John W. Hiscock
Public Employees for Environmental Responsibility
The Coalition to Protect America’s National Parks
Southern Utah Wilderness Alliance
Western Watersheds Project
Basin and Range Watch
SYNOPSIS
A coalition of conservation and public-interest organizations has submitted scoping comments opposing portions of the Bureau of Land Management’s Utah 2026 Third Quarter Competitive Oil and Gas Lease Sale because of the risks posed to the Old Spanish National Historic Trail (OSNHT) in southeastern Utah. The comments focus on parcels 1805, 1806, 1809, 7935, 7937, 7941, and 7947, all of which either cross, closely border, or lie within the broader trail landscape in the Moab Field Office area.
The central concern is that BLM cannot lawfully move forward with leasing in this area without first satisfying its obligations under the National Trails System Act. According to the comments, the Old Spanish Trail is not just another nearby resource; it is a congressionally designated National Historic Trail that must be managed to protect its historic route, setting, and public values. The coalition argues that oil and gas leasing may be allowed only if the Department of the Interior can determine that such uses “will not substantially interfere with the nature and purposes” of the trail.
The comments contend that BLM and the Department of the Interior have failed to complete several required steps needed to make that determination. Most notably, the agencies have never completed the trailwide Comprehensive Management Plan required by law, never formally selected and published the trail right-of-way, and never fully established management corridors and inventories needed to guide land-use decisions in the project area. The filing also argues that the agencies’ later “Comprehensive Administrative Strategy” does not substitute for the legally required management plan and was not completed through the proper NEPA process.
The coalition further argues that the location of the trail has been clouded by contradictory mapping and administratively recommended realignments that were never lawfully finalized. Even so, the comments state that all seven proposed parcels fall within the likely trail protection corridor, that six of the seven are crossed by one or more trail alignments, and that the remaining parcel lies within one-tenth of a mile of an alignment. All seven parcels are also said to be within 3.69 miles of every relevant alignment considered in the filing.
Because of those unresolved legal and management deficiencies, the organizations argue that BLM’s environmental review cannot take the “hard look” required by NEPA. They maintain that the agency must analyze impacts to all potentially applicable trail alignments, including both the congressionally designated route and later recommended alignments, and must account for the area’s high-potential trail segments and associated scenic, cultural, and historic values. The comments also note that some of the same issues are already the subject of ongoing litigation against the Department of the Interior.
In sum, the filing urges BLM not to advance leasing on these parcels unless and until it can demonstrate full compliance with the National Trails System Act, BLM trail-management policy, and NEPA. The coalition’s position is that protection of the Old Spanish National Historic Trail must come first, and that parcels threatening the trail should be removed from the lease sale.
Click here to read the full submission.