FRERC Responds to USFS Invitation to Comment on PSICC Forest Planning

June 29, 2013

PSICC Oil and Gas Scoping Comments
PSICC Supervisor’s Office
2840 Kachina Dr
Pueblo, CO 81008

ATTN: John Dow, PSICC Forest Planner Transmitted electronically


RE: The Pike and San Isabel National Forests and Cimarron and Comanche National Grasslands (PSICC) solicitation for comments on the PSICC Oil and Gas Leasing Availability Analysis Environmental Impact Statement (EIS)


Dear Mr. Dow,

We respectfully submit these public scoping comments on the proposed PSICC Oil and Gas Leasing Availability Analysis on behalf of the Front Range Environmental Resource Coalition (FRERC). FRERC is a not-for-profit organization with approximately 350 members who are residents of Monument and Palmer Lake, Colorado, and whose goal is to protect the quality of air, water, and other natural resources of Northern El Paso County, Colorado while preserving the natural settings and recreational amenities of the region.

Our particular interest in commenting is that as residents living on the eastern front adjacent to Mt. Herman and Mt. Raspberry, we are in an area of continuous high winds and water run-off and have been undergoing an extended period of extreme drought. Our homes are near the fault which lies beneath the foot of these mountains which would likely make any drilling extremely dangerous as any movement of the earth mass along that fault would certainly carry sufficient force to shear all protective containment devices such as cement or steel casing of exploratory or production drill holes and oil and gas recovery piping. Any movement along the fault, which curves westward under the National Forest, would very likely result in casing and piping breakage leading to uncontrolled spillage, possibly into the aquifer systems which lie adjacent to the fault. Since the USFS itself speaks of this being the “3rd set of Rocky Mountains”, as erosion followed by massive land movements have resulted in the protrusion of the land upward many thousand of feet, this is a very real possibility—and impossible to determine if, and just when it may occur. But, as you indicate, it has happened three times in the past and massive earth movement is impossible to predict.

We support your mandate to thoroughly address the public’s interests in offering alternative “best-case” scenarios with specific mitigation actions to minimize impacts and avoid unreasonable or unnecessary damage to the water, ecology, wildlife or cultural resources in the PSICC. We believe that any baseline studies that you can do to inventory and protect the water, ecology, wildlife or cultural resources of the PSICC would be prudent. In particular, we think that inclusion of the following tasks would inform the processes of planning impact mitigation, supporting the accomplishment of the goals and mission of the USFS, and protecting the species and ecosystems that make the PSICC a precious natural resource locally, and for the enjoyment of national visitors:

  • Identification and protection of rare, threatened and endangered botanical and wildlife species and ecological systems.Of particular interest to us in the northern El Paso county are the Black-footed Ferret, the Peregrine Falcon, the Uncompahgre Fritillary Butterfly, and the Preble’s Meadow Jumping Mouse. We would like to see protection of these endangered species specifically addressed in the EIS.
  • Identification and mitigation of impacts to roads, traffic, and industrial activities and installations to habitat – wildlife corridors and birthing grounds, forage areas, flyways, and aquatics.
  • Establishing baseline water, soil, air quality levels and monitoring plans. The Monument and Palmer Lake communities have recognized severe water shortage, as reflected in multi-year rationing, and any threat of further damage to the water supply, including drainage or contamination of the aquifers mentioned above, would have devastating effects of the habitability, property values and fluidity of the area real estate markets—potentially harming many homeowners currently living adjacent to the National Forest.The USFS must determine and disclose potential and actual impacts to local air quality. Energy exploration and development can create significant dust and air pollution from roads, pumpjacks and other activities that affect visibility and air quality. The USFS must analyze the direct, indirect and cumulative impacts of this development on air quality, and reveal this information to the public. Much of the area under consideration is well-known for high-velocity winds typically originating in the northeast and blowing in a southwesterly direction toward the highly populated areas of Monument and Colorado Springs, which are adjacent to the areas of potential drilling under consideration. Extra protective cautions should be considered in an EIS. More specifically, the USFS needs to comply with the Clean Air Act, in particular, compliance with the Act’s Prevention of Significant Deterioration (PSD) provisions pursuant to 42 U.S.C. 7470-7479.
  • In developing its EIS, USFS must present an array of alternatives that reflect the range of choices for management of the PSICC as are both reasonable and lawful. Within these alternatives, USFS is obligated to thoroughly document and analyze impacts associated with the various choices, including impacts to property values and other economic values, impacts to fish, wildlife and imperiled species, impacts to the spread of noxious weeds, impacts to air quality, and impacts to public safety and user conflicts. Furthermore, USFS is not only to look at impacts in isolation, but must analyze connected, indirect and cumulative effects as well.
  • Establishing a monitoring plan for the occurrence and appropriate eradication of noxious/invasive weeds, and restoration, as needed
  • Assessment and plans for protection of meadows, wetlands and riparian areas
  • Assessment and measures to address potential impacts leading to contamination of soils, such as, but not limited to – vehicle “diapers”, proper handling, inventory, storage and disposal of all toxic/hazardous materials and substances
  • Assessment of all chemicals used in the PSICC and potential health effects on wildlife, water and people. Plans for posting the chemical composition of all fracking fluids under consideration and actually utilized should be put in place to provide the relevant medical communities with sufficient information so as to appropriately treat and affected workers or residents in the case of personal injury.
  • Comprehensive geo-hydrological study & independent analysis of deep (17,000’) strata and potential impact of breaching ancient barriers before drilling allowed.
  • Assessment of potential for all unintended impacts leading to contamination of confined and unconfined (surface) waters – ensuring the provision of sufficient performance and payment bonds to reflect projected potential cost of surface and underground contamination mitigation.
  • Assessment and mitigation of impacts of natural gas and oil development on air quality and potential health effects on wildlife, water and people
  • Magnitude and duration of sound impacts from transport vehicles, drilling rigs and compressors. Included should be appropriate analysis of topographical configuration of the areas within reasonable distance from any drilling areas under consideration in order to mitigate and minimize any undesirable sound effects of drilling activities in order to protect both humans and wildlife.
  • Full disclosure of the Operations Plan to protect the environment and human health including potential contamination, directional diversion or temperature change in surface and ground waters, air quality, environmental noise, light and visual pollution.
  • Comprehensive assessment of existing ecological and biological resources, including state and federally listed rare, threatened and endangered species, Potential Conservation Areas, wetland and riparian habitats, surface and subsurface water resources and analysis of potential direct, indirect and cumulative impacts of all drilling related activities.
  • Analysis of likely impacts on and necessary stipulations required to assure the PSICC can achieve its mandate to maintain the biological integrity, diversity and environmental health of all lands and thereby contribute to achieving those objectives on related adjacent land areas.
  • Full and complete analysis of the potential direct, indirect, cumulative and short and long term effects on the exceptional Sense of Place qualities that define the surrounding area including cultural, quietude, rural ambiance of solitude, esthetic, historical, ethical and socioeconomic. Included therein should be an analysis of changes in urban and suburban residences, retail and industrial facilities adjacent and nearby areas of potential drilling, as much has changed in the area in this respect since the 1992 Environmental Impact Statement was completed. For instance, over 200 homes and multiple large industrial and retail complexes have been completed in the past 20 years adjacent to the eastern side of the mountains in the areas of Monument and Palmer Lake.
  • An analysis for Wilderness Designation suitability for any lands subject to drilling.
  • Baseline monitoring data and trends analysis for all wildlife species potentially impacted by the proposed drilling operation.
  • Identification and protection plan for cultural and archaeological resources.
  • Establishing a response plan for any of the potential emergency situations that might arise within the Refuge, including but not limited to – ambulance calls, vehicular accidents, veterinarian, fire, toxic spill or contamination.
  • Assessment of economic impacts and any loss of revenue, to USFS to maintain/restore the integrity of the PSICC. Should unintended contamination consequences occur due to vehicular transport of fracking fluids, including leakage or spillage, or water contamination, or undesirable changes to the landscape, wildlife or communities—these would logically have a serious impact which should be considered and evaluated.
  • The EIS analysis of the socio-economic impacts of the proposed study must be thorough and accurate in order to responsibly manage the public lands.The USFS study must focus specifically on how USFS should evaluate the costs and benefits of conservation alternatives versus extraction alternatives within the PSICC area covered by the plan. As USFS considers proposed oil and natural gas development in the PSICC, it must do a full accounting of the costs and benefits of that project. In general, to facilitate informed investment decisions about publicly owned wild lands, economic analysis must take into consideration both market and nonmarket benefits and costs.USFS must include a broadly defined analysis of economic impacts. It would be both inaccurate and irresponsible for the agency to only describe the beneficial impacts of oil and gas revenue, for instance, without also including detrimental affects from large-scale industrialization of the landscape. In many instances, oil and gas development can actually lower property values due to exposure to hazardous and toxic pollutants, loud and persistent industrial noise, and drinking water and river contamination. Development impairs water quality, threatens roadless and wilderness areas and chops up wildlife habitat with spider webs of roads, pipelines, well pads, overhead power lines, and compressor and treatment facilities. Each of these factors threatens property values that are based not on the agriculture values of the land but instead on scenery and wildlife values inherent to the property.
  • Establishing performance and payment bonding of sufficient financial resource to cover the actual costs of monitoring and mitigation, as determined by the studies and plans. These necessary impact fees include amounts necessary to cover costs for reclamation of the surface and any impacted water resources.

With regard to alternatives and their specific mitigations, we respectfully request that the USFS include the following mitigations and apply them to any alternative that allows drilling:

  1. Full double casing of the entire (12,000 – 14,000) foot drill holes as an added safety measure.
  2. Steps to limit habitat fragmentation from roads, vehicle traffic, drill rigs and drill sites. Further, we request that the EIS present a realistic estimate of total miles of new roads to be constructed.
  3. Development of rigorous, conservative Stormwater and Groundwater Pollution Prevention Plans.
  4. Request a conservative limit on the acreage of any constructed well pads and compressor sites to limit total area disturbed, and require the development of plans to decommission, remediate if necessary, and restore disturbed areas at the end of industrial operations.
  5. Steps to limit disruption of elk/deer/antelope corridors, calving grounds and normal foraging patterns, including limits on industrial activity during calving periods.
  6. Request that wildlife alarm/warning systems be installed on all vehicles, 10 mph speed limits, no vehicle traffic allowed 1 hr. before/after dawn and dusk to limit road kill.
  7. Develop strict rules on refuse/garbage disposal to limit attracting bears and mountain lions into populated areas.
  8. Development of a rigorous plan to avoid the spread of noxious weeds, including but not limited to inspecting and cleaning all vehicles entering the PSICC, immediate reseeding of disturbed areas and road edges, and limiting the extent of soil disturbance and new road construction.
  9. Specific proven “state of the art” measures to prevent spills and other accidents.
  10. Assessment of on and off-site waste dump site impacts, in particular, taking into consideration the nature and direction of area winds and water run-off. For example, winds speeds of over 80 miles an hour have been measured by the US Air Force Academy, which are sufficient to render the consideration of open fracking fluid collection pits to be of high risk to the area population. The areas east of the mountains are well-known for almost continuous wind sufficient to carry dust and liquids great distance.
  11. Specific abatement and mitigation plans for regulated air emissions from oil and gas development and operations activity, including volatile organic compounds, smog-forming emissions, particulates, and fugitive dust emissions from construction and disturbed areas.
  12. Plans to mitigate the risk of wildfire associated with oil and gas development, including limits on venting flammable waste gases, safe storage of explosives and flammable chemicals, spark arrestors for compressors and diesel engines, and signage delineating buried or aboveground gas pipelines.
  13. List ALL chemicals used at the drill site and potential effects on wildlife, water and people as well as the preferred treatment for humans and animals affected by contamination due to windage or spillage .
  14. Limit the magnitude and duration of sound impacts from trucks, drilling and compressors. Specifically disallow any noise levels above the natural background level from 1 hour before sundown until 1 hour after sunup.
  15. Limit impacts of numerous, industrial vehicle traffic on County and local infrastructure and safety.
  16. Include specific scheduled and reviewed monitoring of water quality as well as aquatic species diversity, range and abundance.
  17. Require that bridges be constructed over meadows, wetlands and riparian areas that cannot be avoided.
  18. Conduct pre-drilling, during drilling and post-drilling test well studies and effect continuous monitoring of all creeks and all waterways (including ditches).
  19. Conduct well studies of water quality and species diversity in all streams, ditches and wetlands within ½ mile of a road being used by a well site.
  20. Authorization and funding for a community monitoring teams to oversee drilling activities and monitor impacts on air, water, sound, wildlife, etc.

We appreciate the magnitude of the work before you, to accomplish your mandate on behalf of the national public and the local citizens, in the face of industrial scale activity in the PSICC. Your careful assessment and planning of best practices to protect the unique features of the PSICC will preserve this world class natural resource and fulfill our mutual interests.

Thank you for your consideration of these comments submitted, as you assess the potential environmental impacts and draft your plans.


Most sincerely,

Chris Amensen
President, FRERC


Copy: Members of FRERC
Jeff Hovermale, USFS;
Travis Easton, Mayor of Monument
Nikki MacDonald, Mayor of Palmer Lake
Kim Gortz, PM Source Water Protection, Colorado Springs Utilities
Pres. of area Homeowners Associations

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