The Fortification Creek area is a rare and unique grassland - juniper woodland ecosystem within the Powder River Basin that supports a healthy herd of prairie elk (as well as mule deer, pronghorn, sage-grouse, and a variety of raptors.) Recent studies have demonstrated that wildlife will migrate into less suitable habitat in order to avoid oil and gas developed areas. Elk are particularly sensitive to increases in road-building.  Elk need large chunks of isolated habitat, particularly for crucial winter range and calving.

The Bureau of Land Management's Plan for the Fortification Creek area consists of 7 different coalbed methane (CBM) projects (proposed by 6 different companies) and includes the initial drilling of 158 wells with associated roads, power lines, pipelines, wastewater reservoirs, and other facilities. The full development potential for this area is over 1,000 CBM wells!

Full CBM development would fragment habitat and eventually extirpate the elk population in the Fortification Creek Area. Sage-grouse are another species that need undisturbed habitat in large chunks to survive. A four-year sage-grouse study in its third year found that current levels of CBM development are pushing sage grouse out of developed areas (Naugle,Walker, Doherty, May, 2006).

The Bureau of Land Management will also be considering a road and pipeline through the Wilderness Study Area to access a well site on a section of state land. The Bureau is also soliciting public comments on this potential action. Tell the Bureau that development should NOT occur within the Wilderness Study Area, and if it does, helicopter-access only should be required. BLM is mandated to manage the Wilderness Study Area for its wilderness values!
 
Burea of Land Management's 1985 Resource Management Plan identified the following "Special Resource Values" in the Fortification Creek Area:

• An isolated prairie elk herd numbering 200-300 elk
• A 12,000 acre Wilderness Study Area  in the center of the area
• Rich cultural, historic, and paleontological resources
• Beautiful scenery (classified by Bureau of Land Management as high quality "visual resources")
• "Breaks" topography consisting of steep slopes with highly erosive soils

The combination of these unique resource values led Bureau of Land Management to develop a Special Management policy for the Fortification Creek Area in order to protect the integrity of these resources. Ask the Bureau to explain how this special management policy could possibly accommodate full CBM development while protecting these sensitive lands.
 
For more information, visit the Buffalo Field Office of the Bureau of Land Management's Homepage for the Scoping Notice, a fact sheet, and maps of the Plan Of Development:  http://www.wy.blm.gov/nepa/bfodocs/fortification_creek

Tell the Bureau of Land Management that no further development should be permitted within the Fortification Creek Area until the Bureau has conducted an Environmental Impact Statement that thoroughly analyzes all the resource values of the area.


Email your concerns to: Fort_Crk_WYMail@blm.gov


Send letters to:        
           
Bureau of Land Management
Attn. Paul Beels
1425 Fort Street
Buffalo, WY 82834

Comments should be received by Friday, June 23, 2006.

Additional subjects for comment:

• Bureau of Land Management estimates the direct disturbance of 350 acres in this first phase of development. This estimate is far too low and does not take into account the cumulative disturbance of networks of roads, pipelines, power lines and other infrastructure the entire proposal creates.
  
 
• In addition, there are 62 existing conventional oil and gas wells, and 309 CBM wells (mostly private minerals) on the periphery of the Fortification Creek Area which Bureau of Land Management must consider when analyzing cumulative effects for this proposal.
   
 
• Water management practices accompanying CBM development include discharging huge quantities of salty water into drainages. The proposal calls for the construction of wastewater reservoirs, and treatment and direct discharge into usually dry tributaries of the Powder River, including Bull Creek, and Stotts Draw. Even treated water will damage lowland forage and endanger the Powder River, with its important assemblage of rare native fishes.
     
 
• The proposal projects that industry would use gas or diesel-powered generators at the rate of 3 generators for up to a year, before permanent sources of power were available. Anywhere from 20 to 300 generators could be used in the area at any given time, creating noise and air pollution, which the Bureau of Land Management has not analyzed.
   
 
• Although the Bureau has stated that industry would be expected to cooperate on power, road, and pipeline corridors in order to minimize infrastructure, there is little evidence that this cooperation has taken place. 
   
 
• Invasive noxious weeds are one of the most serious long-term impacts of oil and gas development, and Bureau of Land Management has not demonstrated that they have a handle on this problem. Reclamation has been slow to take place and weed eradication has been inadequate in most cases . The Bureau should not allow any additional CBM development until they can demonstrate that full and successful reclamation and weed control is taking place. 
   
• Bureau of Land Management's Scoping Notice on this proposal is deficient and should be revised and reissued after additional analysis has been completed. The Bureau has underestimated the potential impacts of full development of the Fortification Creek Area, which leaves the concerned public at a disadvantage to comment. The Bureau should remedy this situation with a new Scoping Notice that accurately depicts the potential impacts of the Plan.  
   

Email your concerns to: Fort_Crk_WYMail@blm.gov

Send letters to:
Bureau of Land Management
Attn. Paul Beels
1425 Fort Street
Buffalo, WY 82834

Comments should be received by Friday, June 23, 2006.

On behalf of sage grouse, prairie elk, raptors, pronghorn and mule deer, thank you for speaking out!