Change Justification (Form 3520-7)

U.S. DEPARTMENT OF THE INTERIOR

BUREAU OF LAND MANAGEMENT

JUSTIFICATION FOR NO MATERIAL NON-SUBSTANTIVE CHANGE REQUEST

LEASING OF SOLID MINERALS OTHER THAN COAL AND OIL SHALE

(43 CFR PART 3500)

OMB CONTROL NUMBER 1004-0121

Summary

The Bureau of Land Management (BLM) is requesting a non-substantive change for the Form to 3520‑007 NEL Lease Form which is currently approved under OMB Control Number 1004-0121. The changes do not alter the information collected nor would the changes alter the intended respondents or how the information is used. The changes are generally clarifying in nature and serve to better align the form with the underlying legal requirements. The nature of the changes and the reasons for those changes are discussed below.

1) Nature of the changes (redline attached)

• Editorial/layout clarifications in Part I (lease type checkboxes and headings), including addition of a box that BLM can check for a "Lease Readjustment," movement of the “Hardrock” label and addition of a box BLM can check with an updated description of the attendant renewal rights, plus minor spacing changes for readability. Added “lease renewal / lease readjustment” in Section 1 to cover the lifetime of a lease in case it undergoes any of these actions in the future. These edits do not add fields that the lessee/public must populate or alter the data elements collected on this form.

• Updated statutory citation in Part I, Sec. 1: corrected "of" to "for" and replaced “43 U.S.C. 1201” with the administratively reclassified citation “43 U.S.C. 1457c.”

• Clarification and regulatory alignment of Section 2(b) (Minimum annual production/minimum royalty): Clarified language to better align with the regulatory requirements at 43 CFR 3504.25 so that this standard form is consistent with existing regulations and allows any necessary minimum royalty rate details to be addressed in special stipulations; no changes to what information or data the form collects.

• Clarification and regulatory alignment of Section 3 (Reduction and Suspension): Added clarifying text recognizing BLM’s authority under the applicable Part 3500 regulations so that the form covers all leases issued on this form and not just those issued under the Mineral Leasing Act authorities; no changes to data fields.

• Clarification of Section 6 (Damages to Property and Conduct of Operations): Addition of clarifying language to better identify the regulations being referenced. No changes to what information or data the form collects.

• Update of Section 7 (Protection of Diverse Interests): Removed the sentence referencing Executive Order 11246 (Equal Opportunity), consistent with its revocation by Executive Order 14173 (Jan. 21, 2025); no new requirements are introduced.

• Added statutory citation: In the Notices section, under "Authority," "30 U.S.C. 351-359, 60 Stat. 1099, 43 U.S.C. 1457c" has been added to correctly list the relevant statutory authorities. No new requirements are introduced.

• Corrected regulatory citation: In the Notices section, under "Authority," "43 U.S.C. 3500" has been corrected to refer to the relevant regulatory authority, "43 C.F.R. 3500." No new requirements are introduced.

• No changes to the PRA boilerplate on burden, Privacy Act, FOIA language, or to the OMB control number displayed on the form. The form continues to state OMB Control No. 1004‑0121 and the existing burden statement.

Attachment: Redline — 2026.01.28 DMR changes to 3520‑007 NEL Lease Form (showing tracked changes for the items above).

2) Why the changes are needed

• Accurate legal citations: The update to 43 U.S.C. 1457c ensures the form reflects the current codification of this statute related to the Reorganization Plan No. 3 of 1946 (administrative reclassification in 2021). The form edits also correct the name of the "Mineral Leasing Act for Acquired Lands," add statutory citations to the "Notices, Authority" section and correct the citation to the relevant regulations (43 C.F.R. 3500).

• Consistency with current regulations and authorities: Edits in Sec. 2(b) and Sec. 3 better align the form with existing Part 3500 regulations and established royalty provisions, keeping the form consistent across NEL lease authorities without changing any information requested from respondents.

• Clarifications: Edits in Sec. 6 clarify the regulations being referenced.

• Removing obsolete EO reference: Eliminating EO 11246 language avoids citing a revoked directive and prevents confusion; this does not affect the collection.

• Usability/readability: Minor layout and heading clean‑ups reduce ambiguity for BLM staff using the form while preserving the same fields and data elements for the lessee/public.

3) Why the changes are non‑substantive under the PRA

• No change to information collected: The redlined edits do not add, remove, or alter any respondent‑entered data fields, instructions that change data requirements, or supporting documentation.

• No change in respondent universe or use of information: The edits neither expand the set of respondents nor modify how BLM uses the information.

4) Requested timing for OMB action

BLM respectfully requests your response within 15 days, as we have pending actions that depend on publishing the final version of Form 3520‑7.

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