by Debbie Coffey Copyright 2011 All Rights Reserved
An Open Letter to the BLM
BLM Rocks Springs Field Office
280 Highway 191 North
Rock Springs, WY 82901
Subject: White Mountain/Little Colorado Environmental Assessment Comments
Dear Mr. D’Ewart:
In this BLM Environmental Assessment,
Section 1.2 PURPOSE AND NEED, the EA states:
“The need for this action is to remove excess animals in order to achieve a thriving natural ecological balance between wild horse populations, wildlife, livestock, vegetation, and water resources and to protect the range from deterioration associated with overpopulation of wild horses as authorized under Section 1333 (b) (2) of the 1971 Wild Free-Roaming Horses & Burros Act (1971).”
My comments are:
1) In my opinion, one of my biggest concerns is that this Environmental Assessment is based on flawed reasoning and for reasons listed below is, basically, fraud against the American public, no matter what “authorizations” it hides behind.
Mr. D’Ewart, this is not directed at you personally, I know you are just filling in the blanks on a boilerplate BLM template and doing your job. But for the BLM to do an 80 page EA on the “deterioration to the range” that so few wild horses supposedly do, while at the same time doing a 6 page Finding of No Significant Impact (FONSI) on the oil and gas lease sales on 105,231 acres of public lands in your district, it seems to have absolutely nothing to do with “a natural ecological balance” and the only thing that will be “thriving” are the pockets of politicians who are selling out the American people.
2) Regarding “ecological balance,” it defies logic that:
Only 69 wild horses will be allowed on THEIR Little Colorado Herd Management Area (HMA) which consists of 611,113 acres of public land. (That’s only one horse every 8,711 acres).
And only 205-300 horses will be allowed on THEIR White Mountain HMA which is 236,921 acres of public land. (That’s only one horse every 1,155 acres).
This is the equivalent of only 10 horses causing the same amount of “degradation” as ALL of the oil and gas projects and all of their digging, pipelines, construction, trucks and water usage on 105,231 acres in your district (not to mention the additional fracking from oil shale projects and the effects of the tar sands project mentioned below).
3) Regarding desire to “protect the range from deterioration” by relatively few wild horses, what about the EA for the oil and gas leases? It states the following deterioration: “Contamination of soil from drilling and production wastes mixed into soil or spilled on the soil surfaces could cause a long-term reduction in site productivity” and “Direct impacts resulting from the oil and gas construction of well pads, access roads, and reserve pits include removal of vegetation, exposure of the soil, mixing of horizons, compaction, loss of top soil productivity and susceptibility to wind and water erosion. Wind erosion could be a moderate contributor to soil erosion given the average wind speeds in the area. Dust from vehicle traffic would also be a factor. Indirect impacts such as runoff, erosion and off-site sedimentation could result from construction and operation of well sites, access roads, gas pipelines and facilities.”
YET, BLM gave them a FONSI that claimed this damage “will not significantly affect the quality of the human environment, individually or cumulatively”
4) In connection with the water: Consider that a horse only drinks about 15 gallons of water a day. Then consider what the oil and gas leasing in your district (which was found to have no significant impact) could do:
“Spills or produced fluids (e.g., saltwater, oil, fracking chemicals, and/or condensate in the event of a breech, overflow, or spill from storage tanks) could result in contamination of the soil onsite, or offsite, and may potentially impact surface and groundwater resources in the long term.”
“Petroleum products and other chemicals could result in groundwater contamination through a variety of operational sources including but not limited to pipelines, well (gas and water) construction, and spills. Similarly, improper construction and management of reserve and evaporation pits could degrade ground water quality through leakage and leaching.”
“Water wells developed for oil and gas drilling could result in a draw down in the quantity of water in the residential wells”
So, the BLM finds this to be of no significant impact?
5) Also, regarding “a thriving natural ecological balance” and protecting “the range from deterioration,” let’s just take a little peek at two other things: the proposed oil shale and tar sands projects you’re planning in your district (Wyoming, Utah and Colorado).
Regarding the oil shale, I just have one word to say: FRACKING.
And about the proposed tar sands project, the Indigenous Environmental Network (in Canada, where they have tar sands mining) states: “Water is needed in huge amounts in tar sands production and in all other construction stages of tar sands infrastructure across the continent. It takes five liters of water to produce one of usable petrol…Waste tailings ponds are so vast as to be visible from outer space at this early point in production.”
This, while the BLM removes our wild horses from our sight. And “leases” (sells) our public lands for devastation.
FONSI for oil and gas leases:
The EA this FONSI was based on: