August 13, 2012
CWF submitted comments on August 9, 2012 to the US Forest Service [USFS] on an application for permit to drill [APD] on federal public land in northwest Gunnison County. CWF made these 3 recommendations:
1. We strongly urge that the USFS conduct an Environmental Assessment to compare the area that would be disturbed under the proposed APD Surface Use Plan of Operations with alternative site options, to produce a comparison of surface acres and habitat that would be impacted. Such analysis also would help inform any further APDs for this lease.
2. It is essential that the USFS and BLM develop a process for considering how to avoid and minimize cumulative impacts as their respective jurisdictions overlap within this elk winter concentration area. In light of the projected substantial expansion of gas development in the Bull Mountain unit, attention must be directed sooner rather than later toward minimizing habitat fragmentation.
3. To prevent and minimize cumulative impacts to this elk winter concentration area, we encourage USFS to take the initiative to engage CPW, the operator, and BLM for the purpose of structuring a wildlife mitigation plan to address effectively the anticipated development in this elk winter concentration area.