RE: Scoping Comments – DOI-BLM-UT-0000-2026-0007-EA – BLM Utah 2026 Fourth Quarter Competitive Oil and Gas Lease Sale Environmental Assessment
Submitted via email: bl****************@*lm.gov
July 15, 2026
The following comments are submitted by John W. Hiscock, Public Employees for Environmental Responsibility (PEER), the Coalition to Protect America’s National Parks, Western Watersheds Project, Basin and Range Watch, and National Parks Conservation Association. We are members of the interested public and organizations committed to sound stewardship of public lands. Thank you for the opportunity to comment.
The comments are intended to emphasize the Bureau of Land Management’s (BLM) responsibility to evaluate potential impacts of oil and gas leasing to the Old Spanish National Historic Trail (Old Spanish Trail), a unit of the national Trails System, and the National Landscape Conservation System. There are three proposed lease sale parcels which are proximate to the Old Spanish Trail. Parcel 7990 is located within 3.22 miles of the North Branch Route of the OSNHT, and Parcels 1950 and 1955, are geographically split parcels, but located within, respectively, 3.23 miles and 5.6 miles, of the Northern or Main Route of the Old Spanish Trail. Parcels 7990, 1950 and 1955 must be removed from the Q4 lease sale because the BLM and NPS have failed to complete the required analysis to determine whether the parcels’ development will interfere with the use and enjoyment of the Old Spanish Trail.
The routes were designated and identified by map by Congress in the Old Spanish Trail Recognition Act of 2002, incorporated into and subject to the provisions of the National Trails System Act (NTSA). The Department of the Interior (DOI) was assigned administrative responsibility for the OSNHT pursuant to the NTSA. The DOI then delegated co-administrative responsibility for the OSNHT to the BLM and National Park Service (NPS).
The NTSA mandates that the Administrator or Co-Administrators complete a comprehensive plan for the management of the OSNHT within two years of its statutory establishment. The DOI, BLM and NPS, have failed to complete the Comprehensive Management Plan and it is 23 years overdue. The Secretary of the Interior is also mandated by the NTSA to publish a NTSA right-of-way for the Trail. The NTSA mandates that right-of-way is to be of a width sufficient to protect the nature and purposes of the Trail. This responsibility is also unfulfilled to date. We are plaintiffs in a lawsuit in federal district court requesting enforcement and protections for the Trail.
BLM policies regarding administration of national trails and management of national trails, including the OSNHT are detailed in BLM Manuals 6250 and 6280. Both Manuals call for the establishment of the NTSA right-of-way by the Secretary or Co-Administrators as part of the comprehensive plan process and enactment. Again, neither the plan or the right-of-way have been formally established.
Manual 6280 also mandates the BLM to amend the Resource Management Plan for all relevant land management units crossed by national trails. In this case the Moab Field Office is required to inventory all resources and values of national trails and then to identify and establish a local trail management corridor over the right-of-way for trail management purposes. Manual 6280 then directs and details that the inventories and trail management corridors are to be used in the evaluation of all proposed BLM projects authorized by the Federal Land Policy and Management Act, and in this case the Mineral Leasing Act.
Please see the two attached images which overlay the trail and the lease parcels. The Trail is depicted as it is legislatively referenced NPS feasibility study for the Trail were initially established by Congress by Congress in the Old Spanish Trail Recognition Act. It is important to note that if BLM has completed all of the required analysis, including the required Viewshed Analysis and had determined the right-of-way and trail corridor, that it is very possible that BLM would have determined that 15 miles on either side of the Spanish Trail center line (depicted in the map) would have been protected from any ground disturbance. These three parcels proposed for drilling, would fall well within that corridor and overlap the trail. Without the required analysis, it is impossible to tell if BLM can lease these parcels without interfering with the Spanish Trail
The Secretary of the Interior and the agency are prohibited by the NTSA from taking any action deemed to substantially interfere with the nature and purposes of a national trail. BLM is prohibited from issuing a lease sale that will lead to a project that interferes with the use and enjoyment of the OSNHT.
Due to the fact that DOI, BLM and NPS, have failed to complete a comprehensive management plan and formally publish the statutorily mandated right-of-way for the OSNHT, BLM has also failed to conduct a comprehensive inventory of all OSNHT resources and values in the Moab Field Area, and failed to amend the subject RMP to include a trail management corridor the agencies have left important historic resource vulnerable to complete destruction on these three parcels.
The sale parcels – 7990, 1950, and 1955 must be withdrawn from any lease sale offering until such time as the described statutory and policy mandated requirements are met, and a Secretarial finding of no significant adverse effect of such potential sales on the nature and purposes of the OSNHT legitimately determined.
Sincerely,
Chandra Rosenthal
Western Lands and Rocky Mountain Advocate
Public Employees for Environmental Responsibility
cr********@**er.org
John W. Hiscock, JD
Kanab, Utah
jo**********@***il.com
Kevin Emmerich
Basin and Range Watch
at**************@***il.com
Emily Thompson
Executive Director
The Coalition to Protect America’s National Parks
Em************@********ps.org
Eric Molvar Director
Western Watersheds Project
em*****@***************ds.org
Erika Pollard
Campaign Director
Southwest Region National Parks Conservation Association
ep******@**ca.org