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2017-05-25_REVISION - C1996083
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2017-05-25_REVISION - C1996083
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Entry Properties
Last modified
5/31/2017 6:58:38 AM
Creation date
5/26/2017 8:37:53 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1996083
IBM Index Class Name
Revision
Doc Date
5/25/2017
Doc Name Note
(Citizen Concerns)
Doc Name
Comment
From
Andrew Forkes-Gudmundson
To
DRMS
Type & Sequence
TR112
Email Name
CCW
JRS
Media Type
D
Archive
No
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CONSERVATION GROUPS’ COMMENTS <br />UNCOMPAHGRE FIELD OFFICE RMP AND DEIS <br />79 <br /> <br />NEPA analysis is typically conducted for oil and gas leasing and when permits are <br />issued. This FEIS is the first NEPA analysis where lands that could be made <br />available for lease are identified and stipulated. In a subsequent analysis stage, when <br />there is a site-specific proposal for development, additional air quality impact analysis <br />would occur. This typically occurs when an application for a permit to drill is submitted. <br />Based on the analysis results, additional mitigation or other equally effective options <br />could be considered to reduce air pollution. <br /> <br />Final EIS at 372 (emphasis added). The TRFO set a new standard by recognizing that the climate <br />change impacts from oil and gas industry activities are cumulative and that methane losses from <br />business-as-usual industry practices at the field office level contribute significantly to climate <br />change and must be mitigated. In the Final EIS, the TRFO also recognized that methane <br />emissions represent waste of a key natural resource that belongs to all U.S. citizens, and the <br />failure to control such waste robs the U.S. and state treasuries of royalty revenues. Accordingly, <br />the TRFO adopted six important methane mitigation measures, which include: <br /> <br />• Centralized Liquid Gathering Systems and Liquid Transport Pipelines <br /> <br />• Reduced Emission Completions/Recompletions (green completions) <br /> <br />• Replacement of High-bleed Pneumatics with Low-Bleed/No-Bleed or Air-Driven <br />Pneumatic Devices on all Existing Wells <br /> <br />• Installation of Low Bleed/No Bleed Pneumatic Devices on all New Wells <br /> <br />• Dehydrator Emissions Controls; and <br /> <br />• Electric Compression <br /> <br />Id. at 376. <br /> <br />As the BLM proceeds in the Uncompahgre planning process, it is essential to consider <br />the pioneering action taken by the TRFO. See 40 C.F.R. § 1502.9(c)(1)(ii). The BLM’s <br />dismissive approach to climate change reflected in the Uncompahgre draft RMP/EIS, and its <br />failure to adequately address methane emissions, is plainly incompatible with the climate <br />impacts of oil and gas development. It is incumbent upon the UFO to confront the issues of <br />climate change and methane emissions head-on, which must be accomplished through field <br />office level planning and decisionmaking that is reflective of the challenges we face. <br /> <br />Beyond these methane mitigation measures, additional, widely recognized emissions <br />reduction technologies, best management practices (“BMPs”), and planning tools for mitigating <br />methane emissions and waste are available to the UFO that must be given a hard look in its
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