Proposed Revocation of Public Land Order No. 7923: Public Lands Withdrawal
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Proposed Revocation of Public Land Order No. 7923: Public Lands Withdrawal
Surrounding Chaco Culture National Historical Park Boundary, New Mexico
Environmental Assessment
DOI-BLM-NM-F010-2026-0002-EA
July 2026
I have considered the factors mandated by the National Environmental Policy Act (NEPA). This environmental
assessment represents the Bureau of Land Management’s (BLM’s) good-faith effort to fulfill NEPA’s
requirements by prioritizing documentation of the most important relevant considerations within the
statutorily mandated page limits and timeline. This prioritization reflects the BLM’s expert judgment; and any
considerations addressed briefly or left unaddressed are, in the BLM’s judgment, comparatively nonsubstantive and would not meaningfully inform the BLM’s consideration of environmental effects and the
Secretarial decision to be made. The EA is substantially complete, considers the factors mandated by NEPA,
and, in my judgment, contains analysis adequate to inform the Secretary of the Interior’s decision regarding
the Proposed Action.
Responsible Official & Date: ________________________________________________________________
U.S. Department of the Interior
Bureau of Land Management
Farmington Field Office
6251 North College Boulevard, Suite A
Farmington, New Mexico 87402
TABLE OF CONTENTS
Chapter
Page
CHAPTER 1. INTRODUCTION ........................................................................................................1
1.1
1.2
1.3
1.4
1.5
Background.........................................................................................................................................1
Purpose and Need ............................................................................................................................2
Decision to Be Made........................................................................................................................2
Relationship to Statutes, Regulations, and Other NEPA Documents ..................................2
Public Involvement and Issues........................................................................................................2
1.5.2 Public Information Regarding the Proposed Action that Became PLO
No. 7923 ..............................................................................................................................2
1.5.1.2 Summary of Public Comments Regarding the EA for PLO No. 7923 ....................3
1.5.3 Public Information Regarding the Current Proposed Action .................................3
1.5.4 Issues Identified for Analysis ...........................................................................................3
1.5.5 Issues Identified but Eliminated from Detailed Analysis ...........................................5
CHAPTER 2. PROPOSED ACTION AND ALTERNATIVES ................................................................6
2.1
2.2
2.3
2.4
2.5
No Action Alternative (Alternative A) ........................................................................................6
Proposed Action (Alternative B) ..................................................................................................7
Partial Revocation Alternative (Alternative C) ..........................................................................8
Design Features Common to All Alternatives ..........................................................................9
Alternatives Considered but Not Analyzed in Detail .............................................................9
2.5.2 Revoke PLO No. 7923 for a Smaller Subset of the Withdrawn Lands ................9
2.5.3 Revoke PLO No. 7923 to Allow Only Leasing Under the Mineral
Leasing Laws........................................................................................................................9
CHAPTER 3. AFFECTED ENVIRONMENT AND ENVIRONMENTAL EFFECTS .................................10
3.1
3.2
3.3
3.4
3.5
Introduction .................................................................................................................................... 10
No Action Alternative for All Issues & Reasonably Foreseeable Environmental
Trends .............................................................................................................................................. 10
Reasonably Foreseeable Development Summary under Action Alternatives ................. 11
Issues Analyzed in Detail.............................................................................................................. 13
3.4.1 Resource Issue 1: Minerals Subject to Location and Entry under the
U.S. Mining Laws ............................................................................................................. 13
3.4.2 Resource Issue 2: Leasable Minerals .......................................................................... 15
3.4.3 Resource Issue 3: Socioeconomics ............................................................................. 23
3.4.4 Resource Issue 4: Quality of Life ................................................................................ 27
3.4.5 Resource Issue 5: Air Quality ...................................................................................... 35
3.4.6 Resource Issue 6: Greenhouse Gases ....................................................................... 46
3.4.7 Resource Issue 7: Water Use and Quantity ............................................................ 55
Summary Of Regional Context for Proposed Action ........................................................... 61
CHAPTER 4. CONSULTATION AND COORDINATION..................................................................64
4.1
4.2
4.3
Endangered Species Act Compliance ........................................................................................ 64
Tribal Government-to-Government Consultation and Coordination ............................. 64
Compliance with the National Historic Preservation Act ................................................... 66
CHAPTER 5. LIST OF PREPARERS ................................................................................................68
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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TABLES
Page
Table 1-1. Issues Brought Forward for Detailed Analysis.....................................................................................4
Table 1-2. Issues Identified but Eliminated from Detailed Analysis ....................................................................5
Table 3-1. Reasonably Foreseeable Development That Could Only Occur Under the Action
Alternatives .................................................................................................................................................... 12
Table 3-2. Development Potential Rating and Lease Status of the Proposed Withdrawal
Revocation Area ........................................................................................................................................... 16
Table 3-3. Potential Future Allotted Lease Impacts for Navajo Allotments ................................................. 20
Table 3-4. Development Potential and Lease Status of Lands within Alternative C ................................... 22
Table 3-5. Chacoan Outliers on BLM Managed Lands within Farmington Field Office .............................. 31
Table 3-6. Future Potential Fluid Mineral RFD Emissions (Revocation in Full) ............................................ 38
Table 3-7. Modeled New Federal Oil and Gas Emissions in San Juan County (tons per year) ................ 39
Table 3-8. Maximum Model Concentrations of NAAQS Pollutants (Standard) in San Juan
County............................................................................................................................................................. 39
Table 3-9. Cancer Unit Risk Estimates (EPA 2021) ............................................................................................. 40
Table 3-10. Cancer Unit Risk Estimates (EPA 2021) .......................................................................................... 42
Table 3-11. Maximum Regional Model HAP Concentrations in San Juan County (ug/m3) ........................ 43
Table 3-12. Maximum Regional Model Carcinogenic Risks in San Juan County (unitless) ......................... 43
Table 3-13. Maximum Regional Model Hazard Quotients in San Juan County (unitless) .......................... 43
Table 3-14. Global, United States, and New Mexico Fossil Fuel GHG Emissions, 2016–2022
(Mt CO2/year)............................................................................................................................................... 47
Table 3-15. Full RFD Estimated Life-of-RFD GHG Emissions (tonnes).......................................................... 49
Table 3-16. Comparison of RFD Emissions to Other Sources (Megatonnes) .............................................. 51
Table 3-17. Past, Present, and Reasonably Foreseeable Federal Onshore GHG Emissions (Mt
CO2e).............................................................................................................................................................. 52
Table 3-18. Decision area 2015 Water Use by Category ................................................................................. 56
Table 3-19. Water Use by Oil and Gas Wells for Hydraulic Fracturing in the Decision area for
Calendar Years 2015 to 2024 .................................................................................................................... 57
Table 3-20. Predicted Water Use by Oil and Gas Wells for Hydraulic Fracturing in the
Decision area ................................................................................................................................................. 59
Table 3-21. Past, Present, and Reasonably Foreseeable Future Estimated Landscape
Disturbance in the Decision area Regardless of Secretarial Action ................................................. 62
Table 4-1. Pueblos and Tribes Receiving Consultation Invitations from FFO .............................................. 65
APPENDICES
A
B
C
D
E
F
G
Acronyms and Abbreviations
Literature Cited
Issues Analyzed in Brief
Maps
Report Summarizing Public Input Received
Socioeconomic Analysis Supplement
Additional Consultation Meetings Held
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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1. Introduction
Chapter 1. Introduction
1.1
BACKGROUND
On June 7, 2023, Public Land Order (PLO) No. 7923 withdrew approximately 338,690 acres1 of public
land in northwestern New Mexico adjacent to, but not within the Congressionally-established border of
the Chaco Culture National Historical Park (CCNHP, 33,240 acres) from location and entry under the
United States mining laws and from leasing under the mineral leasing laws, but not from disposal of mineral
materials, for 20 years, subject to valid existing rights. Prior to this withdrawal, the acreage was comprised
of multiple use BLM lands which are intermixed with various subsurface mineral estate – some of which
belongs to native allottees. The withdrawal covers an approximately-10-mile buffer surrounding all units
of CCNHP, with additional acreage to the northwest toward Bisti/De-Na-Zin Wilderness Area and the
area between the main CCNHP and Kin Ya’a to the southwest.
On January 20, 2025, President Trump issued Executive Order (EO) 14154, Unleashing American Energy,
directing the Secretary of the Interior to review agency actions that may unnecessarily restrict domestic
energy and mineral development. In response, the Secretary of the Interior issued Secretary’s Order 3418
on February 3, 2025, instructing Department officials to evaluate existing land withdrawals for their effect
on domestic energy and mineral development. The BLM is conducting this evaluation for PLO No. 7923
and other withdrawals.
Following this review, and consistent with section 204 of the Federal Land Policy and Management Act
(FLPMA), 43 U.S.C. 1714, the Secretary of the Interior is proposing to revoke PLO No. 7923 and reopen
the subject lands to location and entry under the U.S. mining laws and to mineral leasing.
Revocation of PLO No. 7923, in full, would restore discretion over mineral leasing to the BLM and would
re-open the subject public land to location and entry under the United States mining laws while protecting
resources under existing laws, policies, and regulations. PLO No. 7923 did not withdraw the land in
question from disposal under the Materials Act of 1947 (e.g., extraction and sale of common-variety sand
and gravel from federal land could continue); the land also remained open to development through rightsof-way, and other surface land use authorizations under FLPMA and other authorities.
This environmental assessment (EA) has been prepared in accordance with the National Environmental
Policy Act (NEPA) to analyze and disclose the environmental consequences of revoking, or partially
revoking, the withdrawal of approximately 338,690 acres of BLM-administered public land in northwestern
New Mexico to reopen the lands to location and entry under the U.S. mining laws and to leasing under
the mineral leasing laws.
PLO No. 7923 withdrew approximately 338,690 acres of public lands from location and entry under the
U.S. mining laws and from the mineral leasing laws. Its stated purpose was “to protect these public lands
and the greater connected landscape having a rich Puebloan, Tribal Nation, and cultural legacy from
impacts associated with potential oil and gas development and locatable mineral exploration and mining…”
1 PLO No. 7923 identified 336,404.42 acres as withdrawn. This EA describes the withdrawal area based on legal land
descriptions and BLM Master Title Plats. For analysis purposes in this EA, BLM used digital spatial data (referenced to the
NAD83 datum and UTM Zone 13 Projection) to derive “GIS acres,” totaling approximately 338,690 acres. GIS acres are
rounded to the nearest 10 acres which may result in minor rounding discrepancies. Despite these differences in acreage figures,
the 10-mile-wide perimeter around CCNHP evaluated in this EA is intended to be identical to that in PLO No. 7923; no
changes to the boundary have occurred, and no lands have been added or removed.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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1. Introduction
A variety of designations, laws, regulations, and policies offer protections and management directions for
the landscape connected to this cultural legacy. These include CCNHP, United Nations Educational,
Scientific and Cultural Organization (UNESCO) World Heritage Sites, Chaco Culture Archaeological
Protection Sites, Areas of Critical Environmental Concern (ACEC), National Historic Preservation Act
(NHPA) of 1966, FLPMA, Archaeological Resources Protection Act (ARPA) of 1979, Native American
Graves Protection and Repatriation Act (NAGPRA) of 1990, Executive Order 13007: Indian Sacred Sites,
and Executive Order 13175: Consultation and Coordination with Indian Tribal Governments. Each of
these authorities remains in effect and would guide the BLM in managing cultural resources regardless of
which alternative the Secretary selects.
1.2
PURPOSE AND NEED
The purpose and need for the proposed withdrawal revocation is to restore discretion over mineral
leasing to the BLM and facilitate mineral development to meet the policies established by EO 14241—
Immediate Measures to Increase American Mineral Production, EO 14154—Unleashing American Energy, and
Secretarial Order (SO) 3418—Unleashing American Energy. In addition, opening lands to mineral leasing
would facilitate development of mineral interests by Indian allottees on approximately 239,685 acres
within the 10-mile buffer of the CCNHP.
1.3
DECISION TO BE MADE
Section 204 of FLPMA authorizes the Secretary of the Interior or a member of the Office of the Secretary
who has been appointed by the President, by and with the advice and consent of the Senate, to make,
modify, extend, or revoke withdrawals in accordance with the specific provisions of section
204. Therefore, the Secretary of the Interior or appropriate Secretarial official will decide whether to
revoke, revoke in part, or take no action regarding PLO No. 7923 to return all or some of the 338,690
acres withdrawn in 2023 to location and entry under the U.S. mining laws or to leasing under the mineral
leasing laws, or to both, or to neither.
1.4
RELATIONSHIP TO STATUTES, REGULATIONS, AND OTHER NEPA DOCUMENTS
Relevant statutes and regulations applicable to the Proposed Action include section 204 of FLPMA (43
USC 1714) and 43 Code of Federal Regulations (CFR) 2300 (Land Withdrawals), and 43 CFR 2370
(Restorations and Revocations). Mineral resources that may be affected by the proposed withdrawal
revocation are managed under the following authorities: 43 CFR 3160 (Onshore Oil and Gas Operations);
the Mining Law of 1872; the Mineral Leasing Act of 1920, as amended (30 USC 181 et seq.); 43 CFR 3800
(Mining Claims under the General Mining Laws); 43 CFR 3000 (Mineral Management) and 3400 (Coal
Management); the Act of March 3, 1909; and FLPMA.
This EA incorporates by reference the September 2003 Farmington Field Office (FFO) Final Environmental
Impact Statement (FEIS)/Resource Management Plan (RMP) and December 2003 Record of Decision (BLM
2003), as well as the EA prepared in support of PLO No. 7923.
1.5
PUBLIC INVOLVEMENT AND ISSUES
1.5.1
Public Involvement and Information Regarding the Proposed Action that Became
PLO No. 7923
The FFO initiated public outreach via a notice of proposed withdrawal, which was published in the Federal
Register (Volume 87, No. 4, Thursday, January 6, 2022); this notice described the Proposed Action and
initiated a 90-day public comment period. Several documents related to the Proposed Action, including a
Department of the Interior fact sheet and a map of the area proposed for withdrawal, were then made
available to the public on the BLM National NEPA Register website at https://eplanning.blm.gov/. Two in-
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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1. Introduction
person public meetings regarding the proposed withdrawal were held on February 23, 2022, in Farmington,
New Mexico. A virtual meeting was also held on February 24.
The BLM then published a news release on March 25, 2022, extending the initial deadline (which had been
April 6, 2022) for public comments and public meeting requests for an additional 30 days to May 6, 2022.
The BLM held three additional public meetings from April 27 to April 29, 2022, in Farmington, Nageezi,
and Albuquerque, New Mexico.
See Chapter 4. Consultation and Coordination for a summary of government-to-government consultation.
1.5.1.2 Summary of Public Comments Regarding the EA for PLO No. 7923
In developing this EA, the BLM reviewed and incorporated public input received during the development
of the original EA associated with the Secretarial decision which established the withdrawal.
The BLM received over 95,000 submissions, including 928 unique written comments that generated 388
substantive issues used to inform the original NEPA analysis. Following the release of the draft EA on
November 10, 2022, the BLM held a 30-day public comment period, during which the BLM received
16,715 submissions, including 16,478 letters containing non-unique, preformulated language (i.e., “form
letters”). There were 237 unique submissions, from which 179 substantive comments were derived.
The public comment response report for the original Proposed Chaco Area Withdrawal EA is available
at: https://eplanning.blm.gov/Project-Home/?id=098dfbca-a7f2-f011-8407-001dd806295a. The BLM
considered this input in shaping the scope, alternatives, and analysis presented in the current EA.
1.5.2 Recent Public Information and Involvement
As a continuation of the previous years-long public engagement on this topic, on March 31, 2026, BLM
notified Interested Parties of a new 7-day public scoping period to begin on April 1 and end on April 7.
BLM also initiated further consultation under section 106 of the NHPA on March 31, 2026. The BLM
invited the public to submit scoping comments through the BLM National NEPA Register at
https://eplanning.blm.gov where a map of the Proposed Action area and a description of the Proposed
Action was provided. The purpose of scoping is to identify potential issues for analysis in the agency NEPA
document. Given the similarity in subject matter and geography between the current Proposed Action
and the actions considered in the 2023 EA, the issues identified for analysis have substantial consistency
between the two undertakings. The BLM acknowledges and values the input received during those prior
scoping and public comment periods and will present that input to the Secretary as part of the current
decision-making process.
1.5.3 Issues Identified for Analysis
Using internal and external scoping in accordance with the requirements of NEPA and the guidance
provided in the Department of the Interior (DOI) Departmental Manual (DM) 516 DM 1 (DOI 2026), the
FFO interdisciplinary team (IDT) developed a list of issues to analyze in this EA that evaluates the proposed
revocation of PLO No. 7923, in whole or part. The key issues identified during scoping are summarized
in Table 1-1 below. This table also provides the impact indicators BLM used to describe the affected
environment for each issue in Section 3.4, to assess changes in each issue correlated with each
alternative, and to compare the impacts of each alternative.
The BLM also identified, considered, and analyzed in brief (AIB) additional issues during review of the
Proposed Action. Those issues are presented in Appendix C with a concise discussion of the potential
impacts related to each issue.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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1. Introduction
Issue #
Issue 1
Issue 2
Issue 3
Issue 4
Issue 5
Issue 6
Issue 7
Table 1-1. Issues Brought Forward for Detailed Analysis
Issue Statement
Impact Indicator(s)
How would the proposed revocation affect the
Acres withdrawn from location and
availability of locatable mineral resources (uranium)
entry under the U.S. mining laws and
within the decision area?
proposed for withdrawal revocation,
and locations of active mining claims, or
production of minerals subject to
location and entry under the U.S. mining
laws.
How would the proposed revocation affect the
Acres withdrawn from mineral leasing
availability of leasable mineral resources (coal and oil
and locations of existing leases of
and gas) within the decision area?
Federal minerals and production of
leased Federal minerals
How would future potential development of the
Comparative socioeconomic conditions
mineral resources should the Secretary revoke PLO
of counties (population, household
No. 7923, in whole or part affect local economy and
income level, unemployment level, age
government revenue?
structure, education level, employment
and Gross Domestic Product by
economic sector); federal mineral
development costs, mineral production
volumes, mineral sales prices, and local
industrial structures (economic output,
value added, labor income,
employment).
How would the proposed revocation of PLO No.
Relation across natural resources,
7923 in whole or part affect the quality of life of the
ecosystem services, economic output,
American people, including non-economic factors
and human well-being; socioeconomic
such as cultural resources and Native American
change, ecosystem change. Ecosystem
religious concerns?
services include consideration of cultural
resources.
How would future potential development within the
Emissions intensity resulting from
decision area if the Secretary revokes PLO No. 7923 reasonably foreseeable activity levels on
in whole or part affect air quality (particularly
re-opened lands.
National Ambient Air Quality Standards and volatile
organic compounds) in the analysis area?
How would future potential development that may
Total emissions resulting from
occur should the Secretary revoke PLO No. 7923, in reasonably foreseeable activity levels on
whole or part contribute to greenhouse gas (GHG)
re-opened lands.
emissions?
How would future potential development within the
Amount and source of water
decision area affect surface and groundwater
withdrawals.
quantity?
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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1. Introduction
1.5.4 Issues Identified but Eliminated from Detailed Analysis
Through the scoping process, BLM identified several potential issues which could appropriately be
eliminated from detailed analysis. For each issue eliminated from detailed analysis, the supporting rationale
is provided in Table 1-2.
Table 1-2. Issues Identified but Eliminated from Detailed Analysis
Rationale for Not Discussing in Detail in the EA
The decision area is not known to contain any cave or karst resources; therefore,
analysis of potential effects on cave and karst resources is not warranted.
Farmlands, Prime or The decision area does not contain any prime or unique farmland soils as designated by
Unique
the Natural Resources Conservation Service (NRCS); therefore, analysis of potential
effects on farmlands is not warranted.
Lands/Access
PLO No. 7923 did not affect Lands/Access, because PLO No. 7923 did not restrict public
access to public land. PLO No. 7923 only withdrew the area from location and entry
under the U.S. mining laws and from mineral leasing. The BLM would be able to conduct
realty actions under the No Action Alternative as well as the Action Alternatives. All
proposed realty actions would continue to be evaluated as described in the 2003 RMP.
Future potential development in the decision area would be subject to existing land rights
and interests (e.g., easements and water rights). Any potential land use conflicts would be
resolved through other processes, such as administrative or legal proceedings,
independent of Secretarial decision-making regarding PLO No. 7923.
Wetlands/Riparian
The decision area does not contain any designated riparian habitat on BLM managed
Zones
lands. Should the BLM propose to authorize development within the decision area in the
future, the BLM would conduct additional review to confirm the presence or absence of
this resource.
Wild Horses and
The decision area does not contain any Congressionally-designated Wild Horse and
Burros
Burro Herd Areas.
LWC; Wilderness
The decision area does not contain any lands with wilderness characteristics as
designated in the 2003 RMP. Bisti/De-Na-Zin and Ah-Shi-Sle-Pah Wilderness areas are
currently withdrawn based on their wilderness status and have current protections
through the 2003 RMP and Wilderness Act of 1964.
Livestock Grazing
The reasonably foreseeable development of approximately 2,723 acres that may occur
under the Proposed Action represents 0.34% of the total grazing allotment acres for the
four allotments with acres in the withdrawal area. Should the Secretary revoke PLO NO.
7923 in full, minimal Animal Unit Month (AUM) loss would occur that would not affect
authorized livestock grazing within the four allotments. Standard design features on site
specific projects addressing fencing and cattleguard installation, when required, would
assist in management of authorized livestock within affected allotments.
Public Land Health
The reasonably foreseeable development of approximately 2,723 acres that may occur
Standards (PLHS)
under the Proposed Action represents 0.34% of the total grazing allotment acres for the
four allotments with acres in the withdrawal area. Impacts to PLHS from mineral
development that may occur following a Secretarial revocation decision are expected to
be negligible given the acreage withdrawn within the four affected grazing allotments.
Standard design features/Best Management Practices (BMPs) requiring reclamation would
assist in mitigating any impacts from such development.
Invasive
Should the BLM propose any surface disturbing activity within the decision area,
Species/Noxious
regardless of the alternative selected by the Secretary, the BLM would employ or require
Weeds
best management practices to include prevention and treatment of invasive species and
noxious weeds. Given the dispersed nature of the reasonably foreseeable development of
approximately 2,723 acres that may occur under the Proposed Action, site specific
management specifications would prevent spread of invasive species and Noxious weeds.
Resource
Cave and Karst
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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1. Introduction
Resource
Vegetation
excluding US Fish
and WildlifeDesignated Species
Wildlife (Aquatic)
Rationale for Not Discussing in Detail in the EA
Sagebrush (Artemisia sp.) and perennial grasses are the predominant vegetation types
within the area withdrawn by PLO No. 7923. Given the dispersed nature of the
reasonably foreseeable development of approximately 2,723 acres that may occur under
the Proposed Action, standard design features requiring reclamation and utilizing site
specific seed mixes would minimize any effects to long term impacts to vegetation types
from such development.
There are no aquatic wildlife species within the decision area; management of habitat for
aquatic species and existing protections would continue as described in the 2003 RMP.
Chapter 2. Proposed Action and Alternatives
2.1
NO ACTION ALTERNATIVE (ALTERNATIVE A)
In 2023 the Secretary of the Interior withdrew approximately 338,690 acres of public land and federal
mineral estate in PLO No. 7923 within an approximate 10-mile distance from the CCNHP’s boundaries
from location and entry under the U.S. mining laws and from leasing under the Mineral Leasing Act of
1920, for a 20-year term, subject to valid existing rights. The lands were not withdrawn from disposal
under the Materials Act of 1947.
The withdrawal established by PLO No. 7923 affected public land where the BLM manages both the
surface and mineral estates as well as land where the BLM manages the federal mineral estate, but where
the surface may be managed by another federal agency or owned by another entity, such as the State of
New Mexico, Indian and Tribal entities, or private parties.
Therefore, under this alternative, if the Secretary were to take no action:
•
The approximately 338,690 acres of public land and federal mineral estate withdrawn by PLO No.
7923 from location and entry under the U.S. mining laws and the Mineral Leasing Act of 1920
would remain closed to exploration for minerals subject to location and entry under the U.S.
mining laws and any mining activities not supported by valid existing rights. The area would also
remain closed to any exploration for minerals subject to leasing under the Mineral Leasing Act
and to any development of such leasable minerals not subject to an existing lease or permit to
drill, for the remainder of the duration of the original 20-year term (e.g., until approximately the
year 2043).
•
These approximately 338,690 acres of public land and federal mineral estate would remain open
to discretionary mineral material extraction under the Materials Act of 1947 and 43 CFR 3600.
The BLM would continue to follow management direction outlined in the 2003 BLM FFO RMP
for the specific types and varieties of mineral identified by law and regulation as “salable minerals”
or “mineral materials,” which includes common varieties of sand, gravel, and other similar
materials. These regulations give BLM discretion to sell or dispose of federal mineral materials
through contracts with the public, including individuals, corporations, local or state governments,
and other government agencies.
•
Approximately 1,250 Navajo allottees would continue to have limited or no access to
economically feasible development opportunities for their allotted mineral rights absent adjacent
federal minerals. The buffer effectively stranded these assets, making mineral development for
Navajo allottees less desirable.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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2. Proposed Action and Alternatives
2.2
PROPOSED ACTION (ALTERNATIVE B)
The Secretary of the Interior proposes to revoke PLO No. 7923, which withdrew approximately 338,690
acres of public lands from location and entry under the United States mining laws and from leasing under
the mineral leasing laws, subject to valid existing rights, for a 20-year term. Revocation of PLO No. 7923,
in full, would re-open the public lands and federal mineral estate in the entire approximately 10-mile-wide
withdrawal area surrounding CCNHP to mineral leasing and mineral entry.
Revocation of the withdrawal in full would restore BLM’s discretion over mineral leasing and would reopen the land to location and entry under the U.S. mining laws and regulations such as 43 CFR Part 3809.
If the Secretary of the Interior selects this alternative for implementation, the BLM would subsequently
follow existing management direction outlined in the 2003 FFO RMP for leasable minerals (e.g., coal and
oil & gas) and locatable minerals (e.g., most metallic minerals).
The 965,670-acre decision area (containing not only the acres withdrawn by PLO No. 7923 but all lands
within the approximate 10-mile buffer shown in blue in Map 1-1, Appendix D) includes acres managed
by FFO and by other surface management entities. In some instances, the FFO manages federal minerals
where the surface is managed by another entity (see Map 1-2, Appendix D). Table 2-1 lists the land
managers or owners within the decision area along with the acres of federal minerals underlying the
surface acres these entities own or manage.
Table 2-1. Federal Minerals Associated with Federal and Non-Federal Land within the Analysis
Boundary (Acres)
Land Manager or
Surface, Federal Minerals in
Owner
GIS Acres
Withdrawal
Boundary,
GIS Acres
BLM
169,960
156,260
National Park Service
33,240
32,430
State of New Mexico
52,480
14,440
Individual Indian
672,850
129,990
Allotted / Tribal Trust
Private
37,140
5,570
Total
965,670
338,690
In its decision-making regarding any future mineral leasing or development following Secretarial selection
of the Proposed Action, the BLM would commit to implementing the Design Features in Section 2.4 to
mitigate potential impacts to Federal resources. Additional descriptions of the lands summarized in Table
2-1 and illustrated in Map 1-1, Appendix D are provided below.
New Mexico State Lands—In 2019, New Mexico’s Commissioner of Public Lands Stephanie Garcia
Richard signed Land Office Executive Order 2019-002, placing a moratorium on new oil and gas
development on New Mexico state trust land (managed by the New Mexico State Land Office [NMSLO])
in a 12-mile buffer zone around Chaco Canyon. On December 14, 2023, Commissioner Garcia Richard
extended the order through December 31, 2043. This order does not affect federal interests.
Decision Area—The decision area evaluated in this EA consists of the acres withdrawn by PLO No.
7923 from location and entry under the U.S. mining laws and from leasing under the mineral leasing laws,
consisting of the public lands and federal mineral interests in a 965,670-acre portion of McKinley, Sandoval,
and San Juan Counties formed by the approximate 10-mile radius surrounding the CCNHP; these 965,670acres include lands managed by the FFO, the Bureau of Indian Affairs (BIA), NMSLO, the National Park
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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2. Proposed Action and Alternatives
Service (NPS), and private landowners. The Proposed Action pertains only to the status of 338,690 acres
of public lands (including mineral interests) within this Decision Area.
Navajo Tribal Trust Lands—Lands within the Navajo reservation that the United States holds in trust
for the Tribe. These lands can be either on-reservation or off-reservation. Under Federal law, such lands
generally may not be sold, taxed, or encumbered; however, Tribes may be able to lease Trust lands, and
the lessee or sublessees of such lands may be able to grant leasehold mortgages on their leasehold
interests, subject to federal approval.
Individual Indian Allotments (IIA)—Parcels of land held in trust by the United States for individual
Indians or held by Indians and otherwise subject to a restriction on alienation (that is, where there is a
restriction on the Indian owner’s ability to sell or transfer the allotment to another party). Approximately
1,250 Navajo allottees would have an increased opportunity to develop their allotted mineral rights in a
more economically-viable way by considering developments that could include adjacent federal minerals.
Mineral Estate—The ownership of minerals, which may be separately held from surface land ownership.
2.3
PARTIAL REVOCATION ALTERNATIVE (ALTERNATIVE C)
Under the partial revocation alternative, the Secretary of the Interior would revoke PLO No. 7923 only
so far as it applies to approximately 220,970 acres of the 338,690 acres of public lands withdrawn by PLO
No. 7923. Under Alternative C, the federal interests in an approximately 5-mile-wide radius immediately
surrounding CCNHP would remain withdrawn by PLO No. 7923; however, PLO No. 7923 would no
longer be in effect for the federal interests in the approximately 220,970 acres originally withdrawn beyond
this approximately 5-mile-wide radius surrounding CCNHP (See Table 2-1).
For the approximately 220,970-acre area that would no longer be withdrawn should the Secretary elect
Alternative C for implementation, BLM’s discretion over mineral leasing would be restored and the land
would re-open to location and entry under the United States mining laws and regulations such as 43 CFR
3809. Should the Secretary elect Alternative C for implementation, the BLM would follow existing
management direction outlined in the 2003 FFO RMP for leasable minerals (e.g., oil, gas and coal) and
locatable minerals (e.g., most metallic minerals).
In its decision making regarding any future mineral leasing or development following Secretarial selection
of Alternative C, the BLM would commit to implementing the Design Features in Section 2.4 to mitigate
potential resource impacts.
Table 2-2. Federal Minerals Associated with Federal and Non-Federal Land within the Outer 5 Miles
of the Analysis Boundary (Alternative C)
Land Manager or
Surface, Federal Minerals in
Owner
GIS Acres
Outer 5 Miles of
Withdrawal
Boundary,
GIS Acres
BLM
137,170
127,500
National Park Service
0
0
State of New Mexico
38,590
13,640
Individual Indian
392,200
74,900
Allotted / Tribal Trust
Private
25,990
4,930
Total
593,950
220,970
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
8
2. Proposed Action and Alternatives
2.4
DESIGN FEATURES COMMON TO ALL ALTERNATIVES
Should the Secretary revoke PLO No. 7923 in whole or part, the BLM would incorporate the following
Design Features in any future decision making regarding mineral leasing or development of federal minerals
within the withdrawal area to mitigate potential resource impacts from such leasing or development.
Cultural Resources
• If the area to be disturbed under a notice-level mineral exploration or mining operation has not
been sufficiently inventoried for cultural resources, the FFO will conduct the necessary inventory
and recordation of cultural resources as a Design Feature within the 15-day period of review (43
CFR 3809.311(a)). If BLM determines that any of the conditions in 43 CFR 3809.313 apply, BLM
will notify the operator of any additional information or changes to the operation that are required
to prevent unnecessary or undue degradation or to meet other objectives identified in 43 CFR
3809.313.
• Existing protections for and management of cultural resources would continue to apply, even in
the absence of the mineral withdrawal. This includes the protection within the designated
CCNHP, as well as the additional protections afforded cultural resources, either through physical
protection or information documentation, associated with the requirements of NHPA, ARPA,
NAGPRA, Executive Order 13007, and BLM’s implementing regulations and policies.
2.5
ALTERNATIVES CONSIDERED BUT NOT ANALYZED IN DETAIL
Sometimes alternatives are suggested or proposed that upon examination would not adequately respond
to the agency’s purpose and need for action, would be technically or economically infeasible, would not
be suitable for consideration, would be remote or speculative, would be substantially similar in design to
an existing alternative, would have substantially similar effects as an existing alternative, or the authority
does not exist for the agency to approve such actions. In such cases, these alternatives can be eliminated
from detailed analysis. Alternatives that were considered and eliminated from detailed analysis are listed
below, along with the rationale for their elimination.
2.5.1 Revoke PLO No. 7923 for a Smaller Subset of the Withdrawn Lands
This alternative was not analyzed in detail because both a full and partial revocation of PLO No. 7923 is
already being analyzed within this EA. The Secretary may select for implementation an alternative within
the range of alternatives analyzed in detail, including a partial revocation of PLO No. 7923 for any acres
fewer than the entire withdrawal area, because the Secretary has the authority to approve or deny the
Proposed Action in part or in whole based upon this analysis.
2.5.2 Revoke PLO No. 7923 to Allow Only Leasing Under the Mineral Leasing Laws
Should the Secretary elect to revoke PLO No. 7923 in part, to allow only leasing under the mineral leasing
laws on all or some of the 338,690 acres withdrawn under PLO No. 7923, but not re-open any lands to
location and entry under the U.S. mining laws, minerals subject to mineral entry (including minerals
meeting the Critical Minerals definition as set forth in EO 14241) would remain unavailable for
development, except those subject to valid existing rights. Because Critical Minerals and energy-related
minerals such as uranium would remain unavailable should the Secretary revoke PLO No. 7923 in part to
allow only mineral leasing, while the BLM would no longer be prevented from issuing new leases of oil,
gas, and coal in support of the President’s energy agenda, this alternative may not be responsive to that
aspect of EOs 14241, 14154, and SO 3418 and thus would not fully meet the purpose and need for the
action set forth above.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
9
Chapter 3. Affected Environment and
Environmental Effects
3.1
INTRODUCTION
Chapter 3 contains the analysis of environmental effects related to the issues. Section 3.2 describes the
No Action Alternative (Alternative A) for all issues. Section 3.3 broadly discusses reasonably foreseeable
environmental and development trends within the Affected Environment. Section 3.4 presents the issues
that are analyzed in detail. Appendix C contains the issues that are analyzed in brief. Section 3.5
describes the effects of the Proposed Action (Alternative B) and Reduced Action Alternative (Alternative
C) in the context of the reasonably foreseeable environmental trends and planned actions that constitute
the Affected Environment.
3.2
NO ACTION ALTERNATIVE FOR ALL ISSUES & REASONABLY FORESEEABLE
ENVIRONMENTAL TRENDS
Under the No Action Alternative, the Secretary of the Interior (or appropriate Department of the Interior
official) would not revoke PLO No. 7923 to re-open the public lands to location and entry under the U.S.
mining laws and to leasing under the mineral leasing laws around the CCNHP. Absent such a revocation
of the withdrawal, there would be no change to existing conditions and trends related to each issue -that
is, conditions in the area withdrawn by PLO No. 7923 would remain as described for the Proposed Action
in the 2023 EA supporting PLO No. 7923. While there would be no new location and entry under the
U.S. mining laws under the No Action Alternative, development of minerals subject to mineral entry
(locatable minerals) based on valid existing rights could continue; however, mining claims in the current
withdrawal area would be subject to validity testing per 43 CFR 3809.100(a), which states in part that:
BLM will not approve a plan of operations or allow notice-level operations to proceed until BLM has
prepared a mineral examination report to determine whether the mining claim was valid before the
withdrawal, and whether it remains valid.
Given these requirements, and the limited information it has, the BLM has no evidence to indicate whether
development of any of the existing 129 mining claims within the area withdrawn under PLO No. 7923 is
reasonably foreseeable.
Similar to locatable minerals discussed above, while the BLM would not be able to issue new mineral leases
under the No Action Alternative, the BLM could authorize activities under existing leases and would
manage existing leases under the applicable laws and regulations and the provisions of the 2003 RMP. Also,
because PLO No. 7923 did not withdraw the land from disposal of mineral materials under the mineral
materials disposal laws, disposal of mineral materials (such as sand, gravel, and humate) could continue
under the No Action Alternative.
Natural gas and crude oil from existing leased parcels both within (78 existing leases) and outside the
withdrawal area would continue to be produced, and any royalties would accrue to federal and state
treasuries. Continued oil and gas development on existing leases within the withdrawal could sustain or
increase local and regional employment and revenue opportunities related to oil, gas, and service/support
industries until such time as the existing leases have been fully developed.
Even under the No Action Alternative, ongoing industrial development would potentially affect natural
and cultural resources on public lands within the larger regional landscape. Continued mineral
Chaco Withdrawal Evaluation Environmental Assessment
10
3. Affected Environment and Environmental Effects
development activities would contribute to increased air emissions, noise sources, and traffic from
exploration and production operations. BLM estimates up to 1,150 acres of future expansion is expected
in communities within the decision area including development for roads, utilities, and communication
lines and also future expansion of utilities, public spaces, roads, and/or residential areas within federal and
Navajo Nation lands within the decision area, even if no new mineral leases are issued.
Additionally, regardless of any Secretarial decision made regarding PLO No. 7923, as supported by this
EA, BLM estimates that 73 oil and gas wells (251 acres including access roads and well-tie pipelines) could
be drilled and placed in production over the next 20 years due to continued infill of existing leases present
within the current 10-mile Chaco withdrawal boundary (BLM 2025a). These 73 future wells (21 horizontal
Mancos-formation wells and 52 vertical Fruitland-formation wells) are all predicted to occur within the
outer 5-mile withdrawal boundary because the inner 5-mile boundary has limited resource potential
and/or economic viability (BLM 2025a). This estimate is based upon the 16,780 acres of existing Federal
leases in the decision area, using an 800-acre spacing per well for wells targeting the Mancos and 320-acre
spacing per well for wells targeting the Fruitland. The 800-acre spacing assumes 2.5-mile horizontal laterals;
the 320-acre spacing utilizes half of the available 160-acre spacing due to low expected production from
the Fruitland in the decision area compared to wells further north. This further assumes the 21 horizontal
wells would be clustered into 6 well pads with approximately 64 acres of disturbance and the 52 vertical
wells would each occupy one well pad (as is typical for vertical wells) with approximately 187 acres of
disturbance. Both estimates include a representative amount of disturbance from well-tie pipelines and
well pad access roads (horizontal: 10.69 acres per pad; vertical: 3.6 acres per pad).
Therefore, in total, the reasonably foreseeable disturbance under the No Action alternative is
approximately 1,401 acres over the next 20 years.
Should the BLM propose to authorize any future surface disturbing action, regardless of the presence,
extent, or absence of PLO No. 7923, the BLM would employ or require best management practices (e.g.,
stipulations, conditions of approval, design features, etc.), consistent with any lease rights, to mitigate the
effects of such activities on the area’s setting and unique recreational opportunities.
3.3
REASONABLY FORESEEABLE DEVELOPMENT SUMMARY UNDER ACTION
ALTERNATIVES
The area that could be affected by Secretarial revocation of PLO No. 7923 in whole or part (the decision
area) is within the New Mexico portion of the San Juan Basin, a major oil and natural gas basin and the
main structural feature of the Navajo physiographic section of the Colorado Plateau. This analysis employs
the most recent update to the Reasonably Foreseeable Development Scenario (RFDS) for Oil and Gas
Activities in the Farmington Field Office (Engler 2025) and other support documents (such as the 2018
RFDS [BLM 2018] and Chaco Mineral Potential Report [BLM 2022a]) to support the evaluation of the
reasonably foreseeable environmental trends for oil and gas leasing and development and for development
of minerals subject to location and entry under the U.S. mining laws in the area that could occur should
the Secretary revoke PLO No. 7923, in full.
The San Juan Basin has been a producing oil and natural gas field since the early to mid-1900s. It is
characterized by overlapping uses for oil and gas development, grazing, and dispersed recreation. Overall,
the Mancos-Gallup RFDS (BLM 2018) estimates existing long-term surface disturbance across the 4.2million-acre Mancos-Gallup planning area (a subset of the larger FFO management area, overlapping the
current decision area) from oil and gas development to be approximately 56,500 acres from 37,300 wells.
Under both Action Alternatives, the following reasonably foreseeable development over the next 20 years
is considered within the 965,670-acre decision area in this effects analysis scenario:
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
11
3. Affected Environment and Environmental Effects
Energy Leasable Minerals: No new oil and gas wells are foreseen within the 5-mile area surrounding
CCNHP under any of the three alternatives (BLM 2025a). If Alternatives B or C were selected by the
Secretary, and the area withdrawn under PLO No. 7923 became available for leasing and subsequent
development, FFO projects the development of 4 horizontal Mancos-formation wells and 10 vertical
Fruitland-formation wells on new leases over the next 20 years within the outer approximately 5-mile
radius within the decision area (BLM 2025a). The 2025 RFDS (Engler 2025) categorized the entire Chaco
region as unlikely to see further development, whereas the 2018 RFDS (BLM 2018) took a more nuanced
approach that assigned high, medium, low, and negligible potential. In making the prediction of 14 new
wells, FFO considered the 2018 RFDS, the 2025 RFDS, and local industry trends.
New surface disturbance from these 14 potential wells (on new leases, if the decision area were to be
fully leased) in this outer 5-mile radius is estimated at approximately 58 acres. The 2025 RFDS estimates
new surface disturbance in this outer 5-mile radius, including access roads and well-tie pipelines at 10.69
acres per well for future horizontal wells (2 wells per pad) and 3.6 acres per well (one well per pad) for
future vertical wells (BLM 2025a). While the decision area is known to contain coal resources, based on
current market trends and the historic (pre-withdrawal) lack of recent commercial interest in those
resources, the BLM does not foresee any new coal development within the decision area, regardless of
whether the Secretary revokes PLO No. 7923 in whole or part.
Minerals Subject to Mineral Entry: While Secretarial selection of the Proposed Action (Alternative
B) or Alternative C for implementation would re-open their respective decision areas to location and
entry under the U.S. mining laws, a conservative estimate of the number of mining claims reasonably
foreseeable to be developed consists of the 129 active mine claims within the decision area for a total of
approximately 2,665 acres (Proposed Action). Although it is not possible to estimate how many new
claims would be located under Alternative B, fewer new claims are likely to be located under Alternative
C because fewer acres would be opened. Approximately 129 existing claims are located on lands that
would be re-opened to mineral location under Alternative B, of which 109 existing claims would be reopened to mineral location under Alternative C.
Table 3-1 presents a summary of quantifiable surface disturbances associated with reasonably foreseeable
development associated with the Action Alternatives.
Table 3-1. Reasonably Foreseeable Development That Could Only
Occur Under the Action Alternatives
Alternative B: Quantifiable Disturbance Sources
Number of Wells
or Claims
14
Alternative B: Reasonably foreseeable additional future oil and gas development
Alternative B: Reasonably foreseeable additional future development
129
of minerals subject to mineral entry
14 (wells)
Alternative B Totals
129 (claims)
Alternative C: Quantifiable Disturbance Sources
Number of Wells
or Claims
14
Alternative C: Reasonably foreseeable additional future oil and gas development
Alternative C: Reasonably foreseeable additional future development
109
of minerals subject to mineral entry
14 (wells)
Alternative C Totals
109 (claims)
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
Acres
58
2,665
2,723
Acres
58
2,252
2,310
12
3. Affected Environment and Environmental Effects
3.4
ISSUES ANALYZED IN DETAIL
3.4.1
Resource Issue 1: Minerals Subject to Location and Entry under the U.S. Mining
Laws
How would the proposed revocation affect the availability of locatable mineral
resources (uranium) within the decision area?
3.4.1.1 Affected Environment
For more information on the mineral potential in the decision area, see the Mineral Resource Potential
Bureau of Land Management Lands and Minerals Selected Chaco Area Mineral Withdrawal, San Juan and
McKinley County, New Mexico report (BLM 2022a). In the San Juan Basin, there is low potential for
locatable minerals outside of uranium; therefore, this EA does not address other major locatable minerals
such as gold and silver.
3.4.1.1.1 Uranium
The Grants uranium district, located along the southern margin of the San Juan Basin in Cibola, McKinley,
Sandoval, and Bernalillo Counties as well as on Tribal lands, was once one of the largest producers of
uranium in the country (EPA 2025a). Parts of the Nose Rock, Chaco Canyon Church Rock-Crownpoint,
Smith Lake, and Ambrosia Lake subdistricts of the Grants mineral belt are within the boundary of the area
withdrawn by PLO No. 7923. Currently, there are no producing uranium mines in the Grants uranium
district; however, several mines are still undergoing decommissioning and reclamation (NMMMD 2025).
Approximately 409 million pounds of uranium resources that were never mined remain in the Grants
district, as identified by companies in the 1980s and in recent exploration (McLemore 2020).
No uranium production has occurred in New Mexico since 2002 (McLemore et al. 2016). Records indicate
that uranium exploration has occurred in New Mexico as recently as 2017, but the locations of most
recent exploration and interest are largely southeast and southwest of the area withdrawn by PLO No.
7923 (NMMMD 2025). Uranium mining is highly dependent on the price of uranium, and existing sources
in other states and foreign countries can be profitably mined at a lower cost than the New Mexico deposits
(EIA 2020). Within the area withdrawn by PLO No. 7923, approximately 2,665 acres of federal minerals
are currently claimed under the 1847 General Mining Law, although the validity of those claims has not
been examined. (Map 2-2, Appendix D).
No new applications for uranium extraction or exploration have been submitted to the FFO. There are
129 unpatented mining claims (including uranium and all other locatable minerals) encompassing
approximately 2,665 acres within the area withdrawn by PLO No. 7923.
3.4.1.2 Environmental Consequences
3.4.1.2.1 Proposed Action (Alternative B)
Under Alternative B, the Secretary of the Interior would revoke PLO No. 7923, which withdrew
approximately 338,690 acres of public lands from location and entry under the United States mining laws
and from leasing under the mineral leasing laws, subject to valid existing rights, for a 20-year term.
Alternative B would affect the entire approximately 10-mile withdrawal surrounding CCNHP.
A revocation or partial revocation of the existing withdrawal would open BLM lands for exploration under
the U.S. mining laws, including the Mining Law of 1872. As defined in 43 CFR 3809, three different types
of operations with different levels of analysis are identified. Plan-level operations are generally over 5acres in size and are subject to NEPA and NHPA analysis. The regulations also allow for Casual Use and
Notice-level operations, which are not subject to NEPA analysis, but which still require operators to
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
13
3. Affected Environment and Environmental Effects
prevent unnecessary or undue degradation (43 CFR 3809.605). This includes compliance with “…Federal
and State laws related to environmental protection and protection of cultural resources” (43 CFR 3809.5).
There has been no notification provided to the BLM that casual use activities are occurring. Casual use
generally includes the collection of geochemical, rock, soil, or mineral specimens using hand tools, hand
panning, and non-motorized sluicing. The use of metal detectors, gold spears, and other battery-operated
devices for sensing the presence of minerals is allowed but the use of mechanized earth-moving equipment
and truck-mounted drilling equipment is prohibited. Casual use does not include use of mechanized earthmoving equipment, truck-mounted drilling equipment, motorized vehicles in areas designated as closed to
“off-road vehicles” as defined in 43 CFR 8340.0-5, chemicals, or explosives. It also does not include
“occupancy” as defined in 43 CFR 3715.0-5 or operations in areas where cumulative effects of such
activities would result in more than negligible disturbance.
Under the current regulations, new notice-level operations are limited to 5 acres or less and must not
cause more than casual use in certain special status areas defined in 43 CFR 3809.11(c). New notice-level
operations are limited to exploration activities, which does not include extraction of material for
commercial use or sale (43 CFR 3809.5), and must not exceed other limitations on notice-level activities
(43 CFR 3809.11). Under 43 CFR 3809.312, operators must notify FFO fifteen calendar days prior to
conducting notice-level operations. The BLM assesses the notice of operations for completeness and
whether the activities described in the notice would prevent unnecessary or undue degradation. If the
notice is incomplete (43 CFR 3809.311) or other circumstances described in 43 CFR 3809.313 apply, BLM
will inform the operator in writing of the deficiency and operations must not begin until the circumstance
is resolved. Operators must also provide to BLM a financial guarantee for reclamation before beginning
operations. If the proposed activities would not prevent unnecessary or undue degradation, BLM can
determine that the operator may not conduct operations and will notify the operator.
Compared to notice-level operations, plan-level operations are subject to additional requirements (e.g.,
43 CFR 3809.401) and a broader range of review (e.g., 43 CFR 3809.411).
Uranium
The proposed revocation would open federal lands to exploration and characterization of most uranium
resources within the withdrawal area. There are 129 mining claims (this tally includes claims for uranium
and all other locatable minerals) within the revocation area; however, it is unlikely that any of these claims
would be developed in the short term after implementation of the Proposed Action. While the proposed
revocation area has known deposits of uranium in the federal mineral estate, given the typical timeline
required to locate and record a claim, acquire permits, and bring online a uranium development, it is safe
to assume that no production of any uranium on claims that are not already located would be reasonably
foreseeable within the 20-year period PLO No. 7923 would otherwise be in effect (assuming no extension)
(Map 2-5, Appendix D). Any proposed uranium development would be subject to site-specific NEPA
and other environmental review, as well as oversight by the Nuclear Regulatory Commission.
There are currently no uranium producers operating locally, and uranium production in the United States
has been declining since 2014. At the end of 2021, only two uranium recovery operations in the United
States were producing, and nine were on standby (EIA 2022). Other countries have more accessible, highquality uranium deposits, allowing them to produce at a lower cost than the United States (EIA 2020). As
a result, any increases in future demand are likely to be met by foreign sources and resumption of
production at existing facilities currently on standby, rather than by the costly construction of new
facilities. Because of these factors, the development of any uranium claims on the federal mineral estate
within the proposed revocation area is unlikely within the next 20 years.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
14
3. Affected Environment and Environmental Effects
3.4.1.2.2 Partial Revocation (Alternative C)
Under Alternative C, the Secretary of the Interior would revoke the withdrawal of approximately 220,970
Acres of the 338,690 acres of public lands withdrawn by PLO No. 7923.
Uranium
Under the partial revocation, 20 of the 129 mining claims (including uranium and all other locatable
minerals) would be still subject to a validity exam, as they fall within the 5-mile area that would remain
withdrawn. (Map 2-8, Appendix D). Due to low demand, and the fact there are no known active
proposals for uranium developments of federal minerals in the withdrawal area, the development of any
uranium claims within the proposed partial revocation boundary is unlikely. Any proposed uranium
development would be subject to site-specific NEPA and other environmental review, as well as oversight
by the Nuclear Regulatory Commission.
3.4.2
Resource Issue 2: Leasable Minerals
How would the proposed revocation affect the availability of leasable mineral resources
(coal and oil and gas) within the decision area?
3.4.2.1 Affected Environment
3.4.2.1.1 Oil and Gas
According to the 2025 RFDS which forecast development for the entire Farmington Field Office
management area, future oil and gas activity in the region would be primarily horizontal drilling for oil in
the Mancos/Gallup plays, the Mancos shale basin-centered gas subplay to the north near the Colorado
border and the Mancos/Gallup Southern Rim horizontal oil subplay located to the south near Nageezi and
Counselor, NM (Engler 2025). These subplays have seen the highest drilling and completion activity levels
over the last 15 years. Vertical development of oil and gas within the region is expected to be limited to
infill drilling at low rates (Engler 2025). Within the 10-mile withdrawal area, approximately 65 vertical or
directional wells have been completed since the year 2000 along the north-northeast fringe of the 10-mile
withdrawal, with the vast majority completed in the Fruitland coal (Engler 2025). No wells have been
drilled or completed within 5 miles of CCNHP in that timeframe. For more information on the mineral
potential in the withdrawal boundary, see the Mineral Resource Potential Bureau of Land Management
Lands and Minerals Selected Chaco Area Mineral Withdrawal, San Juan and McKinley County, New Mexico
report (BLM 2022a).
The Mancos/Gallup Southern Rim horizontal oil subplay is adjacent to the north-northeast boundary of
the 10-mile Chaco withdrawal area. This area has seen high levels of development since approximately
2013, with 482 wells drilled and completed producing 78 million barrels of oil (MMBO) and 312 billion
standard cubic feet (Bscf) of natural gas (Engler 2025). The main target interval for this subplay sits mainly
outside of the 10-mile withdrawal area with some overlap. The Mancos and Gallup reservoir in this area
consists of barrier bars/islands where coarser intervals follow the Cretaceous shoreline trend of the
Western Interior Seaway (see Figure 6 in Engler et al. 2015). Moving south-southwest into the 10-mile
Chaco withdrawal area, the Mancos/Gallup reservoir becomes more water saturated and begins
shallowing onto the Chaco Slope, which has limited development into the withdrawal area as the reservoir
quality decreases and eventually becomes non-existent. The 2025 RFDS does not predict a significant
expansion of oil and gas activity within the majority of the existing 10-mile withdrawal area, if it is opened
to leasing, due to geologic and production constraints on both vertical and horizontal development. Both
the Fruitland coal and Mancos shale shallow to the south-southwest, and the Fruitland coal outcrops
around the 5-mile area from CCNHP (see Figure 4 and 6 in BLM 2022a).
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
15
3. Affected Environment and Environmental Effects
Within or partially within the area withdrawn by PLO No. 7923, there are 78 existing oil and gas leases
encompassing approximately 94,500 acres of federal mineral estate; approximately 71,900 acres of those
leases lie within the proposed withdrawal revocation area (Map 2-3, Appendix D). As of November 18,
2025, all 78 of these leases are held by production (meaning there is one or more economically producing
well on the lease) so the lease can continue to produce and remains valid beyond its primary term.
Table 3-2, below, shows the development potential for the Mancos/Gallup Southern Rim horizontal oil
subplay from the 2025 RFDS (Engler 2025), which overlaps with the “high” development potential assigned
by the 2018 RFDS (BLM 2018) with the current lease status of each development potential rank. Areas
outside of the Mancos/Gallup Southern Rim horizontal oil subplay and outside of “high” development
potential area from the 2025 RFDS and 2018 RFDS, respectively, were not included as development
targets as described above and in Section 3.3.
Table 3-2. Development Potential Rating and Lease Status of
the Proposed Withdrawal Revocation Area
Development Potential Rating and
Acres
Lease Status
Mancos/Gallup Southern Rim horizontal oil subplay
20,060
Unleased
3,280
Leased—held by production
16,780
Leased—not held by production
0
Negligible Development Potential
277,440
Unleased
224,230
Leased—held by production
53,210
Leased—not held by production
0
Statutorily Excluded
41,190
Unleased
40,080
†Leased—held by production
1,110
Leased—not held by production
0
Sources: BLM GIS, BLM 2018.
† This includes leases within wilderness areas that pre-date the designation.
*Acres are calculated using GIS and rounded to the nearest 10 acres. As a result, minor rounding
errors may occur, and totals may not equal official acreages.
The development of oil and gas has been and continues to be a topic of interest for the local community.
FFO will continue to engage with Tribes and Pueblos to better understand and address the full range of
potential impacts of such development, particularly those that may fall outside conventional environmental
assessment frameworks or standard BLM impact categories. As part of this effort, FFO is participating in
the development of a Programmatic Agreement under section 106 of the NHPA. The agreement is
intended to streamline consultation while enhancing cultural sensitivity, improving data transparency, and
supporting cooperative stewardship with Tribes. These efforts reflect a broader commitment to ensuring
that historic and cultural resources are meaningfully considered in land management decisions.
Navajo Allottee Mineral Owners
The following analysis incorporates by reference information from the EA for PLO No. 7923 (DOI-BLMNM-F010-2022-0011 [BLM 2023]).
Beginning in the late nineteenth century under various authorities, Indian allottees applied for or were
assigned patents of lands. While many of these land patents expressly reserved specific mineral
commodities to the United States, many other patents failed to adequately address the topic of mineral
rights. To alleviate confusion surrounding the mineral estates underlying those patents, the Mescal
Settlement Agreement (MSA) was signed. Following the issuance of allotted supplemental mineral patents,
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
16
3. Affected Environment and Environmental Effects
many allottees have leased minerals to oil and gas producers, coordinated through the Federal Indian
Minerals Office (FIMO). FIMO was established by DOI to provide and improve services to individual Indian
beneficiaries in the management of their oil and gas mineral resources.
3.4.2.1.2 Helium
Helium was trapped in the San Juan Basin in the same way that oil and natural gas were trapped
(stratigraphically and structurally) but was likely created through radiogenic decay of uranium and thorium
in granitic Precambrian basement rocks that underlie the study area (Broadhead 2005). Helium is limited
due to tight constraints on conditions that create helium reservoirs (Engler 2025). After its creation, the
helium migrated upwards into Paleozoic reservoir rocks along high-angle, strike-slip faults on the Four
Corners Platform along the northwest edge of the San Juan Basin, where helium concentrations of up to
7.5% have been documented and production totals reached nearly 1 billion cubic feet (Broadhead 2005).
The faults that the helium migrated along exist across much of the San Juan Basin, following the northwestsoutheast trend of the paleo-shoreline from the Western Interior Seaway, and granitic basement rocks
underlie the entire basin as well. However, no helium wells have been drilled off the Four Corners Platform
in either the Central Basin or Chaco Slope, so it is unknown if commercial volumes of helium exist in
Paleozoic strata off the structural high. No production has occurred within the decision area, and no
proposals to test the helium reservoir exist at the time of writing. Triassic strata within the Basin may also
contain commercial concentrations of helium, but no wells have been drilled to begin delineating fields or
production potential. Helium production and exploration has slowed since the mid-2000s, but there has
been renewed interest in the helium potential of the Four Corners Platform over the past several years
as the global helium supply is low. Recently, Vision Energy has drilled six wells in the old Hogback Field
and is awaiting a build-out of its facilities to process the gas. The nearest producing helium pool in the San
Juan Basin, the North Tocito Dome (approximately 35 miles to the west of the withdrawn area), has
averaged approximately 4.7 million standard cubic feet (mmscf) of helium over the last six years but is
declining in production (Engler 2025). Based on burial depth of key strata and lack of producing or
exploratory wells, it is unlikely that helium would be developed within the proposed revocation areas.
3.4.2.1.3 Coal
The area proposed for withdrawal revocation is intersected by parts of the Bisti Coal Field, Star Lake Coal
Field, and Crownpoint Coal Field. There are no active mines in the withdrawal area. The nearest active
coal mine is the El Segundo Mine located outside the withdrawal area, east of the town of Crownpoint.
This operation is mining coal from the Cleary member of the Menefee Formation (Peabody Natural
Resources Company 2019). The results of the coal unsuitability criteria conducted as part of the
Farmington RMP (BLM 2003) found that in the area eventually withdrawn by PLO No. 7923, approximately
294,670 acres of federal minerals were suitable for coal leasing, 41,190 acres were unsuitable for leasing,
and 2,830 acres were subject to an existing withdrawal (i.e., other than PLO No. 7923). However, absent
a withdrawal, a coal lease could be issued; coal unsuitability criteria could be reapplied, and suitability
results could change (Map 2-1, Appendix D).
In the area of proposed for withdrawal revocation, there are currently zero acres of issued federal coal
leases. There were coal preference right lease applications within the withdrawal area that covered
approximately 38,260 acres of federal mineral estate. The preference right lease applications are all closed,
rejected, or transferred, and are no longer considered valid existing rights. Several federal coal leases that
were issued, comprising approximately 7,740 acres within the withdrawal area, have since been closed or
been relinquished or transferred; they are no longer considered valid existing rights.
The most recent detailed examination of past leases in the area was conducted as part of a Mineral
Resource Report prepared prior to PLO No. 7923 (BLM 2022a). Demand for coal in the United States
has been decreasing due to price competition from natural gas and changes to regulations of emissions
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
from coal power generation. Even if the Secretary were to revoke PLO No. 7923 in full, the BLM does
not anticipate new coal operations would open in the proposed revocation area over the next 20 years.
3.4.2.2 Environmental Consequences
3.4.2.2.1 Proposed Action (Alternative B)
Under the Proposed Action, the Secretary of the Interior or appropriate Department of the Interior
official would open approximately 338,690 acres of public land (including federal mineral estate) to
leasing under the mineral leasing laws, and any subsequent leasing or development would be subject to
current management practices under the 2003 BLM FFO RMP, or the terms of any applicable leases.
Oil and Gas
The proposed withdrawal revocation under Alternative B would re-open 3,280 acres of unleased Federal
mineral estate that could reasonably be subject to leasing and subsequent development within the decision
area in the Mancos/Gallup Southern Rim horizontal oil subplay, as well as 224,230 acres of negligible
development potential (Table 3-2). The BLM predicts limited vertical and horizontal development within
this unleased acreage to test the southern extent of the Mancos/Gallup oil subplay as water production
increases, and to account for limited infill drilling of vertical Fruitland coal wells in areas near existing
infrastructure. The BLM estimates that within the 3,280 acres of the Mancos/Gallup oil subplay that overlap
with the 10-mile revocation area, 14 wells could be developed following Secretarial revocation of PLO
No. 7923, in full: 4 horizontal Mancos wells with 2.5-mile lateral lengths and 10 vertical Fruitland coal
wells. This assumes 800 acres of dedicated acreage per horizontal Mancos well and infill vertical Fruitland
coal wells at 320-acre spacing. The Fruitland coal spacing is currently set at 160 acres, but low EURs for
coal wells in the area (0.5 Bscf/well) (Engler 2025), low commodity price along with high transport cost,
and lack of development within existing leased and/or unitized areas over the last 25 years all support a
more limited development estimate for the Fruitland target.
The boundary of the area withdrawn by PLO No. 7923 and proposed for withdrawal revocation in full
lies almost entirely outside of development targets identified in the 2025 RFDS; that is, the 2025 RFDS
predicts little development within the withdrawal boundary, even absent a withdrawal. The oil subplay
does not extend very far within the withdrawal area and what is present is largely already leased. For
vertical development within the decision area, the Fruitland coalbed methane reservoir is the main target
as evidenced by the vertical wells completed in the area since 2000 (Engler 2025). Two horizontal wells
within the Mancos are currently producing within the 10-mile withdrawal area, but both have high wateroil ratios compared to wells further northeast. Recent development within the oil subplay has been
focused north and northeast of the 20,060-acre area of the subplay that overlaps with the 10-mile decision
area (Table 3-2).
As shown in Table 3-2 above, much of the target area for development is already leased. Over the long
term, the development of federal oil and gas in the withdrawal area under the Proposed Action is likely
to be higher compared with the level of development within the area under the No Action Alternative,
as the BLM would be able to offer and issue new leases. The best available estimate of projected oil and
gas development is provided in the 2025 RFDS, which evaluated development potential irrespective of
lease status or withdrawal status, and estimates 700 new horizontal oil and gas wells from within the
Mancos/Gallup Southern Rim horizontal oil subplay (Engler 2025). As noted in Table 3-2, 20,060 acres
of the oil subplay exist within the decision area, only 3,280 acres of which are currently unleased and
would be affected by revocation of the withdrawal (Map 2-6, Appendix D).
The proposed withdrawal revocation would not affect existing leases, including the approximately 71,100
acres of existing federal oil and gas leases within the proposed revocation area (Table 3-2). The
revocation would not apply to minerals owned by private, state, or Tribal entities, but may allow for
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
additional development of adjacent mineral ownerships via unitization and horizontal drilling implicating
newly available federal leasable minerals. Existing leases not held by production could be developed,
relinquished by the lessee, or expire if not developed within the lease term. Absent the withdrawal, any
leases that expired or were relinquished in the future would be available for leasing again. As under the
No Action Alternative, production from existing wells could continue, and additional wells could and
would likely be drilled on existing leases.
Due to availability of adjacent Federal mineral estate that PLO No. 7923 made unavailable for leasing and
subsequent development, following Secretarial revocation of PLO No. 7923, in full, and the possibility of
new mineral leases, additional wells could be drilled that produce from other, non-Federal fluid mineral
ownership or management types including Trust (Tribal, Individual Indian Allottee), private, and New
Mexico State Land Office minerals. While Secretarial decision-making about PLO No. 7923 does not
directly impact availability of fluid mineral under other ownerships for oil and gas development, the ability
to lease large areas and unitize them for more structured development of these resources could promote
additional drilling in the decision area. Due to uncertainties of individual lease availability for other
ownership types along with the presence of unitized areas across much of the Mancos/Gallup horizontal
oil subplay area that overlaps the decision area, the BLM is not able to estimate a well count for analysis
in this EA.
Navajo Allottee Mineral Owners
The following analysis incorporates by reference information from the EA for PLO No. 7923 (BLM 2023).
To assess potential impacts to individual Indian allottees (IIA) from the Proposed Action, the analysis
methodology looked at each allotment in the decision area and considered the land and leasing status of
the allotment and of adjacent parcels (i.e., whether the land was withdrawn from oil and gas leasing). The
goal was to qualitatively assess whether the Proposed Action (full revocation of the withdrawal) would
influence whether a given allotment would be more or less likely to support a viable oil and gas lease.
In the PLO No. 7923 EA, allotments not sharing a boundary or corner with fluid minerals not proposed
for withdrawal were assigned an unmodified score of Negligible Impact. Allotments with an active existing
allotted lease or Mescal Lease were also assigned an unmodified score of Negligible Impact. Allotments
such as these are not further analyzed for mitigating or aggravating factors. The remaining allotments were
classified into four Future Allotted Lease Impact categories: negligible, low, medium, and high, correlating
with and based upon the parcel’s location in the four areas of development potential from the 2018 RFDS
(BLM 2018). Classification of these areas is largely unchanged in the 2025 RFDS (Engler 2025); however,
these classifications were modified by the mitigating presence of shared-boundary adjacent leases.
For this Proposed Action (revocation of PLO No. 7923 in whole or part), each of the 1,233 base
allotments within or intersecting the withdrawal area boundary was analyzed with respect to its 2018
RFDS development potential, the character of its proximity to Federal fluid minerals that would become
available for potential leasing under the Secretarial implementation of one of the Action Alternatives, the
allotment’s lease status, the allotment’s lease sale nomination history or adjacency to Expressions of
Interest (EOIs) within the last decade (the practical advent of horizontal drilling technology in the basin),
and the allotment’s adjacency to existing Federal, State, and allotted fluid mineral leases. In addition to the
1,233 base allotments within the proposed withdrawal revocation area, the BLM analyzed an additional 35
base allotments adjacent to the withdrawn Federal fluid minerals but exterior to the decision area because
those allotments might be affected by that adjacency (e.g. where access is limited by terrain, where the
development of oil and gas infrastructure was limited by the presence of the withdrawal, etc.). These 1,268
base allotments consist of 1,358 simple, geographic, and resource fractionated allotments (Map 3-4,
Appendix D).
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3. Affected Environment and Environmental Effects
The result of that analysis (Table 3-3) indicates that 98 (just over eight percent) of the unleased 1,186
allotments analyzed may see a high or moderate increase in future lease viability due to conditions
introduced by the proposed revocation of the withdrawal. An additional 173 unleased allotments
(approximately 14.5 percent) may see low, but real, increases in future lease viability due to conditions
attributable to the proposed withdrawal. Unleased Navajo allotments are displayed in Map 3-6,
Appendix D. However, BLM acknowledges that the Navajo Nation and individual Indian allotees have
submitted comments which assert that the economic impact of the withdrawal exceeds the BLM’s
estimates and that the number of allotees affected may exceed 22,000 individuals (Navajo Nation 2021).
The proposed revocation of the withdrawal is estimated to have negligible effect on the lease viability of
the majority of allotments with respect to any augmentation of future lease viability by the proposed
revocation. Specifically, the Proposed Action would have negligible effect on 915 unleased allotments (over
77 percent of unleased allotments) and negligible effect on a further 82 already-leased allotments for a
total of 997 allotments with predicted negligible effect. These allotments were classified as negligible future
lease impact for the following reasons: the parcel is not adjacent to the fluid minerals within the area
proposed for withdrawal revocation, is isolated from existing adjacent leases and situated in areas with
negligible development potential, is already actively leased, is a surface-only allotment with a Mescal Lease,
or some combination of those factors.
In order to simplify the presentation of the data and focus on the predicted non-negligible effects, these
parcels are not depicted in Table 3-3 but all allotments are illustrated in Map 3-5, Appendix D.
Table 3-3. Potential Impacts from Proposed Action on Future Allotted Leases for Navajo
Allotments
Allotment
Adjacent
Analyzed
Analyzed
Count within
Allotment
Allotment Count
Allotment
Allotted Impact Reason
or Intersecting Count outside
(Total Including
Count
Analysis
Analysis
Known
(Total)
Boundary
Boundary
Fractionation*)
IMPACTS TO FUTURE ALLOTTED LEASE LEVEL: Low
Adjacent existing lease in high potential
3
2
5
6
Adjacent existing lease in medium
14
1
15
15
potential
Isolated from adjacent lease in low
3
5
153
158
potential
Total (Low)
165
8
173
179
IMPACTS TO FUTURE ALLOTTED LEASE LEVEL: Moderate
Adjacent existing lease in high potential
6
0
6
7
Corner-Adjacent Existing Lease in
1
0
1
1
Medium Potential, counter-mitigated by
only Corner-Adjacency to Proposed
Withdrawal
Adjacent Existing Lease in Medium
29
0
29
31
Potential, aggravated by Allotted Lease
Nomination and/or Corner/Boundary
Adjacency to EOI
Isolated from adjacent Lease in Medium
14
0
14
17
Potential
Isolated from Adjacent Lease in Low
7
0
7
7
Potential, aggravated by
Corner/Boundary Adjacency to EOI
Total (Moderate)
57
0
57
63
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3. Affected Environment and Environmental Effects
Allotment
Adjacent
Analyzed
Analyzed
Count within
Allotment
Allotment Count
Allotment
Allotted Impact Reason
or Intersecting Count outside
(Total Including
Count
Analysis
Analysis
Known
(Total)
Boundary
Boundary
Fractionation*)
IMPACTS TO FUTURE ALLOTTED LEASE LEVEL: High
Corner-Adjacent Existing Lease in
7
0
7
8
Medium Potential, aggravated by Allotted
Lease Nomination and/or
Corner/Boundary Adjacency to EOI
Corner-Adjacent Existing Lease in
1
0
1
1
Medium Potential, counter-mitigated by
only Corner-Adjacency to Proposed
Withdrawal and aggravated by Allotted
Lease Nomination
Corner-adjacent existing lease in
2
0
2
2
negligible potential
Isolated from Adjacent Lease in High
2
0
2
2
Potential, aggravated by Allotted Lease
Nomination and/or Corner/Boundary
Adjacency to EOI
Isolated from Adjacent Lease in Medium
28
1
29
30
Potential, aggravated by Allotted Lease
Nomination and/or Corner/Boundary
Adjacency to EOI
Total (High)
40
1
41
43
Source: BLM 2023
*Geographic and resource fractionation only; does not account for simple heir fractionation
Coal
Over the short term, if the withdrawal is revoked, the BLM would regain discretion over issuance of new
coal leases and the associated development and recovery of these resources. While the area proposed
for revocation has known deposits of Federal coal, no data on existing conditions support the assumption
that the development of any Federal coal deposits not already leased would be reasonably foreseeable
within the short term. Existing Federal coal mines and leases in the surrounding area exist outside the
area withdrawn by PLO No. 7923. Furthermore, there are only two active large-scale coal mines in the
entirety of the Farmington District, the Navajo and El Segundo Mines – both are outside of the withdrawal
boundary. In addition, non-Federal coal resources in the area are expected to be adequate to meet any
local demand for coal. Therefore, the proposed revocation of the withdrawal would not significantly
increase the potential for development of Federal coal resources (Map 2-4, Appendix D).
3.4.2.2.2 Partial Withdrawal Revocation (Alternative C)
Under the Alternative C, the Secretary of the Interior or appropriate Department of the Interior official
would open approximately 220,970 acres of public land (including Federal mineral estate) to leasing under
the mineral leasing laws, and any subsequent leasing or development would be subject to current
management practices under the 2003 BLM FFO RMP, or the terms of any applicable leases.
Oil and Gas
The partial withdrawal revocation would re-open 3,280 acres of unleased Federal mineral estate that could
reasonably be subject to leasing and subsequent development within the decision area in the
Mancos/Gallup Southern Rim horizontal oil subplay, as well as 146,150 acres of negligible development
potential (Table 3-4). As in Alternative B, the BLM predicts limited vertical and horizontal development
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
within this unleased acreage to test the southern extent of the Mancos/Gallup oil subplay as water
production increases, and to account for limited infill drilling of vertical Fruitland coalbed methane wells
in areas near existing infrastructure. The BLM estimates that 14 wells could be developed under
Alternative C: 4 horizontal Mancos wells with 2.5-mile lateral lengths and 10 vertical Fruitland coal wells.
This assumes 800 acres of dedicated acreage per horizontal Mancos well and infill vertical Fruitland coal
wells at 320-acre spacing. As shown in Table 3-4 below, the overlap between Alternative C and oil and
gas development targets identified in the 2025 RFDS is the same as Alternative B. As described above
under Alternative B, the 2025 RFDS predicts very little development within the withdrawal boundary,
even absent a withdrawal. As in Alternative B, the oil subplay does not extend very far within the
withdrawal area and what is present is largely already leased. For vertical development within the decision
area, the Fruitland coalbed methane reservoir is the main target as evidenced by the vertical wells
completed in the area since 2000 (Engler 2025).
The partial withdrawal revocation would not affect existing leases, including the approximately 69,920
acres of existing Federal oil and gas leases within the proposed partial withdrawal revocation area (i.e.
revocation of the withdrawal on the area beyond an approximately 5-mile buffer around CCNHP) (Table
3-4). On the lands remaining withdrawn under Alternative C, production from existing wells could
continue, and additional wells could be drilled on existing leases. Existing leases not held by production
could be developed, relinquished by the lessee, or expire if not developed within the lease term; however,
should the Secretary implement Alternative C, the lands beyond the approximately 5-mile buffer around
CCNHP could subsequently be re-leased if existing leases are relinquished or expire.
Table 3-4. Development Potential and Lease Status of Lands within Alternative C
Development Potential Rating and
Acres
Lease Status
Mancos/Gallup Southern Rim horizontal oil subplay
20,060
Unleased
3,280
Leased—held by production
16,780
Leased—not held by production
0
Negligible Development Potential
198,180
Unleased
146,150
Leased—held by production
52,030
Leased—not held by production
0
Statutorily Excluded
2,730
Unleased
1,620
†Leased—held by production
1,110
Leased—not held by production
0
Sources: BLM GIS, BLM 2018.
† This includes leases within wilderness areas that pre-date the designation.
*Acres are calculated using GIS and rounded to the nearest 10 acres. As a result, minor rounding
errors may occur, and totals may not equal official acreages.
Navajo Allottee Mineral Owners
Because the estimated 14 wells on the new leases possible under Alternative C would occur in the area
beyond the approximately 5-mile buffer around CCNHP, the land around CCNHP remaining withdrawn
would not be expected to affect the lease viability of Navajo allottee mineral owners. Therefore, the
predicted impact to IIA lease viability under Alternative C (Partial Withdrawal Revocation) would be the
same as predicted under Alternative B.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
Coal
Over the short term, the proposed revocation of PLO No. 7923, in part, to open the lands that lie
beyond 5 miles from the CCNHP boundary would open these Federal lands to exploration and
characterization of federal coal resources. However, the difference in acreage between a full revocation
and a partial revocation of the withdrawal does not change the lack of infrastructure for coal
development in the revocation area, and the economic forces in the Farmington District for coal (Map
2-7, Appendix D).
3.4.3
Resource Issue 3: Socioeconomics
How would future potential development of the mineral resources should the Secretary
revoke PLO No. 7923, in whole or part affect local economy and government revenue?
A detailed Socioeconomic Analysis is provided in Appendix F and the Socioeconomics Technical Report
(BLM, 2025e). It provides details for definitions of socioeconomic indicators, data sources, rationale for
selecting data series, and data tables of the latest nation-wide datasets used to identify the current,
changing, and comparative socioeconomic conditions of the study area. It also provides details for a MultiRegional Input-Output Model developed to evaluate the specific and total economic impacts of the
Proposed Action on the study area, a step-wide and reproducible methodology to carry out the Model,
definitions of economic indicators, rationale for selecting data series, data sources, and calculations.
3.4.3.1 Affected Environment
The study area of this analysis is considered as the 10-mile withdrawal area which reaches four counties
in the State of New Mexico, including San Juan County, Rio Arriba County, Sandoval County, and McKinley
County.
The socioeconomic conditions of the study area are identified based on the following key socioeconomic
indicators for the four counties, the State of New Mexico, and the United States (Table 1, Table 2,
Table 3, and Table 4, Appendix F).
•
Total population (numbers of people) (USCB, 2024)
•
Median household incomes ($) (USCB, 2024)
•
Unemployment rates (%) (USCB, 2024)
•
Population with high school or higher education (%) (USCB, 2024)
•
Age structure: population under age 5 (%), population aged 5 to 64 (%), and population over age
64 (%) (USCB, 2024)
•
Employment by 12 economic sectors (%) (USCB, 2024)
•
Gross Domestic Product (GDP) by 12 economic sectors ($) (BEA, 2024)
• Payments in Lieu of Taxes (PILT) ($) (DOI, 2024)
For meaningful elaboration and consistent comparison, all the dollar values in this analysis are presented
in the 2023 dollars, adjusted respectively with Consumer Price Index (CPI) (BLS, 2025) for median
household incomes and PILT, and with GDP chained dollars for GDP by economic sectors.
The current, changing, and comparative socioeconomic conditions reveal the following characteristics of
the study area.
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3. Affected Environment and Environmental Effects
•
•
•
•
•
•
From 2016 to 2023, the United States, New Mexico, Rio Arriba County, and Sandoval County
have had an increase in population (4.3%, 1.5%, 0.6%, and 9.7%, respectively) whereas San Juan
County and McKinley County have had a decrease in population (-1.1% and -4.3%, respectively).
From 2016 to 2023, the United States, New Mexico, and Sandoval County have had an increase
in real GDP (18.4%, 18.6%, and 26.3% respectively) whereas San Juan County, Rio Arriba County,
and McKinley County have had a decrease in real GDP (-8.9%, -4.9%, and -3.4% respectively).
In 2023, except in Sandoval County ($84,053), the other three counties ($53,020 in San Juan
County, $53,901 in Rio Arriba County, and $44,496 in McKinley) had a lower median household
income level compared with the United States ($78,538) and New Mexico ($62,125).
In 2023, both McKinley County (9.4%) and San Juan County (7.8%) had higher unemployment
rates compared with the United States (5.2%) and New Mexico (6.0%).
In 2023, for United States, New Mexico, and all four counties, the educational services, health
care and social assistance sector (all greater than 23.4%) ranked as the highest sector of
employment, and the wholesale trade and retail trade sector (all greater than 10.4%) ranked the
second highest, among the 12 economic sectors.
In 2023, for United States and Sandoval County, the finance, insurance, real estate, rental and
leasing sector (21.0% and 24.0%, respectively) ranked as the highest sector of GDP among the 12
economic sectors; whereas it was instead the public administration and government sector in
New Mexico, Rio Arriba County, and McKinley County (22.2%, 29.8%, and 41.3%, respectively),
and the natural resources (forestry, fishing and hunting), agriculture and mining sector in San Juan
County (23.2%) which ranked highest.
3.4.3.2 Environmental Consequences
An economic impact study examines the total economic impact of a final‐demand change on a regional or
local economy (BEA 2013). The accuracy of an economic impact study’s results relies on the choice of
the final-demand change, final-demand industry, and final-demand region (BEA 2013). For this analysis, the
following considerations are made:
•
Final-demand change consists of the reasonably foreseeable change in sales of two economic
commodities (crude oil and natural gas) under the Proposed Action (Alternative B) and under the
Partial Revocation Alternative (Alternative C) compared with the No Action Alternative
(Alternative A).
•
Final-demand industry is considered as the oil and gas drilling and extraction industry.
•
Final-demand region is considered San Juan County, Rio Arriba County, Sandoval County, and
McKinley County.
A Multi-Regional Input-Output Model is developed utilizing the IMPLAN platform. San Juan County is
considered as the primary impact region and the other three counties as the broader impact regions with
the rationale that the oil and gas wells for potential development on leases that could only be issued by
the BLM following Secretarial revocation of PLO No. 7923, in whole or part are located in San Juan County
as identified by this EA. IMPLAN is an economic impact model that regionalizes the data from the U.S.
Input-Output Accounts published by the U.S. Bureau of Economics (BEA 2009). The IMPLAN modeling
system includes a Social Accounting Matrices (SAM) system. A SAM is a matrix presentation of certain
aspects of the national accounts and of other parts of the economy—such as employment by type of
worker or income distributions—using the structural linkages provided by the Input-Output Accounts
(BEA 2009).
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3. Affected Environment and Environmental Effects
The scale of each industry in the economy can be represented by its employment and total output. The
structure of each industry in the Input-Output Accounts can be represented by eight indicators (BEA
2009; BEA 2013) in three equations as follows.
•
•
•
Employee compensation + Proprietor income = Labor income
Employee compensation + Proprietor income + Other property income + Tax on production and
imports net of subsidies = Value added
Value added + Intermediate input = Total output
The economic impact of industrial activities on a regional or local economy can be represented by four
types of effects corresponding to each of the above eight indicators connected by the equation as follows.
•
Direct effect + Indirect effect + Induced effect = Total economic effect
To evaluate the economic impacts of the revocation of PLO No. 7923, in whole or part, the following
steps are carried out for the economic modeling process:
(1) The direct effect of combined intermediate input and employee compensation (oil and natural gas
well drilling and completion costs for new leases) and direct effect of output (oil and natural gas
production sale values for new leases) reasonably foreseeable under the proposed revocation are
estimated;
(2) The baseline input-output dataset (2022 year data 2023 dollars, 546 industries) for the three main
relevant economic industries (20 - Oil and gas extraction, 35 - Drilling oil and gas wells, 36 Support activities for oil and gas operations, assuming PLO No. 7923 remains in place) are
integrated as an oil and gas development industry via the IMPLAN platform, and dataset
customization under this new industry structure for the four counties are carried out;
(3) The baseline ratio of intermediate input versus employee compensation of the integrated oil and
gas development industry in San Juan County is utilized to estimate the direct effect of
intermediate input and direct effect of employee compensation, respectively, resulting from the
BLM being able to issue new leases following the proposed revocation; and
(4) The estimates for direct effect of intermediate input, direct effect of employee compensation, and
direct effect of output resulting from the BLM being able to issue new leases following that
proposed revocation are utilized to estimate the four types of economic effects (direct, indirect,
induced, and total effects) in regard to employment, labor income, value added, and total output
on the four countries resulting from new leasing that could follow the proposed revocation.
3.4.3.2.1 No Action Alternative (Alternative A)
The economic baseline scale and structure of the current integrated oil and gas development industry in
San Juan County is presented in Table 8 in Appendix F. It includes an employment of 3,915 workers,
value added of $2,182,721,884 (that is 61.1% of total output), and intermediate input of $1,391,422,642
(that is 38.4% of total output), which sums up to total output of $3,574,144,525. The value added is
composed of employee compensation of $388,418,594 (that is 10.9% of total output), proprietor income
of $10,531,501 (that is 0.3% of total output), other property income of $1,373,893,472 (that is 38.4% of
total output), and tax on production and imports net of subsidies of $409,878,316 (that is 11.5% of total
output). Employee compensation and proprietor income sum up to labor income of $398,950,096 (that
is 11.2% of total output).
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
3.4.3.2.2 Proposed Action (Alternative B)
This EA identifies 4 horizontal wells and 10 vertical wells for potential development associated with new
leases that the BLM could issue following Secretarial revocation of PLO No. 7923 in full in the next 20
years, which leads to 0.2 horizontal wells and 0.5 vertical wells for development on average annually.
Drilling and completion costs per horizontal well and per vertical well are estimated as $9,030,000 and
$3,225,000 in 2023 dollars, respectively, based on the estimates ($7,000,000 and $2,500,000 in 2015
dollars) for the Permian Basin (EIA 2016) which shares a similar geographical location and geological desert
features as the Mancos/Gallup Southern Rim subplay in the withdrawal area, adjusted by CPI (BLS 2025).
Consequently, the average annual cost for all wells amounts to $3,418,500 (2023 dollars) (Table 5 in
Appendix F).
This EA estimates the total oil production and the total natural gas production per horizontal well as
274,209 barrels (bbl) and 570,047 thousand cubic feet (mcf), respectively, and the total natural gas
production per vertical well as 451,812 mcf. Given the estimates of 0.2 horizontal wells and 0.5 vertical
wells for development on average annually in Step (1), this results in the estimates of average annual oil
production and natural gas production for all wells as 54,842 bbl and 339,915 mcf, respectively. The latest
Annual Energy Outlook (EIA 2025) projects the average crude oil prices and average natural gas prices
from 2026 through 2045 for the Lower 48 States as 85.46 $/bbl and 3.34 $/mcf, respectively.
Consequently, the average annual oil and natural gas sales value amounts to $5,822,113 (2023 dollars)
(Table 6 in Appendix F).
Therefore, the overall data input for the Multi-Regional Input-Output Model are direct effect of
intermediate input of $2,666,430 annually, direct effect of employee compensation of $752,070 annually,
and direct effect of total output of $5,822,113 annually (Table 9 in Appendix F). Development on new
leases that could be issued by the BLM following Secretarial revocation of the entire 10-mile withdrawal
is likely to generate the following annual total economic impacts and annual specific economic impacts
benefiting the four counties in New Mexico:
•
For San Juan County, Rio Arriba County, Sandoval County, and McKinley County together, a total
effect of increased employment of 14.14 workers, increased labor income of $1,133,206, increased
value added of $3,963,152, and increased total output of $7,423,893 (Table 10 in Appendix F);
and
•
For San Juan County, a direct effect of increased employment of 7.05 workers, an indirect effect
of increased employment of 3.44 workers, and an induced effect of increased employment of 3.52
workers; a direct effect of increased labor income (that is, the sum of employee compensation
and proprietor income) of $766,178, an indirect effect of increased labor income of $204,033, and
an induced effect of increased labor income of $156,549; a direct effect of increased value added
of $3,155,683, an indirect effect of increased value added of $483,897, and an induced effect of
increased value added of $313,376; and, a direct effect of increased total output of $5,822,113, an
indirect effect of increased total output of $1,024,035, and an induced effect of increased total
output of $553,962 (Table 11 in Appendix F).
In summary, the majority of these positive economic impacts that could follow development on new leases
is expected for San Juan County and contributes to improving the socioeconomic condition of San Juan
County which has had a decrease in population and a decrease in real GDP from 2016 to 2023, and a
lower median household income level and a higher unemployment rate in 2023 compared with the United
States and New Mexico. Moreover, when applying the current minimum Federal mineral royalty rate of
12.5%, the oil and natural gas sales value annually contributes $727,764 of minimum Federal mineral
royalties for Federal and state government revenue (BLM 2025e: Table 7).
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
3.4.3.2.3 Partial Revocation Alternative (Alternative C)
This EA identifies 4 horizontal wells and 10 vertical wells for potential development on new leases that
the BLM could issue for land that lies beyond 5 miles from the CCNHP boundary following Secretarial
revocation of PLO No. 7923, in part, in the next 20 years, which leads to the same level of socioeconomic
impacts as that of the Proposed Action (Alternative B).
3.4.4
Resource Issue 4: Quality of Life
How would the proposed revocation of PLO No. 7923 in whole or part affect the quality
of life of the American people, including non-economic factors such as cultural resources
and Native American religious concerns?
3.4.4.1 Affected Environment
Quality of life or human well-being such as health, safety, and happiness is supported by economic
prosperity, financial security, benefits from available and accessible natural resources, enjoyment from
multiple and continuous ecosystem services, and social and cultural connections. It is closely related to
how human society adapts to socioeconomic change and ecosystem change.
Ecosystem change reflects the changes of ecosystem functions which generate ecosystem services (MEA
2005). Ecosystem services are the benefits from ecosystems to human societies and they can be
categorized as four general types (MEA 2005) including provisioning ecosystem services (such as food,
fresh water, wood and fiber, and fuel), regulating ecosystem services (such as flood control, disease
control, and water purification), cultural ecosystem services (such as aesthetic, spiritual, educational,
recreational experience), and supporting ecosystem services (such as nutrient cycling, soil formation, and
primary production). In the long term, the dynamics of ecosystem functions and the abundance and
continuity of ecosystem services can be affected both positively and negatively by management actions on
the landscape and in regard to natural resources.
From a broad perspective, ecosystem services are the foundation for the availability and accessibility of
natural resources, and natural resources are the foundation for economic production system. Therefore,
ecosystem services, natural resources, economic prosperity, and financial security all contribute to the
quality of life of human society on various landscapes of the ecosystem.
The study area of this analysis is considered as four counties in the State of New Mexico, including San
Juan County, Rio Arriba County, Sandoval County, and McKinley County. The socioeconomic changes
from 2016 to 2023 in the study area reveal the following characteristics (Table 1, Table 2, and Table 3 in
Appendix F).
•
•
•
•
The United States, New Mexico, Rio Arriba County, and Sandoval County have had an increase
in population (4.3%, 1.5%, 0.6%, and 9.7%, respectively) whereas San Juan County and McKinley
County have had a decrease in population (-1.1% and -4.3%, respectively).
The United States, New Mexico, and Sandoval County have had an increase in real GDP (18.4%,
18.6%, and 26.3% respectively) whereas San Juan County, Rio Arriba County, and McKinley
County have had a decrease in real GDP (-8.9%, -4.9%, and -3.4% respectively).
All four counties (3.1%, 4.7%, 4.6%, and 2.6% for San Juan County, Rio Arriba County, Sandoval
County, and McKinley County, respectively) have had a larger increase of percentage of population
over age 64 compared with that of the United States (2.3%).
Except San Juan County (-2.1%), the other three counties (-4.4%, -3.1%, and -6.3% for Rio Arriba
County, Sandoval County, and McKinley County, respectively) have had a larger decrease of
unemployment rate compared with that of the United States (-2.2%) and New Mexico (-2.5%).
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
The most evident ecosystem goods and services within the withdrawal area include cultural and spiritual
uses, rangelands, recreation, and water supply which have been analyzed in AIB-1, AIB-2, Section 1.5.3,
AIB-13, AIB-14, and Section 3.4.7, respectively. These resources and their associated human benefits
represent key areas which may interact with the quality of life of the American people.
3.4.4.1.1 Cultural Resources
The existing withdrawal established additional tools for the BLM to effectively manage the landscape
surrounding CCNHP. Between approximately AD 850 and 1150, the Chacoan culture flourished, with
Chaco Canyon serving as the social and religious center for much of the region. During the AD 900s and
1000s, communities in and around the San Juan Basin constructed structures in the style of those in Chaco
Canyon. These sites are referred to as Chacoan Outliers. Much of the Chaco Canyon area is protected
as the Chaco Culture National Historical Park (CCNHP), established in 1980. The park and six other
nearby sites were designated as a UNESCO World Heritage Site in 1987. Some of the most sensitive and
architecturally significant features are contained in the CCNHP. Those lands and resources benefit from
the highest levels of legal protection due to the protection established by Congress.
There are various cultural resources in the landscape surrounding the CCNHP, many of which receive
protection from other BLM designations (see the Cultural Resources portion of Section 3.4.4.2.2
below). This landscape/setting itself has not been documented as a historic property. The BLM would
consider effects to the landscape when determining whether to approve future leasing or development,
should PLO No. 7923 be revoked in full or part.
3.4.4.1.2 Native American Religious Concerns
The San Juan Basin contains important places of cultural and religious significance for regional Tribes. It is
out of concern for these important places that some, though not all, regional Tribes support limiting
development within the withdrawal area. During past consultations regarding public land management,
some tribal members and officials have expressed a general frustration with the inability of existing laws,
regulations, and policy to fully meet the needs of tribal communities. Policy makers in the previous
administration established broad protective efforts such as PLO No. 7923; however, even without a
withdrawal the BLM considers potential impacts on known archaeological and historic sites and areas of
traditional cultural and religious significance when proposing to issue fluid mineral leases or approve
applications for permit to drill stages for oil and gas development or plan-level development of mining
operations. Even without a withdrawal, the BLM uses existing management prescriptions, including no
surface occupancy and controlled surface use designations, to help ensure the avoidance of adverse effects
on historic properties and sites of traditional cultural or religious significance. Existing laws, regulations,
and policies are applicable for avoiding, reducing, or mitigating any potential adverse effect even if the
Secretary elects to revoke PLO No. 7923, in whole or part, to allow for BLM discretion over energy
development, as discussed below.
In general, the Pueblo tribes view the Chacoan landscape as an integrated cultural system spanning
northwest New Mexico and beyond, not a collection of isolated sites. They see its network of roads and
interconnected communities as reflective of a society that thrived through regional connections rather
than isolation. Pueblo tribes have expressed concern that revoking the withdrawal could further
compromise what remains of the system. Maintaining this landscape is considered important by the Pueblo
tribes for its cultural and historical integrity.
Additionally, the development of the Programmatic Agreement described in Section 3.4.2.1.1 is
intended to streamline consultation while enhancing cultural sensitivity, improving data transparency,
and supporting cooperative stewardship with Tribes.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
3.4.4.2 Environmental Consequences
3.4.4.2.1 No Action Alternative (Alternative A)
The stated purpose of PLO No. 7923 is to protect 338,690 acres of public lands and the greater connected
landscape having a rich Puebloan, Tribal Nation, and cultural legacy from impacts associated with potential
oil and gas development and locatable mineral exploration and mining. The cultural legacy whose
protection PLO No. 7923 is intended to protect is focused on the people affiliated with Chaco Canyon
between approximately AD 850 and 1150. During that period, monumental architecture connected
communities to each other and to a landscape of sacred places. Today, this landscape is still considered
sacred by regional Tribes and holds places of significant importance to these people.
PLO No. 7923 stated that it protected positive cultural values that support the quality of life in this region;
however, the BLM anticipates that the following relevant socioeconomic trends in the study area, which
generally do not positively contribute to the quality of life, are likely to continue without structural change
in economic development, employment opportunity, and infrastructure improvement in the area.
•
•
•
•
Decreased real GDP in San Juan County, Rio Arriba County, and McKinley County compared
with increased real GDP in the United States, New Mexico, and Sandoval County.
Smaller decrease of unemployment rate in San Juan County compared with larger decrease of
unemployment rate in the United States and New Mexico.
Decreased population in San Juan County and McKinley County compared with increased
population in the United States, New Mexico, Rio Arriba County, and Sandoval County.
Larger increase of percentage of population over age 64 in all four counties compared with smaller
increase of percentage of population over age 64 in the United States.
3.4.4.2.2 Proposed Action (Alternative B)
•
•
•
•
•
While the number of wells projected on new federal leases if the Secretary revokes PLO No.
7923 in full under the Proposed Action is modest (i.e., 14) relative to the 37,300 wells on existing
leases, this development would activate a key economic sector in San Juan County, lead to
economic activities in the other three counties, generate the following economic impacts for all
four counties together (Table 10 in Appendix F), increase government revenue, and likely result
in greater economic prosperity, higher financial security, further economic investment and
improved infrastructure, and consequently contribute to the quality of life in the region. An
increased employment of 14.14 workers annually over 20 years
An increased labor income of $1,133,206 annually over 20 years
An increased value added of $3,963,152 annually over 20 years
An increased total output of $7,423,893 annually over 20 years
An increased minimum Federal mineral royalties of $727,764 annually over 20 years
The oil and gas wells which are reasonably foreseeable (Section 3.3) on new leases that could be offered
and subsequently issued by the BLM under Alternative B, would also be forecast to be developed under
Alternative C because those 14 wells would be within the outer approximately-5-mile radius surrounding
CCNHP that would be re-opened under Alternative C. Relative to the No Action alternative, either the
Proposed Action (Alternative B) or the Partial Revocation Alternative (Alternative C) is expected to have
the following effects on the quality of life of the American people, including:
•
•
An incremental increase in access to products extracted or produced from federal lands, such as
refined oil and gas products created from raw material within the withdrawal revocation area,
owing to the RFD of 14 oil and natural gas wells which would otherwise have been precluded.
Little to no effect on way of life and culture or education and knowledge (including research
opportunities) because the future potential for leasing of oil and gas resources and development
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
•
•
•
of oil and gas wells on these leases would largely be confined to already-developed areas on the
outer edges of the withdrawal area and the future potential development of minerals subject to
location and entry under the U.S. mining laws (including uranium) is proportionately small (2,665
acres claimed out of 965,670 acres within the revocation area) and interest in exploring for these
resources is not expected to be particularly intense, as demonstrated by the existence of a
relatively dispersed total of only 129 active mining claims.
Little to no effect on visitor experience. This aspect would be largely unaffected, or only
incrementally affected, by future potential development because dispersed recreation is already
affected by existing development on existing oil and gas leases, while concentrated recreation
activities (i.e., CCNHP) would remain protected by current designations prohibiting development
on National Park lands. Additionally, CCNHP is over 7 miles from the reasonably foreseeable oil
and gas development to the northeast; therefore, even changes to visual resources from such
development, including from the additional 14 anticipated wells on the estimated new leases that
could be issued under the Proposed Action would not likely be experienced by Park visitors.
No effect on public services including provisioning of emergency services, public utilities,
transportation, education, social services, etc.
May affect passive use of ecosystems, which may include evaluations of stewardship, existence
values, and bequest values, especially because of the importance of the Chacoan landscape to the
people who value this cultural resource in ways that are intangible and/or difficult to quantify.
These aspects are further addressed below.
While the number of wells projected on new federal leases if the withdrawal is fully revoked is modest
(i.e., 14 wells) relative to the 37,300 wells on existing leases, even small additions can influence localized
conditions, particularly in this region with cultural sensitivity. The Greater Chaco Landscape is of
profound cultural and spiritual importance to numerous Tribes and Pueblos in the region. Additional
development could result in direct and indirect impacts to known and unknown cultural sites, disrupt
the natural sights and sounds of the area, and interfere with traditional ceremonial practices. The BLM
connects with relevant communities through ongoing community outreach to develop design features or
other mitigation measures for authorized projects to reduce and mitigate such potential impacts.
Additionally, the development of the Programmatic Agreement described in Section 3.4.2.1.1 is
intended to streamline consultation while enhancing cultural sensitivity, improving data transparency,
and supporting cooperative stewardship with Tribes.
Cultural Resources
Surface disturbance associated with reasonably foreseeable actions would have the potential to impact
cultural resources. Such impacts may include, but are not limited to, loss of or damage to cultural
resources or contextual information. The magnitude of impacts associated with reasonably foreseeable
actions would generally depend upon the location of the reasonably foreseeable development relative to
the location of cultural resources and the degree to which the setting has already been affected. Effects
from reasonably foreseeable development on federal lands or with a federal nexus would require separate
National Historic Preservation Act of 1966 (NHPA) processes to avoid, minimize, and/or mitigate effects
on cultural resources.
The FFO has conducted a records review of the New Mexico Cultural Resource Information System
(NMCRIS), and internal BLM data sources to identify known historic properties, traditional cultural
properties (TCPs), sacred sites, and traditional use areas within the Area of Potential Effects (existing
withdrawal area).
Within the FFO, one hundred twenty-five Great House and Great House Outlier structures are known
to exist. Many of these are within the CCNHP boundaries while others are on lands managed by the
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
Bureau of Land Management (BLM), the Navajo Nation (Tribal Trust and Indian Allotted), the Ute
Mountain Ute Tribe, the National Park Service, the State of New Mexico, and private individuals. On BLM
managed surface there are twenty-one outliers with nineteen having additional protections by being within
an Area of Critical Environmental Concern (ACEC), a Chaco Culture Archaeological Protection Site
(CCAPS), or a UNESCO World Heritage Site (WHS) (Table 3-5). Of these twenty-one, nine are present
within the Proposed Action area (Alternative B) with five located within the partial revocation area
(Alternative C).
Table 3-5. Chacoan Outliers on BLM Managed Lands within Farmington Field Office
Outlier
Name
Alt B Potential
Impacts
Alt C
Potential
Impacts
ACEC Name
CCAPS Name
WHS Name
Oil and Gas
Development
Potential
Andrews
Bee
Burrow
Bis'saani
East
Bis'saani
West
Casa Abajo
No
No
Andrews Ranch
Andrews Ranch
--
Negligible
No
No
Bee Burrow
Bee Burrow
--
Negligible
Yes
No
Bis sa’ani
Bisa’ani
--
Medium
Yes
No
Bis sa’ani
Bisa’ani
--
Medium
Yes
Yes
Indian Creek
Indian Creek
--
Negligible
Casa Cielo
Yes
Yes
Indian Creek
--
Negligible
Casamero
No
No
Casamero
Casamero
Negligible
No
No
Indian Creek
Casamero
Community
Church Rock
Outlier
--
--
Negligible
No
No
Halfway House
Halfway House
Halfway
House
High
Yes
No
Upper Kin
Klizhin
Upper Kin
Klizhin
--
Negligible
No
No
Kin Nizhoni
Kin Nizhoni
Kin
Nizhoni
Negligible
No
No
Kin Nizhoni
Kin Nizhoni
Kin
Nizhoni
Negligible
Yes
No
--
--
--
Negligible
No
No
No
--
--
--
Medium
No
Morris 41
Morris 41
--
Medium
Yes
Pierre's Site
Pierre's Site
Yes
Pierre's Site
Pierre's Site
Yes
Pierre's Site
Pierre's Site
No
Chacra Mesa
Complex
--
--
Negligible
No
Toh-la-kai
Toh-La-Kai
--
Negligible
No
Twin Angels
Twin Angels
Twin
Angels
Medium
Church
Rock
Halfway
House
Kin Klizhin,
Upper
Kin
Nizhoni,
Lower
Kin
Nizhoni,
Upper
LA 72343
La Plata
Morris 41
Pierre's El
Faro
Pierre's
House A
Pierre's
House B/C
Reservoir
Ruin
Toh-La-Kai
Twin
Angels
Yes
Yes
Yes
No
No
No
Pierre's
Site
Pierre's
Site
Pierre's
Site
Medium
Medium
Medium
Bolded text highlights differences between Alternative B and C.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
In addition to the Chacoan Outliers, other components of the Chacoan landscape are also within the FFO.
A prominent feature would be the various “roads” that often emanate from Great Houses. Roads may
extend only a short distance from a structure but also may serve to connect individual structures and
features of the landscape across the San Juan Basin. On BLM managed lands, road segments often fall
within, and receive protections from the ACEC, CCAPS, or WHS associated with the outliers. Three
ACECs specific to Chacoan Roads (Ah-Shi-Sle-pah Road, Crownpoint Steps and Herradura, and North
Road) are wholly or partially within the existing 10-mile mineral withdrawal area though portions of the
North Road ACEC and all the Ah-Shi-Sle-Pah Road ACEC are out of the 5-mile area.
NMCRIS serves as a repository for historic property tabular and geospatial data within the area of the
existing mineral withdrawal. As of November 2025, approximately 7,552 known historic properties from
all cultural and temporal affiliations are present within the 10-mile withdrawal area and 4,710 within the
5-mile withdrawal area. These numbers only represent a fraction of the sites that exist as large portions
of the region have not been formally inventoried.
The FFO used various ethnographic sources, including the 2022 Navajo study on the Chaco region
(Ethnographic Report Concerning the Proposed 10-Mile Buffer Zone Encompassing 12 Navajo Chapters
around Chaco Culture National Historical Park, Martin), to assess impacts on cultural resources and
traditional uses. BLM's dataset lists at least 145 Traditional Cultural Properties (TCPs) in the 10-mile
withdrawal area and 46 in the 5-mile area. These figures are minimum estimates, as past ethnographic
studies were not comprehensive and BLM lacks access to all available data.
As described in Section 3.4.2.5, a revocation or partial revocation of the existing withdrawal would open
BLM lands for exploration under the U.S. mining laws, including the Mining Law of 1872. As defined in 43
CFR 3809, three different types of operations with different levels of analysis are identified.
Plan-level operations are generally over 5-acres in size and are subject to NEPA and NHPA analysis. The
regulations also allow for operations (Casual Use and Notice-level operations) which are not always
inventoried for cultural resources or analyzed under NEPA and NHPA, but which still require operators
to prevent unnecessary or undue degradation (43 CFR 3809.605). This includes compliance with
“…Federal and State laws related to environmental protection and protection of cultural resources” (43
CFR 3809.5). It is further stated under 43 CFR 3809.420(b)(8) that:
(i) Operators shall not knowingly disturb, alter, injure, or destroy any scientifically important
paleontological remains or any historical or archaeological site, structure, building or object on
Federal lands.
(ii) Operators shall immediately bring to the attention of the authorized officer any cultural and/or
paleontological resources that might be altered or destroyed on Federal lands by his/her
operations, and shall leave such discovery intact until told to proceed by the authorized officer.
The authorized officer shall evaluate the discoveries brought to his/her attention, take action to
protect or remove the resource, and allow operations to proceed within 10 working days after
notification to the authorized officer of such discovery.
(iii) The Federal Government shall have the responsibility and bear the cost of investigations and
salvage of cultural and paleontology values discovered after a plan of operations has been
approved, or where a plan is not involved.
There is no notification provided to the BLM that casual use activities are occurring. Casual use generally
includes the collection of geochemical, rock, soil, or mineral specimens using hand tools, hand panning,
and non-motorized sluicing. The use of metal detectors, gold spears, and other battery-operated devices
for sensing the presence of minerals is allowed but the use of mechanized earth-moving equipment and
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
truck-mounted drilling equipment is prohibited. Casual use does not include use of mechanized earthmoving equipment, truck-mounted drilling equipment, motorized vehicles in areas designated as closed to
“off-road vehicles” as defined in 43 CFR 8340.0-5, chemicals, or explosives. It also does not include
“occupancy” as defined in 43 CFR 3715.0-5 or operations in areas where effects of such activities would
result in more than negligible disturbance.
Under the current regulations, new notice-level operations are limited to 5 acres or less and must not
cause more than casual use in certain special status areas defined in 43 CFR 3809.11(c). New notice-level
operations are limited to exploration activities, which does not include extraction of material for
commercial use or sale (43 CFR 3809.5), and must not exceed other limitations on notice-level activities
(43 CFR 3809.11). Under 43 CFR 3809.312, operators must notify FFO fifteen calendar days prior to
conducting notice-level operations. The BLM assesses the notice of operations for completeness and
whether the activities described in the notice would prevent unnecessary or undue degradation. If the
notice is incomplete (43 CFR 3809.311) or other circumstances described in 43 CFR 3809.313 apply, BLM
will inform the operator in writing of the deficiency and operations must not begin until the circumstance
is resolved. Operators must also provide to BLM a financial guarantee for reclamation before beginning
operations. If the proposed activities would not prevent unnecessary or undue degradation, BLM can
determine that the operator may not conduct operations and will notify the operator. Should the
Secretary elect to revoke PLO No. 7923, in whole or part, in the event that a notice properly served to
BLM proposes to disturb an area within the boundary of the area previously withdrawn by PLO No. 7923,
which has not been sufficiently inventoried for cultural resources, the FFO commits as a Design Feature
(Section 2.4) to conducting the necessary inventory and recordation of cultural resources within the
Notice review period (43 CFR 3809.311) before operations are allowed to begin.
Should the existing withdrawal area be fully or partially revoked, current laws and regulations would
remain in place. Any potential future development (such as oil and gas development) the BLM proposed
to approve would be subject to site-specific analysis under NEPA and pursuant to 54 U.S.C 300101, et
seq., commonly known as the NHPA as amended, and 54 U.S.C 306108, commonly known as section 106
of the NHPA. At that time, if the BLM determines that an undertaking would result in an adverse effect
that cannot be avoided or minimized, the BLM would develop mitigation in consultation with affected
Tribes, the New Mexico State Historic Preservation Officer (NM SHPO), and the Advisory Council on
Historic Preservation (ACHP), as appropriate. Based on the BLM’s experience with past oil and gas
undertakings, including technological innovations such as directional drilling which reduces infrastructure
footprint, the BLM does not expect it likely that future potential oil and gas development (including the
73 No Action and 14 Alternative B wells) would result in Adverse Effects to historic properties.
Directional drilling can reduce the need to install access roads or additional development pads. Additional
changes in industry, such as the establishment or satellite drilling pads, can also reduce potential
development footprints. With the applicability of existing laws and the commitments made by the FFO
regarding inventory and avoidance of historic properties associated with notice-level mining operations
(Section 2.4), the BLM is documenting a determination of No Adverse Effect to Historic Properties from
Secretarial revocation of PLO No. 7923, in whole or part.
Native American Religious Concerns
Surface disturbance associated with reasonably foreseeable oil and gas operations has the potential to
adversely impact TCPs and religious properties should the Secretary revoke PLO No. 7923, in whole or
part. The magnitude of impacts associated with reasonably foreseeable actions would generally depend
upon the location of reasonably foreseeable development relative to areas of concern to Native American
tribes. Development on federal lands or with a federal nexus would undergo Government-to-Government
and NHPA consultation with regional Tribes, as necessary. In addition, the BLM could apply COAs to
protect such properties, which would serve to avoid or minimize impacts. Through tribal consultation,
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
additional mitigation may be developed to avoid or minimize audible and visual impacts on sensitive TCPs.
The processing of development applications is a separate undertaking that would be analyzed through the
Section 106 process at that time, as directed in law, regulation, and policy.
Consultation was conducted in association with the initial withdrawal and is ongoing for the current
proposed action. Though there were differences regarding the extent of the withdrawal boundary
expressed at those meetings, all Tribes expressed concern for the appropriate management of cultural
resources and places containing religious and cultural significance. Tribes have also indicated that potential
impacts to the cultural landscape could include fragmentation and industrialization of setting, disruption of
cultural use, interference with prayer, pilgrimage, visitation, and traditional practices, and degradation of
the integrity of relationships between places.
Based on the FFO’s records review, there are at least 145 TCPs wholly or partially within the proposed
action area (Alternative B) and 99 within the partial revocation area (Alternative C), where 46 would
remain within the withdrawn lands. These should be considered minimum numbers as past ethnographic
efforts have not been exhaustive, and BLM does not have access to all known ethnographic data. The
known TCPs represent a variety of locations including resource procurement areas, offering locations,
springs, places of significant events, places of clan origins, and places noted in ceremonial prayers and
songs. Such places are often connected with each other across the landscape and are integrated within
daily life and practices of Tribal communities. The BLM will work with tribal partners at the development
stage to provide additional opportunities for consultation. Alternative A would retain all 145 known TCPs
at least partially within the existing withdrawal boundary. Alternative B would remove the current
withdrawal boundary and increase the potential for adverse effects in the areas with development potential
though existing laws, regulations, and policy would remain in place with the ability to avoid, reduce, or
mitigate such effects.
3.4.4.2.3 Partial Revocation (Alternative C)
As noted above, the oil and gas wells which are reasonably foreseeable (Section 3.3) on new leases that
could be offered and subsequently issued by the BLM under Alternative B would also be forecast to be
developed under Alternative C as those 14 wells would be in the approximately-5-mile radius surrounding
CCNHP that would re-open under Alternative C. Therefore, Secretarial selection of Alternative C would
largely result in the same impacts to quality of life as Alternative B, with the following considerations:
•
•
•
The same incremental increase (as with Alternative B) in access to products extracted or
produced from federal lands, such as refined oil and gas products created from raw material within
the withdrawal revocation area, owing to the RFD of 14 oil and natural gas wells on new leases,
which would otherwise have been precluded.
To the extent possible, an even smaller effect than Alternative B; in any case, little to no effect on
way of life and culture or education and knowledge (including research opportunities) because
the future potential development of oil and gas wells on new leases would largely be confined to
already-developed areas on the outer edges of the withdrawal area and the future potential
development of minerals subject to location and entry under the U.S. mining laws (including
uranium) is proportionately small (less than 2,665 acres claimed out of 965,670 acres within the
revocation area) and interest in exploring for these resources is not expected to be particularly
intense, as demonstrated by the existence of a relatively dispersed total of only 20 active mining
claims within Alternative C.
Little to no effect on visitor experience. This aspect would be largely unaffected, or only
incrementally affected, by future potential development because dispersed recreation is already
affected by existing development on existing oil and gas leases, while concentrated recreation
activities (i.e., at CCNHP) would remain protected by current designations prohibiting
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
34
3. Affected Environment and Environmental Effects
•
•
•
•
3.4.5
development on National Park lands. Additionally, CCNHP is over 7 miles from the reasonably
foreseeable oil and gas development to the northeast; therefore, changes to visual resources from
such development would not likely be experienced by Park visitors.
No effect on public services including provisioning of emergency services, public utilities,
transportation, education, social services, etc.
May affect passive use of ecosystems, which may include evaluations of stewardship, existence
values, and bequest values, especially because of the importance of the Chacoan landscape to the
people who value this cultural resource, in ways that are intangible and/or difficult to quantify.
Alternative C would be expected to have a smaller effect than Alternative B due to the smaller
area affected (220,970 acres vs 338,690 acres).
Alternative C would retain 4 of the 9 Chacoan Outliers on BLM lands at least partially within the
withdrawal boundary. Similar to Alternative B, existing laws, regulations, and policy would remain
in place to protect the 5 Chacoan Outliers known to exist at least partially in the revocation area.
Alternative C would retain 46 of the known 145 TCPs at least partially within the withdrawal
boundary. Similar to Alternative B, existing laws, regulations, and policy would remain in place to
protect the 99 TCPs known to exist at least partially within the revocation area.
Resource Issue 5: Air Quality
How would future potential development within the decision area if the Secretary
revokes PLO No. 7923 in whole or part affect air quality (particularly National Ambient
Air Quality Standards and volatile organic compounds) in the analysis area?
3.4.5.1 Affected Environment
Air quality within any geographic region is generally influenced by the quantity of pollutants released within
and upwind of an area and can be highly dependent upon their chemical and physical properties. The area’s
terrain and weather (e.g., wind speed and direction, temperature, air pressure, rainfall, cloud cover) also
influence how pollutants accumulate, form, or disperse in the local and regional environments. An area’s
air quality designation (i.e., compliance with applicable health-based standards) is determined by
monitoring ground level concentrations of regulated pollutants by agencies with authority for determining
compliance with the applicable standards.
The spatial scope for analyzing the effects on air quality is limited to the areas adjacent to where PLO No.
7923 would be revoked. Temporally, regardless of alternative selected –i.e., Alternative A, B, or C –the
BLM expects the potential future development rate to be low, i.e., less than one oil and gas well per year,
with only limited mining. This low development rate would also limit the spatial constraint, as too few
wells are likely to be developed simultaneously to contribute to broader regional impacts.
The Clean Air Act (CAA), 42 U.S.C. §§ 7401-7671(q), requires the EPA to set National Ambient Air
Quality Standards (NAAQS) for pollutants considered harmful to public health and the environment.
Primary standards provide public health protection, and secondary standards provide for public welfare,
including protection against degraded visibility and damage to animals, crops, vegetation, and buildings
(EPA 2024a). The primary NAAQS are required to be set at a level to protect public health, including the
health of at-risk populations, with an adequate margin of safety in order to prevent known or anticipated
health-related effects from polluted air. The BLM does not issue air quality/emissions permits. Such permits
are only required for stationary emissions sources, such as compressors, tanks, or dehydrators, which
operators obtain separately through either the EPA or the New Mexico Environmental Department,
depending on which entity has permitting jurisdiction. Mobile sources, such as drilling rigs and other
vehicle-mounted equipment, are not subject to this stationary source permitting framework. While the
BLM does not issue air quality/emissions permits, it can authorize activities that can affect air quality.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
Historical trends and current conditions for air quality in the analysis area can be found in BLM New
Mexico’s Air Resources Technical Report (BLM 2024d). The Technical Report is hereby incorporated by
reference to describe the Affected Environment. Highlights include the following:
•
•
•
•
Section 2 provides background information on the regulatory entities and authorities, as well as
laws and regulations applicable to types and sources of pollutants commonly associated with land
management activities. This section also provides a description of New Mexico’s air shed
designations (Class I and II).
Sections 3 and 5 provide background information on the regulated air pollutants (criteria and
hazardous), the available monitoring trends and risk data, and standards-based design values for
any applicable state and federal air quality standard. The available data shows that air quality in the
analysis area is currently in compliance with all applicable standards. The latest EPA data (EPA
2025b) also shows that all of San Juan County is in compliance with the National Ambient Air
Quality Standards (NAAQS).
Section 4 provides a summary of the latest available National Emissions Inventory (NEI) data,
which provides a complete county level accounting for all emissions by source type and pollutant
(criteria and hazardous) within the San Jaun Basin (which includes the analysis area). This data
provides additional context for the analysis presented below.
Section 8 provides background information on Air Quality Related Values (AQRVs) and any
associated trends that are monitored at New Mexico’s Class I areas, the closest of which is the
San Pedro Parks Wilderness (approximately 70 km east of the analysis area). The available data
indicates that visibility at San Padro is improving on both the clearest and most impacted days.
Deposition data is not available at San Padro, but regional monitoring trends suggest deposition
in the western U.S. as a whole is declining marginally.
3.4.5.2 Alternative A – No Action
Under the No Action Alternative, the Secretary would not revoke PLO No. 7923 in whole or part to reopen the lands to location and entry under the U.S. mining laws and to mineral leasing. The projected
additional wells under the full revocation alternative would not be drilled, because no new leases could
be offered. Although no new emissions resulting from development of federal oil and gas on potential new
leases would occur under the No Action Alternative, Section 3.2 of this EA states that an additional 73
wells could be developed (infill development) on existing leases present within the current 10-mile Chaco
withdrawal boundary (BLM 2025a). The potential for infill development does not depend upon any
Secretarial decision-making regarding PLO No. 7923. Therefore, current models account for the effects
of the No Action Alternative as part of the baseline of projected impacts (i.e., the Affected Environment).
The emissions projected to occur from drilling of 14 wells on new leases that might be offered and
subsequently issued following Secretarial implementation of the Proposed Action are evaluated below in
comparison to this baseline reflecting the environmental trends in the FFO area (see regional modeling
study discussion and materials that are incorporated by reference).
3.4.5.3 Alternative B – Proposed Action – Full Revocation of Withdrawal
Secretarial revocation of PLO No. 7923, in full, would not, itself, result in any impacts to air quality from
development of leasable minerals; rather, any potential effects on air quality from development of leasable
minerals on a new lease would occur at such time that any subsequently issued lease is developed. The
Proposed Action does not authorize or guarantee the number of leases issued or wells analyzed herein.
If the Secretary does revoke PLO No. 7923 in full, and the BLM does lease the minerals, drilling of wells
on a new lease would not be permitted until the BLM approves an APD. As is true for any mineral lease,
existing or new, any APD received would be subject to site-specific NEPA and other environmental
review. However, development assumptions have been made in this EA to better inform the decision
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
36
3. Affected Environment and Environmental Effects
maker and the public of potential impacts on air resources if the lands withdrawn under PLO No. 7923
are re-opened to mineral leasing and to location and entry under the U.S. mining laws. The focus of this
discussion is on oil, gas and other leasable minerals, as interest in minerals subject to location and entry
under the U.S. mining laws (notably uranium) is less in the withdrawn area.
As stated above, under the Proposed Action, the Secretary would revoke PLO No. 7923, that withdrew
lands within 10 miles of the boundary of CCNHP. The FFO considered multiple factors when estimating
reasonably foreseeable development within the decision area assuming revocation in full of this PLO
(Section 3.3) to provide assumptions that were used to inform the air resources analysis. Specifically,
the BLM’s RFD for the decision area (BLM 2025a) contemplates the development of 10 new Fruitland coal
bed methane (CBM) wells and 4 new Mancos oil wells on new leases over the next 20 years, should the
Secretary revoke PLO No. 7923, in full, and the lands are opened to oil and gas leasing. The CBM wells
would be developed as single wells (1 well per pad) and either be vertical or directionally drilled, while
the oil wells would likely be paired up (2 wells per pad) and horizontally drilled. We note that all this
development is projected to occur within the 5-to-10-mile zone, which means the BLM does not expect
any difference between the action alternatives regarding mineral leasing. To provide for the potential
mineral yields on a per well basis, the BLM relied on its internal oil and gas production tool. The production
tool uses recent development data from the IHS Markit Enerdeq database (commercial source) to estimate
ultimate recovery (EUR) and the associated production decline over the life of a well. The single-well
production estimates for both well types (i.e., horizontal oil wells in the Mancos Southern Rim subplay,
and vertical CBM wells in the Fruitland outcrop) were obtained by intersecting existing wells within the
target formations nearest to the withdrawal boundaries. Although the individual intersects provide a
reliable characterization of the production potentials for the RFD wells (for the purposes of analysis), we
note that this is by no means a guarantee of future production results. The results from the production
tool provide a EUR of approximately 451,812 Mcf of gas and 0 bbls of oil per Fruitland well, and 570,047
Mcf of gas and 274,209 bbls of oil per Mancos well over the life of the wells (assumed 20 years).
The FFO has also identified 129 existing mining claims, some of which may be associated with potential
uranium mining. Most of these claims (109) occur within the outer 5-mile buffer (i.e., that land which both
Alternative B and C would revoke the withdrawal and re-open the land to mineral entry); it is presently
unclear whether these claims would be economically viable to mine. However, wherever the withdrawal
is revoked, surface disturbance may be authorized following the 43 CFR 3800 regulations without the
BLM having to determine the validity of the claim(s).
During any oil and gas well development, there can be emissions of criteria air pollutants (CAPs) and
hazardous air pollutants (HAPs) from earth-moving equipment, vehicle traffic, drilling, and completion
activities. Fugitive dust can increase with additional vehicle traffic on unpaved roads and from wind erosion
in areas of soil disturbance. These emissions are generally short-term in duration during the construction,
drilling, and completion phases, which can last approximately 30 to 60 days. During well production and
operations, there can be continuous longer-term emissions from separators, condensate storage tanks,
flares or combustors, and daily tailpipe and fugitive dust emissions from traffic. Some sources that are
affected by production volumes (e.g., tanks, traffic from site visits) can see reduced emissions over time
with declining production. For the purposes of this analysis, the production phase is assumed to be 20
years of continuous operations.
Emissions estimates for the 14 RFD oil and gas wells that could be developed on new leases that the BLM
could issue following Secretarial revocation of PLO No. 7923 were obtained from the BLM’s Lease Sale
Emissions Tool (hereafter referred to as the “Emissions Tool”). The Emissions Tool was developed using
the EPA Compilation of Air Pollutant Emissions Factors (AP-42), EPA Motor Vehicle Emission Simulator,
EPA Exhaust and Crankcase Emission Factors for Non-road Engine Modeling – Compression-Ignition, and
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
37
3. Affected Environment and Environmental Effects
other sources of factors to build up typical emissions profiles associated with the development of
geographically diverse wells of various mineral types and formations. The Emissions Tool also leverages
the indirect GHG estimation methods used within the 2023 BLM Specialist Report on Annual Greenhouse
Gas Emissions and Climate Trends (BLM 2024a) (Annual GHG Report), which has been incorporated by
reference. Whereas this information provides an estimate of emissions based on typical development
occurring in New Mexico, actual emissions from the development of any given well on a new lease may
differ. Table 3-6 summarizes the maximum annual and total RFD emissions for each well type that were
obtained from the Emissions Tool. The maximum annual emissions assume a single well pad of each type
(CBM – 1 well, and Mancos oil – 2 wells) for a total of three wells being developed simultaneously over a
20-year projection period. In general, the distribution of development was assumed to be uniform over
the projection period. Table 3-6 shows the summarized emissions estimates for each well type, both
individually and for the annual maximums, as provided for by the revocation RFD and the analysis
assumptions.
For reasons discussed in Section 3.4.1.2, the potential for uranium mine emissions has been deemed not
reasonably foreseeable; therefore, the BLM is not providing any emissions estimate for any associated
mining activities.
Table 3-6. Future Potential Fluid Mineral RFD Emissions (Revocation in Full)
Emissions (tons per year)
Future Potential Development
PM10
PM2.5
VOC
NOX
CO
SOX
Fruitland CBM - Single-well Construction
3.066
0.471
0.32
2.487
0.948
0
Fruitland CBM - Single-well Production
1.40
0.23
5.14
1.39
2.33
0.00
Mancos Oil - Single-well Construction
9.45
1.48
1.07
14.5
3.69
0
Mancos Oil - Single-well Production
4.35
0.56
12.19
2.54
5.75
0.00
RFD Max Year - Construction
25.03
3.9
2.78
33.97
9.28
0
RFD Max Year - Production
31.36
4.53
100.17
24.08
46.31
0.01
2020 NEI Emissions (San Juan County)
8,669
3,078
51,789 32,327 50,149
2,996
Max Proposed Action percent compared to
0.36%
0.15%
0.19% 0.011% 0.09%
0.00%
San Juan County
HAPs
0.016
0.36
0.02
0.02
0.07
3.66
4,285
0.09%
Source: BLM (2024d). NEI data pulled September 13, 2024.
To estimate air resource impacts from the potential future development as projected under the RFD, the
BLM is relying on two regional modeling studies that were conducted to analyze both CAP and HAP
emissions from oil and gas operations in the intermountain west. The studies utilized the Comprehensive
Air Quality Model with Extensions (CAMx) and EPA’s 2016 v2 modeling platform (future year 2032) to
analyze oil and gas emissions growth based on projections derived from the U.S. Energy Information
Administration’s (EIA) Annual Energy Outlook (AEO) report (EIA 2023). Several AEO scenarios were
used to allocate development and production for the various basins within the intermountain west based
on both historical patterns and input from individual fluid mineral specialists and petroleum engineers with
firsthand knowledge of the areas. The full reports for these studies are available as the BLM Western US
Photochemical Air Quality Modeling for 2032 (BLM and Ramboll 2024) and BLM Cumulative Hazardous
Air Pollutants Modeling – Final Report (BLM and Ramboll 2023) and are hereby incorporated by reference
to account for any potential impacts from the oil and gas emissions outlined above as projected from the
14 new wells on new leases under the action alternatives as anticipated by the RFD. Below, Figure 3-1
illustrates the distribution of projected emissions growth (NOx for example) adjacent to the northern
border of the CCNHP, and the rest of the San Juan basin at large, as contemplated by the Regional
Modeling Study. Table 3-7 presents the emissions from the 5 grid cells to the north and north-east of
CCNHP that would represent the emissions projected to occur under the RFD, as well as the rest of the
San Juan County emissions.
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3. Affected Environment and Environmental Effects
Table 3-7. Modeled New Federal Oil and Gas Emissions in San Juan County (tons per year)
PM10
PM2.5
CO
NOX
VOC
SO2
HAPs
County Total
1.38E+02
1.33E+02
9.43E+03
3.45E+03
2.07E+04
3.48E+01
2.27E+02
Grid Cell Ranges
0.000 0.000 3.461E+0 - 1.957E+0 - 3.271E+0 0.000 9.081E+00 9.081E+00 7.51E+02 2.026E+02 1.704E+03 1.088E+00
0.000 2.78E+01
Type
Modeled HAPs are Benzene, Toluene, Ethylbenzene, Xylene, n-Hexane, and Formaldehyde.
Figure 3-1. San Juan Basin Federal Oil and Gas Emissions (NOx)
Table 3-8 below shows the maximum modeled results as contributions from the various model source
groups tracked by the regional model. Note that the maximums can come from any cell, and do not
represent any single cell or more accurately any single location. All of the NAAQS are being maintained.
Table 3-8. Maximum Model Concentrations of NAAQS Pollutants (Standard) in San Juan County
Source Group
Cumulative
New Mexico
Total
Farmington
Rest of New
Mexico
Other Study
States
Rest of 12km
Grid
PM10
PM25
(24hr) (24hr)
PM25
CO
CO
(annual) (1hr) (8hr)
NO2
NO2
SO2
O (8hr)
(1hr) (annual) 3
(1hr)
SO2
(3hr)
2.86E+
1.69E+0 6.08E3.76E+0
8.58E+00 4.07E+00
6.00E+01 2.39E+01 6.27E+01
3.14E+00
01
0
01
0
5.92E6.80E3.58E-01 2.04E-01
—
— 1.23E+01 2.90E+00 1.24E+00
6.22E-02
01
02
5.54E6.80E3.54E-01 2.04E-01
—
— 1.23E+01 2.90E+00 1.13E+00
6.21E-02
01
02
4.77E4.92E1.17E-02 8.52E-04
—
— 2.48E-03 3.13E-04 1.86E-01
6.26E-04
02
04
1.56E2.23E1.48E-01 9.01E-02
—
— 2.69E+00 1.47E+00 5.00E-01
4.16E-02
01
02
5.52E1.95E5.70E-05 2.56E-05
—
— 3.42E-04 1.33E-03 2.86E-03
8.72E-07
05
06
Units: All PM (ug/m3), CO (ppm), NO2 & O3 (ppb), SO2 1-hr (ppb), SO2 3-hr (ppm). Maximum value in any cell.
Proposed Revocation of Public Land Order No. 7923 Environmental Assessment
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3. Affected Environment and Environmental Effects
In general, the emissions from the regional model are more than the RFD estimates save for the particulate
matter emissions. The RFD estimates for particulate matter are likely high due to the general nature of
the Emissions Tool and a lack of project specific parameters available for input. The overwhelming majority
of particulate matter emissions come from common earth disturbing activities, such that providing
adequate controls for fugitive dust should alleviate any potential for significant impacts. For most of the
emissions, the gridded data is more than adequate to account for the simultaneous development of the
two well pads that make up the maximum year emissions. The level of development contemplated by the
RFD over the geographically and temporally dispersed projection period is not likely to significantly impact
air resources in the near-field or on a regional basis (based on BLM’s previous experience with APD
analyses). Further, the model contains grid cells with emissions clo
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