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, Wyoming 82520, United States Email Address: [email protected] Day Phone: 1307-332-6700 Evening Phone: Fax Number: Other Phone: Agency: Public Web Page Organization/Group: Trout Unlimited Position: Science Coordinator Andy Rasmussen 1558 KC Lane Logan, Utah 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 1/1 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). TROUT UNLIMITED COMMENTS: UTAH SEPTEMBER 2018 LEASE SALE 2 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