4/16/2018 Request for Scoping Comments

Submission Successful Your Submission ID is: SCOP0918-1-1 13702 Names & Addresses Cathy Purves 220 North 8th Street PO Box 64 Lander, 82520, Email Address: [email protected] Day Phone: 1307-332-6700 Evening Phone: Fax Number: Other Phone: Agency: Public Web Page Organization/Group: Position: Science Coordinator Andy Rasmussen 1558 KC Lane Logan, 84321, United States Email Address: [email protected] Day Phone: 1435-760-0089 Evening Phone: Fax Number: Other Phone: Agency: Public Web Page Organization/Group: Trout Unlimited Position: Utah Sportsmen's Coordinator Comments Comment 1 ID: Comment September 2018 BLM Oil and Gas Lease Sale Title: Hello Sheri,

Please accept the following comments from Trout Unlimited on the 2018 Utah BLM oil and gas lease sale. These comments reflect all field office sales and scoping comments. We appreciate this opportunity. Please also look for a Comment: faxed copy of our comments in case this doesn't get uploaded properly. Thanks, Cathy Purves Trout Unlimited Attachment:TU-UTSept2018LeaseComments-04162018.pdf

Submission Classification Response Type: Front Office Submission Form Delivery Type: Front Office Submission Form Receipt Date: 04/16/2018 Status: ACTIVE Agreements No - Withhold personally identifying information from future publications on this project? Yes - Please include me on the mailing list for this project? Original Submission Files

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Sent via: Fax 801-539-4237 and via electronic ePlanning NEPA Project Link

April 16, 2018

Sheri Wysong Fluid Mineral Leasing Coordinator Bureau of Land Management Utah State Office 440 West 200 South, Suite 500 Salt Lake City, UT 84101

RE: Comments and scoping comments on the September 2018 Utah BLM Oil and Gas Lease Sale for the West Desert BLM District Office and the Utah State BLM Office: . Specifically regarding comments on 7 Fillmore FO Parcels for Lease; . Specifically regarding comments on 26 Salt Lake FO Parcels for Lease; . Specifically regarding scoping comments on 76 Price FO Parcels for Lease; . Specifically regarding scoping comments on 18 Suspended /Sold but Not Issued Parcels

Dear Ms. Wysong,

Please accept the following comments and scoping comments on behalf of Trout Unlimited (TU) for the September 2018 Utah oil and gas competitive lease sale. This sale covers 109 parcels identified for sale: 7 parcels in the Fillmore and 26 parcels in the Salt Lake Field Offices (West Desert District Office) and scoping on 76 parcels in the Price Field Office (Green River District Office). Scoping comments are also included for 18 leases previously sold but were either not issued or suspended due to inadequate stipulations and environmental analysis at the time of those sales.

Trout Unlimited (TU) has a broad diverse network of more than 300,000 members and supporters nationwide with a mission to protect and restore coldwater fisheries and their habitats. In Utah we have approximately 1,800 members associated with eight chapters including chapters in the areas where these parcels are located. Consistent with our mission, it is TU’s policy to encourage energy development in a way that meets the needs of people while eliminating, minimizing, or mitigating the impacts to coldwater fisheries and their watersheds. Our members enjoy fishing and hunting on these public lands in addition to participating in restoration projects to maintain and improve fisheries habitat. On behalf of our members, we offer the following comments.

Overview of Comments

We are concerned about the lack of analysis for watersheds and the associated coldwater recreation fisheries in the Fillmore EA analysis. Our largest concern is based on the use of outdated Resource Management Plans (RMP) in the Fillmore planning office to complete the analysis on the impacts of these proposed parcels. Since the issuance of the 1986 and 1987 RMPs significant research on impacts from oil and gas development have revealed the need for increased stipulations and mitigation measures at the leasing stage.

Increased riparian and stream buffers have been incorporated into newer RMPs, with 500-foot buffer stipulations being applied to perennial streams and up to one-half mile buffers applied in sensitive native trout habitat (Billings RMP). Closer to home, the Salt Lake FO EA contains strong buffer language and stipulations which are attached to lease parcels affecting perennial, spawning and intermittent streams and springs. Trout Unlimited considers 500-feet to be the minimum buffer that should be applied to surface disturbing activities associated with oil and gas development near coldwater fisheries. However, we encourage the BLM to apply stronger buffers exceeding 500-feet and generally recommend a one-quarter mile buffer where native trout habitat exists. Recent studies have shown that streams located in or near areas with high densities of oil and gas development have “consistently low discharge, extreme temperature fluctuations, elevated dissolved and suspended constituents” when compared to streams in undeveloped areas.1 Stronger buffers will help curb permanent damage before it can happen and provides a responsible energy development option.

Trout Unlimited would like the BLM to attach stronger buffer stipulations on those leases adjacent to or within stream habitat. Attaching these stipulations at the leasing stage allows for flexibility in making adjustments at the APD stage, should it be necessary. But if adequate protection is not attached at the leasing stage, it is almost impossible to increase protection measures after the lease is sold. The sale of a lease parcel is an irretrievable commitment of resources and we believe placing stipulations up front at the lease sale remains one of the strongest opportunities for responsible energy development.

In addition to a smart conservation investment, strong buffers are also a smart economic investment for Utah. Fishing and hunting are big economic drivers in this state. Placing stronger protective stipulations on leases in sensitive fish and wildlife habitat help maintain continued interest by hunters, anglers, recreationists and tourists in areas where drilling is expected to occur. Not many people wish to fish, hunt or recreate next to a drilling rig. Finally, protective buffers also help keep the water cleaner, since riparian areas can aid in catching accidental spills and associated contaminants that accumulate on the surface of a drill pad and associated infrastructure.

Of additional concern to TU are parcels located within designated Blue Ribbon Fisheries. Utah established a Blue Ribbon Fisheries Advisory Council in 2000 that allocates monies to the protection and enhancement of Utah’s fisheries, recognizing that “…protecting these Utah waters and their watersheds that provide Blue Ribbon quality public angling experiences for the

1 Girard, Carlin E., The Effects of Oil and Natural Gas Development on Water Quality, Aquatic Habitat, and Native Fish in Streams along the Wyoming Range, at p. 27, M.S., Department of Zoology and Physiology, August 2015).

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purpose of preserving and enhancing these economically valuable natural resources” (mission statement of the Blue Ribbon Advisory Council). This Council developed specific criteria for a river or stream to be designated a Blue Ribbon Fishery2 and water quality and quantity is the primary criteria.

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 and abundant 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 fisheries3 concluding 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). Selling oil and gas lease parcels that abut or exist within Blue Ribbon watersheds threatens water quality and thus has the potential to undermine economic contributions to local businesses and enterprises (such as outfitters, guides, hospitality, and food service businesses).

If increased stipulations cannot be applied that protect fish and wildlife habitat, based on outdated RMPs, TU requests that the leases in question be withdrawn until updated RMPs are in place. For those suspended leases, it does not appear that any increased environmental analysis has occurred that provides increased protection for those parcels and thus, until such analysis is complete, these parcels should remain suspended.

Specific EA Comments

A. Fillmore EA – 4 Parcels of Concern include Parcels UT-0918-8715-020, 8716-021, 8717-022, and 8719-024.

The Fillmore RMP was implemented in 1986 and 1987 and contains inadequate environmental analysis that is reflective of today’s oil and gas drilling issues. The EA determined incorrectly that wildlife and fish populations would not be significantly impacted by any of the alternatives. Since there are only two alternatives—one which leasing would not take place—we believe the EA does not provide adequate consideration of alternatives and therefore provides much less ability to make the claim that no impacts would occur. Had updated information on oil and gas activity impacts been included in the EA, the BLM would have a more thorough understanding in applying stronger stipulations to protect this planning area’s resources and been less likely to dismiss from further analysis impacts to fish and wildlife populations.

All four parcels we mention above are located adjacent to or through coldwater streams containing recreation fisheries and native cutthroat trout expansion habitat (see Figure 1). The EA identifies the ID Team but it appears no fisheries biologists were consulted. In addition to providing a wild trout fishing experience along the Sevier River and within Yuba Lake State Park via Sevier Bridge Reservoir, Bonneville cutthroat trout (BCT) habitat exists in both the Sevier

2 https://wildlife.utah.gov/blueribbon/pdf/overview.pdf 3 Man-Keun Kim and Jakus, Paul M. 2013. The Economic Contribution and Benefits of Utah’s Blue Ribbon Fisheries. Department of Applied Economics, Utah State University, UMC 4835, Logan, Utah. Final report for Center for Society, Economy, and the Environment. CSEE Research Report #4. February 27, 2013.

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River and Chicken Creek. Bonneville cutthroat trout is Utah’s native cutthroat trout and is a BLM special status species and Sensitive Species.

Figure 1: Bonneville cutthroat trout habitat located within September 2018 lease parcel offerings.

The BLM, the state of Utah, the U.S. Forest Service, and the U.S. Fish and Wildlife Service, among others, are signatories and contributors to the Bonneville Cutthroat Conservation

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Agreement4 and the Bonneville Cutthroat Trout Conservation Strategy5 which contains site- specific details of conservation goals and actions. The parcels for this sale are located in the Southern Bonneville GMU (Geographic Management Unit). Conservation objectives for this species include restoring and maintaining at least 53 conservation populations throughout 294 streams miles within the five GMUs in the region, and eliminate or minimize threats to BCT and its habitat.6 These conservation measures were enacted to prevent BCT from being listed as a sensitive species by state and federal agencies and thus, TU has concerns when oil and gas lease parcels are being offered in their habitat.

The EA should include further analysis, referencing the Conservation Agreement and Strategy, consult with the Fish Biologist, and prepare stipulations that keep well pads, roads, and drilling rigs a minimum of 500 feet from these water sources. In a 2015 Utah survey along stretches of the East Fork of the Sevier River, biologists’ data indicates that the potential for further BCT expansion throughout the East Fork Sevier River drainage is significant and represents a boon for BCT conservation.7 This recommendation can be extrapolated to include other expansion areas for BCT, such as the Sevier River itself and Chicken Creek. Maintaining quality habitat conditions and continuation of habitat improvement projects reflects the ability to keep BCT populations at a stronghold that steadily increases over time. In fact, the results of this survey indicate to the biologists that with the help of additional restoration efforts, the potential to make the East Fork Sevier drainage one of the significant strongholds for BCT in the southern Bonneville Basin exists during the next decade. The same can be applied to the Sevier River mainstem.

Trout Unlimited appreciates those stipulations that were attached to these leases Including the consideration of water quality issues for drinking supply, watershed protection for Sevier River, Chicken Creek and tributary drainages, and surface water body quality. Our concern is that they are not strong enough and thus, as mentioned earlier, we ask for an increase in the buffer footage.

Additionally, in contrast to the detailed and scientific treatment climate change received in the Salt Lake FO EA, this EA received sparse discussion and concluded (as this FO has in past lease sale EAs): “The inconsistency in results of scientific models used to predict climate change at the global scale, coupled with the lack of scientific models designed to predict climate change on regional or local scales, limits the ability to quantify potential future impacts of decisions made at this level”. Inserting this type of reasoning is inexcusable at this time—there exists enough research (and we see it used in the Salt Lake FO EA) that we encourage the BLM to improve the

4 Bonneville Cutthroat Trout State of Utah Conservation Team. 2008. Conservation agreement for Bonneville cutthroat trout (Oncorhynchus clarki utah) in the State of Utah. Utah Division of Wildlife Resources, Salt Lake City, Utah. 5 Utah Division of Wildlife Resources. 2004. Bonneville Cutthroat Trout (Oncorhynchus clarki utah) Conservation Agreement and Strategy in the State of Utah Post Implementations Assessment. Publication Number 04-31. Utah Division of Wildlife Resources, 1594 W. North Temple, Salt Lake City, Utah. 72 pp. 6 Utah Division of Wildlife Resources. February 8, 2016: Bonneville cutthroat trout webpage. https://wildlife.utah.gov/get-permit/check-your-progress/135-learn/cutthroat-trout.html and https://wildlife.utah.gov/cutthroat/BCT/index.html. Webpage accessed February 7, 2017. 7 Michael J. Hadley and Golden, Michael E. 2016. 2015 Survey of Bonneville Cutthroat Trout in the East Fork Sevier River Drainage, Utah. Publication Number 16-02. Utah Department of Natural Resources, Division of Wildlife Resources, Salt Lake City, UT. February 2016.

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discussion and increase the analysis on climate change. The EA appears to use the air quality discussion as the foundation for its climate change discussion. We appreciate the attention to direct and indirection greenhouse gas emissions the BLM has offered in the EA but it fails to inform any analysis of climate change and its impacts on water resources. The statement made that the BLM has determined that this analysis “adequately addresses the cumulative impacts for climate change” is dated language. There is plenty of new research that even BLM has used in addressing impacts to watersheds and fisheries.

Utah is a dry state with shrinking water supplies (see EPA website https://www.epa.gov/climate- impacts/climate-impacts-water-resources). Influenced by the Colorado River system, a major water supply for the southwest, climate activities affect and influences ecosystems, including those within the Color Country district office where these parcels are located. Studies show there is a predicted 47 percent estimated habitat loss by 2080 to many highly-valued trout and salmon species.8 U.S. Fish and Wildlife Service discuss ways water resource management can occur in a changing climate and how this will affect fish, wildlife and people in Utah.9 In addition, a 2016 article by EPA10 predicts what Utah will experience on its environment from the impacts of a changing climate, including less snowfall—which start high in the mountains and replenishes Utah’s rivers and streams—drier soils, parched landscapes and higher temperatures. All of which means more wildfires, changes in agriculture and impacts to Utah’s already burdened air quality. The EA needs to include a more robust discussion of climate change impacts.

Therefore, we recommend the following: 1. The UT-S-150 stipulation of No Surface Occupancy that is recommended is outdated, referencing back to the old RMP, and is only 100 feet. We recommend a minimum of 500-foot stipulation for fisheries and stream protection; increase buffers for all other watershed protection measures. 2. Withdraw Parcel 8719-024 that is located between Sevier Bridge Reservoir and Sevier River from this sale. It is too risky to have oil and gas drilling activities, all the roads and infrastructure, pollution and potential contamination located within this popular public recreation area. 3. Develop a stronger climate change discussion and analysis that reflects today’s science. 4. Increase responsible energy development mitigation measures that take into account the fish and wildlife activity located within this landscape.

B. Salt Lake FO EA – 16 Parcels of Concern include Parcels UT-0918-8698-003, 8699-004, 8701- 006, 8702-007, 8704-009, 8708-013, 8710-015, 8711-016, 8712-017, 8722-027, 8727-032, 8728- 033, 8729-034, 8730-035, 8731-036, 8732-037.

8 USGCRP (2009). Global Climate Change Impacts in the United States. “Climate Change Impacts by Sectors: Ecosystems.” Karl, T.R., J.M. Melillo, and T.C. Peterson (eds.). United States Global Change Research Program. Cambridge University Press, New York, NY, USA 9 USFWS. 2011. “Open Spaces: A Talk on the Wild Side. Utah: Managing Water Resources for Fish, Wildlife and People.” June 6, 2011. https://www.fws.gov/news/blog/index.cfm/2011/6/6/Utah-Managing-Water-Resources-for- Fish-Wildlife-and-People 10 United State Environmental Protection Agency. August 2016. “What Climate Change Means for Utah”. EPA publication 430-F-16-046.

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We applaud the BLM’s Salt Lake Field Office EA. It is one of the more comprehensive and detailed EAs we have reviewed in Utah and recommend it be used as an example by other FO’s.

This EA acknowledges the presence of native cutthroat trout habitat for both BCT and Colorado River cutthroat (CRCT), their Sensitive Species status with BLM, adds seasonal considerations for spawning activity, and provides strong stream and riparian stipulations of 600 to 1,200-foot buffer applications. In addition, the analysis and mitigation measures provide adequate protection and reflect some thoughtful insight. We sincerely appreciate the work in this EA.

Figure 2: Lease Parcel locations & Bonneville cutthroat trout habitat

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We appreciate the mention of the springs in this planning area. We noted the dominance of springs and mapped them to reference their positions against the lease parcels. As seen on our Bear River map (Figure 2), there are an unusually high number of springs, which no doubt account for the healthy fisheries and BCT habitat stability, but also present concerns for us due to their vulnerability from drilling activities. The location of many of the lease parcels are in direct conflict with the location of the springs in addition to other parcels whose proximity happens to be very close to other springs. Increasing the buffers around springs may not be successful in preventing any subsurface contamination issues associated with the myriad of drilling activities and infrastructure that would occur should a well pad and roads be developed here. Since these springs have a high contributing value to the watershed, we recommend the withdrawal of parcels located in areas with springs and the implementation of strong buffers for adjacent parcels within spring proximity.

Figure 3: Parcel locations in Bonneville cutthroat and coldwater fish habitat in the Price River drainage.

Parcels are also located within or adjacent to drainages containing perennial streams and coldwater fish. As viewed in Figure 2, Woodruff Creek is an important native BCT stream and wild trout stream that flows into the Bear River drainage, and eventually into Woodruff Narrows and Reservoir, a very popular recreation area for Utah, Wyoming and other recreation

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enthusiasts. It also remains a high value area for native trout restoration. For those parcels in the Price River drainage (Figure 3), there is opportunity for considerable impacts to numerous drainages and the Price River itself, should contamination occur. Though our comments are specifically focused on parcels located on BLM lands, our concerns for any parcels located in native trout and wild trout habitat remains strong.

The Utah Department of Wildlife Resources has identified both the Bear River and Price River drainage geography as high native trout value habitat for BCT. As mentioned earlier, in order to meet the objectives of the BCT Conservation Agreement, we urge the BLM to implement strong protection measures for these areas. In addition, parcels along the Price River are straddling a designated Utah Blue Ribbon fishery and nearly every waterway in the area (White River, Beaver Creek and others) are high potential for native trout restoration.

Several of the parcels are located upland from direct stream contact and for these parcels our concerns are targeted at any erosion and sedimentation events, contamination events, or accidents that would compromise the integrity of native and wild trout habitat, and eventually impact the recreational value of these geographic areas.

Specifically, we request the following:

1. We recommend the withdrawal of parcels or portions of parcels UT-0918-8712-017, 8710-015, 8702-007, and 8704-009 within the Bear River watershed and parcel UT- 0918-8730-035 in the Price River watershed (and which Kuyne Reservoir is located). 2. For those parcels that border areas with springs, we also recommend implementation of the largest buffer restrictions (1,200 feet). 3. For those parcels bordering a Utah Blue Ribbon fishery we recommend implementing the Utah Sensitive Species Stipulation UT-LN-49 and NSO or withdrawal. This area is a high value recreation destination for anglers throughout Utah and the region and any threats to this river system are unacceptable. 4. For the numerous perennial streams that have parcels located within them, we recommend the largest buffer stipulation (1,200 feet) to protect both the direct stream resource but also any downstream effects from drilling activities. This would include Woodruff Creek (Parcels UT-0918-8708-013 and 8699-004), Home Canyon (Parcel UT- 0918-8698-003), Saleratus Creek (Parcel UT-0918-8701-006) in the Bear River drainage; Bear Creek and its spring (Parcel UT-0918-8727-032), Right Fork Kuyne Creek and West Fork Willow Creek (Parcel UT-0918-8729-034 and 8731-036), Horse Creek (Parcel UT- 0918-8731-036 and 8732-037), Price River (both Parcels UT-0918-8732-037), and unnamed drainage where Parcels UT-0918-8722-027 and 8728-033 are located, all in the Price River drainage. 5. Many of the Bear River parcels are located on the Utah-Wyoming border and Wyoming Game and Fish Department should be made aware of this proposed sale and parcel locations, as per the IM2018-034 discussion on BLM field offices and edge effects. We believe this to be a common courtesy among agencies based on a geographic-wide impact to a special status and Sensitive Species recognition.

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C. Price Field Office Scoping: Concerns for Lease Parcels UT-0918-8754-038, 8755-039, 8756- 040, 8757-041, 8758-042, 8759-043, 8760-044, 8761-045, 8762-046, 8763-047, 8764-049, 8765- 50, 8766-051, 8767-052, 8768-053, 8769-054, 8770-055, 8771-056, 8772-057, 8773-058, 8774- 059, 8775-060, 8776-061, 8777-062, 8778-063, 8779-064, 8780-065, 8781-066, 8782-067, 8783- 068, 8784-069, 8785-070, 8786-071, 8787-072, 8788-073, 8789-074, 8790-075, 8791-076, 8792- 077, 8793-078, 8794-079, 8795-080, 8796-081, 8797-082, 8798-083, 8799-084, 8800-085, 8801- 086, 8803-087, 8804-088, 8805-089, 8806-090, 8807-091, 8808-092, 8809-093, 8810-094, 8811- 095, 8812-096, 8813-097, 8814-098, 8815-099, 8816-100, 8817-101, 8818-102, 8819-103, 8820- 104, 8821-105, 8824-106, 8825-107, 8826-108, 8827-109, 8828-110, 8829-111, 8830-112, and 8969-113.

The Price BLM Field Office 2008 RMP includes opportunities for implementing stipulations that address many of the sensitive wildlife and plant species but fails to adequately provide analysis on the watershed and sensitive native trout habitat for existing CRCT. Colorado River cutthroat trout are identified in the Utah BLM Sensitive Species List (November 2017).11 As illustrated in Figure 3, most of the parcels except UT-0918-8824-106 are located in high value native CRCT habitat and we recommend that the strongest protection stipulations be applied on these parcels. For many of the drainages within the San Rafael River system there is potential for native trout restoration. We would like the EA to include a strong analysis that considers the CRCT Conservation Agreement12 and BLM’s obligations and commitments to future restoration opportunities in this geographic region.

For Parcel 8824-106, we are concerned about the parcel’s proximity to the Green River and request the BLM apply the strongest stipulation measures that afford protection from impacts of drilling activities. The current stipulation on this parcel does not mention any watershed or perennial river stipulations.

The Green River is a popular fishery and recreation destination for people from across the nation. It also provides a significant economic income to a variety of business and state agencies. Any type of oil and gas activity can directly and indirectly impact the landscape and fishery. Recent studies have indicated the long-term impacts from oil and gas activities on CRCT habitat and the lingering effects of oil and gas development on cutthroat trout populations.13 Impacts from oil and gas development to native CRCT streams in the Wyoming Range in Bridger- Teton National Forest established a direct connectivity between poor water quality, location of wells, and low populations of CRCT. Streams in the disturbed area of Dry Piney Creek, where well pad density was 3.4 wells per square mile and where an oil spill had occurred in 2012 (affecting fish populations), showed poor habitat conditions, decreased willow cover, increased stream incision and greater prevalence of bare dirt. In Wyoming, a study on the eastern flank of the Bridger-Teton National Forest in the Wyoming Range revealed significant persistent impacts

11 State of Utah Department of Natural Resources, Division of Wildlife Resources. November 1, 2017. Accessed website January 18, 2018. https://dwrcdc.nr.utah.gov/ucdc/viewreports/SS_List.pdf. 12 Hirsch, C.L., M.R. Dare, and S.E. Albeke. 2013. Range-wide status of Colorado River cutthroat trout (Oncorhynchus clarkii pleuriticus): 2010. Colorado River Cutthroat Trout Conservation Team Report. Colorado Parks and Wildlife, Fort Collins. 13 Girard, Carlin E. 2015. The Effects of Oil and Natural Gas Development on Water Quality, Aquatic Habitat, and Native Fish in Streams along the Wyoming Range: A thesis submitted to the University of Wyoming. Zoology and Physiology. Laramie. August 2015.

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on CRCT macroinvertebrate populations, so important to trout survival, were low, leading to the disappearance of native trout along Dry Piney Creek. We therefore recommend the BLM include stronger buffer stipulations along the Green River to protect the ecology of this important habitat.

Figure 4:Parcel locations in the San Rafael River watershed and potential surface and subsurface problems.

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The EA should contain discussion on the impacts to important surface and groundwater resources and the important springs which occur in this area. The strongest set of buffers should be attached to any spring and reference to the Salt Lake FO buffer stipulations on springs would be advisable (1,200-foot buffer). In addition to the obvious degradation issues from surface disturbances, other activities that have the potential to impact water resources include non-point source pollution, point source pollution, water withdrawals and hydraulic fracturing.

Water quantity issues that should be addressed include how the extraction of large amounts of water required to drill and fracture a well will affect river ecology, other federal land users, adjacent land users, and municipalities. The EA should also discuss any water use in oil and gas drilling activities; drilling activities can require significant amounts of water to drill just one well. Estimates range from one million gallons of water for traditional or conventional gas wells up to 35 million gallons of water per well for more advanced unconventional wells using hydraulic fracturing.14 Other estimates from the energy industry have estimated this use from 2 to 7 million gallons of water needed per fracturing event and one well can be fractured several times over its lifespan.15 The amount of water hauled in tanker trucks and the number of tanker trucks it takes to deliver a minimum of 1 million gallons of water to a drill site should also be a consideration in the analysis.

In addition to water quantity, contamination to important streams, creeks, springs, and groundwater systems can occur due to accidental spills if mitigation measures are not properly planned and implemented. Documented incidents and recent research on the impacts of oil and gas activities to native trout suggest that these activities pose risks to trout populations.16 The EA would benefit from a thorough environmental review of development that could occur on the proposed leases and how mitigation measures will eliminate or minimize risks to both water quality and quantity.

D. Utah State BLM Office Parcel Review & EA Scoping: Concerns for Suspended and Sold-But- Not-Issued Parcels

We appreciate the opportunity to offer scoping comments on those leases sold prior to the 2008 Price FO RMP. As viewed in Figure 4, these parcels abut the parcels offered under the Price FO September lease sale and should receive the same stipulations and environmental analysis we’ve requested above under Section C. Should the issues which suspended these 18 parcels prior to 2008 still exist under the current RMP for the Price River FO, then we recommend all the parcels for this field office be suspended until these issues can be resolved. It appears this entire are is a highly sensitive geography based on soil conditions, unique landscape characteristics, numerous special status plant and animal species, and the presence of many BLM Wilderness Study Areas. This area is also a popular tourist and recreation location and care should be taken to consider this during this environmental analysis.

14 FracFocus.org 15 Soeder, D.J., et al. 2009. “Water resources and natural gas production from the Marcellus Shale”. U.S. Dept. of the Interior, US Geological Survey, Reston, Virginia.; Kargbo, D.M., et al. 2010. “Natural gas plays in the Marcellus Shale: challenges and potential opportunities. Environmental Science & Technology 44(15):5679-5684. 16 Weltman-Fahs, Maya, et al. 2013. “Hydraulic Fracturing and Brook Trout Habitat in the Marcellus Shale Region: Potential Impacts and Research Needs.” Fisheries. Vol 38 No 1. January 2013.;

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Parcels closest to the San Rafael River (UTU-085328 and UTU085329) should receive strong buffer protections due to the significance of perennial and intermittent stream drainages in the area and the locations of springs, as depicted in Figure 5. Sensitive soils and impacts from surface drilling activities can negatively affect this watershed.

Figure 5: Suspended & Sold but Not Issued Parcel locations and watershed issues in San Rafael River basin

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Rather than repeat the same analysis considerations for the 76 parcels we mentioned under Section C., we reference all those same environmental considerations and ask they be applied for these 18 parcels.

Conclusion

We thank the BLM for this opportunity to comment on this dual lease sale opportunity and appreciate the help the Utah State Office provided in guiding us to a better understanding of this lease sale process.

We also appreciate the number of BLM stipulations and lease notices identified in the EAs and the Price FO Appendix A. However, our larger concern is that proper and effective environmental analysis be included in all the EAs, with preference to referencing how the Salt Lake FO EA was completed. The Fillmore EA continues to rely on older and dated references from previously outdated documents. New studies are available and they offer significant information for helping agencies work around the impacts of oil and gas development. We respectfully request that the BLM consider what we have offered in this set of comments.

Sincerely,

Cathy Purves Andy Rasmussen Foundation and Science Coordinator Utah Sportsmen’s Coordinator Trout Unlimited Trout Unlimited 220 North 8th Street 1558 KC Lane Lander, Wyoming 82520 Logan, Utah 84321 [email protected] [email protected] 307-332-6700 435-760-0089

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