1 public lands advocacy how to review a federal planning document
TRANSCRIPT
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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”
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Public Lands Advocacy
• REVIEW AND COMPARE MAPS– COMPANY HOLDINGS– RESOURCE MAPS– “NO ACTION” TO “PREFERRED”
ALTERNATIVE (OTHERS IF TIME)– MINERAL POTENTIAL MAPS
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Public Lands Advocacy
• VALID EXISTING LEASE RIGHTS– HOW WOULD PROPOSED
MANAGEMENT UNDER EACH ALTERNATIVE IMPACT:•YOUR EXISTING DEVELOPMENT
•YOUR LEASE HOLDINGS
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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
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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?
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Public Lands Advocacy
• CATEGORICAL EXCLUSIONS (CX)– ARE THE FIVE STATUTORY CXS
ADDRESSED?
– ARE OTHER OPPORTUNITIES FOR CXS IDENTIFIED AND ANALYZED?
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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.
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Public Lands Advocacy
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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Public Lands Advocacy
Claire M. Moseley Executive 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
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Public Lands Advocacy
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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Public Lands Advocacy
Claire M. Moseley Executive Director
SUBMIT COMMENTS• INCLUDE SPECIFIC REFERENCES
TO PAGE NUMBERS AND LANGUAGE OF CONCERN
• OFFER RECOMMENDED CHANGES
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Public Lands Advocacy
Claire M. Moseley Executive Director
FORMAT OF COMMENTS
• SECTION NUMBER• PAGE NUMBER• COMMENT/RECOMMENDATION