Drill in ANWR via Excutive order hypothetical? What would stop bush?

So now that ANWR tack-on has failed, Bush needs to issue a secret Executive Order to drill there. And prosecute anyone who finds out about it and leaks it (excluding Karl Rove and the rest of course). After all the war powers he has gives him the authority to supply gasoline to the troops.

Remember his motto: Just Do it, Constitution be damned

Now give how he issues illegal orders now, what do you think would stop him from doing that?