Rawlins/Great divide comment period

[BuzzH]

Just a heads up for those who enjoy the Red Desert area of southeast/south central Wyoming.

The Rawlins field office of the BLM has made a proposal to install 9000 new oil and gas wells and 2,700 miles of new roads with little to no consideration for wildlife, hunting, fishing, historical/cultural sites, water quality, etc.

To view the current proposal go to this site:

http://www.rawlinsrmp.com/documents.html

To submit written comments you can email them to:

[email protected]

or write a letter to:

Rawlins RMP
PO Box 2407
Rawlins Wyoming, 82301-2407

 

[Oak]

If you're going to that open house on thursday, I might go with you. Then if you guys want to go back out friday and check on things I would tag along (invite myself ).Oak

 

[BuzzH]

Heres the rough draft of the letter that I will be submitting along with verbal testimony I'll be giving at the BLM public meeting on this issue in Laramie this week:

Thank you for the chance to comment on the great divide and red desert proposal that the BLM is endorsing.

I would like my comments to become part of the public record regarding this public comment period.

I would first like to remind the BLM of their responsibilities as they relate to the American Public, the American Public that in fact, owns FEDERAL LANDS. Under the Federal Land Policy and Management Act the BLM is required to manage under the policy described in the Multiple Use Sustained Yield Act. Under this act, section 4(a) says the following about how the BLM is required to manage: “ harmonious and coordinated management of the various resources, each with the other, WITHOUT IMPAIRMENT of the productivity of the land, WITH EQUAL CONSIDERATION given to the relative values of the various resources, and not necessarily the combination of uses that will give the greatest dollar return or the greatest unit output”.

I do not believe that the BLM is meeting this requirement under the policy that the Public, as well as Congress, has demanded from the BLM under the FLMPA . The current BLM proposal of allowing 8,882 gas wells and 2,676 miles of roads across the Great Divide does not give EQUAL CONSIDERATION to the needs of game animals such as mule deer, elk, pronghorn, sage grouse and many non-game species. The impacts of gas development on all these species is well documented and many professionals from a wide range of federal, state and private agencies all openly admit that just how detrimental these impacts are to these animals in largely unknown. What is known is that they will be impacted negatively. There is literally mountains of peer-reviewed science and scientific reports that prove beyond any doubt that roads, power lines and their corridors, etc. associated with gas and oil development negatively impact wildlife. The roads that need to be installed are perhaps the most damaging item that will be caused for big-game. Most all Wildlife biologists I know or talk to, realize that roads and big-game simply do not mix. They become increasingly vulnerable during hunting season, become increasingly vulnerable to poaching, and habitat is lost every time a new road is punched in. In this proposal is there “EQUAL CONSIDERATION” for wildlife?

Another key issue worth noting is the loss of sage grouse under this proposal. Sage grouse are already teetering on the edge of becoming listed under the ESA. The current BLM proposal for the Great Divide, does not address how sage grouse will be impacted. Any further decline in sage grouse could be the catalyst that sends them into threatened or endangered status under the Endangered Species Act. I don’t believe that it is in the best interest of the BLM or the American Public to have to begin dealing with another threatened or endangered species because of a lack of foresight in oil and gas development. Management of Threatened and Endangered species is costly to the American Public and it would be fiscally, socially, and ethically irresponsible to allow another species to become listed all because of a poor management plans.

I don’t believe that EQUAL CONSIDERATION is being given to watersheds in relation to the effects of discharging coal-bed methane water. As everyone is well aware, the Powder River Basin has become a hot-bed of controversy over the loss of macro-inverterbrates important to strong fisheries, loss of aquifers, saline problems, etc. Until the effects of discharging water from coal-bed methane is further studied, and the ultimate effects are known, I believe it is the BLM’s responsibility to allow gas exploration/development at a much slower rate than is currently being proposed. Again, the lack of science on this issue, should be an adequate reason for the BLM to reconsider the proposed scale of oil and gas development in the Great Divide.

Another key issue that needs to be addressed is the loss of aesthetic value in some of the proposed areas the BLM has slated for oil and gas development in this proposal. The BLM, as an agency, is not considering the associated values of roadless country. Many user groups, like hunters, anglers, hikers, etc. enjoy the Great Divide and its environs, because it supports a very diverse ecosystem that is still largely roadless and aesthetically pleasing to many user groups. Further, the BLM has done a very poor job of designating much of its land under the Wilderness Act and maintaining the roadless qualities of much of its landmass. It would make sense for the BLM to maintain what little is left of the roadless portions of the Great Divide ecosystem, in particular the Adobe Town area, Wild Cow Creek area, and Pedro Mountains, for current, as well as future generations. It is nearly impossible to “re-create” roadless country…in particular in country where wagon trails made 100+ years ago are still present and highly visible.

For these reasons, and because a lack of a thorough and well thought out plan, I strongly disagree with the current BLM proposal. The BLM and its managers need to understand that they have an obligation to the American Public, under the law, to manage in a way that gives equal consideration to all the relative values of the Great Divide ecosytem, not just to those that produce the most oil and gas.

It is more than apparent that the BLM is simply catering to the political agenda of the current administration. The BLM has been instructed, since the Executive Order issued 18 May, 2001 by President Bush, to expedite and accelerate projects that will increase production of energy related projects on public lands. Now is not the time to make rash decisions and expedite important processes involving the Public and Public Lands. Now is the time to let science catch up with the impacts of oil and gas development on our Public Lands and do what truly is best for the land, the wildlife, the American Public, and the ecosystem as a whole.

Therefore, I strongly urge the BLM to adopt the Western Heritage Alternative. This alternative promotes a more balanced approach to oil and gas development in a way that protects hunting and fishing, protects surface owner rights, recognizes the need for wildlife corridors, and protects cultural and historic sites within the Great Divide Ecosytem. This proposal will also allow science and scientific studies to address current issues with expedited development of oil and gas and the impacts.

In closing, I’d like to thank the BLM for the opportunity to comment. I also thought it appropriate to close with a passage from a book entitled “The Lochsa Story” written by Bud Moore, retired Powell District Ranger, who I feel has a good grasp of proper land management and land ethics:

“To decide how these values can be used and sustained requires the study of the biotic and abiotic linkages (that is, all of the land’s natural parts) that keep the land whole and healthy and its ecology functioning. It is important here to remember that nature does not extract---it displaces, replaces, and recycles. That’s why our approach to managing lands should focus more on what to leave to keep the land whole in the long term than on the bounty to be harvested for immediate use. The challenge is to relegate the idea of individual resource management to an honored place in history and replace it with management of the land as a whole, where resources are viewed as the multiple outputs resulting from considerate and professional husbandry of the earth. This involves studying each unit of land, unlike but connected to all other units, a piece of the earth to be treasured and examined in preparation for thoughtful management and care. And when considering the lands values, there is no substitute for detailed, on-site examinations of each of these unique places.”

 

[Ithaca 37]

WOW! Good job, Buzz.

 

[Wyodeerhunter]

Buzz,
Thanks for the heads up, I grew up in the Red Desert and its a very special place. Thanks, will submit a thought out written comment.

 

[FAIRCHASEBEN]

You nailed this one Buzz ,
The Red Desert definitely qualifies as '' not needing gas wells '' . The fact that it's one of the largest unfenced ranges in the west is reason enough to leave it alone !
The history of the area is richer than any gas I've ever burned as well .
Anyone who's ever been there would understand , let's write some letters guys .