More Roan comments |

More Roan comments

Ninety-four percent of the natural gas in the Piceance Basin is already available from public lands open to drilling (Save Roan Plateau Fact Sheet, page 1). That leaves only 6 percent under an area that includes the Roan Plateau. Assume for the moment that the entire 6 percent is in the planning area, and that BLM figures indicate that 86 percent of the gas in the planning area is accessible without drilling on top of the plateau (SRPFS, page 1). That means less than 1 percent of the natural gas in the Piceance Basin would require drilling on top of the plateau.The BLM maintains the Transfer Act requires them to lease drilling rights on the Plateau as soon as practicable (Draft Resource Management Plan, page ES-1). Drilling on top of the plateau presents drilling challenges, including sloughing clays and water flows, that have not been overcome as of yet (DRMP, page H3). Today’s technology may require direct drilling, but tomorrow’s technology would be able to extract the remaining gas in a more practical manner if and when it is needed. The question becomes: “Is drilling over 1,000 wells in the planning area necessary or even practical at this time?”Some effects of the BLM’s preferred alternative include drilling 1,324 wells (DRMP, pages 2-10). Each well may produce up to 2,000 cubic yards of drilling mud (DRMP, pages 4-234). That is 2,648,000 cubic yards of drilling mud that may contain hazardous substances deposited on the planning area.Each well will produce condensate and water. Condensate tanks normally hold 300 barrels (DRMP, page 234). Trucks transporting that material hold between 60 and 120 barrels (DRMP, page 234). Add in the drilling rigs, materials, supplies, labor, and hazardous materials to be transported, and you have a substantial amount of trucks and traffic impacting the roads that will have to be constructed.In addition to direct impacts on the plateau, the adverse effect on hunting, scenic and recreational desirability can be severe and irreversible (DRMP, pages 234-236). Under three of the five draft BLM alternatives, 97 percent of the backcountry recreation opportunities will be eliminated (SRPFS, p.4).Hunting on the plateau is worth about $4 million dollars annually, but under BLM’s preferred alternative, 33 percent of the deer population, 5 percent of the elk and 9 percent of overall wildlife could be eliminated (DRMP, pages 4-87). The long-term negative impact of degrading the Roan will last far longer than any short-term economic benefit.In preparing the five alternatives, the BLM did not include the desires of the local population to adequately protect the Roan. BLM’s preferred alternative has all BLM lands open for oil and gas leasing (DRMP, page 10). Perhaps it isn’t too late. We can still permit extraction of the gas in a practical manner and protect the top of the Roan Plateau by prohibiting drilling there and instituting protection for that area. That is a win-win situation and one I hope you will consider.

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