Many thanks for the substantial response to the request earlier this week for letters to the BLM regarding oil leasing of a large parcel on the Wyoming side of the Beartooth Front. At least 15 people indicated, either here or on the No Fracking the Beartooth Front Facebook page, that they were going to write letters.

Local organizations, including the Carbon County Resource Council, also responded, as you can see from the signatories on the letter below.

I thought I would post this excellent letter as a model for others. We will undoubtedly need to write letters about BLM leases in the future. This one states the case very effectively and can be used as a reference. (Remember that you can always use the search box on this site to find posts on topics of interest.)

If you are interested in finding out more about the devastating 2006 gas well blowout referenced in the letter, you can read the personal story of Deb Thomas here.

I’ve run this photo earlier this week, a shocking picture taken by a local resident of the blowout as it occurred.

Crosby 25-3 blowout as it occurred in 2006.

Here is the letter:

BLM Wind River/Bighorn Basin District
Attn: Rita Allen
101 S. 23rd Street
Worland, WY 82401

February 23, 2015

Re: August 2015 Oil and Gas Lease Sale Parcel Environmental Assessment

Dear Ms. Allen:

Please accept the following comments regarding the above-referenced environmental  assessment (EA) that the Bureau of Land Management (BLM) has prepared.

We ask that Parcel WY 1508-237, located on the Absaroka-Beartooth Front be deferred. This parcel lies within a landscape important for wildlife.  It is within greater sage-grouse
general habitat and is within a four-mile buffer of an occupied lek. The area also provides
seasonal range for bighorn sheep, elk, moose, mule deer, pronghorn antelope, mountain goat, and white-tailed deer.  It is habitat for black and grizzly bear, wolves, mountain lion, bobcat, and red fox. A broad diversity of bird life is also present in the area.

This parcel includes and is adjacent to public lands extremely important for hunting,
fishing and recreation that includes hiking, biking, horseback riding, cross country skiing and snowshoeing.  These are uses that depend on clean air, clean water and a healthy outdoor environment.  These recreational activities bring important revenue to the area, the state of Wyoming and the region.

In addition, Parcel WY 1508-237 includes privately held surface, including property in
the Line Creek Wilderness Subdivision.  The rural residential subdivision consists of 90 lots that vary in size and include approximately 54 landowners.

The Line Creek Subdivision is a community that has already been seriously impacted by
oil and gas development.  Although the development consists of only two pads with six wells, the impacts to the community have been huge. Contamination issues, deterioration of community and quality of life, along with serious health issues continue to plague residents. Since 1999, the community has been subject to impacts from oil and gas development that include toxic air emissions, light pollution, noise pollution, dust, leaks, spills, inadequately remediated pits, and disposal of waste on private property.  The most serious, to date, was Windsor Energy Group’s Crosby 25-3 gas well blow out in 2006.

The Crosby blowout released what the Wyoming Department of Environmental Quality
(WDEQ) identifies as the worst case emissions of 97 tons of Volatile Organic Compounds, 11 tons of Hazardous Air Pollutants, which is over 2 tons of BTEX—(Benzene, Toluene, Ethyl Benzene, Xylene), 101 tons of methane and 43 tons of ethane.  During the blowout, twenty-five households in the subdivision were evacuated for three days.  Windsor Energy attempted to evaluate and control the situation for over four hours before alerting residents, putting them in extreme danger.  Luckily, there was no explosion or fire.

In addition to the initial disaster and toxic air emissions, the Crosby 25-3 blowout resulted in groundwater contamination, contaminated private drinking water wells and continues
to be the site of an ongoing monitoring project.  Over 100 monitor wells, 25 private drinking water wells, six springs that flow into Line Creek and four sites on the creek have been monitored for over nine years.  Monitored natural attenuation was approved by the State as a preferred remedial alternative for the shallow alluvial aquifer, and although a pilot project for remediation alternatives of the deeper aquifer has been conducted, remediation has not taken place. Almost ten years later, the contamination is still not remediated.

The many important resources along the Beartooth Front should not be sacrificed for the  development of one.  The oil and gas development in this area has produced small amounts of oil and gas that have resulted in low revenues.  However, the development has created immeasurable damage to the environment that has cost millions of dollars to investigate and monitor.   The development has not only fracked the sub-surface geology and hydrology, it has fractured the community.  It has created a toxic environment and destroyed the health and well being of people who are forced to live with it.

To allow further leasing, permitting or drilling in this area, already under such heavy
impact, is unconscionable.  The environment and the people who live along the Beartooth Front must be protected from any further oil and gas exploration or development.  Deferral of Parcel WY 1508-237 is necessary to protect both.

It is our understanding that all private surface owners were not contacted about the
leasing of this mineral parcel.  Until such due notice can be given to all surface owners, the
parcel must be deferred.  The BLM Handbook on “Competitive Leases,” updated in 2013, is clear that this notice is an essential step during preparation of the oil and gas lease sale
environmental assessment (H-3120-1 “Competitive Leases,” p.13). Before leasing a parcel, as the environmental assessment is being developed, the BLM must determine the impacts of the proposed action on the quality of the human environment. This is of heightened importance for split-estate parcels when the agency must take into account the views of the surface owners. Because due notice of the lease nomination was not made to all landowners affected by WY 1508-237, their views have been unable to be incorporated in the EA and this parcel must be deferred until that situation can be rectified.

Thank you for accepting our comments.  We respectfully ask that you take them into
consideration and recognize the importance of deferring Parcel WY 1508-237.

Sincerely,

John C. Mitchell, Line Creek Resident
Sands Dickson, Line Creek Resident
John Linebaugh, Line Creek Resident
James A. Sonderman, Line Creek Resident
James E. Melton, Line Creek Resident
Dick Bilodeau, Line Creek Resident
Deborah K. Thomas, Line Creek Resident
Pete Dronkers, Area Resident
Christina Denney, Chair, Clark Resource Council,
John Fenton, Board Director, Shale Test
Bruce Baizel Earthworks
Carbon County Resource Council
Jenny Harbine Earthjustice
Amanda Jashan, Wildlife Energy Conservation Fellow, Natural Resources Defense Council

If you’re interested in more on the well blowout referenced in the letter, you can view Deb Thomas’ horrifying description in the video below, beginning at 32:48.