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Mandate for Leadership: The Conservative Promise
24. U.S. Department of the Interior, “Order No. 3354: Supporting and Improving the Federal Onshore Oil and Gas
Leasing Program and Federal Solid Mineral Leasing Program, July 6, 2017, https://www.doi.gov/sites/doi.gov/
files/uploads/so_-_3354_signed.pdf (accessed March 16, 2023).
25. U.S. Department of the Interior, “Order No. 3355: Streamlining National Environmental Policy Reviews and
Implementation of Executive Order 13807, “Establishing Discipline and Accountability in the Environmental
Review and Permitting Process for Infrastructure Projects,” August 31, 2017, https://www.doi.gov/sites/doi.gov/
files/elips/documents/3355_-_streamlining_national_environmental_policy_reviews_and_implementation_
of_executive_order_13807_establishing_discipline_and_accountability_in_the_environmental_review_
and_permitting_process_for.pdf (accessed March 16, 2023).
26. U.S. Department of the Interior, “Order No. 3358: Executive Committee for Expedited Permitting,” October
25, 2017, https://www.doi.gov/sites/doi.gov/files/elips/documents/so_3358_executive_committee_for_
expedited_permitting_0.pdf (accessed March 16, 2023).
27. U.S. Department of the Interior, “Order No. 3360: Rescinding Authorities Inconsistent with Secretary’s Order
3349, “American Energy Independence,” December 22, 2017, https://www.doi.gov/sites/doi.gov/files/elips/
documents/3360_-_rescinding_authorities_inconsistent_with_secretarys_order_3349_american_energy_
independence.pdf (accessed March 16, 2023).
28. U.S. Department of the Interior, “Order No. 3380: Public Notice of the Costs Associated with Developing
Department of the Interior Publications and Similar Documents,” March 10, 2020, https://www.doi.gov/sites/
doi.gov/files/elips/documents/so-3398-508_0.pdf (accessed March 16, 2023).
29. U.S. Department of the Interior, “Order No. 3385: Enforcement Priorities,” September 14, 2020, https://
www.doi.gov/sites/doi.gov/files/elips/documents/signed-so-3385-enforcement-priorities.pdf (accessed
March 16, 2023).
30. U.S. Department of the Interior, “Order 3389: Coordinating and Clarifying National Historic Preservation Act
Section 106 Reviews,” September 14, 2020, https://www.doi.gov/sites/doi.gov/files/elips/documents/signed-
so-3385-enforcement-priorities.pdf (accessed March 16, 2023).
31. Bureau of Land Management, “Updating Oil and Gas Leasing Reform: Land Use Planning and Lease Parcel
Reviews,” IM 2018–034, January 31, 2018, https://www.blm.gov/policy/im-2018-034 (accessed March 16, 2023).
32. Lease Now Act, S. 4228, 117th Cong., 2nd Sess. (2022).
33. ONSHORE Act, S. 218, 116th Cong., 2nd Sess. (2019). https://www.congress.gov/bill/116th-congress/senate-
bill/218/text (accessed March 18, 2023).
34. Federal Register, Vol. 87, No. 130 (July 8, 2022), pp. 40859–40863.
35. The Biden Administration’s 2023–2028 proposed program is fatally flawed. Katie Tubb, “Comment for the
2023–2028 National OCS Oil and Gas Leasing Proposed Program,” BOEM–2022–0031, October 6, 2022, http://
thf_media.s3.amazonaws.com/2022/Regulatory_Comments/BOEM%202023-2028%20lease%20plan%20
comment%20KTubb.pdf (accessed March 16, 2023).
36. See Inflation Reduction Act of 2022, Public Law No. 117–169, §§ 50261–50263.
37. Tax Cuts and Jobs Act of 2017, Public Law No. 115–97, § 20001, and U.S. Department of the Interior, “Order No.
3401: Comprehensive Analysis and Temporary Halt on All Activities in the Arctic National Wildlife Refuge Relating
to the Coastal Plain Oil and Gas Leasing Program,” June 1, 2021, https://www.doi.gov/sites/doi.gov/files/elips/
documents/so-3401-comprehensive-analysis-and-temporary-halt-on-all-activitives-in-the-arctic-national-
wildlife-refuge-relating-to-the-coastal-plain-oil-and-gas-leasing-program.pdf (accessed March 16, 2023).
38. In 2016, Interior Secretary Sally Jewell instituted a moratorium on new coal leases while conducting a
programmatic environmental impact statement under NEPA to address concerns about competition and
inconsistency with the Obama Administration’s climate policy. In 2017, Interior Secretary Ryan Zinke lifted
the moratorium and ended development of a programmatic environmental impact statement. In April 2021,
Interior Secretary Debra Haaland rescinded Zinke’s order and initiated a new review of the coal-leasing
program. See U.S. Department of the Interior, “Order No. 3338: Discretionary Programmatic Environmental
Impact Statement to Modernize the Federal Coal Program,” January 15, 2016, https://www.doi.gov/sites/doi.
gov/files/elips/documents/archived-3338_-discretionary_programmatic_environmental_impact_statement_
to_modernize_the_federal_coal_program.pdf (accessed March 16, 2023); U.S. Department of the Interior,
“Order No. 3348”; U.S. Department of the Interior, “Order No. 3398”; and Federal Register, Vol. 86, No. 159
(August 20, 2021), pp. 46873–46877.
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Department of the Interior
39. Katie Tubb, “No More Standoffs: Protecting Federal Employees and Ending the Culture of Anti-Government
Attacks and Abuse,” testimony before the Subcommittee on National Parks, Forests, and Public Lands,
Committee on Natural Resources, U.S. House of Representatives, pp. 2–4, October 22, 2019, https://congress.
gov/116/meeting/house/110104/witnesses/HHRG-116-II10-Wstate-TubbK-20191022.pdf (accessed March 16, 2023).
40. News release, “Secretary Haaland Announces Steps to Establish Protections for Culturally Significant Chaco
Canyon Landscape,” U.S. Department of the Interior, November 15, 2021, https://www.doi.gov/pressreleases/
secretary-haaland-announces-steps-establish-protections-culturally-significant-chaco (accessed March
16, 2023); News release, “Biden–Harris Administration Proposes Protections for Thompson Divide,” U.S.
Department of the Interior, October 12, 2022, https://www.doi.gov/pressreleases/biden-harris-administration-
proposes-protections-thompson-divide (accessed March 16, 2023); News release, “Biden Administration Takes
Action to Complete Study of Boundary Waters Area Watershed,” U.S. Department of the Interior, October
20, 2021, https://www.doi.gov/pressreleases/biden-administration-takes-action-complete-study-boundary-
waters-area-watershed (accessed March 16, 2023); and News release, “Interior Department Takes Action on
Mineral Leases Improperly Renewed in the Watershed of the Boundary Waters Wilderness,” U.S. Department
of the Interior, January 26, 2022, https://www.doi.gov/pressreleases/interior-department-takes-action-
mineral-leases-improperly-renewed-watershed-boundary (accessed March 16, 2023).
41. Endangered Species Act, Public Law 91–135, § 4(b)(2), and Federal Register, Vol. 85, No. 244 (December 18,
2020), pp. 82376–82389.
42. U.S. Fish and Wildlife Service, “Governing the Take of Migratory Birds Under the Migratory Bird Treaty Act.”
https://www.fws.gov/regulations/mbta (accessed March 16, 2023).
43. Dino Grandoni and Anna Phillips, “Biden Restores Climate Safeguards in Key Environmental Law,
Reversing Trump,” Washington Post, April 19, 2022, https://www.washingtonpost.com/climate-
environment/2022/04/19/biden-nepa-climate-trump/ (accessed March 16, 2023).
44. Donald Trump, “Executive Order on Creating Schedule F in the Accepted Service,” Executive Order 13957,
October 21, 2020, https://trumpwhitehouse.archives.gov/presidential-actions/executive-order-creating-
schedule-f-excepted-service/ (accessed March 16, 2023).
45. Kathleen Masterson, “Nevada Wild Horse Population Skyrockets To New High,” KUNR Public Radio, July 22,
2019, https://www.kunr.org/energy-and-environment/2019-07-22/nevada-wild-horse-population-skyrockets-
to-new-high (accessed March 20, 2023).
46. U.S. Department of the Interior, Bureau of Land Management, “Report to Congress: An Analysis of Achieving
a Sustainable Horse and Burro Program,” Fact sheet, May 8, 2020, https://www.blm.gov/sites/blm.gov/files/
Final%20Fact%20Sheet%20WHB%20Report%20To%20Congress.pdf (accessed March 17, 2023).
47. Pendley, Sagebrush Rebel, pp. 45–47.
48. James D. Linxwiler, The Alaska Native Claims Settlement Act At 35: Delivering on the Promise, Rocky Mountain
Mineral Law Institute, Vol. 53, Chap. 12 (2007), § 12.03(1)(a)(iv), https://www.guessrudd.com/wp-content/
uploads/sites/1600422/2020/05/The-Alaska-Native-Claims-Settlement-Act-at-35.pdf (accessed March 16, 2023).
49. Ibid., § 12.03(1)(a)(vii). See generally Richard S. Jones, Alaska Native Claims Settlement Act of 1971 (Public
Law 92–203): History And Analysis Together With Subsequent Amendments, Report No. 81–127 GOV, June
1, 1981, http://www.alaskool.org/PROJECTS/ANCSA/reports/rsjones1981/ANCSA_History71.htm (accessed
March 16, 2023).
50. 43 U.S. Code, Ch. 33. ANCSA also created 12 Native-owned regional corporations and authorized $962 million
in “seed money.” Linxwiler, The Alaska Native Claims Settlement Act At 35, § 12.03(2)(e).
51. ANCSA provided that the withdrawal of the lands would expire in 1978 if Congress had not designated the
lands as federal enclaves. John K. Norman Cole and Steven W. Silver, Alaska’s D-2 Lands, Rocky Mountain
Mineral Law Institute, Vol. 6B, Ch. 5, September 1978, and Raymond A. Peck, Jr., And Then There Were None:
Evolving Federal Restraints on the Availability of Public Lands for Mineral Development, Rocky Mountain
Mineral Law Institute, Vol. 25, Ch. 3, 1979.
52. Andrus used purported authority under the FLPMA to withdraw 40 million acres, and Carter used purported
authority under the Antiquities Act of to withdraw 56 million acres. James D. Linxwiler, The Alaska Native
Claims Settlement Act: The First Twenty Years, Rocky Mountain Mineral Law Institute, Vol. 38 Ch. 2, 1992 at
2.04(8)(c), https://ancsa.lbblawyers.com/wp-content/uploads/ANCSA-Paper-with-Table-of-Contents-1992.pdf
(accessed March 16, 2023).