ELECTRONIC TRANSMISSION – NO HARD COPY TO FOLLOW
April 28, 2025
The Honorable Doug Burgum, Secretary
Department of the Interior
1849 C Street, N.W.
Washington DC 20240
Subject: Proposed oil and gas leasing on BLM lands adjacent to Theodore Roosevelt National Park
Dear Secretary Burgum:
I am writing to you today on behalf of the Coalition to Protect America’s National Parks, a non-profit organization comprised of over 4,000 current, former, and retired employees and volunteers of the National Park Service. Collectively, our membership represents over 50,000 years of national park management and stewardship experience. Recognized as the Voices of Experience, the Coalition educates, speaks, and acts for the preservation and protection of the National Park System, and mission-related programs of the National Park Service (NPS).
We appreciate your past public statements about your North Dakota upbringing and your reverence for North Dakota’s “omnipresent natural beauty, including the rugged majesty that is the Theodore Roosevelt National Park, home to TR’s Elkhorn Ranch, which is considered the cradle of modern conservation.” We share your passion for Roosevelt’s conservation ethic, which is why we are writing to you now.
We wish to make you aware that the Bureau of Land Management (BLM) has issued a proposed oil and gas lease sale for September 2025 that would lease 29 parcels for oil and gas drilling in Montana and North Dakota, including 3 parcels in close proximity to Theodore Roosevelt National Park (TRNP). The 3 parcels include: 1) A 673-acre parcel that directly adjoins the southern boundary of the Theodore Roosevelt Wilderness Area in the North Unit of the park; 2) A 39-acre parcel that abuts the first parcel and is located only 1 mile from the park’s wilderness boundary; and 3) A 40-acre parcel located less than 8 miles from the Elkhorn Ranch Unit of the park.
In general, BLM’s Draft Environmental Assessment (Draft EA) for the lease sale provides very little analysis of potential impacts to TRNP’s resources and values. Of particular concern is that the Draft EA “considered but did not analyze” potential impacts to wilderness despite the fact that two parcels are in close proximity to the TRNP wilderness area. In striking contrast to this Draft EA, the BLM prepared an EA for a proposed March 2018 lease sale of a parcel adjoining the north boundary of the Theodore Roosevelt Wilderness Area in the North Unit of the park. That EA identified a variety of potential adverse impacts to the park’s resources and values; and based, in part, on that assessment, BLM ultimately made the decision in 2018 to “defer” on leasing the parcel, thus protecting the wilderness character within the park.
As Secretary, you have enormous responsibility for managing and conserving America’s vast public lands through the DOI agencies operating under a variety of different legal mandates. We understand it is also your role to lead the development and implementation of the Administration’s energy dominance agenda. However, we hope that such ambition could be tempered by a genuine commitment to Roosevelt’s conservation ethic that results in responsible management and avoids conflicts with specially protected places and resources such as those found in national parks. In this case, a common sense way to do that would be for the BLM to again defer on leasing the 3 parcels in close proximity to TRNP. However, in the current Draft EA the BLM has NOT considered the option of deferring the parcels near TRNP.
Considering a deferral would also be an appropriate step for you to fulfill your duties under the NPS Organic Act of 1916, as amended. Under the Act, national parks are to be managed and conserved “in such manner and by such means as will leave them unimpaired for the enjoyment of future generations.” (Emphasis added) As explained in Senate Committee Report No. 95-528 for the 1978 Redwood Amendment, which was enacted to reinforce the provisions of the Organic Act: “[T]he Secretary has an absolute duty, which is not to be compromised…to take whatever actions and seek whatever relief as will safeguard the units of the national park system.” (Emphasis added) The Secretary’s “absolute duty” to protect park resources and values is reflected in longstanding DOI Solicitor Opinion # M-36993, which states, in part: “[T]he 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.” (Emphasis added) In this case, drilling for oil and gas in such close proximity to the TRNP boundary would certainly be detrimental.
In closing, we encourage you to take a personal interest in the proposed leasing and respectfully request your support in deferring the leasing of the 3 parcels in close proximity to Theodore Roosevelt National Park. A deferral decision during your watch would avoid the risk of causing long-term adverse impacts to the landscape, resources, and values that Roosevelt found so inspirational. And deferring these 3 parcels for cause, out of the 29 parcels currently proposed for leasing, is unlikely to derail America’s quest for energy independence. We would greatly appreciate your consideration of these concerns.
Sincerely,
Philip A. Francis, Jr.
Chair of the Executive Council
Coalition to Protect America’s National Parks
cc:
Adam Suess, Acting Assistant Secretary for Land and Minerals Management
Jon Raby, Acting Director, Bureau of Land Management
Jessica Bowron, Acting Director, National Park Service
Bert Frost, Midwest Regional Director, National Park Service