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Public Lands Advocacy

HOW TO REVIEW A FEDERAL PLANNING DOCUMENT. Public Lands Advocacy. Public Lands Advocacy. TIME SAVING TIPS KEY CONSIDERATIONS COMMENT FORMAT. Public Lands Advocacy. MANAGEMENT ALTERNATIVES IDENTIFY AND REVIEW COMPARE “NO ACTION” TO PREFERRED ALTERNATIVE

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Public Lands Advocacy

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

  2. Public Lands Advocacy • TIME SAVING TIPS • KEY CONSIDERATIONS • COMMENT FORMAT

  3. Public Lands Advocacy • 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”

  4. Public Lands Advocacy • REVIEW AND COMPARE MAPS • COMPANY HOLDINGS • RESOURCE MAPS • “NO ACTION” TO “PREFERRED” ALTERNATIVE (OTHERS IF TIME) • MINERAL POTENTIAL MAPS

  5. Public Lands Advocacy • VALID EXISTING LEASE RIGHTS • HOW WOULD PROPOSED MANAGEMENT UNDER EACH ALTERNATIVE IMPACT: • YOUR EXISTING DEVELOPMENT • YOUR LEASE HOLDINGS

  6. Public Lands Advocacy 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

  7. Public Lands Advocacy • 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?

  8. Public Lands Advocacy • CATEGORICAL EXCLUSIONS (CX) • ARE THE FIVE STATUTORY CXS ADDRESSED? • ARE OTHER OPPORTUNITIES FOR CXS IDENTIFIED AND ANALYZED?

  9. Public Lands Advocacy • 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.

  10. Public Lands AdvocacyClaire M. MoseleyExecutive 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

  11. Public Lands AdvocacyClaire M. MoseleyExecutive Director 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

  12. Public Lands AdvocacyClaire M. MoseleyExecutive 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?

  13. Public Lands AdvocacyClaire M. MoseleyExecutive Director SUBMIT COMMENTS • INCLUDE SPECIFIC REFERENCES TO PAGE NUMBERS AND LANGUAGE OF CONCERN • OFFER RECOMMENDED CHANGES

  14. Public Lands AdvocacyClaire M. MoseleyExecutive Director FORMAT OF COMMENTS • SECTION NUMBER • PAGE NUMBER • COMMENT/RECOMMENDATION

  15. Public Lands Advocacy 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…

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