Dear Friend of San Luis Valley Ecosystem Council,
As you may or may not know, there is a proposed lease for oil and gas development near the Great National Sand Dunes Park and other important conservation areas in the Sangre De Cristo Mountains. Please read the attached letter and see attached maps of the area involved. Public comments are needed by Friday, April 6th, 2018.
March 19, 2018
Your Public comment is needed!
It has come to our attention that the Bureau of Land Management (BLM), through the Royal Gorge Field office, are now in the process of taking public comment, for the following nominated parcels regarding a potential oil and gas lease sale:
- In Total, 11 parcels/18,358 acres in Huerfano County (#s 8080, 8081, 8082, 8083, 8084,
8085, 8086, 8087, 8088, 8089, 8090). These nominated parcels are located on the eastern side of the Sangre de Cristo mountain range, within the Wet Mountain Valley. Some of these parcels are bordering designated Wilderness and are also located within a few miles of the Great Sand Dunes National Park and Preserve boundaries.
1st Comment deadline coming up: Friday, April 6th, 2018
Address your letter to:
Voice your concerns NOW.
The BLM is currently in the midst of a Thirty-day public review and comment period for a potential lease sale and a draft Environmental Assessment (EA) will be published on Thursday, March 22nd. Your comments will be analyzed and incorporated into the final environmental analysis “as appropriate.” Final announcement of sale is scheduled to take place Friday, July 20th, followed by another 10-day protest period.
Some Major Concerns:
Sangre de Cristo Wilderness and Adjacent Forest Service Roadless Lands:
Parcel 8086 is directly adjacent to the Sangre de Cristo Wilderness. All of the parcels in Huerfano County (parcels 8080, 8081, 8082, 8083, 8084, 8085, 8086, 8087, 8088, 8089, 8089, 8090) are within 6 ½ or fewer miles of the Sangre de Cristo Wilderness. In addition, parcel 8080 is directly adjacent to the Colorado Roadless Rule upper-tier roadless area named Sangre de Cristo: Medano Pass to Carbonate Mountain. There is concern that leasing parcels adjacent to or near these areas could impact air and water quality within these areas and impact the naturalness and opportunities for solitude in these areas or have other impacts.
Great Sand Dunes National Park and Preserve:
All of the parcels in Huerfano County (parcels 8080, 8081, 8082, 8083, 8084, 8085, 8086, 8087, 8088, 8089, 8089, 8090) are less than 8 miles from the Great Sand Dunes National Park and Preserve. Portions of parcel 8086 are less than 1 mile from the Great Sand Dunes National Park and Preserve. We are concerned that leasing parcels adjacent to or near these areas could impact park resources and values, including, but not limited to, sensitive species like the population of dwarfed short horned lizard (Phrynosoma hernandesi) occurring on top of Mosca Pass near the proposed lease area.
- The National Park Service’s Air Resources Division air quality trends monitor for 2015 (the most recent year for which monitoring data is available) assigned Great Sand Dunes National Park the highest level of air quality concern for ozone as well as Sulphur and nitrogen indicators.
Dark Night Skies and Natural Sounds
Great Sand Dunes National Park and Preserve is highly valued for its near-pristine qualities of nighttime darkness, and its natural soundscapes. These two characteristics can especially be experienced in the backcountry of the preserve, the portion of the park which is closest to the proposed parcels of concern in Huerfano County.
The NPS’ Natural Sounds Program has conducted acoustic monitoring in the park and found that Great Sand Dunes to have one of the lowest levels of measurable ambient noise in the national park system. This natural quiet was partly the basis for a 2009 U.S. District Court decision preventing oil and gas drilling in the Baca Wildlife Preserve managed by U.S. Fish and Wildlife Service, which is adjacent to the park on the west side of the dune fields. (See: Turina, “Protecting the Acoustic Conditions at Great Sand Dunes National Park and Preserve,” NPS Park Science, 2015, available online: https://www.nature.nps.gov/ParkScience/index.cfm?ArticleID=379)
Parcels 8080, 8081, 8082, 8083, 8084, 8085, 8086, 8087, 8088, 8089, 8089, 8090, are all within or overlap very important areas for elk and mule deer consisting of winter concentration areas, severe winter range, and production areas (calving and fawning areas). Parcels 8080, 8081, 8082, 8083, 8084, 8085, 8086, 8087, 8088, 8089, 8089, 8090, which comprise all the parcels in Huerfano County, are in areas that are especially sensitive because all of the parcels either overlap production and important winter areas for elk or important areas for both elk and mule deer. Parcels 8081 and 8082 overlap production and important winter areas for elk and mule deer severe winter range. Parcels 8080, 8081, 8082, 8083, 8084, 8086, 8088, 8089, 8089, 8090 overlap areas identified by Colorado Parks and Wildlife for the Colorado Oil and Gas Conservation Commission as Sensitive Wildlife Habitat. Parcel 8086 overlaps a significant portion of land set aside as a conservation easement through the Rocky Mountain Elk Foundation.
- The National Park Service, in partnership with the U. S. Forest Service is working to control the spread of white pine blister rust, a fungus that infects Limber and Bristlecone Pines. These species of trees occur on the preserve and the forest near the proposed leasing areas. This control project includes trimming of infected trees and collecting seeds from resistant trees and propagating resistant seeds in order to propagate a rust resistant strain of pines.
Since this project is occurring near the proposed lease area it is important to bring this to your attention.
Wolf Springs Ranch:
Parcels 8089, 8081, 8082, 8083, 8084, 8086 are all within the Wolf Springs Ranch (8084 also includes a portion of BLM lands just south of the ranch) which is part of the Colorado Parks and Wildlife Ranching for Wildlife program. The Public Hunter Management / Ranch Rules indicate that the top soil in the ranch is extremely fragile. BLM analysis should analyze possible impacts to top soil.
- The north half of the Wolf Springs Ranch was recently sold to the Navajo Nation. The Ranch includes “areas where a mountain sacred to the Navajo people can be viewed.” - Mt. Blanca-
- What sort of tribal consultation took place regarding the potential sale of these leases?
- A revision of fluid mineral leasing opportunities in the Royal Gorge Field Office is currently underway through the ongoing Eastern Colorado Resource Management Plan (ECRMP) process. Until the ECRMP process is completed, it is requested that the BLM withdraw the parcels of concern from the September 2018 lease sale and any pursuant lease sales.
- Air quality in Royal Gorge Field Office is already a significant concern. The area contains the northern Front Range Eight-Hour Ozone Control Area, which reaches from Colorado Springs to the Wyoming state line. This area has failed to attain the Environmental Protection
Royal Gorge Field Office:
Agency’s eight-hour ozone National Ambient Air Quality Standards (NAAQS) under 2004 and 2008 guidelines; its designation under more stringent 2015 guidelines has been delayed.
- The BLM needs to consult with United States Geological Survey regarding potential seismic activity and impacts to sensitive geologic formations, such as dune formation within the park and preserve.
- Based on the unique geology of vertical dikes throughout Huerfano County, that can act as transmission zones for water and fracking fluids alike, which are known to be present within the proposed leasing area; that it be highly recommended that a hydrogeology study be conducted and the 2018 lease sale be withdrawn until a further understanding of the complex hydro/geology contained within the potential lease sale area be understood. Water is far more precious resource within the headwaters State of Colorado than potential oil and gas leasing.