The proposal to lease these parcels is irresponsible, unnecessary, and dangerous:
- North Fork Valley farms are the organic breadbasket of Colorado, offering a safety net to what are currently at risk or likely contaminated farms. Four of the top agricultural producing counties in the State are also four of the top natural gas-producing counties in the state. Delta County is the 5th largest agricultural producing county with 1250 farms.
- The parcels around Paonia Reservoir are dangerously close to the dam. Canadian researchers have found that fracking results in induced seismicity and recommend a 3-mile buffer around sensitive infrastructure such as dams and reservoirs. These parcels are within that recommended buffer.
- Rural gas gathering pipelines are exempted from state and federal pipeline safety and integrity regulations, and the BLM should impose a moratorium on oil and gas leasing and development until the safety of rural gas gathering pipelines can be independently monitored and inspected.
State Highway 133 corridor between Hotchkiss and Paonia Reservoir is listed as the #2 most serious landslide threat in the entire state of Colorado. It contains “extremely active landslides along entire corridor, [and] severe rockfall hazard on west side of Paonia Reservoir.” At risk is the highway itself, the railroad line, and coal-mining and irrigation facilities. The nearby East Muddy Creek Landslide is listed as the #12 most serious in the state.
The deadline for Preliminary EA Comments ended September 11, 2018. Colorado’s December Lease Sale is the first oil and gas lease sale subject to the BLM’s new oil and gas leasing policy which has cut the leasing timeline by more than half, from 13 months to 6 months. Under this aggressive and unrealistic timeline, the BLM has scrambled to conduct its environmental analysis and in the process appears to have been negligent in its handling of comments from the public and local government. Due to BLM’s failure to consider the Town of Paonia, the frontline community’s scoping comments along with leading agricultural organizations–Valley Organic Growers, Colorado Farm and Food Alliance, West Slope Slow Food, and West Elks Winery Association, the Western Slope Conservation Center and dozens of individual comment letters, this EA is fatally flawed and should be redone.
Gunnison County, the Town of Paonia, Governor Hickenlooper, Senator Michael Bennet and a coalition of citizens groups, environmental and conservation organizations have all weighed in on the lease sale requesting that these parcels be deferred and withdrawn from the December 2018 Lease Sale. In addition, to address public disenfranchisement due to the ridiculously short 15-day scoping and EA comment periods, which in both cases fell over federal holidays, a coalition of citizens’ groups requested a public hearing, which was denied by the BLM.
Organizational and government comment letters submitted:
CHC EA Comment Letter (submitted by Western Environmental Law Center along with 6 other environmental and conservation groups)
CHC and Coalition Letter on Failure to Solicit and Consider Public Input
CHC and Coalition Letter Requesting a Public Hearing
Western Slope Conservation Center
Senator Michael Bennet
Delta County * only one to not request deferral and to not express concern around erosion of local control and public comment period.
Town of Paonia
Valley Organic Growers Association and West Slope Slow Food
North Fork Valley Creative Coalition
For all of these reasons stated above and more, these lease parcels should be withdrawn from the December 2018 lease sale. More importantly the BLM should consider the reasonable no-leasing alternative already demanded by 42,000 people in 2016; it’s the only way to guarantee that this irreplaceable corner of Colorado is not irreparably harmed.
BLM has the discretion to withdraw these parcels from the December 2018 Lease Sale. If BLM does not withdraw these parcels, the next formal opportunity to protest this lease sale will be in late October.
The Preliminary Environmental Assessment is available at: