1 Public Lands Advocacy HOW TO REVIEW A FEDERAL PLANNING DOCUMENT.

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Public Lands Advocacy

HOW TO REVIEW A

FEDERAL PLANNING DOCUMENT

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• TIME SAVING TIPS• KEY CONSIDERATIONS• COMMENT FORMAT

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• 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”

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• REVIEW AND COMPARE MAPS– COMPANY HOLDINGS– RESOURCE MAPS– “NO ACTION” TO “PREFERRED”

ALTERNATIVE (OTHERS IF TIME)– MINERAL POTENTIAL MAPS

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• VALID EXISTING LEASE RIGHTS– HOW WOULD PROPOSED

MANAGEMENT UNDER EACH ALTERNATIVE IMPACT:•YOUR EXISTING DEVELOPMENT

•YOUR LEASE HOLDINGS

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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

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• 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?

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• CATEGORICAL EXCLUSIONS (CX)– ARE THE FIVE STATUTORY CXS

ADDRESSED?

– ARE OTHER OPPORTUNITIES FOR CXS IDENTIFIED AND ANALYZED?

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• 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.

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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

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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

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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?

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SUBMIT COMMENTS• INCLUDE SPECIFIC REFERENCES

TO PAGE NUMBERS AND LANGUAGE OF CONCERN

• OFFER RECOMMENDED CHANGES

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FORMAT OF COMMENTS

• SECTION NUMBER• PAGE NUMBER• COMMENT/RECOMMENDATION

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SECTION 4.1.3.1, 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…

1 Public Lands Advocacy HOW TO REVIEW A FEDERAL PLANNING DOCUMENT.

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