Upper Green River Valley Coalition: Issues

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RMP Revision

"The minerals industry has been denied almost nothing – not even release from winter range stipulations." - Leo & Rosemary Benson, Bodurant

Issues: RMP Revision Wildlife Air Quality Socio-economic Hotspots

Revising BLM’s Pinedale Resource Management Plan
The BLM is presently revising the document that guides drilling and other land uses on the 1.2 million-acre Pinedale Resource Area. The agency’s preferred vision, outlined in a draft released in the winter 2007, would authorize nearly 8,000 new wells, tripling the current number in place in the Upper Green River Valley over the next 10 to 15 years. Take action today! Without environmental and community safeguards, the revised Resource Management Plan (RMP) could merely serve as a roadmap to ruin. Or it could be a model template for appropriate resource development on public lands across the West.

The coalition’s position regarding RMP revision builds on the draft’s conservation-minded Alternative 3, which would protect the valley’s many non-energy resources and natural values, while accommodating nearly as much energy extraction as the “preferred” alternative. Our position mirrors those advanced by Governor Dave Freudenthal and the Wyoming Game and Fish Department officials, who have called on BLM to balance energy production with the Upper Green’s irreplaceable natural values. A sound RMP will ease the drilling boom’s impacts on Upper Green communities, which are struggling to cope with housing and labor shortages, truck traffic, drug abuse and other crime, school crowding, and social services and infrastructure that are stretched to the breaking point.

I am not confident that there that will be long-term protection of resources other than oil and gas development throughout the life of this RMP. Given the intense level of such in areas administered by the Pinedale Field Office, there needs to be a high level of assurance that the very limited remaining unleased portions of the management area remain unavailable to leasing in order to maintain a functional landscape for wildlife habitat, recreational opportunities, grazing, cultural resources and open space.

—Governor Dave Freudenthal

Demand Industry Drill Responsibly

While the BLM’s preferred plan includes some positive components, it contains problematic loopholes and fails to provide measures and protections needed to preserve the valley’s non-energy values. The proposed plan would open to development swaths of biologically important big game habitat, and result in further declines in already degraded air quality. The Upper Green River Valley Coalition encourages the public to stay involved although the comment deadline has passed. Echoing in part what the governor and wildlife officials have said in their RMP comments, the coalition is urging the BLM to adopt an improved Pinedale RMP that:

Paces development, including not allowing new major gas fields to be developed until development in existing and expanding fields has been completed
Preserves and enforces seasonal drilling stipulations that protect wildlife
Withdraws important wildlife and scenic areas from future oil and gas leasing availability
Mandates the clustering of new infrastructure and the use of directional drilling to minimize industry’s footprint on the ground
Removes loopholes that allow areas designated for minimal development to become intensively developed and allow surface drilling in No Surface Occupancy (NSO) areas
Requires use of the cleanest technologies and environmentally protective practices

Here, in PDF, are comments submitted by stakeholders and outside experts supporting a sound revision of the Pinedale RMP:

RMP Comments: Conservation groups' joint comments
The Upper Green River Coalition and its conservation partners lay out support for Alternative 3, which provides a great deal more protection to the Upper Green's air quality, wildlife and quality of life than the BLM's "preferred" alternative, while allowing almost as much energy extraction. See supporting exhibits below. (240K)

RMP Comments: Wildlife
Exhibit 1: Comments prepared by wildlife biologist William Alldredge, a retired university professor from Thermopolis, Wyo. Alldredge concludes the Draft RMP fails to consider an alternative that would truly protect wildlife, fails to take the requisite "hard look" at the environmental consequences of the proposed level of development, and "fails to present adequate plans for monitoring, mitigation and reclamation such that impacts to big game animals and their habitats could be evaluated and reduced." (162K)

RMP Comments: Sage grouse
Exhibit 2: An analysis of impacts to sage grouse by biologist Clait Braun, a respected sage grouse expert. (177K)

RMP Comments: Sagebrush ecosystems
Exhibit 3: An analysis of impacts to sagebrush ecosystems by Carl Wambolt, a range sciences professor at the Montana State University. (177K)

RMP Comments: Air quality
Exhibit 4: Air quality comments prepared by experts Cindy Copeland and Megan Williams, who found that the Draft EIS does not adequately analyze the air quality impacts associated with the level of oil and gas development outlined in the draft RMP. And the preferred alternative fails to ensure compliance the Clean Air Act.

RMP Comments: Water quality
Exhibit 5: Don Duerr, a Pinedale physicist, writes that the Draft EIS does not adequately address potential impacts to surface and ground water. Nor would the "preferred" alternative adequately protect this precious natural resource from oil and gas development. (709K)

RMP Comments: Socioeconomic analysis
Exhibit 6: An analysis of the RMP's socioeconomic impacts by Michelle Haefele and Joe Kerkvliet of The Wilderness Society. The researches conclude that the BLM's Draft EIS overestimates the benefits of accelerated oil and gas development, as well as downplays its costs, and fails to assess the benefits of phasing development. (246K)

RMP Comments: Wildlife habitat
Comments regarding impacts to wildlife habitat by Janice Thomson and Mark Wilbert of The Wilderness Society's Center for Landscape Analysis. The researchers discovered a consistent bias favoring oil and gas development in the draft RMP, which fails to take into account the best science available to assess and mitigate the impacts of oil and gas development on wildlife habitat. The BLM needs to consider an alternative requiring clustered and phased development. (1MB)

RMP Comments: Loopholes
An analysis of problematic loophole language in the proposed RMP revision by Peter Aengst and Nada Culver of The Wilderness Society. The researchers found these loopholes could lead to the redesignation of protected lands as intensively developed gas fields and the waiver of No Surface Occupancy stipulations, thereby allowing drilling in sensitive lands. (88K)

RMP Comments: Governor Freudenthal
Gov. Dave Freudenthal urges balance in the revised RMP. "Given the intense level of (oil and gas development) in areas administered by the Pinedale Field Office, there needs to be a high level of assurance that the very limited remaining unleased portions of the management area remain unavailable to leasing in order to maintain a functional landscape for wildlife habitat, recreational opportunities, grazing, cultural resources and open space,” he wrote. (50K)

RMP Comments: Wyoming Game and Fish Department
Wyoming wildlife officials' comments endorse Alternative 3, insisting on "a reasonable and balanced approach to energy development and management of the other uses and resources" in the Upper Green.

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