Presentation on theme: "1 Public Lands Advocacy HOW TO REVIEW A FEDERAL PLANNING DOCUMENT."— Presentation transcript:
1 Public Lands Advocacy HOW TO REVIEW A FEDERAL PLANNING DOCUMENT
2 Public Lands Advocacy TIME SAVING TIPS KEY CONSIDERATIONS COMMENT FORMAT
3 Public Lands Advocacy MANAGEMENT ALTERNATIVES –IDENTIFY AND REVIEW –COMPARE “NO ACTION” TO PREFERRED ALTERNATIVE IDENTIFY CHANGES TO STIPULATIONS, NO LEASE AREAS, SPECIAL MANAGEMENT AREAS MANAGEMENT “COMMON TO ALL ALTERNATIVES”
4 Public Lands Advocacy REVIEW AND COMPARE MAPS –COMPANY HOLDINGS –RESOURCE MAPS –“NO ACTION” TO “PREFERRED” ALTERNATIVE (OTHERS IF TIME) –MINERAL POTENTIAL MAPS
5 Public Lands Advocacy VALID EXISTING LEASE RIGHTS – HOW WOULD PROPOSED MANAGEMENT UNDER EACH ALTERNATIVE IMPACT: YOUR EXISTING DEVELOPMENT YOUR LEASE HOLDINGS
6 Public Lands Advocacy REASONABLY FORSEEABLE DEVELOPMENT PROJECTS LEVEL OF ACTIVITY FOR THE NEXT 15 TO 20 YEARS TOOL TO ANALYZE CUMULATIVE EFFECTS BASED UPON STANDARD LEASE TERMS IN AREAS OPEN TO LEASINGTHE RFD IS MODIFED BY ALTERNATIVE BASED UPON PROPOSED MANAGEMENT
7 Public Lands Advocacy RFD –WAS CURRENT INFORMATION USED (INCLUDING INDUSTRY PLANS)? –ARE THE SURFACE DISTURBANCE ASSUMPTIONS FOR WELLS, ROADS, AND FACILITIES ACCURATE? –ARE EXISTING LEASES AND FIELDS IDENTIFIED AND ANALYZED –HAVE ALL TYPES OF DEVELOPMENT BEEN INCLUDED AND ANALYZED?
8 Public Lands Advocacy CATEGORICAL EXCLUSIONS (CX) –ARE THE FIVE STATUTORY CXS ADDRESSED? –ARE OTHER OPPORTUNITIES FOR CXS IDENTIFIED AND ANALYZED?
9 Public Lands Advocacy Individual surface disturbances of less than five (5) acres so long as the total surface disturbance on the lease is not greater than 150 acres and site-specific analysis in a document prepared pursuant to NEPA has been previously completed. Drilling an oil and gas location or well pad at a site at which drilling has occurred within five (5) years prior to the date of spudding the well. Drilling an oil or gas well within a developed field for which an approved land use plan or any environmental document prepared pursuant to NEPA analyzed drilling as a reasonably foreseeable activity, so long as such plan or document was approved within five (5) years prior to the date of spudding the well. Placement of a pipeline in an approved right-of-way corridor, so long as the corridor was approved within five (5) years prior to the date of placement of the pipeline. Maintenance of a minor activity, other than any construction or major renovation of a building or facility.
10 Public Lands Advocacy Claire M. Moseley Executive Director ENERGY POLICY CONSERVATION ACT IM 20003-233, REQUIRES BLM TO: –REVIEW ALL STIPULATIONS TO ENSURE THEY ARE STILL NECESSARY AND THE LEAST RESTRICTIVE NECESSARY TO ACCOMPLISH THE PROTECTION REQUIRED ASSESS WHETHER THIS HAS BEEN DONE IN THE PLAN
11 Public Lands Advocacy Claire M. Moseley Executive Director RESOURCE VALUES REVIEW RESOURCES WHOSE MANAGEMENT COULD IMPACT FUTURE DEVELOPMENT (CHAPTER 3) –AIR QUALITY, WATER QUALITY, WILDLIFE, CULTURAL RESOURCES, PLANTS, SOILS, LANDS WITH WILDERNESS CHARACTERISTICS –ENSURE ACCURACY
12 Public Lands Advocacy Claire M. Moseley Executive Director ENVIRONMENTAL CONSEQUENCES –IMPACTS MUST NOT BE OVERSTATED AND MITIGATION MUST BE ACKNOWLEDGED –HAS PROPER METHODOLOGY BEEN USED FOR AIR AND WATER QUALITY? –ARE NEW/EXPANDED STIPULATIONS JUSTIFIED? –HAVE THE EFFECTS OF OVERLAPPING STIPULATIONS BEEN ADDRESSED?
13 Public Lands Advocacy Claire M. Moseley Executive Director SUBMIT COMMENTS INCLUDE SPECIFIC REFERENCES TO PAGE NUMBERS AND LANGUAGE OF CONCERN OFFER RECOMMENDED CHANGES
14 Public Lands Advocacy Claire M. Moseley Executive Director FORMAT OF COMMENTS SECTION NUMBER PAGE NUMBER COMMENT/RECOMMENDATION
15 Public Lands Advocacy SECTION 220.127.116.11, GROUNDWATER QUALITY AND QUANTITY ON PAGE 4-19, FACTORS THAT AFFECT THE AMOUNT OF SEDIMENT DELIVERY ARE LISTED, … COMMENT AND RECOMMENDATION: BLM MUST RECOGNIZE THAT THE SITE-SPECIFIC BMPS DESIGNED DURING THE ONSITE INSPECTION…