WSCC Opposes Bull Mountain Decision + Ways to Take Action

By wscc 4 weeks agoNo Comments

On October 4th, 2017, the BLM published its record of decision on the Bull Mountain Master Development Plan, approving the drilling of 146 natural gas wells and 4 wastewater injection wells in the Muddy Creek drainage above Paonia Reservoir. The Western Slope Conservation Center strongly opposes this decision due to the direct negative impacts that will occur to the air, water, wildlife, and local economies in the North Fork watershed. To read more on the specific impacts of concern, see below.

The Western Slope Conservation Center stands with the coalition of conservation and citizens groups who submitted a formal complaint to the federal government this week. The Western Slope Conservation Center believes every community has the right to protect itself from negative impacts from oil and gas development.

We hope local relief from Bull Mountain is found through the formal complaint process. In the meantime, we need your help in securing large landscape protections from future oil and gas development through the land planning processes currently underway in our region:

Take action: The North Fork Alternative + BLM Resource Management Plan

Please sign our petition today in support of the North Fork Citizen’s Alternative Plan, which was included in the Draft Resource Management Plan released last year. We will be submitting this petition to the BLM later this year, showing that our community still stands strong behind protections from oil and gas. The RMP will determine how the BLM manages all of its public lands and minerals in our region for 30 years!

Stay tuned: Gunnison Public Lands Initiative

We’re working with a wide variety of stakeholders “over the hill” in Crested Butte and Gunnison on a collaborative initiative with the goal of producing a bill that would include protections for areas across Gunnison County, which includes the upper North Fork watershed. Stay tuned for updates on forward progress with this initiative.

Take action: GMUG Forest Plan Revision

The Grand Mesa, Uncompahgre, and Gunnison (GMUG) National Forest is currently undertaking its Forest Plan Revision Process, similar to the BLM’s RMP process, which will determine how the forests are managed for decades to come. The GMUG Draft Assessments will be published on November 6th, with a 30-day comment period. You will be able to submit comments by emailing: gmugforestplan@fs.fed.us.

WSCC volunteers spent the fall “ground truthing” roadless areas, inventorying for wilderness character and other conservation resources to be protected. This revision process is especially important for the upper North Fork watershed including rare habitat and roadless areas threatened by oil and gas development. The Western Slope Conservation Center has been working with a coalition of partners to submit a conservation proposal in the current Assessment Phase.

PLUS: Too Wild to Drill campaign

There’s no denying that the Bull Mountain MDP threatens our homes, families, and livelihoods in the North Fork Valley. We’re glad that The Wilderness Society included the North Fork in their Too Wild To Drill campaign, identifying our region as one of the 15 areas in the country needing protection from oil and gas, in the company of the Arctic National .

The Western Slope Conservation Center will continue to work to raise the profile of the North Fork and Lower Gunnison watersheds, working over the long haul to stop irresponsible oil and gas activity and secure protections for our land, water, and air.

Specific WSCC Concerns on Bull Mountain Impacts

  1. The BLM must issue a moratorium on all oil and gas development in the Uncompahgre area for as long as the UFO RMP remains uncompleted. As stated in our past comment letters on the Bull Mountain Unit Master Development Plan, the BLM should not proceed with new oil and gas activities until the UFO Resource Management Plan has been completed. The 1989 UFO RMP is out-dated and can no longer serve as the foundation for decisions on oil and gas development within the UFO. We ask the BLM to wait until the Record of Decision on the new RMP has been finalized. We understand the draft RMP will be made available for public comment some time this year.
  2. The BLM has not adequately considered the cumulative impacts of this proposal in conjunction with historic, existing, or reasonably-foreseeable fluid mineral developments in the Rivers, wildlife and air currents do not recognize property boundaries, and this project should not be considered in a vacuum. We respectfully ask the BLM to evaluate the Bull Mountain Unit MDP’s impacts to air, water, wildlife, farmlands, and our community in conjunction with the following projects: 1) the 76 active gas wells in Delta and Gunnison Counties, 2) the FRAM Whitewater Unit proposal for 108 wells in western Delta County, 3) the Petrox proposal for up to 50 wells at Pilot Knob, 4) Gunnison Energy’s Master Plan for 60-600 wells north of Somerset, 5) the BLM-approved Master Surface Plan for Gunnison Energy’s 16-well proposal in the North Fork/Muddy Creek planning Unit, 6) the Spadafora Waste Disposal Pits, 7) reasonably foreseeable development for the 30,000 acres in  the lower North Fork Valley first nominated for the February 2011 lease sale, and 8) the six APD’s identified in the BLM’s March 23, 2015 scoping notice.
  3. The BLM has not sufficiently analyzed cumulative impacts to As stated in our past comment letters on the Bull Mountain Unit Master Development Plan, the BLM should develop a wildlife mitigation plan (WMP) in consultation with Colorado Parks and Wildlife. The DEIS offers mitigations, but only a cursory discussion on impacts that recognizes that the proposed action would reduce the availability of habitat and forage as well as increase habitat fragmentation.
  4. The BLM has not provided a reasonable range of alternatives. The narrow range of alternatives presented should: 1) analyze and apply the best science available by setting mandatory stipulations that provide specific or adequate protections for federally listed species and their habitats; 2) analyze and stipulate that the best available methane reduction technologies are used; 3) apply stipulations for best management practices for oil and gas development to all lease parcels; and 4) consider a phased approach.
  5. The BLM has not addressed bonding. The DEIS fails to mention required BLM regulations require lessees to purchase a bond in the amount of at least $10,000 before surface disturbing activities can begin. The BLM also has the authority to require additional bonding when the cost of reclamation exceeds the present bond amount. We encourage the BLM to evaluate bonding amounts on a case-by-case basis, similarly to the way that Colorado Division of Mining, Reclamation and Safety (DRMS) evaluates bonding for coal mines, which is based upon estimates as to the cost of reclamation.
  6. The BLM has not adequately addressed compliance The DEIS falls short in discussing compliance monitoring of air, water, and wildlife impacts. We ask the BLM to require monitoring efforts beyond the minimum practices established by the Colorado Oil & Gas Conservation Commission. The BLM should require on-going wildlife monitoring through the life of the project, and not limit monitoring to the reclamation phase. Baseline and on-going air
  7. The BLM failed to consider the social costs of In September 2014, U.S. District Court Judge R. Brooks overturned Arch Coal’s proposal to expand their coal mining operations under the Sunset Trail Roadless Area because the NEPA analysis failed to take a “hard look” at green house gas emissions and ignored the social costs of the project’s potential contribution to climate change. The air quality review of the Bull Mountain Unit MDP DEIS provided in the comments submitted by Citizens for a Healthy Community et. al, indicate that the green house gas emissions from the Bull Mountain development will have significant negative impacts on the human environment. The BLM must provide a “hard look” at the social costs of carbon.
  8. The BLM failed to analyze the impacts of increased traffic along Highway 133 in Delta County. The BLM’s traffic analysis is limited to impacts in Gunnison County, yet the two lane Highway 133, beginning in Hotckiss, is the likely access point to the project area. This stretch of highway, especially between Hotchkiss and Paonia has numerous entrances and exits from the highway with limited vision and short lines of sight creating hazards for vehicles accessing and leaving the roadway. There are no 3rd lane pull-overs or exit/entrance passing areas in this stretch of road. Increased vehicle traffic, especially truck traffic, increases the present risk of vehicle collisions beyond the many near misses that already occur. The EIS should include an examination of the impact of increased truck traffic and some coordination with CDOT to reduce accident risks in this area.
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