Conservation Groups Challenge Utah Oil and Gas Lease Sale Near Old Spanish Trail – The Coalition To Protect America's National Parks

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Synopsis

On March 30, 2026, representatives of Public Employees for Environmental Responsibility (PEER), the Coalition to Protect America’s National Parks, Western Watersheds Project, and the Southern Utah Wilderness Alliance submitted joint comments on the Bureau of Land Management’s BLM Utah 2026 Second Quarter Competitive Oil and Gas Lease Sale Environmental Assessment (DOI-BLM-UT-0000-2026-0003-EA). The comments focus on proposed lease parcels in southeastern Utah that either cross or lie near the Northern Route and North Branch of the Old Spanish National Historic Trail (OSNHT), especially in the Moab and Monticello Field Office areas.

The organizations argue that BLM’s Environmental Assessment fails to satisfy NEPA’s required “hard look” because it omits key legal and policy requirements, relies on erroneous and incomplete information, and does not adequately address concerns raised during the earlier scoping process. They contend that moving forward with leasing under these circumstances would be arbitrary, capricious, and contrary to law under both NEPA and the Administrative Procedure Act.

At the center of the comments is the claim that BLM has not met its duties under the National Trails System Act for managing and protecting the Old Spanish National Historic Trail. The letter argues that the Department of the Interior, BLM, and the National Park Service have still not completed a legally required Comprehensive Management Plan for the Trail, despite the statutory deadline having passed many years ago. The agencies instead relied on a 2017 Comprehensive Administrative Strategy, which the commenters argue is not a lawful substitute because it did not fulfill the statutory planning mandate or NEPA review requirements.

The comments also assert that DOI and BLM have failed to establish and publish a legally required right-of-way for the Trail, failed to complete a comprehensive inventory of trail resources and values, failed to conduct an adequate viewshed analysis, failed to designate a Trail Management Corridor, and failed to amend the governing Resource Management Plans in the Moab and Monticello areas to provide clear protection standards for the OSNHT. According to the letter, those failures make it impossible to credibly conclude that oil and gas leasing in the affected parcels would not “substantially interfere” with the trail’s nature and purposes, as federal law requires.

A major factual concern raised by the groups is that BLM’s assessment misstates the trail’s alignment and the proximity of numerous lease parcels to the congressionally designated route. They argue that the agencies have relied on confusing and procedurally flawed alignment changes associated with the 2017 administrative strategy, which in turn has distorted the Environmental Assessment’s parcel-by-parcel impact analysis and limited the public’s ability to comment meaningfully.

The letter further argues that BLM’s proposed lease stipulations and notices are inconsistent, incomplete, and not an adequate substitute for the legally required trail planning and inventory work. In the commenters’ view, protective stipulations cannot cure the underlying defects because the agencies have not first established the trail corridor, inventoried the resources at risk, or completed the required management framework. They maintain that the agency should have retained and adopted an avoidance alternative rather than relying on piecemeal stipulations.

The coalition points to BLM’s own more recent solar-energy planning approach as evidence that the agency already recognizes the need for full trail inventory and broader protective analysis before authorizing major development near National Trails. They argue that oil and gas leasing should be held to the same standard to prevent cumulative degradation of the Old Spanish National Historic Trail.

In conclusion, the signers urge BLM to retract or defer the identified lease parcels from the 2026 second-quarter sale until the agency completes the overdue Comprehensive Management Plan, establishes the OSNHT right-of-way, conducts a full trail inventory and viewshed analysis, designates Trail Management Corridors, and updates the relevant Resource Management Plans through a lawful public process. Until then, they argue, the proposed leasing should not proceed.

Click on the following title to read the full submission: