The Combating Obstruction Against Leasing Act of 2025 directs the Secretary of the Interior to act on coal lease applications that meet defined criteria. It defines what counts as a coal lease and what constitutes a qualified application, and it sets a sequence of agency actions to be taken as soon as practicable after enactment.
Those actions include publishing a draft environmental assessment (if not already published) and implementing regulations, finalizing the fair market value of the coal tract, taking intermediate steps necessary to grant the qualified application, and ultimately granting the application. The bill also requires additional approvals for mining on previously awarded coal leases.
Finally, the Act nullifies Executive Order 3338, the federal coal moratorium, by stating it shall have no force or effect.
The bill’s explicit aim is to remove procedural obstacles to coal leasing and to accelerate development on qualifying federal coal leases. Proponents argue that clearing these impediments improves energy supply and resource development timelines.
Critics, however, may view the measure as elevating leasing speed over environmental review and other safeguards associated with NEPA and other laws. The bill does not address broader energy transition considerations or environmental mitigation beyond the NEPA and regulatory steps referenced above, but it does rely on standard federal leasing processes and a formal valuation mechanism for lease tracts.
At a Glance
What It Does
Defines coal leases and qualified applications, then requires the Interior to publish draft NEPA documents (if needed), finalize lease values, take intermediate steps to grant the qualified applications, and grant those applications. It also directs action on previously awarded leases to enable mining.
Who It Affects
Federal coal lease applicants with pending qualified applications; the Bureau of Land Management and other Interior agencies; and coal mining activities on federal lands.
Why It Matters
It institutionalizes a rapid-leasing pathway for qualified coal projects, potentially accelerating production and royalties while elevating the pace and scope of environmental reviewing processes under NEPA.
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What This Bill Actually Does
The COAL Act of 2025 creates a streamlined path for certain coal lease applications on federal lands. It defines two key concepts—coal lease and qualified application—and directs the Interior Department to act quickly once the bill is law.
Specifically, the Secretary must publish a draft environmental assessment and applicable regulations if they have not already been published, determine the fair market value of the coal tract, and take the necessary steps to grant the qualified application. For already awarded coal leases, the bill requires approvals needed to begin mining.
In addition, the Act reverses the federal coal moratorium by declaring Executive Order 3338 of January 15, 2016 to be without force. This change signals a shift toward faster leasing and development of federal coal resources.
While the bill foregrounds procedural steps (NEPA draft, FMV, grant actions), it does not amend broader climate or land-use protections beyond those embedded in the normal leasing and environmental-review framework. The net effect is to reduce typical procedural frictions for qualified coal projects, while raising questions about environmental safeguards and long-term policy alignment with energy transition goals.
The Five Things You Need to Know
The bill defines a coal lease as a lease entered by the United States as lessor via the BLM using Form 3400–012.
A 'qualified application' is a lease application pending as of enactment for which NEPA review has commenced.
Within as soon as practicable after enactment, the Secretary must publish a draft environmental assessment and applicable regulations for each qualified application.
The Secretary must finalize the fair market value of the coal tract and take intermediate actions to grant the qualified application, then grant it.
Executive Order 3338 (the federal coal moratorium) shall have no force or effect under this Act.
Section-by-Section Breakdown
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Leasing for qualified coal applications
Section 2 establishes the scope by defining key terms and outlining the core mandate. It sets the criteria for what counts as a ‘coal lease’ and what constitutes a ‘qualified application,’ tying qualification to pending status as of enactment and the initiation of the environmental review under NEPA. The provision anchors the rest of the Act’s expedited process to these definitions, ensuring that only applications meeting these criteria receive the accelerated treatment.
Definitions: coal lease and qualified application
This subsection defines a coal lease as a lease in which the United States, through the Bureau of Land Management, is the lessor and the applicant is the lessee, using BLM Form 3400–012 (or successor). It also defines a qualified application as a coal-lease application pending as of enactment, submitted under the BLM’s lease-by-application program under the Mineral Leasing Act, with NEPA environmental review already commenced.
Mandatory leasing and approvals
As soon as practicable after enactment, the Secretary must publish a draft environmental assessment and any applicable implementing regulations for each qualified application (if not previously published). The Secretary must finalize the fair market value (FMV) of the tract and take intermediate actions necessary to grant the qualified application, and then grant it. For previously awarded leases, the Department must provide additional approvals required for mining to commence.
Future coal leasing
Section 3 states that Secretarial Order 3338 (the Federal coal moratorium) shall have no force or effect, thereby removing the moratorium barrier to leasing and signaling a policy shift toward expedited coal development on federal lands.
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Explore Energy in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Qualified coal lease applicants with pending applications—gain a faster path to lease approval and potential development timelines.
- Coal mining companies planning to operate on federal lands—receive accelerated access to leases and mining rights.
- Bureau of Land Management and the Department of the Interior—benefit from clearer, expedited processes and reduced review delays.
- State and local governments with coal resources—could realize earlier royalty and tax revenue from faster project commencement.
Who Bears the Cost
- BLM/DOI staff and support offices—face higher administrative workload to publish NEPA documents, set FMV, and process approvals.
- Environmental review practitioners and agencies—could experience increased demand for environmental assessments and compliance oversight.
- Local communities and ecosystems near proposed coal sites—may bear environmental risks associated with accelerated leasing and mining activities if safeguards lag.
- Taxpayers—potentially subsidize agency costs associated with expanded NEPA-related work and expedited permitting.
Key Issues
The Core Tension
The central dilemma is whether to prioritize policy goals of rapid resource development and energy supply on federal lands or to preserve rigorous environmental review and balanced land-use planning in a shifting energy landscape.
The bill creates a tension between expediting coal leasing and maintaining environmental safeguards. By compelling NEPA document publication (where needed), finalizing market-based lease valuations, and pushing to grant qualified applications, the Act compresses timelines in a regulatory context that often involves multiple reviews, public comment, and potential litigation.
The combination of expedited approvals and a federal moratorium withdrawal could provoke challenges from stakeholders who argue that environmental protections or competing land uses should not be overridden or rushed. The provision also centralizes decision-making authority within the Interior Department, with less room for deliberation across other agencies or states affected by these actions.
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