Talking Points for Comments on the Blackleaf

Below are some points that you may want to include in your written comments to the BLM on the Blackleaf Area drilling proposal. Feel free to cut and paste the direct text or use it as a template and modify it as you like. It is important that you tell the BLM why you oppose drilling on the Rocky Mountain Front, but also important that you include specific items that you want them to analyze in the Environmental Impact Statement.

A Real No Action Alternative: Demand that the EIS include a viable no-action alternative, one that evaluates and quantifies the costs for the government to trade or buyout all of the leases in the Blackleaf unit.

Air Quality: Montana’s largest Wilderness Area, the Bob Marshall Wilderness, is immediately adjacent to the Front and has been designated a Class I airshed. Ask that the BLM detail air quality impacts from particulates from construction, pollution from vehicles and generators, hydrogen sulfide releases in the natural gas, and damage to agriculture from particulates and pollution.

Sense of Place: Drilling activity undermines the unique sense of place and wilderness values and adversely impacts the viewshed for a larger area. Ask that the BLM assess these values. The Forest Service’s 1997 leasing EIS found that "sense of place" was an important value for the Front that would be impacted by drilling and could not be mitigated. This BLM EIS should also analyze what drilling would mean to this value.

Wildlife: Ask that the EIS detail the habitat fragmentation that would result from road and well pad construction and what the impacts will be to threatened and endangered species. Remember that all of the proposed drilling sites are in occupied grizzly bear habitat.

Cumulative Effects: This initial exploration proposal could easily lead to major "full field development." So the EIS needs to seriously analyze the cumulative impacts of full field development including: noise and lights from drilling and production, associated impacts of pipelines and a sweetening plant, fragmentation and impacts that extend beyond the footprint of proposed roads and drill pads.

Economic Impacts: The EIS needs to fully disclose the economic impacts from the loss of hunting and fishing opportunities, diminished wildlife viewing and tourist activities, and reduced outfitting business. Furthermore, the EIS should include a true cost-benefit accounting of what the proposed drilling would mean to the local county’s budget and to a larger area, like Great Falls, since their quality of life and economy is connected to the recreation and other values of the Front.