# Federal Land Management Crosswalk An ASCII crosswalk of the **four agencies that manage 607 million acres of the United States** — the [[Bureau of Land Management]], the [[United States Forest Service]], the [[United States Fish and Wildlife Service]] and the [[National Park Service]] — set against the statute each answers to, the mandate that statute imposes, and what it actually takes to move an acre out of any one of them. Part A is the four columns. Part B is the five levers that move land, or appear to. The distinction Part B is built on is the one the 2025–26 record turns on: **four of the five levers never move an acre between columns at all.** They change what may be done on land that stays exactly where it is. Only the fifth — disposal — removes land from federal ownership, and it is the one lever that has barely been used, because it is the only one Congress guarded properly. Companion to the [[Executive Branch Org Chart]], which shows where these four agencies sit in the departmental structure but not what governs them. Sibling to the [[Emergency Powers Crosswalk]] in form. > [!note] How to read this chart > **■** marks a column or a lever. **§** marks the statute doing the work; **✎** marks the instrument that actually executes the lever — the thing somebody signs. **⚑** means Congress is told; **✕** means Congress is told and cannot stop it. **⚖** marks what a court may review. **⇄** marks a lever that moves only the *overlay* — the management rules layered on top of land whose owner does not change. **⇥** marks a lever that moves the *land*, out of federal title. **[live]** marks an action in motion at the build date. **[unconfirmed]** marks anything not run down to a primary source. Acreage is as of **September 30, 2024**, the newest figure that exists, per CRS R42346 as updated September 14, 2026. Officeholders are in a dated table below the chart, not inside it. ``` FEDERAL LAND MANAGEMENT CROSSWALK — FOUR COLUMNS, AND THE FIVE LEVERS │ Legend: ■ column / lever ◆ sub-route § statute ✎ signing instrument │ ⚑ Congress is notified ✕ notified and cannot stop it ⚖ judicial review │ ⇄ moves the OVERLAY only ⇥ moves the LAND out [live] in motion Sep 26 2026 │ Time-slice: acreage as of Sep 30 2024 · law and pending actions as of Sep 26 2026 │ ■ PART A — THE FOUR COLUMNS │ ├─◆ BUREAU OF LAND MANAGEMENT ............................. 244.4 M acres (40.3%) │ │ parent ......... Department of the Interior │ │ § organic ...... Federal Land Policy and Management Act of 1976 │ │ 43 U.S.C. § 1701 et seq. │ │ the mandate .... MULTIPLE USE AND SUSTAINED YIELD, § 1732(a). Grazing, │ │ minerals, energy, timber, recreation and conservation are │ │ co-equal candidate uses. Nothing wins by default. │ │ who decides .... the Resource Management Plan. There is no national rule │ │ about what may happen on BLM land; there are ~160 plans. │ └─ ⇥ THE EXIT .... SALE, administratively, under § 203. Three criteria, any one │ sufficient. Over 2,500 acres Congress is notified — see │ LEVER 5 for what that notice is worth. │ ├─◆ UNITED STATES FOREST SERVICE ......................... 193.1 M acres (31.8%) │ │ parent ......... Department of Agriculture — the only one of the four │ │ outside Interior │ │ § organic ...... Organic Administration Act of 1897, 16 U.S.C. § 475 │ │ + Multiple-Use Sustained-Yield Act of 1960, 16 U.S.C. §§ 528-531 │ │ + National Forest Management Act of 1976, 16 U.S.C. § 1600 et seq. │ │ the mandate .... MULTIPLE USE, same words as BLM, three statutes instead of one │ │ who decides .... the Forest Plan, under NFMA. Same architecture as an RMP. │ └─ ⇥ THE EXIT .... NO GENERAL SALE AUTHORITY EXISTS. Land leaves by EXCHANGE │ (General Exchange Act of 1922, 16 U.S.C. § 485), by the │ Small Tracts Act (≤ 40 acres, value cap $150,000), by │ administrative-site disposal, or by an act of Congress. │ NFMA 1976 closed the old route back to the public domain. │ ├─◆ UNITED STATES FISH AND WILDLIFE SERVICE ............... 89.3 M acres (14.7%) │ │ parent ......... Department of the Interior │ │ § organic ...... National Wildlife Refuge System Administration Act of 1966 │ │ as amended by the Improvement Act of 1997, 16 U.S.C. § 668dd │ │ the mandate .... DOMINANT USE — conservation wins. § 668dd(d)(3)(A)(i): the │ │ Secretary may not initiate, permit, expand, renew or extend │ │ ANY use without first finding it COMPATIBLE with the refuge │ │ purpose. Six wildlife-dependent recreational uses are named │ │ priorities; everything else starts from no. │ └─ ⇥ THE EXIT .... THE ONLY EXIT IN THE SYSTEM THAT REQUIRES A VOTE. Refuge land │ leaves only on a finding that it is no longer needed, APPROVED │ BY THE MIGRATORY BIRD CONSERVATION COMMISSION — a statutory │ body of 7 voting members that includes TWO SENATORS AND TWO │ REPRESENTATIVES (16 U.S.C. § 715a). Proceeds are locked: they │ go to the Migratory Bird Conservation Fund to buy more land. │ └─◆ NATIONAL PARK SERVICE ................................. 80.1 M acres (13.2%) │ parent ......... Department of the Interior │ § organic ...... National Park Service Organic Act of 1916, │ now 54 U.S.C. § 100101(a) │ the mandate .... NON-IMPAIRMENT — the strictest of the four. Conserve the │ scenery, natural and historic objects and wild life, and │ provide for enjoyment BY SUCH MEANS AS WILL LEAVE THEM │ UNIMPAIRED. Enjoyment is subordinate to preservation. │ who decides .... Congress, unit by unit. Park boundaries are statutory. └─ ⇥ THE EXIT .... AN ACT OF CONGRESS, FULL STOP. 54 U.S.C. § 100506 lets the Secretary make a "minor boundary change" — capped at 5% of a unit's federal acreage AND under 200 acres AND under $750,000 appraised, with owner consent and committee notice — and then says in terms: a minor change "involving only deletions of acreage owned by the Federal Government ... may be made only by Act of Congress." │ ■ ✱ THE FIRST FINDING IS THE ORDERING. Exit difficulty runs OPPOSITE to acreage. │ 244.4 M acres leave on a Secretary's signature. 193.1 M leave by trade. │ 89.3 M require four legislators to vote. 80.1 M require a statute. │ The agency holding the most land has the weakest lock on it, and the agency │ holding the least has the strongest. Nobody designed this; it is the residue of │ 1897, 1916, 1966 and 1976 never being reconciled. │ ■ PART B — THE FIVE LEVERS │ ■ LEVER 1 — MONUMENT DESIGNATION AND REDUCTION ......................... ⇄ overlay │ § ................ Antiquities Act of 1906, 54 U.S.C. § 320301 │ ✎ ................ a PRESIDENTIAL PROCLAMATION. Nothing else. │ process .......... NONE. No notice, no comment period, no environmental │ review, no consultation requirement, no finding to make. │ ⚑ Congress ....... NOT NOTIFIED AT ALL. There is no notice provision. │ ⚖ review ......... UNSETTLED AFTER 120 YEARS. No court has ever decided │ whether a president may SHRINK a predecessor's monument. │ does it move land? NO. A monument is an overlay. Bears Ears is jointly managed │ by BLM and the Forest Service before and after; the acreage │ never left either column. What changed is the rulebook. │ the § 204(j) trap FLPMA § 204(j) expressly bars THE SECRETARY from modifying │ or revoking an Antiquities Act monument — and is SILENT as │ to the President, who is the only one who ever does it. │ ✱ the 1938 → 2025 reversal: AG Homer Cummings held in 1938 that a president │ could not abolish a monument outright. A 2025 OLC opinion reversed that, │ concluding a president may find objects "never were or no longer are" │ deserving of protection. │ [live] Jul 13 2026 — Proclamations 11043 and 11044, both published 91 FR, │ Jul 17 2026: │ Bears Ears ................ 1.36 M acres → 121,096 (−91%) │ Grand Staircase-Escalante . 1.87 M acres → 181,541 (−90%) │ Both invoke the Act's "smallest area compatible" clause as the authority for │ subtraction. Sep 2 2026: plaintiffs moved to reactivate the 2017 D.D.C. │ litigation (Hopi Tribe v. Trump · Wilderness Society v. Trump), arguing the │ Act is a ONE-WAY delegation. │ ■ LEVER 2 — MINERAL WITHDRAWAL AND ITS REVOCATION ..................... ⇄ overlay │ § ................ FLPMA § 204, 43 U.S.C. § 1714 │ ✎ ................ a PUBLIC LAND ORDER, published in the Federal Register │ process .......... segregation, notice, comment, an environmental assessment │ the ceiling ...... 5,000 acres or more: 20 years maximum, renewable. │ Emergency withdrawals under § 204(e): 3 years maximum. │ ⚑ Congress ....... notified at 5,000+ acres, with a 90-day window to │ ✕ disapprove by CONCURRENT RESOLUTION — held an │ UNCONSTITUTIONAL LEGISLATIVE VETO in National Mining │ Association v. Zinke (9th Cir. 2017) for want of │ presentment, and severed. The notice survives. The veto │ does not. │ ◆ REVOCATION ROUTE A — administrative. Another Public Land Order, same │ process in reverse. Revocation does not reopen the land by itself; a │ separate opening order sets the terms. │ [live] Jul 15 2026 — BLM proposed revoking Public Land Order No. 7923 IN │ FULL: 336,404 acres around Chaco Culture National Historical Park, │ withdrawn in 2023 for 20 years. Comment closed Jul 29 2026; no final │ decision published to date. ✱ On revocation, management reverts │ to the 2003 FARMINGTON RESOURCE MANAGEMENT PLAN — removing the overlay │ does not write new rules, it exposes a 23-year-old plan. │ ◆ REVOCATION ROUTE B — the Congressional Review Act. And this one works. │ [done] Public Land Order 7917 (Jan 2023, 225,504 acres in the Superior │ National Forest, Cook · Lake · St. Louis counties, MN) was treated as a │ "rule," disapproved by H.J. Res. 140 — House Jan 2026, Senate 50-49 on │ Apr 16 2026 — and SIGNED INTO LAW Apr 27 2026. │ ✱ THE SECOND FINDING SITS HERE. Congress wrote itself a veto over withdrawals │ and it is void. The instrument that actually reversed a withdrawal in 2026 │ came from a different statute entirely — and the only difference that matters │ is that a CRA joint resolution goes to the President's desk and a FLPMA │ concurrent resolution does not. Congress's power over public land is real │ exactly where it used ordinary lawmaking and nowhere else. │ ■ LEVER 3 — THE REGULATORY OVERLAY ................................... ⇄ overlay │ § ................ each agency's organic act, via notice-and-comment rulemaking │ ✎ ................ a rule in the Code of Federal Regulations │ process .......... Administrative Procedure Act § 553: proposal, comment, │ reasoned final rule. Months to years, and reversible by │ exactly the same machinery. │ ⚑ Congress ....... only through the CRA, and only inside its lookback window │ ⚖ review ......... YES — arbitrary-and-capricious review under the APA. This │ is the ONLY lever of the five with settled judicial review. │ [done] Jun 11 2026 — BLM's Conservation and Landscape Health Rule (the │ "Public Lands Rule," 2024) RESCINDED IN FULL. RIN 1004-AF03; 43 CFR Part │ 6100 removed entirely. The rescinded rule had made conservation a discrete │ "use" under FLPMA multiple use and created restoration and mitigation │ leasing. BLM's stated ground: conservation is not a co-equal use and the │ leasing exceeded § 302 authority. │ [live] Aug 20 2026 — Forest Service PROPOSED rescinding 36 CFR Part 294 │ Subpart B, the 2001 Roadless Area Conservation Rule, IN ITS ENTIRETY: │ 58.5 MILLION ACRES of inventoried roadless areas. RIN 0596-AD66, Docket │ FS-2025-0001. Comment extended 15 days to Oct 6 2026 (91 FR, Sep 11 2026). │ ✱ 58.5 M acres is a quarter of the Forest Service's holding, and the instrument │ reaching it is a rule — not a statute, not a proclamation, not a land order. │ ■ LEVER 4 — THE PLAN ................................................. ⇄ overlay │ § ................ FLPMA § 202, 43 U.S.C. § 1712 (BLM) · NFMA (Forest Service) │ ✎ ................ a Resource Management Plan or Forest Plan, and its amendments │ process .......... scoping, a draft and final environmental impact statement, │ comment, then a protest and a consistency review │ ⚑ Congress ....... NOT NOTIFIED. Congress has no role in a plan at all. │ ◆ the GOVERNOR'S CONSISTENCY REVIEW, 43 CFR 1610.3-2 — 60 days to identify │ inconsistencies with state plans; silence is DEEMED CONSENT. The State │ Director decides; the governor may appeal to the BLM Director within 30 days; │ the Director decides finally and publishes the reasoning. │ ◆ the PROTEST, 43 CFR 1610.5-2 — any person who participated and is adversely │ affected may protest to the Director within 30 days. "The decision of the │ Director shall be the final decision of the Department of the Interior." │ There is no appeal above him. │ ✱ THE QUIETEST LEVER AND THE ONE THAT DECIDES THE MOST. A plan is where every │ acre of BLM land learns what it is for. Both of its checks terminate inside │ the agency: a governor's objection is resolved by the governor's counterpart's │ boss, and a citizen's protest is resolved by the same official. Neither │ reaches Congress and neither reaches a judge except through the EIS. │ ■ LEVER 5 — DISPOSAL ................................................. ⇥ MOVES LAND │ the only lever on this chart that takes an acre out of federal ownership. │ ◆ BLM — SALE, FLPMA § 203, 43 U.S.C. § 1713. Any ONE criterion suffices: │ the tract is difficult and uneconomic to manage · the purpose it was acquired │ for has expired · disposal serves important public objectives outweighing │ recreation and scenic values. Fair market value required. │ ⚑ over 2,500 acres: notice to Congress, with a disapproval mechanism │ ✕ that is the SAME CONCURRENT-RESOLUTION LEGISLATIVE VETO struck down in the │ withdrawal context. Under 2,500 acres Congress is not told at all. │ ◆ BLM — EXCHANGE, § 206. Same state, public interest, values essentially │ equal (cash equalization capped at 25%). No acreage trigger. │ ◆ BLM — Recreation and Public Purposes Act: below-market or free conveyance to │ states, tribes, local governments and nonprofits, with reversionary clauses │ and per-state annual caps. Federal Land Transaction Facilitation Act: │ permanent sale authority whose proceeds buy other land. │ ◆ FOREST SERVICE — exchange, Small Tracts Act, administrative sites. No general │ sale authority. See Part A. │ ◆ FWS — the Migratory Bird Conservation Commission vote. See Part A. │ ◆ NPS — an act of Congress. See Part A. │ ✱ THE THIRD FINDING. Every single 2025-26 action on this chart used an OVERLAY │ lever. Nothing of consequence moved through Lever 5. That is not restraint — │ it is the rational response to the incentive structure. An overlay lever is │ faster, cheaper, needs no buyer, and is reversible; the disposal lever is the │ only one with a real congressional lock on it for three of the four agencies. │ So the land does not change hands. It changes rules, and the rules are what │ decide whether the land is a wilderness or a mine. │ ■ WHAT THIS CHART DOES NOT SETTLE │ ◆ whether a president may shrink a monument — unsettled for 120 years, now │ back before the D.D.C. │ ◆ whether the FLPMA § 203(g) sale veto is void. Zinke struck the § 204(c) │ withdrawal veto; nobody has litigated the sale twin, which has identical │ defects. [unconfirmed] as to sale. │ ◆ how much land has actually been sold. There is no consolidated public │ accounting of FLPMA § 203 sales by acreage and year. No figure is asserted │ here because none could be sourced. │ ◆ what happens to the Chaco revocation. Comment closed Jul 29 2026 and the │ decision has not published. ``` **Named officeholders, verified 2026-09-26** — kept outside the chart because seats turn over and a chart should not rot. | Seat | Holder | Since | Status | |---|---|---|---| | Secretary of the Interior | Doug Burgum | 2025-02-01 | Senate-confirmed | | Secretary of Agriculture | Brooke Rollins | 2025-02-13 | Senate-confirmed | | Director, Bureau of Land Management | Stevan Pearce | 2026-05-18 | Senate-confirmed, party-line | | Chief, U.S. Forest Service | Tom Schultz | 2025-02-27 | not Senate-confirmed — the Chief is a departmental appointment | | Director, U.S. Fish and Wildlife Service | Brian Nesvik | 2025-08-01 | Senate-confirmed | | Director, National Park Service | Jessica Bowron | 2025-01-20 | **ACTING**, ~20 months. No confirmed director. | ## Notes - **The BLM directorship was vacant for sixteen months and the Park Service directorship still is.** [[Stevan Pearce]], a former Republican member of Congress from New Mexico, was confirmed on a party-line vote on 2026-05-18 — the first Senate-confirmed BLM director of the term. The National Park Service has had no confirmed director since 2025-01-20; Jessica Bowron has performed the duties since that date. The nomination of Scott Socha, a hospitality and concessions executive, was announced in February 2026 and **withdrawn on 2026-04-28**. The 80.1-million-acre column with the strictest statutory mandate is the one running without a confirmed head, which is worth holding next to [[How a Federal Agency Is Dismantled]] and [[Federal Workforce Structure Tree]]. - **The Forest Service Chief is not a Senate-confirmed office**, which is why [[Tom Schultz]] could be named by the Secretary on 2025-02-27 with no confirmation vote, and why the reorganization described below needed nobody's consent. Reported as the largest restructuring in the agency's ~120-year history: regional offices dissolved in favor of **15 state director positions**, headquarters relocating from Washington to Salt Lake City, and nearly five dozen research and development stations under review for closure, with state offices expected operational in late October or early November 2026. This is the internal-reorganization route, not a statutory one — the same route mapped at [[Reorganization Authority]]. - **Acreage caveat, stated rather than papered over.** The four figures are federal acreage only, as of 2024-09-30, from each agency's own land-status report as compiled by CRS. The National Park Service figure of 80.1 million is *federal* acreage; the commonly quoted ~85 million counts non-federal inholdings inside authorized park boundaries, which the Service does not own. The two numbers are both correct and answer different questions. No current-year figure exists for any of the four. - **Two levers were deliberately left off this chart.** Grazing permits and mineral leasing are *authorizations issued under* a plan, not levers that move land or overlays; they belong to a downstream map. Wilderness designation is omitted because it is the one overlay only Congress can create, which makes it the mirror image of everything in Part B rather than a member of it. - **The monument lever does not appear in Part A for a reason.** A national monument is not an agency. [[Bears Ears National Monument]] is managed jointly by [[Bureau of Land Management]] and the [[United States Forest Service]]; [[Grand Staircase-Escalante National Monument]] by BLM. The [[Antiquities Act]] proclamation sits on top of whichever column already holds the title and changes nothing about who holds it — which is exactly why a 91% reduction shows up nowhere in the acreage table. - **On the legislative-veto point.** [[National Mining Association v. Zinke]] held FLPMA § 204(c)'s concurrent-resolution disapproval unconstitutional under the presentment rule of [[INS v. Chadha]], and severable, leaving the Secretary's withdrawal authority intact. FLPMA § 203(g) contains the same device for sales over 2,500 acres and has not been litigated. Meanwhile the [[Congressional Review Act]] worked on a Public Land Order in April 2026 because a joint resolution *is* presented. The lesson is narrow and load-bearing: Congress's reserved powers over public land survive only where it did not try to shortcut bicameralism and presentment. - **The 2025 [[Office of Legal Counsel]] opinion is doing real work.** It reversed the 1938 Attorney General opinion that a president could not abolish a monument. No court has adopted or rejected it. The July 2026 proclamations rest on it. ## See also - [[Executive Branch Org Chart]] - [[Emergency Powers Crosswalk]] - [[How a Federal Agency Is Dismantled]] - [[Federal Workforce Structure Tree]] - [[Reorganization Authority]] - [[Bureau of Land Management]] - [[United States Forest Service]] - [[United States Fish and Wildlife Service]] - [[National Park Service]] - [[Federal Land Policy and Management Act]] - [[Antiquities Act]] - [[Resource Management Plan]] - [[Public Lands Rule]] - [[Roadless Rule]] - [[Migratory Bird Conservation Commission]] - [[National Mining Association v. Zinke]] - [[Congressional Review Act]] - [[Bears Ears National Monument]] - [[Grand Staircase-Escalante National Monument]] - [[Department of the Interior]] - [[Department of Agriculture]] - [[Federal Agencies Hub]] - [[Foundations Hub]]