# Proposed Revocation of Public Land Order No. 7923: Public Lands Withdrawal > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/tribal%3Apueblo_isleta%3A20538c06733b0f09 ## Record - **Collection:** Tribal code - **Document type:** Tribal code ## Text 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 ii 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 iii 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 1 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 2 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 3 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 4 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 5 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 6 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 7 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 17 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 18 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). Proposed Revocation of Public Land Order No. 7923 Environmental Assessment 19 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 Proposed Revocation of Public Land Order No. 7923 Environmental Assessment 20 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 21 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 22 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. Proposed Revocation of Public Land Order No. 7923 Environmental Assessment 23 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). Proposed Revocation of Public Land Order No. 7923 Environmental Assessment 24 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 25 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 26 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 27 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 28 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 29 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 explori [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/tribal%3Apueblo_isleta%3A20538c06733b0f09. Public record. Not legal advice.