January 9, 2008

Great Divide Plan a Blueprint for Industrial Destruction; Last Chance for Your Input

• Fails to even consider the Western Heritage Alternative (the blueprint developed by conservationists to balance industrial use with habitat protections). Every alternative considered by the BLM is heavily slanted toward more oil and gas drilling.
• Protects only 40,000 acres of Adobe Town inside the current Wilderness Study Area, leaving more than half of Adobe Town open to oil and gas development despite the fact that the state has designated Adobe Town ‘Very Rare or Uncommon.’
• Fails to prevent full-scale industrial activity in crucial sage grouse, big game, and raptor habitats. Instead, the proposed plan provides a continuation of biologically meaningless and discredited timing regulations that have been shown by scientific studies to lead to major wildlife declines.
• Fails to adequately protect historic trails and sites of national importance, giving a buffer of only 1/4 mile for industrial development.
• Cuts areas designated as Areas of Critical Environmental Concern (ACECs) from four to two, and leaves them wide open to oil and gas leasing and mining indefinitely. Important and sensitive areas like the Powder Rim and mountain plover nesting concentration areas were never even considered for protection.
• Allows for over a doubling of air pollution (42,305 tons) by the year 2023.
• Fails to address oil and gas leasing issues in the lands surrounding Encampment and Saratoga.
• Radically increases the number of new oil and gas wells (from 1,400 in the 1990 plan to 8,822) and permits over 3,100 miles on new roads to service them. 

There are very few bright spots, but the proposed plan would provide strong protection to the Wild Cow Creek and Pedro Mountains proposed wilderness areas, protects the Shirley Mountains proposed ACEC, and establishes a new ACEC in the Ferris Dunes (but leaves it wide open to oil and gas drilling and mining). 

The time to protest this plan is very short, only 30 days - submit your protest to the BLM by Feb 4, 2008! 

Use the sample protest below to tailor your own:

Dear Director Caswell: 

Pursuant to 43 CFR Section 1610, I protest the Final EIS for the Rawlins Resource Management Plan because it fails to adequately balance oil and gas drilling and other industrial uses with the competing needs of wildlife conservation and public recreation. The BLM’s proposed plan dedicates the overwhelming majority of the public lands – 98% — to industrial uses that are incompatible with wildlife and recreation, and does not provide for multiple use as required by law.

I support the Western Heritage Alternative, which received vastly more public support than any BLM alternative in the Draft EIS process and yet was not even considered as an alternative by BLM. None of the alternatives considered in the EIS present a fair balance between development and conservation: Oil and gas leasing and other industrial uses are far too widespread, and conservation measures lacking, in each alternative. BLM has a legal obligation to consider a range of reasonable alternatives, including the Western Heritage Alternative as well as alternatives of phased leasing and development, setting limits on the density of roads and wells in oil and gas fields, and requiring directional drilling to avoid disturbance of sensitive wildlife habitats. Even halting oil and gas leasing altogether would provide for an increase in oil and gas drilling on presently existing leases well into the future. By failing to consider an adequate range of alternatives, the Final EIS violates federal law. 

While a few scattered wildlife areas received adequate protections, the measures proposed for sage grouse and big game crucial habitats and migration corridors across the planning area are completely inadequate. In the face of scientific knowledge that allowing industrial development in these habitats, while regulating only the time of year that drilling and construction can occur, it is arbitrary and capricious for the BLM to continue to pursue this business-as-usual approach in the face of declines of sensitive wildlife. Stronger wildlife protections must be considered and implemented; numerous scientific experts have made recommendations that are not represented in the Final EIS.  

Proposed expansions of Wilderness Study Areas in Adobe Town and the Ferris Mountains were left open to industrial destruction in the proposed plan. The Powder Rim and mountain plover nesting areas meet all of the criteria to become Areas of Critical Environmental Concern, yet receive no protection. The Ferris Dunes is proposed as an ACEC for rare plants, which is good, but inexplicably, drilling and mining are not restricted. Protections for historic trails extend a maximum of ¼ mile from the trail, instead of protecting all of the lands visible from the trail. Wild Cow Creek, the Pedro Mountains, and the Shirley Mountains all received strong protections, which I support. The same level of protection should be given to the sensitive landscapes outlined above. 

Please overhaul the proposed land-use plan to provide strong protection for wildlife and important recreation areas, so that mineral resources can be developed in a way that maintains wildlife populations, recreation opportunities, sensitive lands and resources, and open space. 

Mail your protest by February 4th to:

Jim Caswell
Director, BLM
Attn: Brenda Hudgens-Williams
P.O. Box 66538
Washington, D.C. 20035 

ON BEHALF OF ALL THE RARE NATIVE CREATURES THAT CALL THE GREAT DIVIDE THEIR HOME, THANK YOU FOR TAKING ACTION!