In a lawsuit first filed in 2020 to challenge the Secretary of the Interior’s August 2020 authorization of an oil and gas leasing program in the Coastal Plain of the Arctic National Wildlife Refuge, three environmental organizations filed an amended and supplemental complaint on January 13, 2026 to also challenge the “newest iteration” of the authorization of the program, which the Secretary issued in October 2025. The plaintiffs assert that both the 2020 and 2025 programs exceeded congressional authorization and violated the Administrative Procedure Act, the Wilderness Act, the Alaska National Interest Lands Conservation Act (ANILCA), the National Wildlife Refuge System Administration Act, NEPA, and the Endangered Species Act. The complaint alleged that “[t]he Coastal Plain, like the rest of America’s Arctic, is already profoundly stressed by the effects of climate change” and that “[c]onsumption of fossil fuels—encouraged by expanded oil and gas development such as that proposed by Defendants the Secretary of the Interior and BLM in the Program—is the main cause of climate change.” The plaintiffs alleged that the defendants’ NEPA review “ignored or obscured potential harm to tundra, permafrost, and other landscape features, water quantity and quality, air quality, the climate, wilderness characteristics, and wildlife” and “included a misleadingly narrow range of alternatives.”

Challenge to federal review and approval of an oil and gas leasing program for the Coastal Plain of the Arctic National Wildlife Refuge.

Natural Resources Defense Council v. Burgum

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Plaintiffs Challenged “Newest Iteration” of Oil and Gas Leasing Program on Coastal Plain of Arctic National Wildlife Refuge

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An aim to achieve a quantifiable outcome within a given time-frame, set by an institution such as a national government.

Policy instruments are techniques or tools used by governing authorities to promote certain policies in order to achieve predetermined goals. Put simply, instruments are how a government tries to achieve its goals, with this taxonomy being focused on national policy instruments.

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Justice is the ethical and political framework that addresses fairness, including issues of responsibility, rights, and structural inequity.

Renewable energy means all forms of energy produced from renewable sources in a sustainable manner.

Fossil fuel is a generic term for non-renewable energy sources such as coal, fossil gas, and oil (including crude oil, and petroleum products), that can be used for electricity and heat generation. Fossil fuels are hydrocarbons formed from pressurised and heated organic material buried over millions of years.

Molecules in the atmosphere that play a key role in the greenhouse effect by trapping heat radiating from Earth’s surface.

Area of the economy in which actors engage in identical or related activities.

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The management and allocation of funds, assets and investments to meet various objectives

A tax advantage is a fiscal incentive where the government reduces or exempts selected activities, goods or actors from taxes.

Zoning and spatial planning are both methods for guiding the distribution of people and activities in a space, and are regulatory restriction.

A ban is a legal action that prevents the sale or supply of a product or service, or that recalls a product from the market. Examples are bans on SF6, greenwashing, fossil fuel advertisement or single-use plastics.

Either money or something of monetary value is transferred between two or more organisations, people or countries.

Oil is a combustible liquid fossil fuel composed mainly of hydrocarbons, occurring as crude oil and refined into petroleum products such as petrol, diesel and kerosene.

Fossil gas, commonly known as natural gas, is a fossil fuel consisting chiefly of methane with smaller amounts of other hydrocarbons and trace gases, found in underground deposits.

People with different national or cultural traditions from the dominant population

Social and cultural groups that share collective ancestral ties to the lands and natural resources where they live, occupy or from which they have been displaced

Any compulsory, unrequited payment to the government levied on corporations or individuals. This can be for environmental reasons, such as introducing a Carbon tax to set a price that emitters must pay for the greenhouse gases they emit.

Activities of industries that extract natural resources, such as mining, oil, and gas, for commercial use.

Activities that involve planning, designing and building infrastructure, residential, and commercial structures.

This sector involves the wholesale and retail selling of goods.

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Activities involving the catching, processing, and selling of fish for food, recreation, and industry.

Plaintiffs Challenged “Newest Iteration” of Oil and Gas Leasing Program on Coastal Plain of Arctic National Wildlife Refuge

Policy instrument

Impacted group

Fossil fuel

Greenhouse gas

Economic sector

Finance