The Biden ruling does not add sales or impact the lands that the Bureau of Ocean Energy Management may lease under the current 2024- 2029 program. However, the decision removes a barrier to areas that were otherwise fenced off indefinitely and keeps the door open for future program cycles to contemplate leasing those lands. In other words, while the current five-year program remains Gulf-focused, the Biden ruling limits future administrations that may attempt to freeze OCS leasing beyond a President’s term.
The DOI and the BLM have since taken steps to translate policy into leasing activity. On October 22, the BLM published a call for nominations and comments for the 2025 NPR-A Oil and Gas Lease Sale, opening a 30-day window to identify tracts for the first NPR-A lease sale since 2019. The notice specifies that nominations must be received by November 21, and anchors the offering to the areas designated for leasing under the December 2020 NPR-A Integrated Activity Plan.
Conclusion
Onshore: DOI Moves to Rescind the 2024 NPR-A Rule and Restart Leasing
Taken together, the D.C. Circuit’s approval of the DOI leasing program, the Western District of Louisiana’s curtailment of indefinite OCS withdrawals, the BLM’s move to unwind the 2024 NPR-A rule, and the current BLM call for nominations signal a shift toward expanded leasing opportunity on federal lands.
On May 7, 2024, the BLM finalized the NPR-A Management and Protection Rule, which created a codified structure for identifying, designating, and managing “Special Areas” and other surface- resource protections across large portions of the 23-million-acre Alaskan reserve. In a significant pivot on June 3, the BLM proposed rescission of the 2024 rule, reasoning that rescission would better align with the Naval Petroleum Reserves Production Act’s development mandate and remove regulatory friction that may impede exploration and leasing.
The Authors: John Chadd Tanner Boyzuick Steptoe & Johnson PLLC
Rudy Family Memorial Scholarship
The Ellis Rudy Memorial Scholarship has a new name for 2026: The Rudy Family Memorial Scholarship . This Scholarship will be available for individuals looking for assistance to attend the 2026 NADOA Annual Institute at the Omni Las Colinas Hotel in Irving, TX. This scholarship does not cover the full cost of the Institute. It will cover registration. If you receive a scholarship, please be available to volunteer during the Institute. Please see the application form posted in NADOA magazines or contact Vicki Danielson vdanielson@ att.net . In appreciation for the many years of dedication and support in which the scholarships have been made available to assist NADOA members attend Institute, NADOA presented Austin Rudy with an award recognizing the new name.
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