Stop oil and gas drilling beneath Ouray National Wildlife Refuge
Notice of Intent To Amend the Vernal Resource Management Plan for Oil and Gas Leasing and Prepare an Associated Environmental Assessment, Utah
Bureau of Land Management· Ouray National Wildlife RefugeFederal Register 2026-18054 ↗
The groups on this fight
4 groups predicted likely to care in Utah
Predicted likely to care is a guess from footprint in Utah, by the same match the STAND matchmaker runs, with no link to this decision. Give straight to them; nothing routes through us.
- Bears Ears Inter-Tribal Coalition
Predicted likely to care · a guess
Works Utah: the five-Tribe coalition that petitioned for the monument and shared in managing it until the July 2026 proclamation disbanded the Bears Ears Commission.
- Grand Staircase Escalante Partners
Predicted likely to care · a guess
Works Utah: the monument’s friends group: science, stewardship, and the legal fight over its boundaries.
- Southern Utah Wilderness Alliance
Predicted likely to care · a guess
Works Utah: sued BLM in August 2024 to void 51 reaffirmed oil and gas leases in the San Rafael Desert, including one in the heart of the Labyrinth Canyon Wilderness carved by the Green River.
- Utah Diné Bikéyah
Predicted likely to care · a guess
Works Utah: the Native-led nonprofit whose cultural mapping work built the original monument proposal.
Every group above is on STAND for Public Lands, with its court record, its filings and who backs it.
BLM wants to open federal minerals under a national wildlife refuge to oil and gas leasing.
What’s at risk
The Ouray National Wildlife Refuge in Utah could face subsurface oil and gas development through directional drilling from outside the refuge boundary. Wildlife habitat and refuge integrity are at risk from industrial energy extraction beneath protected lands.
If this goes through
If approved, the Vernal Resource Management Plan would be permanently amended to allow oil and gas leasing under the refuge, setting a precedent for subsurface drilling beneath national wildlife refuge lands.
Our plain-English read of the official notice ↗. Check it against the agency’s own words below.
By the numbers, from the agency’s own document
- Federal mineral acres proposed for oil and gas leasing
- less than 5,200 acres
- Length of public scoping and comment period
- 30 days
SUPPLEMENTARY INFORMATION
Open the document ↗“encompasses less than 5,200 acres of federal minerals managed by the BLM”
DATES
Open the document ↗“please ensure your comments are received prior to the close of the 30-day scoping period”
Each figure is checked word for word against the decision document ↗; open a label to read the sentence it comes from and the document it’s in.
The agency’s own analysis
What the notice says, and what it leaves out
The strongest findings read from the agency’s own document, each quoted word for word. The window has closed; the record of what was missing stays.
SUMMARY
The agency says
“an associated Environmental Assessment (EA) to consider opening the federal minerals beneath the Ouray National Wildlife Refuge to oil and gas leasing”
The agency has chosen to prepare an Environmental Assessment rather than a full Environmental Impact Statement for a proposal to open a National Wildlife Refuge to oil and gas leasing.
Purpose and Need
The agency says
“in response to external interest in leasing federal oil and gas minerals beneath the Ouray National Wildlife Refuge”
The Purpose and Need section defines the agency's need for action as satisfying external commercial interest and carrying out direction from two executive orders.
Preliminary Alternatives
The agency says
“The BLM is considering two preliminary alternatives in the RMPA--a No Action Alternative and the Proposed Action.”
The Preliminary Alternatives section lists only two options: No Action and a single Proposed Action.
Planning Criteria
The agency says
“The BLM has identified seven preliminary issues for this planning effort's analysis.”
The Planning Criteria section states that seven preliminary issues have been identified for analysis but does not name a single one.
SUPPLEMENTARY INFORMATION
The agency says
“The scope of this land use planning process does not include addressing the evaluation or designation of Areas of Critical Environmental Concern (ACEC)”
The SUPPLEMENTARY INFORMATION section explicitly excludes ACEC evaluation from the planning process without providing any explanation or legal basis for doing so.
10 holes in the agency’s own analysis
What the public could have raised, from the agency’s own document
- I oppose this action as proposed, and I ask the agency to weigh the specific harms below.
- The agency has chosen to prepare an Environmental Assessment rather than a full Environmental Impact Statement for a proposal to open a National Wildlife Refuge to oil and gas leasing. The SUMMARY announces an EA without explaining why this action would not constitute a major federal action with potentially significant environmental effects, which triggers a NEPA requirement for an EIS. No Finding of No Significant Impact has been reached, no categorical exclusion is cited, and no significance analysis is provided. The agency should prepare a full Environmental Impact Statement.
- The Purpose and Need section defines the agency's need for action as satisfying external commercial interest and carrying out direction from two executive orders. A Purpose and Need framed around satisfying outside interest in leasing pre-determines the outcome and forecloses meaningful alternatives analysis because any alternative that does not satisfy that interest reads as unresponsive to the stated need. The agency should rewrite the Purpose and Need to identify specific statutory or resource management deficiencies in the current Vernal RMP, independent of external interest or executive directives.
- The Preliminary Alternatives section lists only two options: No Action and a single Proposed Action. NEPA requires analysis of a reasonable range of alternatives; for an action affecting a National Wildlife Refuge, intermediate options such as partial openings, buffer zones, seasonal restrictions, or phased leasing with additional stipulations are readily conceivable candidates. Inviting public suggestions for additional alternatives does not relieve the agency of its obligation to independently develop a reasonable range. The agency should develop and analyze at least two additional action alternatives with differing stipulations before completing the RMPA.
- The Planning Criteria section states that seven preliminary issues have been identified for analysis but does not name a single one. Those issues are available only on a project website, not in the Federal Register notice. A member of the public reading the notice cannot determine whether the seven issues are complete, cannot identify missing issues, and cannot comment on the analytical framework without separately locating and reviewing an external document. The agency should publish all seven preliminary issues and the full planning criteria in the Federal Register and extend the comment period accordingly.
Show every point from the document
- The SUPPLEMENTARY INFORMATION section explicitly excludes ACEC evaluation from the planning process without providing any explanation or legal basis for doing so. FLPMA requires the BLM to give priority to the designation and protection of ACECs; a National Wildlife Refuge managed by a separate federal agency for wildlife protection is a plausible candidate for that protection. The agency cannot simply declare the question off-limits. The agency should explain in writing the legal basis for excluding ACEC evaluation from this planning process and, if no adequate basis exists, incorporate ACEC review into the RMPA.
- The Additional Information section commits to compliance with the Endangered Species Act and Section 106 of the National Historic Preservation Act but makes no reference to any USFWS authorization or approval process that applies to the proposed action. The entire surface area is USFWS-managed refuge land, yet no USFWS regulatory role in approving, conditioning, or rejecting the proposed leasing appears anywhere in the notice. The agency should identify and disclose in the EA what USFWS approvals are required before leasing can proceed and commit to analyzing how those approvals will be obtained.
- The DATES section sets the comment deadline as October 5, 2026, while stating the public meeting will be announced only at least 15 days in advance. The notice was published September 3, 2026. A meeting announced as late as September 20 and held as late as October 5 leaves the public no time to incorporate information from the meeting into written comments before the deadline closes. The agency should announce the public meeting date in a revised notice and extend the comment period to at least 30 days after the meeting is held.
- The Preliminary Alternatives section presents the no surface occupancy restriction as the primary protection for the Refuge and states that drilling must originate from outside the Refuge boundary, but the notice contains no indication that subsurface impacts of drilling beneath the Refuge will be analyzed. Directional or horizontal drilling beneath a wildlife refuge can cause groundwater disturbance, methane migration, induced seismicity, and subsurface habitat disruption regardless of where the surface pad is located. The agency should explicitly commit in the scoping notice to analyzing all subsurface impact pathways, not only surface disturbance, in the EA.
- The Interdisciplinary Team section lists specialists in only five disciplines: air quality, water quality, minerals and geology, wildlife and fisheries, and economics. Standard NEPA resource categories for an oil and gas leasing amendment affecting a wildlife refuge include soils, cultural resources, recreation, visual resources, noise, and paleontology, none of which appear in the list. The Additional Information section separately commits to Section 106 cultural resources compliance but names no cultural resources specialist in the IDT. The agency should add soils, cultural resources, recreation, and visual resources specialists to the team before completing the EA.
- The Additional Information section states the BLM will consult with Indian Tribal Nations but provides no information about which Tribes have been or will be consulted, what consultation has already occurred, or how Tribal input was considered when the seven preliminary issues were identified before scoping began. Preliminary issues were developed through "early engagement" with unspecified Tribes before the public notice was issued, yet the notice gives no account of what concerns were raised or whether any were carried into the analytical framework. The agency should disclose which Tribes were engaged during early outreach, what issues those Tribes raised, and whether any Tribal concerns appear in the seven preliminary issues.
- Say something only you can say. The law requires the agency to consider and respond to substantive comments, and specifics are what make a comment substantive.
In the agency’s own words
In compliance with the National Environmental Policy Act (NEPA) of 1969, as amended, and the Federal Land Policy and Management Act (FLPMA) of 1976, as amended, the Bureau of Land Management (BLM) Utah State Director intends to prepare a Resource Management Plan Amendment (RMPA) with an associated Environmental Assessment (EA) to consider opening the federal minerals beneath the Ouray National Wildlife Refuge to oil and gas leasing, subject to a no surface occupancy stipulation, and by this notice is announcing the beginning of the scoping period to solicit public comments and identify issues and is providing the…
On the record for this fight
2 people have filed on this fight through PLAN. The official record is still catching up.
- Karen W.49 seals
- and 1 more steward
Ranked on letters found on the agency’s record, then letters filed. Readers appear as first name and last initial, or as a steward in their state; switch yours off in your record. All boards
Did the agency answer?
10 issues are on this record. The agency has not published its decision document yet, so each one stays pending until the agency answers.
Issues on the record, awaiting the decision
- PendingThe Interdisciplinary Team section lists specialists in only five disciplines: air quality, water quality, minerals and geology, wildlife and fisheries, and economics.
The Interdisciplinary Team section lists specialists in only five disciplines: air quality, water quality, minerals and geology, wildlife and fisheries, and economics. Standard NEPA resource categories for an oil and gas leasing amendment affecting a wildlife refuge include soils, cultural resources, recreation, visual resources, noise, and paleontology, none of which appear in the list. The Additional Information section separately commits to Section 106 cultural resources compliance but names no cultural resources specialist in the IDT. The agency should add soils, cultural resources, recreation, and visual resources specialists to the team before completing the EA.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe Preliminary Alternatives section lists only two options: No Action and a single Proposed Action.
The Preliminary Alternatives section lists only two options: No Action and a single Proposed Action. NEPA requires analysis of a reasonable range of alternatives; for an action affecting a National Wildlife Refuge, intermediate options such as partial openings, buffer zones, seasonal restrictions, or phased leasing with additional stipulations are readily conceivable candidates. Inviting public suggestions for additional alternatives does not relieve the agency of its obligation to independently develop a reasonable range. The agency should develop and analyze at least two additional action alternatives with differing stipulations before completing the RMPA.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe Preliminary Alternatives section presents the no surface occupancy restriction as the primary protection for the Refuge and states that drilling must originate from outside the Refuge boundary, bu
The Preliminary Alternatives section presents the no surface occupancy restriction as the primary protection for the Refuge and states that drilling must originate from outside the Refuge boundary, but the notice contains no indication that subsurface impacts of drilling beneath the Refuge will be analyzed. Directional or horizontal drilling beneath a wildlife refuge can cause groundwater disturbance, methane migration, induced seismicity, and subsurface habitat disruption regardless of where the surface pad is located. The agency should explicitly commit in the scoping notice to analyzing all subsurface impact pathways, not only surface disturbance, in the EA.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe DATES section sets the comment deadline as October 5, 2026, while stating the public meeting will be announced only at least 15 days in advance.
The DATES section sets the comment deadline as October 5, 2026, while stating the public meeting will be announced only at least 15 days in advance. The notice was published September 3, 2026. A meeting announced as late as September 20 and held as late as October 5 leaves the public no time to incorporate information from the meeting into written comments before the deadline closes. The agency should announce the public meeting date in a revised notice and extend the comment period to at least 30 days after the meeting is held.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe agency has chosen to prepare an Environmental Assessment rather than a full Environmental Impact Statement for a proposal to open a National Wildlife Refuge to oil and gas leasing.
The agency has chosen to prepare an Environmental Assessment rather than a full Environmental Impact Statement for a proposal to open a National Wildlife Refuge to oil and gas leasing. The SUMMARY announces an EA without explaining why this action would not constitute a major federal action with potentially significant environmental effects, which triggers a NEPA requirement for an EIS. No Finding of No Significant Impact has been reached, no categorical exclusion is cited, and no significance analysis is provided. The agency should prepare a full Environmental Impact Statement.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe Planning Criteria section states that seven preliminary issues have been identified for analysis but does not name a single one.
The Planning Criteria section states that seven preliminary issues have been identified for analysis but does not name a single one. Those issues are available only on a project website, not in the Federal Register notice. A member of the public reading the notice cannot determine whether the seven issues are complete, cannot identify missing issues, and cannot comment on the analytical framework without separately locating and reviewing an external document. The agency should publish all seven preliminary issues and the full planning criteria in the Federal Register and extend the comment period accordingly.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe SUPPLEMENTARY INFORMATION section explicitly excludes ACEC evaluation from the planning process without providing any explanation or legal basis for doing so.
The SUPPLEMENTARY INFORMATION section explicitly excludes ACEC evaluation from the planning process without providing any explanation or legal basis for doing so. FLPMA requires the BLM to give priority to the designation and protection of ACECs; a National Wildlife Refuge managed by a separate federal agency for wildlife protection is a plausible candidate for that protection. The agency cannot simply declare the question off-limits. The agency should explain in writing the legal basis for excluding ACEC evaluation from this planning process and, if no adequate basis exists, incorporate ACEC review into the RMPA.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe Additional Information section states the BLM will consult with Indian Tribal Nations but provides no information about which Tribes have been or will be consulted, what consultation has already o
The Additional Information section states the BLM will consult with Indian Tribal Nations but provides no information about which Tribes have been or will be consulted, what consultation has already occurred, or how Tribal input was considered when the seven preliminary issues were identified before scoping began. Preliminary issues were developed through "early engagement" with unspecified Tribes before the public notice was issued, yet the notice gives no account of what concerns were raised or whether any were carried into the analytical framework. The agency should disclose which Tribes were engaged during early outreach, what issues those Tribes raised, and whether any Tribal concerns appear in the seven preliminary issues.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe Purpose and Need section defines the agency's need for action as satisfying external commercial interest and carrying out direction from two executive orders.
The Purpose and Need section defines the agency's need for action as satisfying external commercial interest and carrying out direction from two executive orders. A Purpose and Need framed around satisfying outside interest in leasing pre-determines the outcome and forecloses meaningful alternatives analysis because any alternative that does not satisfy that interest reads as unresponsive to the stated need. The agency should rewrite the Purpose and Need to identify specific statutory or resource management deficiencies in the current Vernal RMP, independent of external interest or executive directives.
A hole PLAN found in the agency’s own notice, quote verified against the text
- PendingThe Additional Information section commits to compliance with the Endangered Species Act and Section 106 of the National Historic Preservation Act but makes no reference to any USFWS authorization or
The Additional Information section commits to compliance with the Endangered Species Act and Section 106 of the National Historic Preservation Act but makes no reference to any USFWS authorization or approval process that applies to the proposed action. The entire surface area is USFWS-managed refuge land, yet no USFWS regulatory role in approving, conditioning, or rejecting the proposed leasing appears anywhere in the notice. The agency should identify and disclose in the EA what USFWS approvals are required before leasing can proceed and commit to analyzing how those approvals will be obtained.
A hole PLAN found in the agency’s own notice, quote verified against the text
The reporting behind this
From More Than Just ParksIt’s referred to as Unit 346 in the Twin Mountain II Timber Sale. On the ground, it’s some of the most spectacular old growth we’ve ever witnessed, and it’s marked for clearcutting.
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