Importance of Local Plans…Must “address local ecological site variability” for regional / sub-regional plansRequires a “hard look analysis” at these local plans via NEPA Habitat Map Review…. Habitat maps “may change as new information becomes available” They must be “science-based” and “coordinated with CPW”
1) Spring 2012: BLM invited Garfield County to participate in the scoping efforts of the DEIS Alternatives as Cooperating Agency (Signs MOU with BLM)2) Spring 2012 through winter 2012 / 2013: County attended a set of Cooperating Agency Meetings in Craig, CO3) Summer 2012 through Summer 2013: County began formal Coordination meetings with BLM, CPW, DNR, USFWS to resolve inconsistencies with habitat mapping, science and policies4) Spring 2013: County adopted GSG Conservation Plan and requested BLM include as alternative in the “Internal” DEIS…BLM denied5) Late Summer 2013: BLM releases DEIS for Public Comments without Garco plan as an alternative.6) Garfield County provides comments to BLM by December 2, 2013
Wide Variety of Partners: BLM, USFWS,DOW, Wilderness Society, EnergyCompanies, Grouse Int., Trout Unlimited,The Nature Conservancy, GarfieldCounty, etc
PPR Plan: 2008 BLM / CPW Habitat Mapping CPW Mapping for BLM EIS March, 2012Modeled Potential GSG Habitat ?
1-km grid scale Based on the methods Four Mile Buffer cited, we were unable to / Production reproduce the PPH/PGH Area delineations.“CPW Occupied Range”
Parachute
NoRegulatoryAssuranceper USFWS
Pinedale WyomingExample of PriorityHabitat cited asbasis for the NTTReport Example local landscape in Garfield County mapped as “Priority Habitat”
To provide private and publicland owners with landmanagement principles,policies and BMPs based onthe best available science thatare tailor-fit to the County’sunique landscape and habitatcharacteristics for thebetterment of the species.
Performed extensive literature search on influences to GSG habitat Compiled criteria from a number of published and peer-reviewed studies with emphasis on local studies in the PPR Area by both BLM and CPW. Established common habitat criteria for PPR area Slope Canopy Cover Vegetation Community Distances from forested areas http://www.elev8- inc.com/upload/GarCo_Habitat_Chip_WM V.mp4
Validates well with 92% capture w/ 100 meters of boundary (Ground-truthed!)Aligns well with CPW’s Restricted Surface Occupancy Map (RSO)DNR Meeting at Capitol = SWH Map is a consultation tool and not “habitat”
CPW: 220,000 acres of Primary & General SGS habitat 73% Reduction!! Garfield County: 59,093 acres ofSuitable SGS habitat
Comparison of Results: CPW Mapping
Comparison of Results: Garfield County Mapping
2008: CPW / BLM Model 2012: CPW SWH “consult” map 2012: CPW RSO (Lek) map 2012: CPW to BLM: DEIS “Habitat” map 2013: Garfield County Suitable Habitat map Garco Map aligns with CPW Lek dataWe are here now…
1) County adopted the “Greater Sage Grouse Conservation Plan” that protects habitat & accommodates multiple use of our public lands.2) Respond to the BLM Draft Environmental Impact Statement Point out Flaws in the CPW Mapping & Science Peer review of County Modeling / mapping efforts with ultimate publication as Best Available Science Point out inconsistencies b/t County Plan and DEIS (Science & Mapping…NEPA and FLPMA requirements)3) Provide Testimony to the Colorado Oil and Gas Conservation Commission (COGCC) on Habitat Mapping4) Coordinate with US Fish & Wildlife Service on data / science verification to prevent a listing
1) Tax revenues from natural gas development directly fund services to the local community: education, fire protection, medical services, county road infrastructure improvements, etc. for residents in Garfield County. Personal Property tax revenue Natural Gas production Tax Revenue State Severance Tax Federal Mineral Lease dollars Federal Mineral Lease District2) The BLM’s current draft proposal will result in significant loss in: Personal property and oil and gas production tax revenue Basic and non-basic jobs Local economic turnover of dollars spent in local communities (sales tax) Future grazing rights / opportunities Recreation (Hunting, Fishing, ATV, skiing, Hiking) opportunities
Even though federal laws direct your agency to prepare this DEIS in coordinationwith Parachute for the purpose of resolving conflicts with Parachute to ensurethat the health, safety and welfare of the public is fully considered in thisprocess, your agency has failed to do so.In 2012, the Town of Parachute received $111,829 in tax revenues directlyattributable to oil and gas production in Garfield County…which is 27.84% of ourtotal Town revenues. The Town of Parachute would not be able to continue tofunction without these tax revenues.
Last year, revenue directly attributed from oil and gas production to our Districtwas $1,548,866 which is 95% of our total revenue. The income we have derivedfrom oil and gas production within our District has allowed us to hire sevenfulltime staff and six part-time “on-call” firefighters. This level of staffing isnecessary to ensure we can protect the lives, homes, lands and wildlife withinour 800 sq. mile District. Without this revenue, we could not properly respondto emergencies and this area would be vulnerable to unforeseen disasters. Additionally, we immediately extinguish fires of private property when we arrive on the scene, which your agency is precluded from doing. As your DEIS points out, much of the greater sage-grouse habitat is on private property. Without our continued services great harm could come to this species. Yet, this was not considered or analyzed in the DEIS.
Federal Mineral Lease: $615,417 $498,310Federal Mineral Severance: $922,000Federal Mineral Lease District $2,035,727Grants 2012 & 2013: Total:
1) The County is aligned with Bureau of Land Management, Colorado Parks & Wildlife, and Department of Natural Resources in their desire to prevent a listing of the GSG.2) It’s the “How to achieve that?” that is unique to Garfield County as was specifically required by the BLM to consider (IM-044…)3) The County supports the BLM’s own Mission to manage public lands for multiple-uses.4) The County’s GSG Plan balances accurately defined habitat and associated protection measures with the multiple-use mission of the BLM on our public lands.5) Ultimately, the DEIS fails to meet its requirements under NEPA to 1) provide a reasonable set of alternatives by excluding the Garfield County Plan and 2) does not adequately define the socio-economic impacts to our communities
1) Cover Letter highlighting major comments a) Exhibit A: Detailed Comments per individual sections of the DEIS (Analysis of the 4 alternatives, proposed habitat map, socio-economic impact analysis) b) Exhibit B: Suitable Habitat Map contained in the Garfield County Greater Sage Grouse Conservation Plan C) Exhibit C: Economic Impacts of Sage-Grouse Management: Supplemental Report (Piceance basin Development Analysis) (BCC Research and Consulting)
1) There has been a lack of adequate demonstration that the existing rules / regulations in the “No Action Alternative” contain measures to protect the habitat;2) The DEIS provides little in the way of actual “regulatory assurance” sought by the USFWS for protections of habitat;3) The DEIS does not provide habitat mapping that addresses local ecological site variability” for the areas in Garfield County and NW Colorado that was required by the BLM Director;4) The BLM failed to consider and properly analyze the Garfield County GSG Conservation Plan as required by NEPA;5) The Current set of proposed action alternatives (B-D) do not provide a wide set of policy alternatives; rather they are slight shades of gray;
6) The DEIS does not provide a basis or define what a “healthy and Stable” population is in Garfield County…thus no baseline or goal to reach;7) Habitat maps provided by CPW grossly map large areas of non-habitat in the County despite cited literature and specific text in the DEIS. This results in CPW mapping 160,000 acres of non-habitat as “habitat”;8) BLM is erroneously applying specific local landscape management policies to a 50,000-foot view consultation map provided by CPW;9) As a practical matter, the BLM alternatives provide virtually no information on how or who implements the specifics of the policies;10) The socio-economic impact analysis fails to accurately characterize fundamental socio-economic components of each alternative and therefore underestimates impacts to the region, counties and cities and towns;
11) The DEIS glosses over (1 page in 1,000) one of the most critical socio- economic impact issues;12) Tax revenues from natural gas development directly improve our community: education, fire protection, medical services, county road infrastructure improvements, etc. for residents in Garfield County.
13) BBC Consulting: produced a Supplement Report with the objective to… Demonstrate the potential economic consequences for Garfield County of BLM’s implementation of the proposed Sage-Grouse habitat preservation plans and thus restricting the development of natural gas reserves in the Piceance Basin. Further, this report is not meant as a substitute analysis for the BLM’s study, but rather a simple demonstration of the order of magnitude economic impacts to Garfield County that were not documented or revealed in the EIS. It is hoped that representation presented here can illuminate the EIS’s shortcomings and the magnitude of the document’s missing information.14) Despite our efforts as a Cooperating Agency and through Coordination, the BLM refused to follow NEPA and include the County Plan as an Alternative;15) The BLM’s DEIS attempts to assert its management authority on private lands….1/4 of privately held lands in the County
Adopted Coordination Adopted Data Validation MeetingResolution & Letter Sent to The County Greater Sage-Grouse with CPW on MappingBLM Asserting Coordination Conservation Plan Developed from December, 2012 to April, 2013 Sought 1st 2nd 3rd Sought 4th Sent Plan to GarfieldCoordination Coordination Coordination Coordination Assistance Coordination BLM CountyNEPA Policy Meeting with Meeting with Meeting with Testifies in Meeting in BLM, USFWS requesting it Congress Assistance With BLM BLM CPW Analyzing as Science & CPW Alternative in EISMay June July - September January April - June May June
BLM Releases DEIS BLM DEIS for 90-day Public Comments Due Comment Dec Period Garfield 5th Meeting with County Coordination Mike King &Testifies in Meeting withCongress BLM, CPW & CPW at Capitol on DNR mappingJune Aug September
Method: Performed two methods (or models) of suitabilityanalysis:Weighted Overlay Fuzzy Overlay Model Model applies ‘fuzzy logic’ to provide a more flexible method for combining criteria(commonly known as a Habitat that handle vagueness and uncertainty Suitability Index ) in the attributes and geometry of the data.
Performed extensive literature search on influences to GSG habitatCompiled criteria from a number of published and peer-reviewedstudies with emphasis on local studies in the PPR Area by both BLMand CPWEstablished common habitat criteria for PPR area Slope Canopy Cover Vegetation Community Distances from forested areas
Sought to utilize publicly available data to streamline workflow,minimize acquisition costs, and maintain consistency with othermodeling efforts.Acquired percent slope and canopy cover from USGS.Reviewed multiple publicly-available vegetation data sources: ReGAP [Regional Gap Analysis Project: 30-meter resolution] NLCD [National Land Cover Dataset: 30-meter resolution] CVCP [Colorado Vegetation Classification Project: 25-meter resolution] LANDFIRE [30-meter resolution]
Review and assessment of vegetation datasets revealed numerous spatial andthematic inaccuracies, also noted by other researchers.Concern with using publicly available vegetation data to yield credible and reliableresults.
As a result, Garfield County sought to improve the accuracy of thevegetation data. Accurately identify vegetation communities Accurately delineate forested stands Accurately identify and quantify transition zones between vegetation communitiesPerformed a supervised image classification process on color-infraredaerial photography with a 2-meter cell resolution.A process that combines multiple spectral bands from the same imageto detect reflectance values from objects on the ground.
An image is composed of one or more spectral bands that determine intensity values of theobjects contained in the photograph. The number of bands in the image determines howthe image appears and what types of information can be extracted.For example, a true color image is composed of three bands of data (red, green and blue)that capture reflectance values within the visible spectrum. When combined, the bandsproduce a natural color image that depicts objects in true color, exactly as they appear to ahuman observer.
Color-infrared photography adds a fourth band to a true color image. The fourthband is near infrared and lies just outside the visible spectrum, but can yield avariety of information about objects in an image.When the near infrared channel is mapped to one of the RGB bands in an image,a false color image is produced, allowing the viewer to see the infrared intensityvalues returned in the image.
Once the band combinations have been generated, they are then consolidated andutilized in the image classification process to identify separate classes based on similarspectral ranges.
The resulting classes are then further consolidated into majorvegetation cover type communities.
Search