Forest Service Preferred Alternative

The San Juan NF's preferred alternative (1A) approves drilling 79 well pads and 36 miles of roads through the HD Mountains Roadless Area. It waives existing environmental protections for No Surface Occupancy leases and the Fruitland Formation outcrop. The Forest Service's plan is a reckless gamble that endangers people's lives and property, devastates forests and watersheds, and intentionally hides critical information from the public.

Endangers People's Lives and Property

Coalbed methane drilling within the HD Mountains and on the Fruitland Formation outcrop will destroy the domestic wells of numerous local residents and dry up area springs because of vast water table drawdowns, and even endanger the lives of some residents because of increased methane seepage infiltrating area homes. The Forest Service plan irresponsibly gambles with people's homes, property and lives.

Devastates Forests and Watersheds

Coalbed methane drilling will create widespread landslides and dump vast quantities of sediment into area streams. CBM development violates existing Forest Plan standards for water quality and will devastate entire watersheds including Ignacio Creek. The Forest Service approves 15 miles of roads and 24 well pads on areas identified as high-hazards for landslides.

Hides Critical Information from the Public

The DEIS displays a pattern of deceit and deception in selective omitting critical environmental information. The analysis of the national Roadless Area Conservation rule is intentionally misleading, and fundamentally incorrect (it claims federal courts have overturned the roadless area rule when in fact two federal courts have reach opposite conclusions about its validity).

The DEIS omits any mention of the ongoing, congressionally-mandated, wilderness suitability review for the HD Mountains. The San Juan NF, in response to this congressional direction, is currently analyzing wilderness suitability for the HD Mts and other roadless areas in the ongoing San Juan Forest Plan revision. Unfortunately, the DEIS hides the fact that a wilderness suitability analysis even exists.

The DEIS intentionally conceals from public view the Forest Service's own recommendations for Research Natural Area designation of Ignacio Creek, recommendations that resulted from agency-sponsored public working groups meeting over the course of two years. The DEIS also hides from public scrutiny similar recommendations for an expanded Spring Creek Archeological District, also the result of agency-sponsored public working groups.

The DEIS covers up the existence of several thousand acres of No Surface Occupancy leases on the east side of the HD Mountains. Instead, the Forest Service plans to drill a dozen wells and build a dozen miles of road on lands currently off-limits to surface occupancy. The Forest Service compounds this secrecy by making false public claims that its "hands are tied" because existing leases require drilling.

The DEIS never addresses other substantial issues of great importance to this project, such as the option of buying back leases to forestall disastrous development.

The DEIS also fails to reveal the consequences of future downspacing, moving from 320 acres to 160 acres per wellsite, or from 160 acres to 80 acres.

Air Pollution

Air quality in both Mesa Verde National Park and the Weminuche Wilderness Area will be substantially impacted by cumulative oil and gas development across the San Juan Basin, including Farmington, Southern Ute Reservation, and HD Mountains. Even with cleaner wellhead engines (NOx emission rate of 2.0 g/HP-hr) than are currently required, significant adverse impacts will occur at Mesa Verde 3 to 10 days per year and at the Weminuche 2 to 12 days per year. Note that these cleaner engines are not presently required either in Farmington or Colorado.

Water -- wells and springs

CBM development will result in large drawdowns of shallow groundwater along Fruitland Formation outcrop and will affect up to 20 domestic wells. CBM development will also dry up springs and seeps along the outcrop.

Roadless Area

The preferred alternative rips the heart out of the HD Mountains Roadless Area by constructing at least 36 miles of roads and drilling 79 wells in the most environmentally sensitive portions of the area. One major gas road will cut down the spine of the HDs and cross numerous high-hazard landslide areas. Another major gas road invades the bottom of Ignacio Creek and ravishes all of the old-growth ponderosa stands along the valley. One-half of the roadless area will be entirely obliterated by CBM development, leaving two isolated distinct pieces.

The DEIS cleverly insinuates that the national Roadless Area Conservation Rule promulgated under the Clinton Administration is no longer in effect, and consequently the Forest Service plans to approve 3 miles of road, a compressor station, and at least one gas well on lands presently leased with stipulations that prohibit surface occupancy precisely to protect their roadless characteristics. By omitting key facts, the DEIS leaves readers with the erroneous conclusion that the roadless rule has been enjoined by a federal court ruling in Wyoming. The DEIS fails to mention that a federal appeals court has upheld the roadless rule in an Idaho case, and that there is no clear direction on the status of the roadless rule. Consequently, the preferred alternative proposes activities that are illegal under current law.

The DEIS omits any mention of the ongoing, congressionally-mandated, wilderness suitability review for the HD Mountains. Instead, the DEIS erroneously implies that Congress considered and rejected the HDs for wilderness designation. The 1980 Colorado Wilderness Act did not include the HD Mountains as wilderness, but that Congress also directed the Forest Service to again analyze wilderness suitability when Forest Plans are revised. The San Juan NF, in response to this congressional direction, is currently analyzing wilderness suitability for the HD Mts and other roadless areas in the ongoing Forest Plan revision. Unfortunately, the DEIS hides the fact that a wilderness suitability analysis even exists.

Ignacio Creek

The proposed Ignacio Creek Research Natural Area will be obliterated. Originally identified because of its pristine, unroaded, weed-free, old-growth ecosystem, CBM development will utterly destroy all aspects of the proposed RNA. Ignacio Creek was identified as a result of a Forest Service contract with Colorado Natural Areas Program to inventory the entire national forest for RNA candidates. Ignacio Creek's significance as a potential RNA was confirmed with recommendations from a public working group organized by the Forest Service that met over the course of two years. Despite this history, the DEIS makes absolutely no mention of the proposed Research Natural Area, nor does it describe impacts to RNA qualities.

Old-growth Ponderosa Pine

Roads and wellpads will penetrate nearly every single stand of old-growth ponderosa pine in the HD Mountains. 87% of old-growth stands will be impacted through ecosystem fragmentation, and changing physical and biological conditions. The DEIS misleads the public by claiming only 36 acres, or 5%, of old-growth will be impacted. Old-growth ponderosa pine is the rarest forest type in the San Juans and this project will wipe out most of the remaining stands in a large swath of the national forest.

Archeological Resources

The DEIS fails to incorporate comments provided by the Hopi Tribe and demonstrates a minuscule effort at consultation with the numerous affected tribes. The DEIS does not mention several proposed extensions of the existing Spring Creek Archeological District listed in the National Register of Historic Places. Extensions to include Bull Canyon and Armstrong Canyon were identified and recommended by Forest Service public working groups that met over the course of two years during initiation of the Forest Plan.

Methane Seeps

The DEIS correctly notes that methane seepage will be seriously aggravated by additional CBM drilling. At least two homes along Fossett Gulch Road could be made uninhabitable because of methane seepage, exposing residents to safety risks. The amount of vegetation killed by methane seeps will double from 340 acres to 640 acres. Hydrogen sulfide seeps are expected to increase in the project area. Given the pattern of other information hidden from public scrutiny, it seems quite likely that impacts will be dramatically worse. In similar cases of methane seepage in the past, industry shirked any responsibility and forced homeowners to sue for damages. Who will pay for losses this time?

Accelerated methane seepage will result in loss of 59 billion cubic feet of gas over the life of the project. This methane is vented to the atmosphere where it contributes to global warming. By comparison, the HDs only contain an estimated 110 billion cubic feet of gas, so half as much gas will be lost to venting as is pumped into pipelines.

Wildlife

The DEIS intentionally obscures the lack of wildlife population data for the HD Mountains. Black bears and wild turkeys were eliminated from consideration as indicator species in the HDs simply because the Forest Service lacks data on their population levels, and realizes this is a significant legal shortcoming. For example, the EIS prepared for the adjacent Missionary Ridge timber sale project noted turkeys were an ideal indicator species because they possessed "limited habitat on the forest that will readily monitor change." In the HDs DEIS, turkeys are dismissed because they are influenced by many factors and apparently will not readily monitor change. How can the Forest Service reach opposite conclusions for two adjacent projects?

Contrary to regulations, the Forest Service lacks population data for most of the wildlife species chosen as indicators for the HD Mountains, including Abert's squirrel, green-tailed towhee, and mountain bluebird. The Forest Service chose brown trout as an indicator of riparian habitat when it does not even exist throughout most, if not all, of the HD Mountains.

Black bears will be most dramatically impacted by CBM drilling because of the extensive disruption of gambel oak habitat. The HD Mountains provide the largest amount of fall bear habitat on the San Juan National Forest. Despite the obvious direct impact to bears by this project, the Forest Service refused to use bears as a wildlife indicator as required by regulations.

The wildlife analysis used an old set of sensitive species instead of the current regional list of sensitive species.

Capacity of Industry to Undertake This Project

According to information supplied by industry for the DEIS, the companies proposing to drill in the heart of the HD Mountains and on the Outcrop are undercapitalized. For example, Petrox objects to horizontal drilling because it is more expensive and thus might jeopardize the company's ability to obtain bank financing for drilling. Elm Ridge claims it should be able to experiment with fracture stimulation technology in the HDs until the technology is "either successful or fails."

Drilling in the HDs will be the most expensive, technically complex, and challenging location anywhere in the San Juan Basin. The Forest Service should not grant undercapitalized, cut-rate companies looking to experiment with new technology in a location as difficult and sensitive as the HDs.