1. United States
2. Utah
3. Letter

Reject the proposed amendment to the Vernal Resource Management Plan that would open federal minerals beneath the Ouray National Wildlife Refuge to oil and gas leasing. This land was set aside for a reason. Drilling beneath a congressionally designated wildlife refuge — even through directional wells from outside the boundary — is exactly the kind of major federal action NEPA's Environmental Impact Statement threshold was designed for. BLM has provided zero documented rationale for why an EA is sufficient here. That's not a procedural quibble; it's a legal problem. The process itself is rigged against meaningful public input. The scoping period closes October 5, 2026 — just 30 days — and the only public meeting date hasn't even been announced yet, with only 15 days' notice promised. BLM has also categorically excluded ACEC evaluation with no explanation, listed only two alternatives when intermediate options clearly exist, and invoked "modern drilling technology" as justification for reopening this closure without citing a single study or technical finding. The agency hasn't disclosed whether USFWS has signed off on a compatibility determination, or whether ESA Section 7 consultation is even underway. The Ouray Refuge belongs to the public and to the wildlife that depends on it. No surface occupancy stipulation does not make industrial extraction beneath a protected refuge acceptable. This amendment should be withdrawn.