The Wilderness Society et al. Scoping Comments (Feb. 23, 2026) is a formal comment letter submitted to the U.S. Bureau of Land Management (BLM) regarding the proposed Wyoming 2026 Third Quarter Competitive Oil & Gas Lease Sale, which includes 271 parcels totaling approximately 357,357 acres.
The letter, submitted by The Wilderness Society and partner conservation organizations, raises significant legal and environmental concerns. Key themes include: Rejection of the “national energy emergency” justification for expediting leasing or bypassing standard NEPA procedures. BLM’s authority to defer parcels, emphasizing that leasing is discretionary under the Mineral Leasing Act and must comply with FLPMA’s multiple-use and sustained-yield mandates. Concerns over outdated or legally vulnerable Resource Management Plans (RMPs) that may not adequately address climate change, wildlife migration corridors, or cumulative impacts. Implications of the 2025 Reconciliation Act, particularly regarding potential limits on BLM discretion and restrictions on adding lease stipulations beyond those in existing RMPs. Requirement for full NEPA analysis at the leasing stage, including evaluation of conservation conflicts, big game migration corridors, sage-grouse habitat, environmental justice impacts, and cumulative climate effects.
Objection to BLM Instruction Memorandum 2025-028, which the authors argue unlawfully directs offering all “eligible” parcels regardless of environmental conflicts. Overall, the letter argues that BLM must conduct a thorough environmental review, apply the leasing preference criteria carefully, and defer parcels where conflicts arise with wildlife, habitat, or other public land values.
Read the full document here.