2008-06-09_PERMIT FILE - C1980007 (6)

Home Browse Search

Response to Comments • r1 Table 5-1 DEIS Comments and Responses Commenter Comment Comment/Response Colorado Wild, et 24 We are very concerned about damage to riparian areas and possibly to water al. quality from the siting of well pads and access roads in wet areas. The DEIS states that there would be 33 well pads and 5.8 miles of road with 13 stream crossings in or adjacent to the water influence zone ("WIZ"). DEIS at 43. This is not acceptable. Facilities must be located in areas where damage to the riparian, aquatic, and water quality resources is the least likely, tuiless the impacts of constructing and operating the facilities and needed access roads would be even more damaging than siting them near the WIZ. RESPONSE: The analysis in the EIS discusses drill pad and road locations as occurring in windows and "corridors" that allows for the facilities to be field fit in a spot that minimizes disturbance. The analysis discloses the effects for the acreage associated with the whole window or corridor, when at implementation, the actual on the ground disturbance will be less. Therefore, there is some over-estimation of disturbance in particular vegetation types (which would include WIZ or riparian). The design criteria (EIS, Table 2-1) will be implemented to ensure that any field placement minimizes, to the maximum extent possible, effects not only to the riparian areas, but also to geologically instable areas which may have greater impact to riparian/wet areas by the release of sediment and increased erosion. Where activity occurs in wet areas that activity will be designed with strict adherence to FSH 2509.25 and appropriate federal and state permits will be obtained. Colorado Wild, et 24 This especially true for any facilities in roadless areas. Under exception 7, any al. road construction or reconstruction in roadless areas must be conducted in a manner that minimizes effects on surface resources, prevents unnecessary or unreasonable surface disturbance, and complies with all applicable lease requirements, land and resource management plan direction, regulations, and laws. 36 CFR 294.12(b)(7) (2001). RESPONSE: See response immediately above. The FS is very concerned about the riparian and WIZ area for every area in this project and has many design criteria specific to this resource (EIS, Table 2-1). Colorado Wild, et 26 Note that the Forest Plan requires protection of riparian areas. See Plan at III- al. 50 and III-185 though -187. Note especially that in cases of resource conflicts, preferential consideration will be given to riparian area resources over other resources within the management unit. Forest Plan at III-173. RESPONSE: The Forest Plan provides direction Management Prescription 9A as stated, as well as, "Riparian areas are inclusions in other management areas and will be site specifically identified and mapped as part of the NEPA process or during riparian area inventories. The goals listed in this prescription apply to the riparian areas themselves and are in addition to the general directions and standards and guidelines for the MA [Management Area] in which the riparian area is located...: And "Standards and guidelines may or may not apply to ephemeral streams, seeps, springs, bogs or developed livestock water, dependent upon site specific objectives." (FP III-173) The project area is subject also to Management Area Prescriptions SA (big game winter range) and 6B (livestock grazing). Deer Creek Ventilation Shaft and E Seain Methane Drainage Wells FEIS 181