Project 2025: Department of the Interior

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With comments by Ken Stromborg, Ph.D., Wildlife Biologist

Editor’s Note: This is our fifth article on the Mandate for Leadership. Each one stands alone, but you might also be interested in the others:

I have no personal expertise in the area of “the interior,” so I entered this section of the Mandate for Leadership with eyes wide open, ready to learn. For some reason, though, I found this chapter of Project 2025 particularly challenging. I am happy to report, however, that I had an expert by my side, and he will interject his comments as we go; I believe his perspective will clarify yours. Now I will summarize for you what I found, along with astute commentary by Dr. Ken Stromborg, Ph.D., certified Wildlife Biologist. Dr. Stromborg, a much-published scientist, served the U.S. Fish and Wildlife Service as a Fish and Wildlife Biologist from 1985 to 2007; he served also as the Environmental Contaminants Specialist for Green Bay. Then he volunteered with the same agency at the Horicon Marsh from 2007 to 2013.  

Now, let’s launch our summary. We’ll begin, as always, with some background on the author, William Perry Pendley.

About the Author

According to Wikipedia, Pendley is an American attorney, conservative activist, political commentator, and government official who served as the acting director of the Bureau of Land Management from 2019 to 2021 but was  never confirmed by the Senate. His appointment was opposed by the Sierra Club, Patagonia, the Wilderness Society and others.

Previously he was a captain in the US Marine Corps. He served as deputy interior secretary under Reagan, but was reassigned due to an issue about underpricing coal mining leases. He was formerly the long-time president of a conservative group advocating the selling off of federal lands in the West. He has called climate change “junk science” whose believers are “kooks.” He moved the Bureau of Land Management to Grand Junction, CO, where he said he’d rather work. 321 positions were moved; 41 employees actually moved; 287 left the bureau. 91 groups with connections to public lands demanded his resignation in 2019, but they were called “environmental extremists.”

Since Pendley never actually won Senate approval as director of the Bureau of Land Management, when a  judge ordered him to leave the position, he apparently refused on the grounds that he’d never actually been appointed. Now let’s summarize what Pendley advises the next administration to do about the Department of the Interior.

Dr. Stromborg weighs in: Wikipedia’s synopsis of Pendley is spot-on in terms of the biases he brings to this section. He is a right-wing zealot devoted to privatizing use and ownership of federal lands by any and all means.  His efforts to dispose of large portions of Bureau of Land Management (BLM) managed lands were too extreme for even the Trump administration, although that was most likely because of probable political blowback from the public. Note the U.S. Constitution, Article IV, Section 3: “The Congress shall have Power to dispose of and make all needful Rules and Regulations respecting the Territory or other Property belonging to the United States.”

History and Mission

The author starts with an overview of the work and mission of this department: “oversees, manages, and protects the nation’s natural resources and cultural heritage; provides scientific and other information about those resources; and honors the nation’s trust responsibilities or special commitments to American Indians, Alaska Natives, and affiliated island communities.” The work includes “more than 500 million acres of federal lands” and “700 million acres of sub-surface minerals.” It also includes “1.7 billion acres of the Outer Continental Shelf... 566 Indian Tribes and Alaska Natives,” and more. The budget has grown 12% from 2023 to 2024, Pendley says, and “DOI will generate receipts of $19.6 billion.”

Pendley says the department was created in 1849 but changed its focus to natural resources with the conservation movement of the twentieth century. It was, he says, “the nation’s dam builder” in 1902. With 70,000 employees “in 2400 locations,” the department was “historically bipartisan,” Pendley explains, with many rural western counties made up of 50% to even 90% federal land. “That ended with Jimmy Carter,” he says, because Carter was “beholden to environmental groups that supported his election.” Pendley goes on to characterize each administration since Carter, and I confess that I have a hard time following his reasoning, so I will not make a poor attempt to summarize it. At one point he says that “antipathy to oil and gas activity on federal lands as mandated by Congress could not have come at a worse time,” and “the fracking revolution soon swept the nation... but not, thanks to Obama, on western federal lands.” He says that Trump “immediately ordered his DOI to comply with federal laws, conduct congressionally mandated lease sales, and seek to achieve energy dominance or independence.” He concludes that we “achieved energy security for the first time since 1957 in 2019.”

Apparently the Biden administration’s DOI “abandoned all pretense of complying with federal law regarding federally owned oil and gas resources.” Returning to the previous administration, Pendley asserts that “not since the Reagan Administration was the radical environmental agenda... rolled back as substantially as it was by...Trump.” He says “efforts were expended, barriers were removed, and career employees were aided in the accomplishment of those missions.” The author claims that “Biden’s DOI is at war with the department’s mission, not only [its] obligation to develop the vast oil and gas and coal resources... but also... to manage much of federal land.” Apparently the administration wants most federal land to be “placed off-limits to all economic and most recreational uses.”

Dr. Stromborg weighs in: Per the Federal Register , DOI was created to deal with most nonmilitary functions of the Federal Executive, pre-civil war. It has sometimes been described as the “Department of Everything Else.”  In the past 195 years, a great variety of functions have been moved into and out of DOI, but the primary function has now evolved into administration and management of public lands and natural resources. In the early days, outside the original boundaries of the U.S., land and resources of the U.S. were viewed as potential sources of wealth and various mechanisms of transferring control away from the federal government to newly formed states or to private interests. Texas was an exception because it was a nation state and entered as an already functioning government. The state government systematically liquidated most public lands, and today a small amount of federal property has been acquired by purchase for transfer (<2% of total land). This is an example of the model Pendley is trying to implement.  Gradually, DOI began to shift from a development model to a mixed conservation/development role, primarily beginning after the Great Depression. Tension between development and conservation philosophies continues, and Project 2025 is an extreme blueprint of the “development” point of view.

Structure of the Department

Next Pendley explains the department’s budget structure, which he calls “small relative to many other federal agencies.” He “forecasts more than $19.6 billion in ‘offsetting receipts’ from oil and gas royalties, timber and grazing fees, park user fees, and land sales.” Most of that is divided among nine bureaus:

  • Bureau of Indian Affairs, responsible for 566 tribes, supporting their natural resource education, law enforcement, and social service programs; BIA operates 18 schools and dormitories and 29 tribally controlled community colleges, universities, and post-secondary schools.

  • Bureau of Land Management, responsible for 245 million acres of public land and 700 million acres of subsurface federal mineral estate; focused on energy and mineral development, forest management, timber and biomass production, and wild horse and burro management.

  • Bureau of Ocean Energy Management, dealing with the Outer Continental Shelf, 6,400+ fluid mineral leases on approximately 35 million OCS acres; issues leases for 24% of domestic crude oil and 8% of domestic natural gas supply; manages offshore renewable energy projects.

  • Bureau of Safety and Environmental Enforcement. Regulates offshore oil and gas facilities on 1.7 billion acres of the Outer Continental Shelf; oversees and researches oil spill response.

  • National Park Service. Manages 401 natural, cultural, and recreational sites, 26,000 historic structures, and more than 44 million acres of wilderness.

  • Office of Surface Mining Reclamation and Enforcement. Regulates coal mining and site reclamation; provides grants to states and tribes for mining over-sight; mitigates the effects of past mining.

  • US Fish and Wildlife Service. Manages the 150-million-acre National Wildlife Refuge System, 70 fish hatcheries; manages endangered species recovery; protects migratory birds and some marine mammals.

  • U.S. Geological Survey. Conducts scientific research in ecosystems, climate, and land-use change, mineral assessments, environmental health, and water resources; produces information about natural hazards (earthquakes, volcanoes, and landslides); leads climate change research for the department.

Restoring American Energy Dominance

“Given... Biden’s war on fossil fuels,” the author explains, it’s important to restore the “department’s historic role managing the nation’s vast store-house of hydrocarbons, much of which is yet to be discovered.” He says “valuable natural resources owned generally by the American people... [and by] Indian tribes and individual American Indians” were “injured by Biden’s illegal actions.”

Apparently the “federal government owns 61% of the onshore and offshore mineral estate,” but “only 22% of the nation’s oil and 12% of US natural gas comes from” that land, and it is “declining.” Pendley says “42% of coal production takes place on federal lands in 11 states.” He says there is a “subsurface mineral estate of 700 million acres onshore and 1.76 billion acres offshore,” and that the Bureau of Land Management manages only 39% of those areas’ minerals [if I’m reading this correctly]. It seems the problem, according to Mr. Pendley, is that Biden is “aligning the management of... public lands and waters... to support robust climate action.” Apparently he has banned “federal coal, oil, and natural gas leasing on federal lands and waters” and “unilaterally overhauled resource management plans, lease sales, fees, rents, royalty rates, bonding requirements, and permitting processes to prevent new production of coal, oil, and natural gas on federal lands and waters.”

The scourge of the current administration is further characterized: Apparently they are trying “to dramatically increase production of solar and wind energy... to remove federal lands from... productive use... abusing National Environmental Policy Act (NEPA) processes [and] the Antiquities Act.” The clear  goal behind all this, Pendley says, is “to advance a radical climate agenda, ostensibly to reduce greenhouse gas emissions.” The author explains that Biden has no statutory authority to do these things because “congressional acts clearly [establish] principles and processes [for] production of coal, oil, natural gas, and other minerals, as legitimate activities.” He accuses the administration of “hoarding supplies of energy” and being “a bad manager of the public trust” that “has operated lawlessly.”

Administration Priorities

With all that in mind, Mr. Pendley lays out his priorities:

Rollbacks: “roll back Biden’s orders, reinstate the Trump-era Energy Dominance Agenda... Reinstate Trump DOI secretarial orders.” Here the author lists 12 specific orders, including a coal moratorium, America-first strategy, solid mineral leasing, expedited permitting, and more.

Actions: He recommends nine specific actions, including these:

  • Reinstate quarterly onshore lease sales in all producing states...[to] increase state participation and federal accountability for energy production on the federal estate.

  • Conduct offshore oil and natural gas lease sales to the maximum extent permitted

  • Review all resource management plans... to restore the multi-use concept...

  • Set rents, royalty rates, and bonding requirements to an appropriate level

  • Comply with [3 acts] ... to establish a competitive leasing and development program in [Alaska’s] Coastal Plain...

  • Conclude ... review of the coal leasing program... work... to restart... immediately.

  • Abandon withdrawals of lands from leasing in [3 areas listed in CO, NM, MN] ...

  • Require regional offices to complete right-of-way and drilling permits...

Rulemaking: Rescind [several specific policies listed] and reinstate President Trump’s plan for opening most of the National Petroleum Reserve of Alaska to leasing and development.

Personnel Changes: Explaining that “States are better resource managers than the federal government because they must live with the results,” Pendley says Trump’s Schedule F hiring proposal should be reinstated and cooperative agreements broadened.

Dr. Stromborg weighs in: Your summary document, Lynn, has a fine-grained analysis of the abrupt policy changes that will be attempted should Trump become Chief Executive again. The most serious threat to DOI is the direct call to reinstate Schedule F as Civil Service personnel procedures. Schedule F explicitly bases political loyalty to the Chief Executive above the Oath to Constitution and the Public that career civil servants now use as guiding principles. This, combined with the disastrous Supreme Court decision repudiating the Chevron Deference, will result in political loyalists dictating policies made for political reasons, not based on public interest or scientific merit.

Immediate Actions

Here the author explains three actions that must be undertaken immediately by the new conservative administration. First he asserts that the Bureau of Land Management HQ “belongs in the American West,” where the bureau manages 245 million acres in 11 western states. He says his decision to move it to the west was “implemented efficiently and effectively,” and he then devotes four paragraphs to explain the benefits of the move and how humanely the HR aspect was handled. Apparently the total cost of the relocation was $17.9 million, which, Pendley explains, “will save money for the American people.” He devotes a paragraph to explaining that point and then another paragraph showing how “the Biden Administration failed to recognize the wisdom” of the move and foolishly relocated it back to D.C. Now “BLM’s ‘top cop’ might as well be on the moon,” he charges. More examples of folly are provided, explaining that the oil, gas, and minerals are in the west, not in D.C. For example, the person responsible for wild horses and burros is in the east again, “despite the fact that the uncontrolled growth of wild horses and burros poses an existential threat to public lands” in the west. He provides one more paragraph detailing the losses incurred by the move of the bureau back east.

Dr. Stromborg weighs in: The proposed evisceration of BLM headquarters under the pretense of moving staff closer to their responsibilities is absurd. The line staff were already positioned near their Federal lands (97% of employees diffused across the West in field offices). The handful of positions in DC were mostly upper management folks who dealt with political relationships with Congress, other agencies, and DOI managers in the DOI Secretary's office. This was an alternative to making the type of changes finally spelled out in the Schedule F plan. It is tempting to speculate that this was an experiment at politicizing an agency that led to fleshing out the Schedule F scheme.  A perhaps unanticipated result was the mass resignation of senior administrators that foreshadowed the stated objective of replacing experienced executives with political loyalists.

Mr. Pendley’s next pressing issue relates to BLM’s law enforcement officers. Following 9/11, he explains, Congress widely supported recommendations regarding such officers, but one, he says, “remained undone: placing all BLM law enforcement officers (LEOs)... in an exclusively law enforcement chain of command.” Every Inspector General has supported that, he says, but “BLM leadership stonewalled.” That was changed “in the final days of the Trump administration,” and “leadership heads exploded,” we are told. “They were furious with their loss of authority,” Pendley explains. That order [which apparently had been issued by Pendley himself] was suspended early in the Biden administration.

Finally, “wild horses and burros” must be dealt with. “In 1971, Congress ordered the BLM to manage wild horses and burros to ensure their iconic presence never disappeared from the western landscape,” we are told. Now, Pendley explains, “95,000 wild horses and burros roam nearly 32 million acres in the West—triple what scientists and land management experts say the range can support.” He says they have “overwhelmed and crowded out indigenous species” and “turned sod into concrete.” Their population grows “10 to 15 percent annually,” and they “face starvation” because they’ve doubled in number in just the past ten years. The author says it takes “nearly $50 million annually to care for them in off-range corrals,” and the care is “neither compassionate nor humane.” Esteemed veterinary organizations have apparently called for reducing the overpopulation for their own protection. Plans submitted, he says, will not solve the problem. “Congress must enact laws permitting the BLM to dispose humanely of these animals.”

Alaska: Immediate Actions Needed

Mr. Pendley tells us that, in 1959, Alaska was granted the right to select 104 million acres “to manage for the benefit of its residents.” They selected 26 million acres, and Stuart Udall froze any further land selections “to protect any claims that might be asserted by Native Alaskans.” When oil was discovered at Prudhoe Bay in 1968, the Alaska Native Claims Settlement Act allowed the Native community to select another 44 million acres. Pendley says environmentalists were “upset that too much of the land they coveted” would be developed, and demanded withdrawal of 80 million acres for parks, national forests and such. Then, in 1978, Jimmy Carter apparently “forced Congress’s hand” and “unilaterally withdrew 100 million acres from any use by the state or Native Alaskans.” Alaskans sued, and, we are told, those Carter withdrawals were revoked. The 100 million acres were apparently put “permanently in federal enclaves,” which “doubled the acreage of national parks and refuges, and tripled the amount of land declared to be wilderness.”

The result, Pendley says, is that Alaska got less than half the land promised to them upon statehood, and Natives received only one-third of the land due to them. Reagan promised 30 million acres, and 60% of what was promised to Natives was actually delivered. The author says, “the federal government has yet to fulfill its statutory obligation to Alaska and Alaska Natives.” He recommends that Alaska and its Natives be allowed to select what was promised, and then all other Public Land Orders should “be revoked immediately.” He adds that, “Without oil production, the Alaskan economy would be half its size.” Pendley then offers three specific recommendations, which include: “Approve the ... largest pending oil and gas projection in the United States in the National Petroleum Reserve-Alaska, and expand approval from three to five drilling pads.”

He also recommends approval of the proposed 211-mile Ambler Road Project “and open the area only to mining-related industrial uses, providing high-paying jobs.” He then cites the “injustice” of the federal government’s treatment of Alaska’s wildlife and waters, recommending an end to “this injustice” by revoking rules about predator control and bear baiting; recognizing the state’s authority to manage fish and game on all federal lands; declaring navigable waters to be owned by the state; reinstating “Trump’s 2020 Alaska Roadless Rule for the Tongass National Forest in Alaska.” The Biden rule that replaced it, Pendley says, “has prevented multiple infrastructure projects... Logging has been shut down to the extent that New York harvests more timber than does all of Alaska.”

Other Actions Recommended

Pendley begins with the “30 by 30 Plan,” and I confess I can make neither head nor tail of it. But, Ken Stromborg to the rescue! Dr. Stromborg explains: 30 X 30 Plan is an international initiative signed onto by about 150 governments worldwide to protect biodiversity on 30% of land and water and establish connecting corridors between units to that end. This is a well-established conservation goal that has been around for several decades.  It is not strictly a U.S. Program and certainly not a land grab.

Next is “national monument designations,” which spawns some colorful language: “Biden has abused his authority under the Antiquities Act of 1906... outrageous, unilateral withdrawals from public use of multiple use federal land... Trump courageously ordered a review of national monument designations.” Apparently the result “was insufficient.” Pendley seeks “a fresh look at past monument decrees and new ones by President Biden,” and he urges the new administration “must vigorously defend the downward adjustments it makes... to reduce the size of national monuments by the U.S. Supreme Court” and “seek repeal of the Antiquities Act of 1906, which permitted emergency action by a President.”

Dr. Stromborg weighs in: The National Monuments and Antiquities Act allows the president to protect Federal lands by executive action.  It does not deal with private lands and customarily incorporates public input. While the Antiquities Act authorizes the president to establish a national monument at the president’s sole discretion, this Administration has invited public comment at meetings in the local communities. Administration officials, including from the Department, have attended many community meetings across the nation and have heard from stakeholders interested in protecting the places they care about. These officials have also heard from stakeholders concerned with the potential impacts of any such designation.

Next Pendley urges action related to the Oregon and California Lands Act of 1937 – something related to a national monument (illegally) keeping people from harvesting timber. He advises to “ensure that the timber is ‘sold, cut, and removed.’” He then turns to NEPA reforms ­– National Environmental Policy Act of 1970 – saying it has become a “tree-killing, project-dooming, decade-spanning monstrosity.” Trump, he says, “adopted common-sense NEPA reform that must be restored immediately.” Then the reader encounters a rather accusatory analysis related to “settlement transparency,” followed by discussion of the Endangered Species Act, the “success rate” of which, he says, “is dismal,” due mostly to “conflict of interest,” as asserted by “a renowned expert.” He refers to “species cartels afflicted with group-think, confirmation bias, and...desire to preserve the prestige, power, and appropriations of the agency that pays or employs them.” [I confess: the language and tone are rather breath-taking.] After an angry outing of a suspicious “sage-grouse monograph,” he offers specific suggestions that will “end its use to seize private property, prevent economic development, and interfere with the rights of states over their wildlife populations.” To wit: Delist the grizzly bear in the Yellowstone and Northern Continental Divide ecosystems; delist the gray wolf in the lower 48; give western states jurisdiction over the sage-grouse.

Dr. Stromborg weighs in (thank heavens!): This section is a succinct example of the underlying conflict regarding federal lands policy.  Pendley is a leading advocate for the “Sagebrush Rebellion” philosophy of disposal of federal lands to state and private entities versus retaining federal control for the benefit of the entire public. His viewpoint is a throwback to 19th century practices designed to “settle the west” (“Manifest Destiny”) through deliberate actions to divest ownership of the vast public domain acquired after the formation of the U.S. The discussion of NEPA and Settlements is just smoke covering the objective of privatization – get out of the way of “progress” and minimize costs for those who want to profit from land transfer.

Now, the Endangered Species Act (ESA) – This is a really difficult section for me because I have some personal experience on the fringes of that program. The real problem is that all of the comments are either vague, misleading, or blatantly political. The section opens as a screed of complaints about ESA being applied to “end its use to seize private property, prevent economic development, and interfere with the rights of states over their wildlife populations.” No, ESA is intended to prevent irreversible loss of species. Once gone, they can never be restored. ESA has been wildly successful in saving a handful of species but failed in other instances. Recovery efforts are extremely complex, and triage decisions must and have been made to attempt to match woefully inadequate funds with management efforts that can potentially be successful. By the time a species is evaluated for listing, its very existence is in peril. Complex scientific decisions must be made based on biology and political reality. The notion that there are “species cartels” making these decisions is libelous and an affront to the dedicated experts who undertake this work on behalf of the public. 

Delisting Grizzlies and Wolves and ceding all management authority for Sage Grouse to western states are just three high-profile cases from the anti-ESA playbook. Grizzlies are a concern of a few landowners around Yellowstone National Park, a private property rights dispute between a handful of special interest groups and the interests of the greater public nationwide. Wolf delisting is a controversy rooted in the population biology of wolves. While the wolf population has recovered over some of its potential range, there are still areas without recovery. Biologists and land managers are engaged in active deliberations about when to declare victory and how to continue recovery in some places. Ceding sage grouse management to states is currently a primary objective of anti-ESA groups. The sage grouse is an indicator species for a large, complex western ecosystem type. Valuable as a species in itself, the sage grouse is even more valuable for its indicator role. Remember, vast tracts of the arid west are FEDERALLY owned. Ceding management to states will lead to steady encroachment of private special interests through fragmented decision making at a more local scale that is much more vulnerable to special interests.

These items are all related to the notion that ESA decisions are somehow made without considering the public's interests. ESA decisions are always triaged based on budgetary limitations. ESA data are subject to public review and access via Freedom of Information Act if necessary.  Limited data are lawfully withheld if, for example, those data might be used to illegally harvest species.  These are rare exceptions and are thoroughly reviewed. Experimental species population programs are a rather rare and relatively new tool for perpetuating a few species populations.  Their intent is to provide a potential buffer in case something goes terribly wrong with an extant population segment of a species, such as a disease outbreak. This is a difficult and experimental approach and not the implied Federal land grab.

The Wisconsin Whooping Crane restoration program is a great example of such an approach. Initially, the concept was to establish a separate population from the extant population that bred in prairie Canada and wintered on the Gulf coast. The reasons were to have a backup in case of disease or a catastrophic event like a hurricane damaged the existing population. Decades of captive propagation and research resulted in the current Wisconsin breeding population that migrates to wintering grounds in Indiana and Alabama. Two other experimental restoration projects have been initiated to build on the lessons learned from the Wisconsin project. The important message here is that this success was possible because of effective cooperation between federal, state, and private entities in  the U.S. and Canada to save a species that was virtually extinct in the early 1940s. At the low point, only 15-20 birds were left in the one Canadian breeding flock at Wood Buffalo National Park. From this tiny remnant, the free-living population has increased to more than 500 nationwide, 60-70 of which are in the Wisconsin population.  Only the Wood Buffalo segment is self-sustaining at this point, but the Wisconsin population might be approaching that point. Our population was begun in 2001 after the failure of the experimental flock in the Rocky Mountains. Endangered species restorations are difficult and success is never guaranteed.

The author now recommends five actions by the Fish and Wildlife Service, to include:

  • “End its abuse ... by re-introducing so-called ‘experiment species’ populations into” certain habitats.

  • “Design and implement an impartial conservation triage program” that will maximize returns under a constrained budget.

  • “Prevent the agency’s opaque decision-making” by making data public.

  • End “reliance on so-called species specialists who have obvious self-interest.”

  • Conform with the Information Quality Act.

Finally, “abolish the Biological Resources Division (BRD) of the U.S. Geological Survey,” and get your research  data elsewhere.

Dr. Stromborg weighs in: The effort to abolish the BRD of USGS extends back to 1993 when Bruce Babbitt was Secretary of Interior. He consolidated most biological research functions from various pieces of DOI (predominantly FWS) into the Biological Research Survey in order to improve the quality of research and foster communications between DOI scientists. But, behind it all was persistent insistence by anti-ESA forces that decisions were biased and capricious. The name was changed from “Survey” to “Service”  in 1995 to emphasize that this was not a scheme to grab power over private interests by, for example, searching for endangered species on private land without owners' consent. (Yes, things were that bad back then also.) Then, after Republicans got real control of Congress in 1994, the attempt to break up and defund research activities by DOI scientists almost succeeded. Last minute politicking by the Director of BRS saved it, but only by moving the whole thing to US Geologic Survey and renaming it Biological Resources Division (BRD). There was also a substantial budget cut in 1996. BRD continues to function but is, in some ways, more like an academic research system because it has lost a close association with the management side of DOI programs. It is my opinion that the politicians behind these efforts do not understand that it is not the scientists who are in charge of making the decisions that Mr. Pendley and his associates do not like. It is policy makers in management positions. Hence, in attacking BRD, they are actually missing their real target, albeit doing great damage anyway (and let's not tell them). In fact, most of the BRD folks who lived through this were happier and more productive than back in the early ‘90s. But here we have another offensive jab at the integrity of civil servants. I invite you to read this scholarly history article by Fred Wagner.

Now we turn to the Office of Surface Mining (OSM), established in 1977 “to administer programs for controlling the impacts of surface coal mining operations.” Pendley points out that 20% of the nation’s electricity “is a mainstay of many regional economies.” He directs the office to perform its mission “without interfering with the production of high-quality American coal,” offering seven specific improvements: Relocate the OSM Reclamation and Enforcement HQ to a Pennsylvania coal field; reduce the number of coal reclamation inspectors; reissue Trump’s Schedule F to get rid of some employees; permit coal company employees to take OSM training; consider extenuating circumstances in applying the “Applicant Violator System”; maintain the current Ten-Day Notice rule; permit “efficient and environmentally sound surface mining” via Directive INE-26.

And then we’re on to Western Water Issues, offering five ways to return to the good work President Trump accomplished: update dam-water control manuals to “develop additional storage capacity across the arid west”; consolidate federal water working groups for efficiency; adopt proposed improvements in reservoir operations and snow observation systems; “foster opportunities for locally led investment in water infrastructure” through clarity and consistency; “reinstate  the Presidential Memorandum on Promoting the Reliable Supply and Delivery of Water in the West.”

American Indians and US Trust Responsibility

The author first asserts that “The Biden Administration has breached its federal trust responsibilities to American Indians.” How? Through “war on domestically available fossil fuels and mineral sources.” He enumerates the charges, which I will try to summarize:

  • Tribal governments are being deprived of the revenue and profits they might realize from their oil and gas resources, forcing “American Indians... among the poorest Americans” to “choose between food and fuel.”

  • Indian nations “have some of the highest quality and cleanest-burning coal in the world.” Biden has destroyed that market and has pushed electric vehicles, “not a choice for Indian communities.”

  • “Critical minerals” on Indian land cannot be mined.

  • Indian nations “have primary responsibility for their lands,” but Biden is, instead, putting them “in charge of environmental regulation on their own lands.”

What other Biden policies have “disproportionately impacted American Indians and Indian nations”?

  • Failure to secure the border “has robbed Indian nations on or near the Mexican border of safe and secure communities.” They are “swamped” by “illegal drugs, particularly fentanyl.”

  • Failure to account for BIE student return from Covid shutdowns

  • “BIE is not reporting student academic assessment data to” the appropriate parties.

Actions, therefore, to be taken by the next administration:

  • “End the war on fossil fuels and domestic... minerals and facilitate their development on lands owned by Indians and Indian nations.”

  • “End federal mandates and subsidies of electric vehicles.”

  • Let “tribal governments... enforce environmental regulation on their lands.”

  • “Secure the nation’s border to protect the sovereignty and safety of tribal lands.”

  • “Overhaul BIE schools to put parents and their children first.”

And, finally, Pendley urges congressional reauthorization of the “Land Buy-Back Program,” which, I believe, sunsetted in November 2022.

That, my friends, is my best effort at summarizing a rather short report that I did not expect would be so challenging. I rather think the challenge for me was the blast of negative emotion and criticism that permeated each page. And I guess I wasn’t alone – Let’s close with final comments by my collaborator (who is my classmate in the Lifelong Learning Institute).

Dr. Stromborg’s final thoughts: I can’t help but feel that this is a personal attack on everything I did during my career.  Every piece of Project 2025 is founded on a philosophy I reject. There are non-monetary values of the public interest that should supersede private profit-driven results, particularly regarding public resource management. My final observation on the whole Department of Interior chapter is that it is a laundry list of every natural resources program that benefits the public interest. It must have cost a fortune to hire the army of consultants who combed through DOI program documents to compile this list.  Of course, when you have billionaires financing the operation, maybe money is no object. I heard it said by some pundit that when you happen to find the other team's playbook, you better take it seriously and make a plan for defense. 

Interestingly, just as we were about to publish this “conversation,” I received an update regarding the perpetual dialog about the appropriate balance between development and conservation of public Federal natural resources and lands for the benefit of the American people. I invite you to read it here.