October 2012 letter re South Park

October 23, 2012

 CWF, NWF, Colorado Trout Unlimited, Trout Unlimited and Theodore Roosevelt Conservation Partnership sent a letter to Dept. of Interior Secretary Ken Salazar earlier this month concerning South Park, Colorado. [Note:  see also News 11/17 for BLM decision to defer the parcels from February 2013 lease auction.]  

The letter appears below:


October 11, 2012

Secretary Ken Salazar

Department of the Interior

1849 C Street Northwest

Washington, DC


Dear Secretary Salazar:

 South Park is a Colorado treasure in imminent danger of substantial and unnecessary harm. Specifically, Colorado BLM Director Helen Hankins and the Royal Gorge Field Office (FO) propose to include six parcels in South Park in its February 2013 oil and gas lease auction. This proposed decision comes just months following BLM’s decision to reject master leasing planning (MLP) under Instruction Memorandum No. 2010-117 due to a supposed lack of interest in leasing in the area – a premise clearly disproved by BLM’s current proposal to lease the six parcels. South Park serves as a source watershed for Colorado’s largest metropolitan area, supports critical fish and wildlife values including Gold Medal fisheries, and key wintering habitat for elk and mule deer.  If any watershed warrants the MLP approach, it is South Park. We ask that you direct BLM to refrain from issuing leases in South Park at this time and instead to use MLP in order to ensure a balanced approach to oil and gas leasing in South Park.

 BLM rejected MLP, then proposed leasing – putting water supply, fisheries and communities at risk.  Colorado Wildlife Federation (CWF), joined by other organizations and more than 200 residents, requested on November 4, 2011, that the Colorado BLM Director Helen Hankins undertake a MLP process for South Park under Instruction Memorandum (IM) No. 2010-117. We have attached a copy of the proposal for your reference.  The number of residents who added their support grew to more than 400 by early January 2012.  The MLP application addressed in detail the numerous shortcomings in BLM continuing to rely on its 1996 resource management plan for the Royal Gorge FO to make leasing decisions in 2011, as well as for potential future lease sales. Park County formally endorsed the MLP proposal on November 7, 2011 (attached).

BLM rejected the proposal on February 7, 2012.  In its letter to CWF (attached), BLM stated that the proposal did not meet the IM’s third criterion for preparation of an MLP: “The oil and gas industry has expressed a specific interest in leasing, and there is moderate or high potential for oil and gas as confirmed by the discovery of oil and gas in the general area.” Only four months after rejecting the proposal for preparation of an MLP, however, BLM began scoping for its February 2013 oil and gas lease sale and announced that six parcels in South Park would be included.  Five of the parcels are located extremely close to Spinney Mountain Reservoir and Spinney Mountain State Park—some as near as a ½ mile. As you are no doubt aware, Spinney Mountain Reservoir is an important municipal water supply and a Gold Medal fishery, accessible within a drive of two hours or less from Denver and Colorado Springs.

Despite urging from CWF, Park County and other supporters of the MLP, BLM did not remove the South Park parcels from further consideration in its February 2013 lease sale. In its draft Environmental Assessment (Draft EA), issued on August 17, 2012, BLM presented its rationale for offering leases in February 2013; according to BLM, if it does not offer leases as soon as possible it 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.”  

We question why the BLM would rush to include South Park in its February lease sale.  Its rationale referenced above is unpersuasive.  The chart in the Draft EA shows no oil and gas activity in South Park.  Further, in its February 7 letter rejecting the master leasing plan proposal, BLM stated, “… there are no producing oil and gas wells in the South Park Basin. Oil and gas development in South Park is still in the exploratory stage and highly speculative."

 Simply put, the draft EA did not justify the risk to water supplies and the fishery or to the community, values that are highlighted by the existing South Park National Heritage Area. The South Park National Heritage Area (NHA) designation was approved by the US Congress and signed by the President in 2009.   According to Park County, the designation “opens the door” to obtain grants and matching funds “to help Park County preserve its valuable history and natural resources and to help others learn to appreciate our preservation of the past.” It will promote tourism, ranching, and mining. South Park was also designated in 2006 as a Preserve America Community, a national honor awarded by the First Lady to communities that demonstrate strong efforts in preservation, education and tourism programs.  The Draft EA does not even mention the South Park National Heritage Area designation, nor does the Draft EA document whether and to what extent the BLM “consult[ed] and coordinate[d]” with Park County “to the maximum extent practicable,” as directed by the NHA’s designating statute.

We question why BLM does not plan to await the completion of Park County’s baseline water quality testing and assessment before deciding whether and where to offer leases.  Serious impacts to the general public and to the local recreation economy will result if South Park’s water quality becomes degraded.  To our knowledge, BLM has not undertaken any modeling to understand the important interaction of groundwater and surface water in South Park.  In fact, BLM acknowledged during a meeting of the Park County Board of Commissioners on February 25, 2012 that it knows little concerning the South Park water basin.  Draft EA Section 3.2.5, Water, devotes only one general paragraph to surface water and to groundwater, respectively.

 Park County has already tested shallow water wells near two of the six parcels.  Instead of waiting until the next phase of the study is completed (which would address deep water aquifers), BLM states in the Draft EA (at page 26) in reference to both surface water and to groundwater: 

… activities at the exploration and development stage could have impacts to water quality. The magnitude and location of direct and indirect effects cannot be predicted until the site-specific APD stage of development…. 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.

BLM does not address the water table or known natural radioactivity found in Park County's water quality assessment samples.  These are critical issues that a rush to leasing will prevent from receiving the careful review and consideration they require.  In contrast, master leasing planning effectively would incorporate that data that have emerged from testing shallow water wells and the forthcoming findings from testing deep water aquifers. 

We question why Colorado BLM would work so hard to deny the usefulness and applicability of a master leasing plan for South Park. We have demonstrated that all of the criteria set out in IM 2010-117 requiring preparation of a plan have been met; BLM’s claim that there is not interest in leasing has been shown to be inaccurate. Further, BLM’s guidance contemplates that master leasing planning can be conducted at the discretion of the Colorado State Office. For South Park, the community strongly believes such planning is needed and BLM instead is relying on a FO management plan that was completed 13 years before South Park’s formal designation as an NHA and that did not contemplate oil and gas development – thus putting at risk an important municipal water supply, high-value fisheries and the local recreation-based economy.

 Master leasing planning would allow for a balanced approach to oil and gas leasing, providing a framework for addressing the many South Park resources affected by oil and gas development that are not addressed by the 1996 RMP. South Park would become the first place in Colorado where a formal master leasing plan would be prepared.  BLM’s proposed inclusion of the six parcels in the February 2013 lease sale undercuts its reasoning for rejecting the application for master leasing planning, since there clearly is interest in leasing and developing South Park. Instead of moving forward with leases under an outdated and inadequate plan, the BLM should use MLP as a vehicle to consider how to protect this community, as well as an important water supply and gold medal fishery, before authorizing oil and gas leasing.

We request your assistance in ensuring that South Park’s special status and natural attributes are considered and protected. We can envision oil and gas development as part of this local economy, but not in a way that ignores the other values that define it. Thank you for considering our concerns and for your assistance in making your oil and gas reforms meaningful for South Park. We would welcome the opportunity to meet with you to discuss this further and are glad to provide any additional information that you would find helpful.



Suzanne O’Neill

Executive Director

Colorado Wildlife Federation


David Nickum

Executive Director

Colorado Trout Unlimited


Kate Zimmerman

Senior Policy Advisor – Public Lands

National Wildlife Federation


Robert Meulengracht

Colorado Sportsmen for Responsible Energy Development

Trout Unlimited


Edward B. Arnett, Ph.D.

Director, Center for Responsible Energy Development

Theodore Roosevelt Conservation Partnership



cc:        BLM Colorado State Director Helen Hankins

            BLM Acting Director, M. Pool

Senator Mark Udall

Senator Michael Bennet


Enclosures: South Park MLP Proposal, Letter of support-Park County, BLM rejection letter


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