GENERAL32022

• Permit No: M1983194
• IBM Index Class Name: General Documents
• Doc Name: COVER SHEET-2 PUBLIC COMMENTS ON DRAFT EIS & RESPONSES TO COMMENTS
• Media Type: D
• Archive: No

2. RESPONSES TO PUBLIC COMMENTS
There has been no concrete evidence submitted by WRC
that will ensure or verify the existence of mud in the annulus
during well life or after abandonment. This fact entered
into our consideration and mitigation of the proposed well
completion and abandonment. In addition, intensive
monitoring during the pilot project and early stages of the
commercial-scale project will help to determine the technical
and environmental soundness of [he chemical gel type mud
(casing pack). For further clarity, please see Appendix A.
Response No. 87. This section does not describe the
anion as BLM would approve it. Please refer to the
mitigation stated in Appendix C.
We acknowledge the fact that a fluctuating level of brine
may exist in the 5 1/2-inch x 8 5/l3-inch casing annulus;
however, this brine is noncorrosive and a chance for a leak
in the casing is remote. The leak detection system for
production wells, as described in the draft EIS on page
2-8, Section 2.2.12.2, will detect ami leaks greater than 3
gallons per minute (Jones 1985). Monitoring of sufficient
groundwater bearing zones will detect leaks less than 3
gallons per minute. If any leaks are detected remedial actions
will be required to prevent adverse impacts to groundwater.
Response No. 88. A portion of ow' committed mitigation
(Appendix C) includes a requiremt:nt to run a Cement
Evaluation Tool or equivalent lag ;titer cementing the 8
5/8-inch casing. This log is more comprehensive than a
noise or temperature log in determining [he cement bond
and potential for fluid movement through channels adjacent
to the well bore. Appropriate remedial actions will be taken
to assure a competent cement bond, iii needed.
Wildlife
Response No. 89. We concur with your statement that
current vehicle related deer mortality has declined since the
1977-1981 period. This data was intended to illustrate that
road kills can be a significant fagot in deer mortality.
However, we feel this information also supports general
impact analysis and provides a basis for recommendations
encouraging the use of employee mast transit and the
scheduling of shift changes and product haulage to coincide
with low activity periods of deer.
Response No. 90. Section 2.2.13, Other Applicant
Proposed Mitigation on page 2-9 of the draft EIS, lists
applicant-generated mitigative measures that are considered
integral with the proposed action. Section 2.4.1.1.8, Range
and Wildlife on page 2-29 of the draft, lists additional BLM-
generatedmitigation that would be imposed on the applicant.
The first item under this section involves Raptor Research
Report No. 4, although the address is apparently outdated.
We have changed the address accordingly.
Response No. 91. BLM chose not to include the
comprehensive species list Vaditionally comprised of known
or expected wildlife occurrences. There are numerous
government and consultant prepared compilations of this
nature that are duly referenced in the text. As expressed
in the draft EIS, in the opening paragraph of Section 3.8
(Wildlife), only those species that may be significantly
affected or that befit special state or federal concern are
discussed in detail. BLM would certainly consider
incorporating additional species accounts if reasonable
concern was expressed by the public or other involved parties.
Response No. 92. BLM believes that the deer-related
mitigation scheme imposed through stipulation is commen-
surate with direct and indirect habitat losses associated with
each alternative. Although we see short-term impacts as
inevitable, we view wildlife-oriented site rehabilitation as
fundamentally important in minimizing long-term impacts
to the Piceance mule deer population. Concurrent habitat
enhancement work is intended to ameliorate short-term
effects, although we question the effectiveness of any
mitigation strategy designed to fully compensate the
immediate effects of habitat loss, especially considering the
high degree of winter range fidelity demonstrated by Piceance
deer and the difficulty in determining displacement patterns
during project implementation. As stated on page 2-29 of
the drag EIS, deer-related mitigation options are very much
flexible at this point. USFWS involvement during mitigation
coordination and development would be welcome.
Response No. 93. Raptor survey methods employed by
WRC were outlined in their baseline report as referenced
(W ol(Ridge Corporation 1984). Methods of data acquisition
were reviewed and accepted by BLM before being used
for impact analyses.
As additional information, pedestrian searches for active
and inactive tree nests were conducted in a systematic
fashion, along parallel zig-zag transects marked on USGS
7.5 minute topographic maps. Four man-days of intensive
effort were expended in June 1984, covering 447 acres of
pinyon juniper habitat. Further information was gained
opportunistically in the course of an additional 10 man-
days of field work in July.
We believe this information is adequate to support current
impact analyses and feel the information is at least as
sufficient as the data bases available for other animal groups
analyzed in this document. However, we also recognize the
weaknesses inherent in one time/one season survey efforts,
particularly when applied to long-lived projects. We have
acknowledged the potential for future raptor nesting activity
by imposing raptor nest survey requirements that include
USFWS coordination (Section 2.4.1.1.8 in the draft).
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