Sample letter to the BLM on Blackleaf Scoping

Dear Montana BLM:


Please consider the following comments as you prepare the environmental impact statement (EIS) on natural gas drilling proposals for the Blackleaf area along the Rocky Mountain Front.
Americans have long known the natural and biological values of the Front and have supported its protection. It is therefore crucial that you include in the EIS a legitimate No Action/No Drilling alternative that quantifies, among other things, the costs the federal government might incur to trade or buy out all the leases in the Blackleaf unit. Given that both Montana Senators have stated that they could support the buy out or trade out of Front leases (and one Senator has introduced related legislation), the BLM’s EIS must have an in depth buy out/trade out component to it. Anything short of that will be a paper exercise designed only to justify a foregone drilling decision.

Because of the Blackleaf area’s proximity to the Bob Marshall Wilderness Area, Montana’s largest and a designated Class I airshed, air quality concerns loom large. Please detail all air quality impacts from particulates from construction, pollution from vehicles and generators, hydrogen sulfide releases in natural gas and damage to agriculture from particulates and pollution.
Drilling activity undermines a unique sense of place and wilderness values. It can adversely impact the viewshed for a much larger area than simply the project sites. Please ensure that the EIS assesses those values and likely impacts. When it wrote a similar document in 1997, the U.S. Forest Service found that "sense of place" is an important value for the Front, one that drilling would affect in ways that cannot be mitigated. The BLM must also analyze the impact of drilling on this value.

The wildlife values of the Front are matchless. It is essential that the EIS detail the habitat fragmentation that will follow road and well-pad construction and what such fragmentation will mean to sensitive species. The document must also keep in the forefront of its analysis the fact that all the proposed drilling would occur in occupied grizzly habitat.

The initial exploration proposal could easily lead to major, full-field development. The EIS must fully assess the cumulative impacts of development on that scale – meaning beyond the eight wells contemplated in this EIS. These include noise and light pollution, associated impacts from pipelines and a sweetening plant, and fragmentation and other impacts that could extend well beyond the actual disturbed area of proposed drill-pads and roads. It would be disingenuous and misleading to ignore these impacts in the EIS.

Finally, the EIS needs to fully disclose the economic damage that could result from a loss of hunting, fishing and wildlife-viewing opportunities, diminished outfitter business and a general decline in area tourism. And the EIS should include a thorough and accurate cost-benefit accounting of what the proposed drilling could mean to the local county’s budget and to a larger geographic area that includes Great Falls and perhaps other communities whose economies are linked to the natural, scenic and recreational values of the Front as they exist today.

Thank you for considering my comments.

Sincerely,
(Your name and address)