¹⁸ and on lands “with high potential for development, “¹⁹ some of these areas risk further concentrating and expanding development, exacerbating ongoing and historical degradation to the affected area and other resource values that are present. We urge the BLM to not assign a “high” preference value to proposed lease parcels that are in proximity to existing oil and gas development and/or are on lands with high development potential, if the proposed parcels are on lands where other sensitive resources are present.

For the reasons discussed below and in accordance with existing BLM policy and the law, we recommend that the BLM designate at least three of the proposed parcels as having low preference for leasing, and subsequently defer them from the BLM Montana-Dakotas 2025 Fourth Quarter (October) Oil and Gas Lease Sale. The following subsection discusses the environmental analysis we urge the BLM to include in its NEPA review and associated parcel deferral recommendations.

V. The BLM must analyze the impacts of leasing parcels adjacent to and in close proximity to Theodore Roosevelt National Park, and defer parcels from leasing on lands where development would impact the recreational, historical, and wildlife habitat resources present within the park.

Three parcels under consideration for inclusion in this sale are adjacent to or in close proximity to Theodore Roosevelt National Park, a national park that hosts open range populated by bison, horses, elk, prairie dogs, and other wildlife, numerous recreation trails, expansive views of the Great Plains, and clear, dark night skies. The BLM must provide a full analysis of the reasonably foreseeable impacts to the recreational, historical, and wildlife habitat resources present within Theodore Roosevelt National Park from development of the proposed lease parcels. Development in the immediate and close vicinity of the park could impact the visitor experience by intruding on visual resources, risking harm to the park’s historical resources, and threatening the populations of sensitive wildlife that inhabit the area.

Parcel ND-2025-10-6884 is directly adjacent to the North Unit of the park, and parcels ND-2025-10-0782 and ND-2025-10-6882 are located within 1 mile of the North Unit. All three parcels overlap lands that host fawning and foraging areas for mule deer, an ungulate species with fragile populations in TRNP.

In applying the leasing preference criteria for the parcels under consideration for inclusion in the BLM Montana-Dakotas 2025 Fourth Quarter (October) Oil and Gas Lease Sale, parcels ND-2025-10-0782, – 6882, and -6884 should, therefore, be found to have low preference for leasing. In accordance with the Final Leasing Rule, we urge the BLM to subsequently recommend these parcels for deferral and remove them from the sale.

VI. The BLM has an “absolute duty” to protect national park resources and values from BLM-managed activities on public lands adjacent to Theodore Roosevelt National Park.

In light of the many concerns summarized above, we respectfully remind the BLM that in contrast to the BLM’s “multiple use mandate” under FLPMA²⁰ national park resources and values, such as those identified in the park’s Foundation Document, are protected under the “conservation mandate” of the NPS Organic Act of 1916 and subsequent amendments. As described in NPS Management Polices 2006²¹ Section 1.4.1, “the most important statutory directive for the NPS is provided by interrelated provisions of the NPS Organic Act of 1916 and the NPS General Authorities Act of 1970, including an amendment to the latter law enacted in 1978 and commonly referred to as “the Redwood amendment.” The key management-related provision of the Organic Act is as follows:

[The National Park Service] shall promote and regulate the use of the Federal areas known as national parks, monuments, and reservations hereinafter specified… by such means and measures as conform to the fundamental purpose of the said parks, monuments, and reservations, which purpose is to conserve the scenery and the natural and historic objects and the wild life therein and to provide for the enjoyment of the same in such manner and by such means as will leave them unimpaired for the enjoyment of future generations. (54 USC § 100101(a))

As described Management Policies Section 1.4.2:

Congress intended the language of the Redwood amendment to the General Authorities Act to reiterate the provisions of the Organic Act, not create a substantively different management standard. The House committee report described the Redwood amendment as a “declaration by Congress” that the promotion and regulation of the national park system is to be consistent with the Organic Act. The Senate committee report stated that under the Redwood amendment, “The Secretary has an absolute duty, which is not to be compromised, to fulfill the mandate of the 1916 Act to take whatever actions and seek whatever relief as will safeguard the units of the national park system.” (Emphasis added)

As further explained in Management Policies Section 1.4.3:

Congress, recognizing that the enjoyment by future generations of the national parks can be ensured only if the superb quality of park resources and values is left unimpaired, has provided that when there is a conflict between conserving resources and values and providing for enjoyment of them, conservation is to be predominant. This is how courts have consistently interpreted the Organic Act.(Emphasis added)

To further reinforce the point that the Secretary and therefore the Department and its bureaus such as the BLM have a “absolute duty” to protect national park resources and values from BLM-managed activities on public lands adjacent to TRNP, it has been a longstanding opinion of the DOI Office of the Solicitor that “the Secretary of the Interior has the legal authority to reject the applications for mineral exploration if the record supports a finding that mineral development activities that might eventually follow exploration could be detrimental to the resources or values of a [national] park unit.”²²

VII. Deferring parcels adjacent to Theodore Roosevelt National Park from this sale is consistent with previous BLM action taken in 2018.

Deferring these three parcels from leasing now would be consistent with the precedent established by the North Dakota Field Office in 2018 during the first Trump Administration in which the BLM deferred a parcel adjacent to the North Unit of TRNP from leasing due to concerns about potential impacts to park resources and values, including wilderness characteristics. The Coalition and the National Parks Conservation Association (NPCA) submitted joint comments²³ about that proposed lease sale expressing significant concerns about impacts to TRNP and the Theodore Roosevelt Wilderness. The deferral decision is described on the BLM E-Planning website²⁴

under the NEPA identifier “DOI-BLM-MT-C030-2017-0133-EA.” Because the current leasing proposal involves three parcels, not just one as in the 2018 deferral, it seems likely that the current proposed action could have a similar or greater level of adverse effects on TRNP resources and values than the proposed parcel that was deferred in 2018.

For all of the reasons listed above, we, therefore, urge the BLM to defer from leasing the three parcels in the vicinity of TRNP. However, if the BLM decides to proceed with further evaluating the potential leasing of these three parcels when it prepares the environmental assessment (EA), we offer the following recommendations:

The EA should identify and evaluate the direct and indirect impacts of noise, light pollution, visual intrusion, and water quality threats of the proposed leasing on TRNP, in general, and especially to the portions of the park within the Congressionally-designated Theodore Roosevelt Wilderness.
BLM should invite the NPS to participate as a cooperating agency for the express purpose of assisting BLM with the analysis of potential impacts to park resources and values within TRNP.

VIII. Conclusion

In closing, we appreciate the opportunity to comment on this important issue. Should you have any questions about our comments, please do not hesitate to contact us.

Sincerely,

Phil Francis Signature

Philip A. Francis, Jr.
Chair of the Executive Council
Coalition to Protect America’s National Parks

1
See Inflation Reduction Act of 2022, H.R. 5376, 117th Cong. §§ 50262–50263 (2022).
2
NPS, Theodore Roosevelt National Park History, available at https://nps.gov/thro/learn/historyculture/park-history.htm
3
SDA, Northern Great Plains Management Plans Revision Draft Supplemental Environmental Impact Statement for Oil and Gas Leasing, available at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/fseprd1082964.pdf
4
NPS, January 2017 Theodore Roosevelt National Park, North Dakota Historic Resource Study, available at http://www.npshistory.com/publications/thro/hrs.pdf
5
30 U.S.C. § 226(a) (emphasis added).
6
Id. § 226(b)(1)(A) (emphases added).
7
Udall v. Tallman, 380 U.S. 1, 4 (1965) (“The Mineral Leasing Act [MLA] of 1920 . . . left the Secretary discretion to refuse to issue any lease at all on a given tract.”); United States ex rel. McLennan v. Wilbur, 283 U.S. 414, 419 (1931) (ruling that the Interior Secretary possesses “general powers over the public lands as guardian of the people,” which include the authority to deny oil and gas lease applications); W. Energy Alliance v. Salazar, 709 F.3d 1040, 1044 (10th Cir. 2013) (“The MLA, as amended by the Reform Act of 1987, continues to vest the Secretary with considerable discretion to determine which lands will be leased.”); New Mexico ex rel. Richardson v. BLM, 565 F.3d 683, 710 (10th Cir. 2009) (“It is past doubt that the principle of multiple use does not require BLM to prioritize development over other uses. . . . Development is a possible use, which BLM must weigh against other possible uses including conservation to protect environmental values. . . .”); Bob Marshall Alliance v. Hodel, 852 F.2d 1223, 1230 (9th Cir. 1988) (“[T]he Mineral Leasing Act gives the Interior Secretary discretion to determine which lands are to be leased under the statute. . . . Thus refusing to issue the . . . leases . . . would constitute a legitimate exercise of the discretion granted to the Interior Secretary under that statute.”); McDonald v. Clark, 771 F.2d 460, 463 (10th Cir. 1985) (“It is clear that the Secretary has broad discretion in this area. While the statute gives the Secretary the authority to lease government lands under oil and gas leases, this power is discretionary rather than mandatory.”); Burglin v. Morton, 527 F.2d 486, 488 (9th Cir. 1975) (“The permissive word ‘may’ in Section 226(a) allows the Secretary to lease such lands, but does not require him to do so. Although Section 226(c) requires the Secretary to issue the lease to the first qualified applicant if the land is leased, the Secretary has discretion to refuse to issue any lease at all on a given tract.”).
8
89 Fed. Reg. 30,916, 30,985 (Apr. 23, 2024).
9
See McDonald v. Clark, 771 F.2d 460, 463 (10th Cir. 1985) (holding that the “fact that land has been offered for lease does not bind the Secretary to actually lease the land, nor is the Secretary bound to lease the land when a qualified applicant has been selected”); see also Justheim Petroleum v. Dep’t of Interior, 769 F.2d 668, 671 (10th Cir. 1985) (language in 30 U.S.C. § 226 mandating that “lands to be leased … shall be leased to the highest responsible qualified bidder” did not require issuing a lease, but only required awarding lease to that bidder “if [the Secretary] is going to lease at all”); Western Energy All. v. Salazar, No. 10–cv–0226, 2011 WL 3737520, *3–6 (D. Wyo. June 29, 2011) (holding that BLM is not required to issue leases after offering them at auction; it only needs to make a decision within 60 days on whether to issue the leases); 89 Fed. Reg. at 30,945 (“[T]he Secretary retains the discretion to decide, even after lands have been determined to be eligible and available, what lands will ultimately be offered for lease.”). The permanent injunction on the leasing “Stop” issued by the District Court for the Western District of Louisiana does not alter this vast discretion. The scope of the injunction does not cover “Lease Sales cancelled or postponed after March 24, 2021, and as to any lease sales involving non-plaintiff states,” which precludes Wyoming, New Mexico, Colorado, and Nevada, among others. See Louisiana v. Biden, No. 2:21-CV-00778, 2022 U.S. Dist. LEXIS 148570, at *42 (W.D. La. Aug. 18, 2022). Further, the order enjoins the Administration only from implementing “a Stop . . . as set forth in Section 208 of Executive Order 14008.” Id. The injunction thus poses no obstacle to Interior deferring parcels or completely canceling a lease sale for other reasons.
10
See Balt. Gas & Elec. Co. v. NRDC, 462 U.S. 87, 97 (1983).
11
Id. (internal citation omitted); accord Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, Inc., 435 U.S. 519, 553 (1978).
12
See Robertson v. Methow Valley Citizens Council, 490 U.S. 332, 349-50 (1989).
13
See Sierra Club v. FERC, 867 F.3d 1357, 1371 (D.C. Cir. 2017) (internal quotation omitted).
14
FLPMA § 102(a)(7), 43 U.S.C. §§ 1701(a)(7)-(8), 1702(c), 1702(h).
15
Id. at § 103(c).
16
43 U.S.C. §§ 1732(b).
17
43 C.F.R. § 3120.32
18
43 C.F.R. § 3120.32(a).
19
43 C.F.R. § 3120.32(e).
20
FLPMA § 102(a)(7), 43 U.S.C. §§ 1701(a)(7)-(8), 1702(c), 1702(h).
21
NPS 2006 Management Policies, available at https://www.nps.gov/orgs/1548/upload/ManagementPolicies2006.pdf.
22
See DOI Solicitor Opinion # M-36993,# which is commonly referred to as “the Doe Run opinion.”
23
CPANP, Coalition Comments on Proposed Oil and Gas Leasing Near Theodore Roosevelt NP (October 29, 2017), available at https://protectnps.org/2017/11/01/coalition-comments-on-proposed-oil-and-gas-leasing-near-theodore-roosevelt-np/
24
BLM, March 13, 2018 Oil and Gas Lease Sale, available at https://eplanning.blm.gov/eplanning-ui/project/87486/510