Mar 01 2019 03.05PM 3073329299 page 1

TROUT UNLIMITED FAX COVER SHEET

TO: Sheri Wysong, BLM Flu id M inerals Leasing Coordinator, Salt Lake City, Office

FAX NUMBER: 801-539-4237

FROM : Cathy Purves, Trout Unlimited. 307-332-6700 ext. 10

DATE: March 1, 2019

SUBJECT: TU Protest to Utah BLM March 2019 Oil & Gas Lease Sale.

Number of PAGES: 11 including cover

Sheri,

Please find attached TU's Protest Letter for the March 2019 UT lease sale. I am also mailing you a copy since the maps may not come across as clearly in a faxed copy.

Thank you for this opportunity.

Sincerely, Cathy Mar 01 2019 0305PM Trout Unlimited 3073329299 page 2

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Sent Via FAX to: 801-539-4237 March 1, 2019

Sheri Wysong Fluid M inerals l easing Coordinator Bureau of Land Management Utah State Office 440 West 200 South, Suite 500 Salt Lake City, UT 84101

RE: Protest of 11 Specific Parcels offered In the March 2019 Utah BLM Competitive OIi and Gas Lease Sale Specific Protest to Parcels In the Price Field Office: UT-121B-8737-001; UT-UlS-8738-002, UT- 1218-B740·004, UT-1218-8746-010, UT-1218-8747-011, UT-1218-8749-013, UT-1218-8750-014, UT-1218·8751-015, UT-1218-8752-016, UT-1218-B-8988-245

-Specific Protest to Parcel In the Vernal Field Office: UT-1218-8735·229

Dear Ms. Wysong.

Trout Unlimited (TU) respectfully protests, pursuant to 43 C.F.R. §§ 4.450-2 and 3120.1·3, the Bureau of Land Management's (BLM) lease sale offering of 11 Parcels UT-1218-8737-001; UT-1218-8738-00Z, UT- 1218-8740-004, UT-1218-8746-010, UT-1218-8747•011, UT-1218-8749-013, UT-1218-8750-014, VT- 1218-8751-015, UT-1218-8752-016, Ul-1218-B-8988-24S, and UT-1218-8735-229 (hereinafter referred to as the HParcels" ) ln Utah's scheduled March 25·26, 2019 Competitive Oil and Gas Lease Sale. Trout Unlimited protests the offering of t hese Parcels for the followlng reasons:

• Conflicts with Colorado Rive r cutthroat trout populations, a Utah State and BLM Designated Sensitive Species. • Lack of substantial protective stipulations to protect native trout species. • Location of Parcels in Utah designated Blue Ribbon fisheries and lack of sufficient stipulations. • Lack of signtflcant protection measures for Parcels In designated Utah recreational areas.

I. Interest of the Protestlng Party

Trout UnUmlted is a non-profit conservation organization with more than 300,000 members and supporters nationwide. Our mission is to conserve, protect and restore North America's trout and salmon fisheries and their watersheds. Trout Unlimited recognizes the value of public lands is unparalleled in providing habitat to coldwater fisheries, drinking water, wlldllfe habitat and public recreation opportunities. Consistent with our mission Is TU's policy to encourage energy development In a responsible manner that meets the needs of people while e llmlnatlng, minimizing or mitigating the impacts to coldwater fisheries and their watersheds.

Trout Unlimited has a strong base in Utah with approximately 1,800 members associated with eight chapters throughout the state, including chapters In the vicinity of the proposed lease Parcels. Through

Trollt Unlimited: Anr&'ricn's l t!adi11g Coldwater risl,eries Conseruation Organiz.,ition 220 North Sth Street, Lander. WY 82520 (307) 332-6700 • www.Lu.org Mar 01 2019 03:05PM Trout Un limited 3073329299 page 3

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passion, commitment and agency cooperation, these volunteer members have been active for years in coldwater fisheries projects throughout Utah. rn addition, TU staff have Invested in restoration and protection projects on public lands that include partnering w th BLM and state agencies.

II. General Comments

A. Parcel Stipulations Need Improvement

Trout Unlim,ted participated in the July 2018 scoping process for those Parcels offered in the December 2018 lease sa e. Our comments highlighted resource issues that remain applicable for the Parcels in question. Specifically, our concerns were about the location of Parcels in critical watersheds and in. popular fishing and recreation areas where those Parcels had not received adequate protective stipulations. We understand that during the environmental review process conducted by the SLM, many Parcels we Identified were deferred from the December sale and others received stronger stipulation measures. We appreciate the BLM's attention to our concerns. Our comments, and the reason for our protest letter, concentrate on the need to strengthen protections for vulnerable watersheds that may-through the action of selling lease parcels - be put at significant risk from oil and gas activities.

In September 2018 an Idaho federal district court initiated a preliminary Injunction that temporarily halted lease sales for the December sale due to inadequate public comment opportunity and issues of leasing in critical sage grouse habitat The Utah BLM response was to cancel the December lease sale, reconsider lease parcel offerings, which they did In the Utah sale, and reoffer those parcels in the March 2019 sale. However, concerns we Identified for the December 2018 sale remain for 11 of those Parcels.

For this protest, we seek permanent removal of portions of Parcels located in critical native trout habitat and increased stipulation attachments to other Parcels located In important coldwater fisheries and recreational areas.

Specifically, we request that the BLM withdraw those identified Parcels that are within critical Colorado River cutthroat trout (CRCT} habitat and Utah Blue Ribbon designated streams. Because CRCT require cold clean water, intact habitat and a supportive food web for healthy populations to be sustained, any negative impacts si9niflc:mtly reducq CRCT survivol. Our concern I:. related to protecting these Important streams for the current and future benefits of Utah's vibrant fisheries, recreational and tourist economy, and the health of coldwater resources. Dur intention is not to stop energy development.

B. Buffer Increases

Trout Unlimited has consistently requested increased buffer extensions to parcels offered in lease sales in order to better protect the watershed and trout survival. Whlle BLM has occasionally applied additional stipulations, the request for Increased buffer space has remained unresolved. We are curious as to why BLM does not acknowledge the obvious-the wider the buffer the better the protection.

Results from a study on BLM surface use stipulations in Resource Management Plans (RMPs} in the Rocky Mountain West, showed that the application of more protective surface use stipulations did not negatively affect the pace of oil and gas development or the number of jobs created. In fact, increases in Mar 01 2019 0305PM Trout Unlimited 3073329299 page 4

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jobs and wells drilled were noted even with the increase environmental protections.> Despite the BLM denying our request (even with our sclence•based support) for Increased stipulations to protect its resources, SLM on the other hand provides no scientific data that proves 100 feet, or 330 feet, is sufficient to protect watersheds from oil and gas activity damage. The literature identifying the benefits supporting increased buffers is abundant, whether it Is in association with agricultural, munlcipalitles. oil and gas siting or In federal agency planning documents. It is worth noting from a management standpoint that recent USFS and BLM leasing decisions In respective land use plans have resulted in native trout and water quality protections that far exceed the 330·foot NSO buffer zone that is applied as a stlpulation on the protested Parcels. For instance, the following provide some e1

• 's Butte BLM Final RMP (2009) that applies a one-half mlle NSO buffer for occupied and potential cutthroat trout habitat. • In Colorado's Little Snake BLM Final RMP (2011) a buffer up to one•quarter mile NSO ls applied for all perennial streams. • In Utah's Dixie National Forest Final Land Use Plan (2011), a SOD-foot NSO butter Is applicable for all suitable native trout reintroduction habitat.

These recently adopted stipulations are the result of thorough analysis and they Incorporate commitments derived from native trout conservation agreements such as that for CRCT species, Because setbacks are linear in profile, modern directional drilling technology allows access to oil and gas resources that may underlie an area covered by a setback, while still providing an effective degree of protection from spills and sedimentation. This makes setbacks an effective management tool to achieve balanced development.

We have provided significant science-based and peer-reviewed research support in our scoping comments for the application of increased protective stipufatlons and for consideration of the withdrawal of some Parcels due to their increased sensitivity from potential impacts from drilling activities. We provided studies showing where cutthroat trout were permanently Impacted by lingering oil and gas activities that remain in subsurface and surface waters in the Ranae. i We have offered studies where increased buffers provide more protectionJ Including protecting native trout habitat. Studies on brook trout and hydraulic fracturing in the Marcellus Shale region illustrates the need to implement extra precautionary measures, including expanding buffer zones, to pravent

1 Ruple, John and Mark Capone. 2017. NEPA, FLPMA, and Impact Reduction: An Empirical Assessmenr of BLM Resource Management Planning and NEPA m the Mounroin West. Environmental Law Articles, Vol 46: Issue 4. Lewis & Clark Law School; Ruple, John and Mark Capone. 2016. NEPA -Substontlv~ Effectiveness Under a Procedural Mandate· Assessment ofOil and Gas E/Ss In the Mountain West. George Washington Journal of Energy & Environmental Law. Winter 2016 Pp. 36-51. 2 Gerard, Carline. 2015. The Effects of 0 ·1and Natural Gas Development on Water Quality, Aquatic Habitat, and Native Fish In Streams along the Wyoming Range.: A thesis submitted to the un·verslty of Wyoming. Zoology and Physic ogy. Laramie. August 2015. l Eaton, Timothy T. Science-based decision-making an complex issues: Marcellus shale gas hydrofracking and New York City water supply Science of the Total Environment 461-462 j2013) 158-169. !l!.UtiLseesdeot.soo a .awritirg gc.cu ny.edu/files/2017 /09/fatonl3STE•paper-2017 .pdf ; McBroom, Matthew et al. 2012 Sor/ Erosion and Surface Warer Qualiry Impacts of Natural Gas Development In Ease Texas, USA . Ecological Watershed Management Water 2012, 4(4), 944-958, https·//doi.org/10.3390/w40t.0944; Conservation Tools,org. The Science Behind the Need for Riparian Buffer Protection hnps.//conservatioritools.org/guides/13 1-the-sclencf:!­ be hj n d-the-need-for -riparian-buff er -protect,qn. Mar 01 2019 03:05PM Trout Unbmited 3073329299 page 5

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Increased harm from water withdrawals, increased sediment loads occurring In drilling activities, and chemical waste implications as a result of hydraulic fracturing activlt·es.•

Simply put, oil and sas activit ies are hazardous by nature; Incidents of contamination In Utah are documented and remain a concern.5 tn a study conducted by EPA on the number of hydraulic fracturing related spills in states, Utah recorded four that resulted in some levels of contamination. 6 And m Utah's 7 Department of Water Quality 303 Report for 2016 , of the 750 river and stream segments covering 15,583 stream miles, including the Price River, 47 percent did not meet water quality standards to protect uses such as drinking water, rf!creation, aquatic wildlife, .ind agriculture, and another 32 percent had insufficient data to make a water quality determination.

We understand BLM's vlew that selling parcels is not an impact to the resource. However, the act of selling a parcel is an action that assumes development is to take place and thus remains an Irretrievable commitment of resources. Our contention is that by protecting Utah's resources at the front end of the process (the leasing process). there is more flexibility for increased or decreased protection language on parcels than after a lease is sold without sufficient lease stipulations. The APO stage is not available for attaching new stipulatlons. We respectfully request that parcels located in sensitive areas either be withdrawn or be assigned stronger stipulations at the leasing stage. This is where the best protections can be made.

Ill. Statements of Reasons

A. Conflicts with COiorado River Cutthroat Trout Conservation and Recovery

The Parcels in question on BLM lands (Parcels UT-1218·8737-001, UT-1218-8738-002, UT-121S--8740- 004, UT-1218-8747-011, UT-1218-8746-010) encompass both occupied and potential habitat for Colorado River cutthroat trout fn the Price River drainage, the Beaver Creek drainage, Horse Creek, and Ford Creek drainage (Map 1). Colorado River cutthroat trout are designated Sensitive Species by the Utah Department of Wildlife Resources (UDWR) and the SLM, necessitating a more robust analysis and sufficient level of protection than what was afforded In the environmental review for this lease sale. Although CRCT (or even Bonneville Cutthroat trout) are not identified in the Price River RMP (2008), the BLM and UOWR do identify CRCT as a Sensitive Species and this Identification supports our argument for stronger stipulations.

The Conservation Agreement for Colorado River Cutthroat Trout8 (2006) Is a collaborative and cooperative effort among resource agencies to eliminate or reduce threats to CRCT that warrant listing as special status species by state and federal agencies. The Conservation Agreement (CRCT Agreement) and the associated Colorado River Cutthroat Trout Conservation Strategy (CRCT Strategy) are documents that both the Forest Service and BLM are signatories to and committed to implementing. In Utah, the

4 Weitman-Fahs, Maya and Jason M. Taylor. 2013. Hydraulic Fracturing and Brook Trout Habitat in the Marcellus Shale Region: Potential Impacts and Research Needs. American I· ishcrii:s Sociely. Vol 38, No. I. Janunr)' 2013. 5 https //www d eseretnews.com/a rtlcle /7000 3979 7 /Oil-spill-In ·Red•Bune-Creek-t hreaten S•Waters-w1I dlife .html ' 0 Environmental Protection Agency 2015. Review of State and Industry Splll Data: Characterization of Hydraulic Fracturing-Related Spills. EPA/601/R-14/001 I May 201S. www.epa.gov.hfstudy 7 Utah Department of Environmental Quality, 2016 Final Integrated Report. httos, //doc ur.ients. deg.utah .gov /wa t er-g ua ljty/monltoring •reporting/int egrated•report/DWQ-2017 -004941.pdf ij CRCT Conservation Team. 2006. Conservation agreement for Colorado River cutthroat trout (Oncorhyni:hus clarkll pleuriticus) In the States of Colorado, Utah, and Wyoming. Colorado Division of Wildlife, Fort Collins. l0p. Mar 01 2019 03 06PM Trout Unbmited 3073329299 page 6

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most recent CRCT Rangewide Assessment estimates that CRCT occupy only 20')!; of their original historic habitat'. The Strategy requires protecting both existing and potential habitat and requires agency land use plans to reflect protection strategies. The CRCT Strategy states:

Land monagemenr agencies agree ro protect existing and potential cutthrpqt waters from adverse effects of other fond uses and to consult with wildlife agency biologists on forest plans, permit processes, and other proposed activities ro avoid or minimize potential negative Impacts. Signatory agencies will ensure that their olqnninq documents are consistent with Chis Strategy. (CRCT Conservation Srrategy, at page 20.) (Emphasis added.)

Offering these lease parcels without the consideration of these commitments in a leasing sale decision violates the basic premise of the CRCT Agreement. Our protest arguments reflect our scoping comments that we ottered in the December 2018 review. Thus, we fee t that the exist'ng lease terms for the Parcels mentioned are not adequate to protect CRCT resources. -;:::=:;:::=:...::======::-Utah BLM March 2019 Lease,- parcels - Price FO - Price---- River ---,-.--- -- Crttlr.al t 1UI '4• ""1 ,l lMle Pwf• LMH•nt •·• ....,...... " ..-.~ ...... -·.. , ..·...... ··· . '"""- ;.•-··· .. ,.-...... , ...... j ...'9-.... •.•...••~r•••• ,.,._ ..._ .... ·r ...... , ...

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I I ·- ~J " I .-.... M• •~ 0...... ,. .iw...., ..,.-.,,rPC•..- ~t:0 UM.I ~ ...... ~ ~ ~•. "'41...... h~ ~--r-.r.,, &61 _. .... ~fJ1 bllCIII... ~ , ..1 , 1 :._ ---...:~=;;;;;;:~•=-c:-=::...:.;''"::..;':..;;..._;; "4=V•.:::.•.:;C...... ,..,a_..;;_;::._ ___ .:..,· - - - ~--' Map 1. March 2019 BLM Lease Parcels located In Sensitive Colorado River cutthroat trout habit.at.

~ H rsch, C.L, M.R. Dare, and S.E. Albeke. 2013. Range-wide status of Colorado River cutthroat trout (Oncorhynchus clorkii pleuriclcus); 2010 Co orado River Cutthroat Trout Conservation Team Report. Colorado Parks ard Wildlife, Fort Collins. '1ar 01 2019 0307PM Trout Unlimited 3073329299 page 7

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For portions of the Parcels UT-1218-8738-002 and UT-1218-8740-004 straddling the Price River and Parcels UT·l218-8737•001 and UT-1218-8738-002 straddling public lands on Beaver Creek (Map 2 - circled areas), we request the BLM, In a compromise gesture, to withdraw these sections of Parcels from the March sale . We strongly believe, based on submitted prevailing science and demonstrated accident reports, that neither the timing nor NSO stipulations provide adequate protections should development occur on these highly sensitive sites. In addition to containing native CRCT populations, the h ghhghted portion of the Price River Is a Utah designated Blue Ribbon fishery with extremely high-volume usage. Additionally, TU has ongoing restoration projects and partnerships with land owners throughout this watershed Furthermore, Utah Stipulation Ul-LN-49 for Sensitive Species should be applied to all Parcels located in sensit ve ftsh habitat, as has been appl,ed In past lease s~les.

The drainages of the Price River are v,tahy important as a fishery to the entire region and the many entitles that depend on its healthy and thriving status. Any surface and groundwater impacts would affect the entire system and the future of CRCT populations. The proposed stipulations, while appreciated, would be inadequate to protecr the public's Interest, the Investment in restoration act1111tles, and the fish population itself.

r.======U=ta=h=B:...... LM March 2019 Lease parcels - Price FO - Price River

cnuea1 ,,.,. ttaNtet& ._... ,.,.,,,. loc:110"' ---- ..... ,. ., ~-.. ·- ...... -;:....,.-.~ .. "'" .... , ...... --- :. .. A,.. - ....,. ,. ·~-...... ,. .. .. ti.-~~-··· ...... , ,...... , .. -·· 11.w.-

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Map 2, Close-up view of those portions of Parcels TU Is requestlna to be withdrawn from the March sale due to their high value ecologlcal Importance. Mar 01 2019 03:08PM Trout Unlimited 3073329299 page 8

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Finally, we cannot end our discussion of the importance of one of Utah's native cutthroat trout streams without referencing the incredibly popular and prized Utah Cutthroat Slam event'°• a state DWR sponsored effort to help fund native cutthroat trout conservation projects and educate the public about the importance of protecting and conserving native trout habitat.

B. Conflicts with Utah's Blue Ribbon Fisheries Streams

We mentioned this In past lease sale comments, including our scoping comments for the December 2018 lease sale, and again re,terate here: Parcels UT-1218-8738-002 and UT-1218-8740•004 are located within designated Blue Ribbon Fisheries for this March 2019 sale (see Map 2).

In 2000, Governor Michael Leavitt and UOWR established the Blue Ribbon Fisheries Advisory Council 11 The mission of the council Is to identify and recommend to the Director of UDWR those Utah waters that provide or have the potential to provide blue-ribbon-quality public angling experiences for the purpose of preserving and enhancing these valuable economic and natural resources. Waters Identified as Blue Ribbon Fisheries In the Price Field Office include Scofield Reservoir, Huntington Creek, and Fish Creek below Schofield through the confluence with the White River, forming the Price River, and downstream to Royal. Water quality and quantity remains the primary criteria in developing specific criteria for a river or stream to be des gnated a Blue Ribbon Fishery. In addition, the council allocates monies to the protection and enhancement of Utah's Important fisheries. Including lease parcels that have the potential to develop oil and gas wells on these fisheries remains too high a risk, even with an NSO stipulation (which only includes a 330-root buffer) and we request that those Parcels located along the Blue Ribbon corridor of the Price River be withdrawn.

In addition to the enjoyment of the angling and recreational experiences on Blue Ribbon waters in Utah the economic contributions from angling, especially in highly popular, pristine fishing areas. remains significant. In fact, in 2013 a report was published that discussed the economic contribution and benefits of Utah's Blue Ribbon fisheries 12 concludlng that direct expenditures from fishing on Blue Ribbon waters outweighed fishing on non-Blue Ribbon waters significantly ($184 million spent fishing Blue Ribbon fisheries versus $75 million spent on non•Blue Ribbon fisheries). The top ranking attribute from a list of nine attributes that people Identified in deciding where to go fishing was water quality (page 8).

Utah benefits tremendously from n.itional media coverage of these Slut! Ribbon fisheries from ESPNu to statewide coverage. On any given day or in any given year, you will find print media espousing the wonderful attributes of these Important watersheds 14, Including Identifying the Price Rivera as one of Utah's top 25 places for fly fshing in Utah.16 All coverage results In economic benefits to Utah's outfitters, guides, and local businesses Selling oil and gas lease parcels that abut or exist within Blue

10 Utah Division of WI dllfe Resources. httc://wy,w.utahcutthroatslam org/. II htrps.//w,ldlife.utah .gov/b uerrbbon/pdi/oyer.. iew.pdf, 12 Man-Keun Kim and Jakus. Paul M. 2013. The Economic Concnbution ond Benefits of Utoh's Blue Ribbon Fisheries. Department of Applied Economics, Utah Slate University, UMC 4835, Logan, Utah. Final report for Center for Society, Economy, and the Enw onment. CSE E Research Report #4. February 27, 2013. u http / /www .espn.com/outdoors/fishlng/news/story ?page-f_map_OS_UT _ Lower_ F1sn_C reek 14 hpps.//journal amberjack.com/2016/01/6-nlaces•you•h ave-to-fish-I n,urnh/ ; https.//www.promon:oryclub.corn/blue-r,bbon•trout-fi>ning-uta~-trip-1ifetin,e/ ; https ://www.sta noa rd.net/lifestyle/rec •eat ion/ explore-ul a h-s-blue-ribbon-flsherles/a rt,cl e 9 6Q4Sd63-f dbb. SOcS. 8278-6161 b~$7 l f05.html 11 http://www.perfectflystore.com/w:,r cer .htm, Mar 01 2019 03.08PM Trout Unurnited 3073329299 page 9

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Ribbon watersheds threatens water quality a nd thus has the potential to undermine economic contributions to those local businesse!> and enterpri,ses (such as outfitters, guides, hospitality, and food service businesses). For this section of the Price River, we ask that the Parcels be permanently withdrawn from the March 2019 sa le.

C. Conflicts with Designated Recreational and Fishing Access Areas

In addition to concerns about selling Parcels m critical habitat for CRCT and In Blue Ribbon waters, TU observed that several Parcels in the March 2019 sale in the Price Field Office are located In designated public recreation and fishing access areas (see Map 1 and 3). These popular access areas17 provide opportunities for recreation along t he Price River, in Ford Creek Canyon, Horse Creek and in both Crandall and Sulphur Canyons. Therefore, Parcels UT-1218-8746-010, UT-1218-8747-011, UT-1218· 8749-013, UT-1218-8751-015, UT-1218-8751-016 and UT-1218-8-8988-245 must have Stipulation UT­ LN-49 for sensitive fish species and stronger NSO stlpulattons to protect the Price River corridor.

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Map 3. Location of popular public recreation areas and fishing access areas that have lease parcels being offered In the March 2019 sale.

16 httos://f \yfahi ngrook'e com/top-25-olaces-for-fly-fishin g•I n-us ahL l/ Utah Div sion of Wildlife Resources. h1tcS'//wildljfe.utah.gov/hotspots/brwaterbooy.php ?(d=28 Mar 01 2019 03:09PM Trout Unlimited 3073329299 page 10

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D. Conflicts with Native Trout Recovery Habitat in Vernal Field Office

The Vernal resource planning area contains important conservation and recreational fishery components that are not discussed in the EA where lease parcels are being offered. In addition to the economic importance of recreational fisheries in this area, native trout habitat has the potential to be affected without proper analysis and adequate stipulations.

Trout Unlimited has reviewed the Parcels located in the Vernal Field Office region and Identified portions of one Parcel that should be removed from the March 2019 sale (Map 41. Portions of this Parcel (UT-2018-8735-229) are in Willow Creek ne.1r Bender Mountain n the far northeast corner o·r Utah.

Utah SLM Marth 201 9 Leesa Sele • Vernal Field Office- Wilow Creek • • 0 "• • ' I.I I' C, .~~git,t ar•• •4em,f1•• bc•ici,, c,I P~~•I wt1ch ..ma, llhould L>- .,;-,,o,..,,. ftom lh• Lu.. Salo 0 1 .... NSO • Sp•n111 9\ipjl8hOn nach..i atd no dnlling acavit1tt wovld oc.tul en vw .. waaw c,,,._ a, a1nag1

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- 7 uar..,...... ""'• .,_SffLAi.&alt l,t,~~u..o-,,in !~.,.a~t,.C••. GCICO U'-C~ U,O Nl'tS NIIICMf 0,. ~H'.. o,___,._ G..... , . s.,...... UC,1 l.4uc... - ~ tcor1J...a•••-,v e ~ai,mlM,;tDII •"-tt't•Di3 n•C'"'.,.•"'lt

Map 4. WIiiow Creek parcel locations where TU Is requesting withdrawal of portions of the Parcel within the WIiiow Creek drainage or stronger NSO and Spring stipulations.

Willow Creek Is a recognized coldwater trout stream and 1s identified as expansion habitat for CRCT recovery. Trout Unlimited requests that the southeastern portion and the northwest ponion of this Parcel's aliquots located In Willow Creek itself be applled with NSO stlpulatlons or withdrawn from the sale. In addition, the presence of natural springs m Willow Creek where the parcel aliquots Join requires Mar 01 2019 03:1 OPM Trout Un 1imited 3073329299 page 11

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a minimum of one•quarter mile NSO buffer. In our review, we did not see this stlpulatlon and therefore request it be applied.

Trout Unlimited is justified In making this request, based on supportive BLM l,1nguage in the 2008 Vernal RMP, where the Record of Dec sion directs the SLM to Implement conservation actions such as the CRCT Stragey, to protect this species The stated goal of the CRCT Strategy:

To assure the long-term viability of CRCT throughout their historic range, areas that currently support CRCT w,11 be maintained, while other areas will be managed for Increased abundance. New populations will be established where ecologically and economically feasible, while the genetic diversity of the species Is maintained. The cooperators envision a future where threats to wild CRCT are either el1minoted or reduced to the greatest extent possible.

As a reminder, the CRCT Agreement and Strategy recommends the most effective protection measures be applied for both occupied and expans1on and/or potential cutthroat trout habitats, such as that found in Willow Creek. This extra st1pu lation measure would stlll leave slgnifieant portions of the total pilrcel available for development. As il Supporting Organization to the CRCT Agreement and Strategy, TU values the SLM as a partner in the conservation and restoration of this important native trout and we ask that the BLM take a hard look at the effects of reasonably foreseeable development on CRCT before offering the entire Parcel UT-2018-8735-229 fur sale.

IV. Conclusion

Trout Unlimited supports responsible oil and gas development and believes that developing enersy resources on public lands can have import,1nt benefits both locally and nationally. Nevertheless, responsible 0 11 and gas leasing and development In sensitive areas, Including Utah's highly valued watersheds, require thoughtful consldemtion for where and how development should occur, The most current Information and circumstances m ust Inform leaslng decisions.

We have attempted to provide updated information for the BLM to consider in this protest. And when and use plans exceed their useful Me, we feel that it is equally important to take a step back and prevent the leap Into committing our public land resources to an irretrievable action, such as oil and gas leasing, without the benef't of a hard look that ncludcs app ylng an adaptive management approach and review of stipulatlon consistencies, as outlined In the new lease reform IM No. 2018-034.

We appreciate the opportunity to provide our comments In this protest and we urge the BLM to defer or withdraw those Parcels we mention, and to increase protective stipulations on the remaining Parcels we mention.

c.!az~~- cathv Purves Andy Rasmussen Foundation & Science Coordinator Utah Publlc Lands Coordinator Trout Unlimited Trout unlimited 220 North 8th Street 1558 KC Lane Lander, WY 82520 Logan. UT 84321 cpurves@tu org arasmussen@tu org