September 1, 2012
CWF and NWF are working on comments re the BLM's ill-conceived draft Environmental Assessment (EA) that would include 6 South Park parcels in its February 2013 oil and gas lease auction.
The public comment deadline on this draft EA is September 17.
Five of the parcels are close to ½ mile from Spinney Mountain Reservoir, a gold medal fishery, an important recreation area, as well as source of drinking water. A portion of a parcel is within 1/4 mile of the South Platte River. The 6th parcel is in the BLM’s Bald Hill unit, in elk, deer and pronghorn winter range.
South Park is a unique fish and wildlife resource that offers world-class recreation and scenic beauty and is less than a two-hour drive from a major metropolitan area.
BLM is working from an outdated 1996 Resource Management Plan. BLM has stated it would begin a revision process to its resource management plan this fall, although that timeline might have slipped.
The BLM should be engaging in a comprehensive planning process that addresses South Park's resources, including inquiry into potential cumulative impacts and conflicts --before any new leasing.
South Park, as part of the Royal Gorge Field Office, apparently is included in the BLM’s overall rationale for its proposed leases in nine other counties: It states (p. 23), “The absence of federal leases would set up situations in which reservoirs could not be adequately developed and public minerals would be drained by nearby private or state wells, resulting in a loss of revenue due to drainage situations that could be resolved by timely leasing. Drainage cases commonly occur in northeastern Colorado where land and mineral ownership patterns are complex.”
In February, BLM rejected the request made in November 2011 for master leasing planning from CWF, more than 400 residents, the County, NWF and others. The request was that BLM use new tools announced in May 2010 to undertake comprehensive planning, before more leasing. BLM determined that it was too soon for such planning and that there was insufficient interest in South Park by oil and gas companies. Yet four months later it published an intent to lease these 6 parcels! On July 5, the Park County Board of Commissioners also requested by letter that the BLM comprehensively plan before issuing any more leases in South Park. BLM had not notified the County of the decision announced in late June.
BLM makes clear in the draft EA intends to address the very complex, difficult questions at the application for permit to drill stage - rather than now through a comprehensive planning process. (The application for permit to drill stage is when an individual lessee determines its desired drilling site(s), roads, and other associated infrastructure.) It is essential that BLM tackle questions such as impacts to the South Platte River watershed and its water quality, cumulative impacts to wildlife, and other important factors before deciding to offer these parcels at the lease auction -- not on an individual by individual site basis. Cumulative impacts must be assessed at a landscape scale – not only or first considered in the context of individual applications for permit to drill. At the application for permit to drill stage the lease contracts are already in place. For example, on pages 26-28, the draft EA discusses surface water and states,"...Potential impacts to the site specific water quality associated with any exploration and development activities would be assessed for each location during specific project proposals." ( at the APD stage). Park County is in the process of conducting a water quality assessment. BLM certainly should await the outcome of this assessment as its rationale for including South Park parcels in the February auction is flawed.
BLM acknowleges that portions of the parcels in close proximity to Spinney Mountain State Park will impact the physical and social setting of this popular area.
BLM classifies portions of parcels as Visual Resource Management class III with an objective established in the old existing 1996 resource management plan. The stated objective is to "partially retain the existing character of the landscape." We also will include in our comments this aspect of the EA.