Comments submitted to BLM re North Park

January 19, 2012

 CWF and NWF submitted comments to BLM re the Kremmling Field Office's Draft Resource Management Plan for North Park on January 17.  We also renewed our collective request for master leasing planning (similar to CWF's request for master leasing planning for South Park) and urged that it become incorporated into the RMP.  It is important that oil and gas development be done in a thoughtful way that protects important wildlife habitat for mule deer, elk, moose and pronghorn.  Alternative C in the draft RMP does include time limitations stipulations for critical winter range. This does not address the need to maintain habitat intact.  Clustering development is a key tool that would retain large areas of habitat intact.

In addition, streams must be protected from damage caused by oil and gas development activities.  Alternative C includes stipulations that would prohibit such activities within 2,500 feet of both sides of the high water mark along 5 major river corridors.  Other riparian areas and other fisheries would receive less protection.  In addition, in December 2011 BLM issued an Instruction Memorandum (IM 2012-044) which states its greater sage grouse land use planning strategy.  It states that " ... conservation measures must be subjected to a hard look analysis as part of the planning and NEPA processes.  This means that a reasonable range of conservation measures must be considered in the land use planning alternatives.  As appropriate, the conservation measures must be considered and incorporated into at least one alternative in the land use planning process."  In the Instruction Memorandum the BLM's National Technical Team recommended that oil and gas development should not be permitted in priority sage grouse habitat and that expired or terminated lease should not be available for future leasing. 

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