Frequently Asked Questions
Supplement to the Draft EIS for the San Juan Plan Revision
How is the Supplement to the Draft EIS organized?
This Supplement to the Draft EIS follows the same organization as the Draft EIS and is organized as follows:
- Chapter One—Purpose and Need: This chapter includes an explanation of why the Supplement has been developed and why it has the same purpose and need as the Draft EIS. It also includes a list of the new information and where it can be found in the Supplement.
- Chapter Two—Alternatives: This chapter provides a summary of information from the Draft EIS relative to the alternatives and the oil and gas leasing availability decision in order to provide context for how the Gothic Shale Gas Play (GSGP) fits within the alternatives and analysis of the Draft EIS. Summary tables of the development projections analyzed in the draft, with the GSGP additional projections, and the acres available for lease and stipulated by alternative are found in this Chapter. Additionally, this chapter includes the new standards and guidelines proposed for air quality and water.
- Chapter Three—Affected Environment and Environmental Consequences: This chapter includes the analysis of environmental consequences from the potential development of the Gothic Shale Gas Play area. The analysis in this chapter is organized by resource and supplements, or adds to, the analysis in the Draft EIS. The Introduction to Chapter Three includes an overview of the assumptions used for analysis.
- Chapter Four—List of Prepares: Specialists listed in this chapter have contributed to the Supplement and are in addition to the List of Preparers in the Draft EIS.
- Chapter Five—References: References listed in this chapter are specific to the analysis in this Supplement, and are in addition to the References in the Draft EIS.
- Chapter Six—Acronyms: Acronyms listed in this chapter are specific to the analysis in this Supplement, and are in addition to those in the Draft EIS.
Why is the San Juan Public Lands Center (SJPLC) publishing a Supplement to the Draft EIS for the San Juan Plan Revision?
The Supplement was primarily developed to update the oil and gas development projections in the Draft EIS to include the shale gas projections associated with the Gothic Shale Gas Play area. Additionally, the Supplement discloses the results of a recently completed air quality model based on the new development projections. By publishing a Supplement to the Draft EIS, the public is given the opportunity to review and comment on the new information and analysis.
What is the Gothic Shale Gas Play area and why is it being added to the Draft EIS?
The Gothic Shale Gas Play1 (GSGP) is a 646,403 acre shale gas formation that was discovered on the western side of the San Juan Public Lands, primarily within Dolores and Montezuma counties, and to a lesser extent in San Miguel and La Plata counties. Comments received on the Draft EIS (published in 2007) indicated that the projections and development scenarios analyzed in the Draft EIS were inadequate because they did not include the Gothic Shale Gas Play area. A Supplement is warranted when conditions have changed substantially enough to need public review and comment. Based on the most current and best information available (including technology, geology, economics, etc.), the development projections for the GSGP could result in an additional 1012 wells on currently leased and unleased USFS and BLM mineral estate lands. The projected amount of gas to be yielded from the shale gas play over the next 15 years (on federal, state, local and private lands) is estimated to be 2.7 trillion cubic feet of gas (TCFG). After reviewing information about the GSGP area, San Juan Public Land (SJPL) managers determined that these new development projections represented a significant change in conditions and analysis scenarios—enough to warrant publishing a Supplement2 to the Draft EIS.
Why was a new air quality model completed and why is it part of the Supplement to the Draft EIS?
Oil and gas development is a primary activity influencing air quality in Southwest Colorado and the greater Four Corners region; hence there is a close relationship between oil and gas development and air quality impacts. Comments received on the Draft EIS contended that the type of air quality model used in the Draft EIS was inappropriate for the scale of the plan and that we had exceeded the analysis capability of that model. Given the concerns about the air quality model and having new development projections for analysis, the SJPL managers determined it was appropriate to remodel air quality based on the new development projections and to use a modeling system that is more capable of identifying the source of pollutants.
What are the primary changes that the Supplement makes to the Draft Land Management Plan (Draft LMP) and Draft Environmental Impact Statement (Draft EIS)?
As described above, the Supplement updates (or changes) the oil and gas development projections and analysis of associated impacts; and it discloses the results of the recently completed air quality model. In most cases, the types of impacts to resources and programs (e.g., soils, ecosystems, recreation, etc.) are the same as described in the Draft EIS; only the potential magnitude of projections and impacts (i.e., number of wells, acres of disturbance, etc.) changed in the analysis for most resources. However, the different methodologies used for developing shale gas (compared to conventional gas) did indicate new and different potential impacts to air quality and water resources. Considering these different types of potential impacts, the SJPL managers have developed new standards and guidelines to mitigate potential impacts to air quality and water. These new standard and guidelines are listed in Chapter Two. Because these are newly developed since the Draft LMP and Draft EIS were published, we especially want to make reviewers aware of them for public comment.
The air quality model assumed application of the new, proposed air quality standards and guidelines. Cumulative impacts identified by the model indicated the potential for relatively high levels of nitrogen deposition at Mesa Verde National Park (a class one airshed) that could exceed Forest Service and National Park Service significance thresholds for nitrogen and sulfur. In light of the model findings for potential cumulative impacts, the San Juan has developed a suite of additional “mitigation options” aimed at reducing nitrogen, sulfur, and greenhouse gas emissions. The SJPL managers have ranked the “mitigation options,” as to how effective we think they will be at reducing emissions. We would appreciate the public’s consideration and comments on these mitigation options (located in the Air Quality section of Chapter Three, pg. 3.43), as we will be selecting the best ones and making them requirements in the Final Land Management Plan and Record of Decision. Please provide comments on whether we have identified the most effective options for reducing emissions, or if there are different options that we did not consider.
Is the Supplement analyzing a project proposal?
The Supplement is not analyzing a project proposal. The oil and gas decision made for the plan revision is “identifying lands available for lease” and what stipulations (i.e., mitigation measures) apply to the lands that are “available” for lease. This is the first of three stages 3 of analysis for oil and gas development. At subsequent analysis stages (i.e., Stage 3--Application for Permit to Drill or Field Development), specific project proposal(s) will be analyzed. At the plan revision analysis stage, the analysis is based on assumptions about how the field might develop if the lands identified for lease are subsequently leased and developed. Assumptions about how the play might develop were based on the best information available at the time analysis began. (See the Introduction to Chapter Three for more details.)
How does the Supplement relate to the San Juan Draft Land Management Plan (Draft LMP) and Draft Environmental Impact Statement (Draft EIS) that was published in Dec. 2007?
The Supplement is intended to be part of the Draft Environmental Impact Statement (Draft EIS). The reason for the Supplement is to disclose the new information and request public review and comment on the new information and analysis. Because the Supplement is only adding new information, it does not repeat information from the Draft EIS and is not a stand-alone document. Hence, the Supplement must be reviewed with the Draft EIS (Dec. 2007) in order to understand the full range of alternatives and plan revision issues.
What happened to the comments the public provided on the Draft LMP and Draft EIS?
All comments received on the Draft LMP and Draft EIS (between December 14, 2007 and April 11, 2008) are still valid and will be addressed in the Final EIS. Comments received on the Draft LMP and Draft EIS are not addressed in the Supplement because the Supplement is narrowly focused on disclosing the new information for public review and comment. The comments received in 2008, plus the comments we receive on this Supplement will create the complete set of comments that will be considered in developing the Final EIS and Proposed Land Management Plan (Proposed LMP). The Proposed LMP and Final EIS are anticipated to be released by the end of calendar year 2012.
How can I get a copy of the Supplement, Draft LMP/EIS, and Supporting Documents?
The Supplement to the Draft EIS, as well as the Draft LMP and Draft EIS can be viewed online at: http://ocs.fortlewis.edu/forestplan . All supporting documents (e.g., the 2009 RFD Addendum, and Air Quality Technical Support Document) are also available on this webpage. You can request a CD or hard copy of the Supplement by calling (970-385-1552 or 970-385-1229) or emailing: emretzlaff@fs.fed.us
How can I provide comments on the Supplement?
The Notice of Availability (NOA) for the Supplement to the Draft EIS was published in the Federal Register on August 26, 2011. The published NOA initiates the 90-day public review and comment period. Comments must be postmarked by November 25, 2011 to be considered in the Final EIS and Proposed LMP. Comments will only be accepted on the information in the Supplement to the Draft EIS during this comment period.
Comments may be made via:
Email: comments-planrevision-sanjuan@fs.fed.us;
Mail: SJPL Supplement Comments, Attn: Shannon Manfredi, 15 Burnett Court, Durango, CO 81301-4216; or
Fax: 970-375-2331.
How can my comments be most effective?
In general, the most effect comments are those that identify information or ideas that the SJPLC failed to consider in the analysis (i.e., errors, oversights, or inadequacies). It is also helpful for comments to: 1) clearly state what the concern is (preferably reference the page or cite the passage); 2) explain why it is a concern; and 3) what you recommend for addressing your concern. In light of the increased development potential, the public may want to comment on where leasing should be limited or prohibited within the GSGP area, explaining why and what resource values should be protected from the impacts of gas shale development. The public may want to comment on specific resources or areas within the GSGP area that need specific protection, or suggest field development design measures, which could be useful for developing minerals, while also maintaining other uses and values of the area.
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